You must keep your Authorising Officer, Key Contact and Level 1 User details accurate on your sponsor licence to stay compliant with Home Office requirements. We will guide you on how to add or replace your Authorising Officer, Key Contact, or Level 1 user.
- The Sponsorship Management System handles most changes through the Manage Your Licence or Request Changes to Licence Details functions
- Check that your new Authorising Officer, Key Contact or Level 1 User meets Home Office eligibility criteria before submitting any change
- Submit the change request in SMS, upload any required supporting documents and respond promptly to any UKVI queries
- Leaving ex staff listed or failing to notify changes within twenty working days can cause problems at audits and may contribute to licence downgrades
- Priority processing costs £350 per request and typically completes within five working days after payment for eligible change types
A Y & J Solicitors can review your current key personnel setup, help you plan safe replacements and manage SMS updates to keep your sponsor licence compliant.
Table of Contents
Understanding the Importance of Accurate Key Personnel
Key personnel are the named individuals UKVI relies on to ensure your sponsor licence operates properly. The Authorising Officer holds senior legal responsibility for the licence. The Key Contact acts as your main liaison with UKVI. Meanwhile, the Level 1 User handles day to day administration in the Sponsorship Management System. Together, these roles form the foundation of your compliance framework.
The Home Office expects these people to be suitable, generally UK based and actively involved in your organisation. Furthermore, you must update their details promptly if they leave, the role got changed or no longer meet the requirements. Failure to do so creates compliance risks. These risks show up quickly during audits and can contribute to enforcement action.
This guide gives you a clear, practical walkthrough on how to add or replace your authorising officer and key personnel correctly. It also shows what can go wrong if you ignore these changes.
Who Are the Authorising Officer, Key Contact and Level 1 User
Understanding these roles helps you choose the right people. It also helps you manage changes effectively.
Authorising Officer
What is an Authorising Officer? They are the most senior person responsible for the sponsor licence.Typically, this is a HR Director, Managing Director, CEO or equivalent. Their responsibilities include overall compliance and ensuring systems are in place to meet sponsor duties. They also approve internal processes for sponsorship. The Authorising Officer must generally be based in the UK. They need to be senior, trustworthy and genuinely involved in the organisation.
Key Contact
The Key Contact is your main point of contact between UKVI and your organisation. This person may be the Authorising Officer, an HR lead or in some cases an external representative such as a legal adviser. The rules depend on your specific route. Their typical duties include receiving Home Office correspondence through SMS messages and email. They ensure the right people act on communications promptly.
Level 1 User
The Level 1 User is the day to day administrator of the Sponsorship Management System. Their responsibilities include assigning Certificates of Sponsorship to workers. They report changes in worker and organisation details to the Home Office within the required deadlines. They also add or remove Level 2 users if your organisation uses them. Level 1 Users must meet Home Office suitability criteria. Importantly, they must have their own individual login. Never share credentials.
These three roles are central to UKVI’s trust in you as a sponsor. You must report within 20 working days if there are any changes to these key personnel.
Before You Change Key Personnel
Preparation prevents problems. Before you make any changes in SMS, complete these essential checks. Gather the necessary information first.
Eligibility Checks for New Key Personnel
Your new Authorising Officer, Key Contact or Level 1 User must generally be based in the UK. Limited exceptions exist for certain routes like UK Expansion Worker. They cannot be barred from holding such roles due to immigration offences. Unspent criminal convictions or previous involvement with revoked sponsor licences will disqualify them. They must be a genuine employee or office holder within your organisation.
Internal Planning
Confirm who will take on each role and why they are suitable for the position. Agree on internal responsibilities and escalation routes. Everyone needs to know what happens when issues arise. Furthermore, ensure the new person has the necessary access. They will need access to HR systems, personnel records and communications to perform their duties effectively.
Information to Gather
Before updating SMS, collect full name, date of birth and contact details. You need a phone number and an email address. You will also need job title and department. Level 1 Users require National Insurance Number. If UKVI needs proof of appointment, be ready to provide it. This may include an organisational chart showing their position. You might need an employment contract or letter of appointment. In some cases, you will need a letter of authorisation from senior management.
