Choosing and Vetting Your Key Personnel (AO, Key Contact, Level 1/2 Users) is one of the most decisive steps in securing and maintaining a compliant sponsor licence. The individuals you assign as your “sponsor licence key personnel” become the link between your organisation and the UK immigration framework, shaping how effectively you meet your sponsorship duties, respond to audits, and handle compliance checks. Whether your business is applying for a new licence or managing an existing one, understanding how these roles intertwine with governance, accountability, and day-to-day HR processes can make all the difference between smooth sponsorship and serious risk.
Why “Key Personnel” matters?
The key personnel you nominate are not just named on your licence application; they carry the responsibility for managing your sponsor licence, maintaining compliance and serving as the primary contacts for UKVI when things go right or wrong. According to the guidance, failure to have eligible, suitable key personnel can lead to refusal of a licence, reduction or removal of your Certificate of Sponsorship (CoS) allocation, suspension or revocation of the licence altogether and because of this, the vetting of these individuals must be as rigorous as the vetting of the organisation itself.
Role-Descriptions
Authorising Officer (AO)
- Senior organisational leader (e.g., Director or senior manager) with overall responsibility for compliance, choice of key personnel, sanction risk, and sponsorship strategy.
- Ensures policies are in place for right to work checks, training, reporting, and record keeping.
- Approves major compliance decisions, reviews periodic audits and acts as the final escalation point.
Key Contact
- Interface with UKVI: receives correspondence, responds to requests, and liaises in inspections.
- Maintains up-to-date contact details in the SMS.
- Works with the Level 1 User to ensure cooperation, clarity and speed of response to UKVI queries.
Level 1 User
- Primary SMS user: assigns CoS, manages changes to worker status, reports events, handles allocations.
- Maintains day-to-day processes: right to work checks, record-keeping, and reporting of non-compliance.
- Coordinates with HR/Payroll/Compliance to monitor worker status, addresses issues and ensures audit trail.
Level 2 User (optional)
- Support role within SMS with fewer permissions (e.g., views, updates, and less risk functions).
- Ideal for junior sponsorship administration, freeing senior staff for oversight.
These roles can be held by the same person or split among multiple individuals—depending on your business size, structure, risk appetite and capacity for oversight. Importantly, the guidance emphasises you must always have at least an eligible AO and Level 1 User throughout the life of your licence.
Eligibility and integrity checks for key personnel
Selecting key personnel requires more than a title—it requires eligible, suitable and high-integrity candidates. Here’s what UKVI expects:
1. Basic eligibility
For each person nominated, you must ensure they:
- are based in the UK for the period they will fill the role (unless a particular route exception applies)
- have a valid National Insurance Number (unless formally exempt and evidence is provided)
- are within your organisation (not a pure contractor or consultant) unless an exception applies
- are not a contractor or consultant “for a specific purpose” in that role
2. Suitability and integrity – what UKVI checks
UKVI will conduct background checks on nominated key personnel, including checks against its own records and the Police National Computer (PNC). You must demonstrate that the individuals are suitable to hold these roles. Examples of issues that may render someone unsuitable include:
- involvement in previous licence revocations or serious breaches of immigration rules
- serious criminal convictions or ongoing investigations
- lack of ability to assure compliance (e.g., inadequate systems, inadequate organisational oversight).
3. Workload, segregation & capability
It is not sufficient to simply appoint people; you must ensure they have capacity, capability and the right segregation of duties so that your licence remains well-managed and risks of non-compliance are minimised. For example, the AO should not be overburdened with unrelated duties that impair their ability to monitor sponsorship compliance. Level 1 Users should be trained, supervised and backed up. If key personnel cannot perform, your organisation must be able to replace them quickly and maintain continuity.
Planning for absences, replacements and external representatives
Even the best-run organisations will face staff changes, absences (e.g., sickness, maternity/paternity leave), or transitions. Proactive planning is essential.
1. Absences and replacements
- You must always ensure you have an eligible AO and Level 1 User in place. If either fails to meet eligibility requirements, your licence may be revoked.
- If an AO or Key Contact/Level 1 User leaves or becomes ineligible, you must notify UKVI via SMS and replace them promptly. The manual for SMS (SMS Manual 2) covers how to request changes.
- Your internal policy should include: a nominated deputy or alternate for each key role, a documented handover procedure, training logs and early warning for absence.
2. Using external representatives
Some organisations engage external immigration or compliance representatives to assist. That is permissible, but you must ensure your key personnel retain ultimate accountability and oversight. The guidance emphasises that a contractor or consultant cannot fill key roles unless specific circumstances allow.
If you use an external rep, ensure:
- your AO and key personnel remain internal and fully empowered.
- the rep’s role is clearly documented, with segregation of duties (e.g., rep provides guidance, your Level 1 User executes).
- your own internal systems remain primary (you cannot outsource compliance oversight in a way that undermines responsibility).
Checklist for “sponsor licence key personnel”
Below is a practical checklist you can use right away to assess your own readiness:
Pre-appointment checks:
- Confirm the individual is UK-based and holds a National Insurance Number.
- Check for previous licence revocations, immigration non-compliance or criminal records.
- Assess their job description: does it allow them the capacity to fulfil the role?
- Document the role in an internal sponsor compliance policy.
Onboarding and training:
- Provide SMS access and training (especially for Level 1 Users).
- Ensure each key person signs a statement acknowledging their duties and responsibilities.
- Implement a handover file and continuity plan for absences.
Segregation & governance:
- Map out who does what in your sponsorship management (AO, Key Contact, Level 1 User).
- Ensure no single person carries full control without oversight.
- Establish an audit or review function for reporting, document retention, and right-to-work checks.
Absence/replacement planning:
- Nominate a deputy for each key role (with clear guidelines).
- Create calendar reminders for renewals, licence expiry, and CoS counts.
- Keep up-to-date contact details in SMS for each key person.
External representation (if applicable):
- Clearly define the role of the external rep and how they interface with your internal team.
- Maintain internal accountability: your AO and Level 1 User must retain control.
- Document your outsourcing arrangements, responsibilities and review frequency.
Ongoing compliance monitoring:
- Regularly review key personnel eligibility (UK base, NI number, internal status).
- Monitor CoS assignment, worker reporting, right to work checks and lead times.
- Ensure changes to key personnel are promptly notified to UKVI.
- Keep a file of key personnel decision-making and training records for audit or inspection.
Final thoughts!
Selecting and vetting your key personnel is much more than a one-time administrative formality — it’s the backbone of a well-governed sponsorship system. The strength of your Authorising Officer, Key Contact and Level 1 or 2 Users defines how effectively your organisation maintains compliance, handles audits, and responds to change. Treat these roles not as individual positions, but as part of an interconnected framework that supports long-term licence integrity. With structured oversight, training, and contingency planning, you can turn compliance into confidence.
If you’re ready to strengthen your team structure and ensure full compliance, keep following Sponsor Licence Hub for expert insights, updates, and practical guidance on managing sponsor licence responsibilities with precision and professionalism.