How to Add or Replace the Authorising Officer
To replace your authorising officer, the process requires careful handling. This is the most senior key personnel role. Consequently, UKVI reviews these changes closely. Following the Sponsor Licence Guidance for Employers ensures you meet all current requirements when making these critical changes.
Process Overview
Log in to SMS using your Level 1 User account. You’ll need the right permissions to handle key personnel changes. Look for the section that deals with your licence details. This could be called Manage Your Licence, Organisation Details, or Key Personnel—it varies depending on how your system’s been set up.
Find the Authorising Officer section. What you do next depends on your situation. If there’s no AO on record right now, you’ll be adding a new one. If someone’s stepping down or they’re not suitable anymore, you’ll be replacing the current one.
Entering Required Details
Getting the details right here is more important than it might seem. Put in their full legal name exactly as it shows on their official documents. No shortened versions or nicknames. You’ll also need their job title within your company, plus their phone number and email address. The system might ask for their address and National Insurance Number as well. Before you submit anything, go through it all again.
Declarations and Submissions
These declarations confirm the person is actually suitable for this role and that you’ve got their permission to put them forward. Once you send the change request through SMS, you’ll get a reference number back. Write it down or save it somewhere you can find it later.
Supporting Documents
Upload any requested documents promptly. This may include a board resolution or letter confirming the Authorising Officer appointment. You might need evidence that the person is senior and involved in day to day management. An organisational chart or contract usually suffices. Sometimes you need proof of their UK residency status if UKVI questions this.
Monitoring and Response
Monitor SMS messages from UKVI after submission. Reply promptly if they request more information or clarification. The Home Office may approve the change immediately if all criteria are met. Alternatively, they may review it manually if additional verification is needed. Standard processing can take several weeks. However, priority processing is available for £350 if you need faster consideration.
Start this process before the old Authorising Officer leaves where possible. Leaving your licence without an eligible Authorising Officer is a red flag at compliance visits and can increase Home Office scrutiny.
How to Add or Replace the Key Contact
Changing the Key Contact follows a similar process. However, it is generally simpler than replacing the Authorising Officer. What is an Authorising Officer compared to a Key Contact? The Authorising Officer holds ultimate responsibility, while the Key Contact manages day-to-day communications.
Process Steps
Log in to SMS and go to the Key Personnel or Key Contact section. Choose Add or Replace Key Contact depending on your situation. Enter personal details and contact information for the new Key Contact. Make sure phone numbers and email addresses are current. Ensure they are monitored regularly.
Internal or External Contact
Confirm whether this is an internal staff member who works for your organisation. Alternatively, it might be an external representative such as a legal adviser. This must fall within Home Office rules. Be aware that not all routes permit external representatives as Key Contact. Check the current sponsor guidance if you plan to appoint someone outside your organisation.
Submission and Follow Up
Submit the change and upload any supporting evidence if UKVI requests it. Track the request through SMS and respond to any queries promptly. Once approved, ensure the new Key Contact understands their responsibilities. They must monitor Home Office messages in SMS regularly. They need to check their email for important communications.
Choose someone who will actually read and act on communications. A Key Contact who ignores messages creates serious compliance risks. The Home Office tries to notify you of issues or request information within deadlines. Missing these can trigger enforcement action.
How to Add, Replace or Remove a Level 1 User
Level 1 Users handle day to day work in SMS. Managing these users properly is essential for smooth operations. It is also crucial for compliance.
Adding a New Level 1 User
Log in to SMS as an existing Level 1 User with rights to manage other users. Go to the Users or Manage Level 1 Users area within SMS. Select Add Level 1 User and enter personal details. Include name, date of birth and contact details. Provide their role and department in the organisation. Enter their National Insurance Number where required. This became mandatory from June 2023. If they do not have a NINO and qualify for an exemption, provide the exemption details.
Eligibility Confirmation
Confirm suitability by checking that they are based in the UK. Verify they meet the Home Office criteria. For applications made after 31 December 2024, at least one Level 1 User must be a settled worker. They must also be an employee, director or partner in your organisation. This ensures compliance with the updated requirements that took effect at the start of 2025.
Approval and Access
After you’ve submitted your request, you’ll need to wait for UKVI to give it the green light. Once they approve it, your new Level 1 User will receive instructions to create their login credentials. They should set this up straight away. First, confirm they can actually log in successfully before you start relying on them for anything important. You don’t want to discover access issues when you’re in the middle of something urgent.
Replacing a Level 1 User
Always add the new Level 1 User before you remove the old one. It’s a mandatory requirement. You need to maintain at least one active Level 1 User at all times. Once your new user is up and running and has confirmed they can access everything properly, then you can go back into the Users list in SMS. Find the old Level 1 User and select the option to Remove or Disable Access (the exact wording might vary depending on your SMS interface).
Removing a Level 1 User Who Has Left
Remove or disable former Level 1 Users as soon as possible after they leave or change role. Never let ex staff keep live SMS credentials. This creates security and compliance risks. The Home Office checks user lists during audits. Finding ex employees with active access raises serious concerns about your internal controls.
Critical Reminders
Logins should never be shared between staff members. Each Level 1 User needs their own credentials to maintain proper accountability. Every user’s audit trail in SMS tells a story, and that story matters when the Home Office comes asking questions during compliance checks.
Removing Old or Incorrect Users
Regular cleanup of your user list is one of those tasks that often gets pushed to the bottom of the to-do list, but it really shouldn’t.
Why It Matters
An outdated user list is a genuine security and compliance risk. Former employees who still have active logins can access sensitive information they have no business seeing anymore. They could potentially assign Certificates of Sponsorship or make changes that could cause serious problems. UKVI expects your key personnel and user records to be current and accurate. When they find stale accounts during an audit, it can suggest you’re not paying enough attention to security or internal controls.
What to Do
Regularly review the list of Level 1 and Level 2 users in SMS. Ideally, do this every quarter. Remove or disable anyone who has left the organisation. This applies even if they left recently. Also, remove users who no longer need access for their current role. Permission requirements change when people move to different positions.
Good Practice
Run this review at least quarterly as a scheduled compliance task. Include the removal of SMS access in your standard HR process when someone leaves. This way, it happens automatically when someone departs. Create a simple checklist that HR completes for every leaver. Include confirmation that SMS access has been removed. This goes alongside email, building access and other systems.
Clean user lists demonstrate good governance. They make it easier to manage your sponsor licence effectively. You will not need to worry about unauthorised access.
Common Mistakes Sponsors Make When Changing Key Personnel
Avoiding these frequent errors saves you from compliance problems. It also prevents enforcement action.
Letting the Authorising Officer Leave Without a Replacement
The single biggest mistake is allowing your Authorising Officer to leave without appointing a replacement in SMS first. This leaves you without an eligible Authorising Officer. Under current Home Office rules, this can result in mandatory licence revocation. Always have the new person in place before the old one departs. If you need to replace your Authorising Officer urgently, consider using priority processing to expedite the approval.
Using Someone Too Junior as Authorising Officer
Choosing someone too junior just for convenience undermines the purpose of the role. The Authorising Officer must be genuinely senior and involved in the organisation. Appointing a junior staff member because they are available creates compliance risks. UKVI may question their suitability during reviews.
Leaving Ex Employees as Level 1 Users
Keeping former employees on the system because they know how it works is never acceptable. This creates security breaches. It shows UKVI you are not taking access control seriously. Remove access to all ex-staff immediately.
Sharing One Level 1 Login Among Several Staff
Sharing credentials among team members defeats the entire purpose of individual user accounts. You cannot track who did what. You lose all accountability when errors occur. Every person who needs access must have their own login.
Nominating a Key Contact Who Never Checks Messages
If you appoint someone as Key Contact who rarely checks their SMS messages or emails, you’re going to miss crucial updates from the Home Office. Deadlines will slip past unnoticed. Requests for information will go ignored. Problems that could’ve been sorted out with a quick response end up becoming much bigger issues than they needed to be.
Forgetting to SubmitDocuments or Respond to Queries
Submitting a change request and then ignoring follow-up messages from UKVI causes unnecessary delays. Monitor your SMS messages after making changes. Respond promptly to any requests for additional information or clarification.
When auditors see these kinds of problems, they read it as a sign of weak internal controls and a lack of proper attention to your sponsor’s responsibilities. And that’s when enforcement action starts looking more likely.
What Happens If You Do Not Update Key Personnel Correctly
Let us walk you through what’s actually at risk here. This might help you see why these tasks deserve proper attention.
Audit and Visit Risk
UKVI officers look at outdated or unsuitable key personnel and draw conclusions about how seriously you’re taking your sponsor licence duties. When they visit for compliance checks, one of the first things they’ll examine is your key personnel setup. They want to see whether the people you’ve appointed actually make sense for these roles. They verify that your records are current. Discrepancies or outdated information create immediate concerns.
Possible Enforcement Action
Consequences can include written warnings about specific issues. These warnings require correcting within set timeframes. You may face a downgrade from an A rating to a B rating with an action plan in place. The action plan costs £1,579 and stops you from sponsoring new workers until completion. In serious or repeated cases, the Home Office may suspend or revoke your licence entirely.
Practical Disruption
Beyond formal enforcement, outdated key personnel create practical problems. Confusion over who is responsible for SMS leads to tasks falling through the gaps. Missed Home Office messages and deadlines occur when the Key Contact does not check communications. Increased stress affects HR teams and sponsored workers when systems break down.
Updating key personnel is a relatively simple fix compared to the consequences of ignoring it. Taking these administrative tasks seriously protects your licence. It keeps your sponsorship operations running smoothly.
Special Scenarios
Here are some situations that need extra care and planning to maintain compliance.
Authorising Officer Leaves Suddenly
If your Authorising Officer resigns or departs unexpectedly, prioritise appointing a new Authorising Officer immediately. Submit the change through SMS as soon as you have identified a suitable replacement. Explain the circumstances to UKVI if necessary. Request priority processing if you need faster approval. When you need to replace your Authorising Officer in an emergency, acting quickly minimises the risk of compliance issues.
External Legal Representative as Key Contact
In some cases, sponsors can appoint an external legal representative as their Key Contact. However, this person cannot usually be the Authorising Officer. Sponsors must still maintain internal capability for managing their sponsor duties day to day. Check the current sponsor guidance for your specific route. Confirm whether external Key Contacts are permitted.
Overseas Authorising Officer for UK Expansion Worker
The UK Expansion Worker route allows a provisional setup. The Authorising Officer can be overseas initially. They must be coming to the UK to establish the business. Once the business is established in the UK, key personnel may need to be updated to UK-based staff. This moves you from a provisional rating to an A rating. Plan these transitions early. Submit the changes through SMS as soon as the eligible UK-based staff are in place.
For complex structures or unusual circumstances, seek professional advice. Do not guess what UKVI will accept. Getting it wrong can delay your operations. It can also trigger compliance issues.
How A Y & J Supports Sponsors with Key Personnel
At A Y & J Solicitors, we help sponsors manage key personnel changes correctly. We also help you build better internal processes for ongoing compliance.
Reviewing Current Key Personnel
We conduct Sponsor Licence Key Personnel Health Checks. These reviews check whether your current Authorising Officer, Key Contact and Level 1 Users are appropriate. We verify they comply with Home Office requirements. Sometimes we find gaps—maybe someone’s left the company, or they no longer tick all the UKVI rules. We’ll also have a look at how you handle key personnel changes internally to see if your processes are working properly.
Planning and Executing Changes
When you need to make changes, we’ll help you figure out who should fill each role. We’ll consider their position in the company, whether they’re suitable, and whether they’re willing to take this on. Then we’ll guide you through the whole SMS change request process, double-checking that you’ve filled everything in properly before you submit it to UKVI. If they respond asking for additional information or documents, we’ll work with you to prepare those. What we’re trying to do is get everything right the first time so you’re not stuck in endless rounds of back-and-forth.
Building Better Processes
We help design simple internal procedures. Future changes trigger timely SMS updates automatically. When Level 1 Users leave or people change roles, your HR team knows exactly what to do. They do not rely on memory or guesswork. We also run training sessions for new Level 1 Users to show them the ropes with SMS. We’ll go over their specific responsibilities and point out the common mistakes people make so they can avoid them.
Supporting Complex Situations
If you have already received Home Office concerns about your key personnel setup, we help you respond effectively. We resolve issues before enforcement action occurs. We prepare sponsors for audits where key personnel will be examined. Your setup will demonstrate proper controls and compliance with sponsor duties.
Through our Sponsor Licence Key Personnel Health Check service, we help sponsors maintain accurate, compliant key personnel arrangements. These arrangements protect licences and support smooth operations.
Frequently Asked Questions
Who can be an Authorising Officer on a UK sponsor licence?
An individual in your organisation at a senior level (e.g. director, HR director, CEO), and their activities will embrace day-to-day tasks. They need to be suitable and not have any relevant convictions or disqualifications.
How do I change the Authorising Officer on my sponsor licence?
Log in to SMS as a Level 1 User → go to Key Personnel → select “Replace Your Authorising Officer” → enter new person’s details → submit. Then send any requested supporting documents and keep an eye on your emails for approval or queries from UKVI.
Can my immigration lawyer be our Key Contact?
Yes, a UK-based legal representative can be appointed as Key Contact, depending on your licence type. But external lawyers generally can’t serve as Authorising Officer — that role should reside with a senior person inside the company.
How do I add a new Level 1 User to the Sponsorship Management System (SMS)?
You’ll need to be logged in as an existing Level 1 User.Go to Manage Users and click on Add Level 1 User. Fill in everything they ask for, including the NI number. The new user won’t be able to log in straight away. They’ll have to wait until UKVI approves the request first.
What happens if my Level 1 User leaves the company?
You must remove their access immediately. Disable their SMS account to maintain compliance and security.
Do key personnel have to be based in the UK?
Yes. The key personnel (AO, Level 1 / Level 2 Users) generally must be UK-based. Representative or external contact must also be UK-based if appointed.
Is there a new requirement for Level 1 Users (2025)?
Yes. For any sponsor licence applied for on or after 1 January 2025, at least one Level 1 User must be both a settled worker (not subject to immigration control) and a direct employee, director or partner of the organisation.
How long does it take for UKVI to process changes to key personnel?
Well, this can vary. It can take several weeks. Priority service at £350 per request (if available) can speed up processing.
Is it a problem if former employees are still listed as Level 1 Users?
Yes. Keeping ex-employees with active SMS access is a compliance and security risk. You need to remove them as soon as they leave.
Can we have more than one Level 1 User?
Yes, you can have multiple Level 1 Users. But always ensure that at least one meets the “settled worker + employee/director/partner” requirement (if the licence was applied from 2025 onward).
Take Action to Keep Your Key Personnel Compliant
Keeping your Authorising Officer, Key Contact and Level 1 Users up to date is not optional. It is a fundamental compliance requirement. This directly affects your ability to maintain your sponsor licence. When key people leave, change roles or no longer meet UKVI requirements, you must act quickly. Make sure you update SMS within that 20-working-day window. Missing this deadline creates audit risks. It can contribute to enforcement action and serious consequences like downgrades, suspensions, or even losing your licence altogether.
At A Y & J Solicitors, we help sponsors navigate key personnel changes correctly. We support you whether you are replacing someone who has left, cleaning up outdated user lists or responding to Home Office concerns about your current setup.
A Y & J Solicitors is a multi award winning, Legal 500 recommended immigration law firm with over 15 years of specialist experience in UK sponsor licence compliance. We have successfully supported more than 5,000 clients, including businesses facing complex key personnel changes and licence compliance issues. We achieve outstanding results with a 98% success rate across our immigration practice
Get Expert Help
A Y & J Solicitors is an immigration law firm which specialises in Sponsor Licence applications and compliance. We understand the immigration laws and are result-focused professionals. You can connect with us at +44 20 7404 7933 today for assistance with your visa application or any other UK immigration law concerns. We’re here to help!
