The Role of the Authorising Officer in 2025

The Role of the Authorising Officer in 2025 is central to any organisation holding a sponsor licence, acting as the senior figure responsible for ensuring that all sponsorship activities comply with UK Visas and Immigration (UKVI) requirements. Beyond simply being named on the licence, the Authorising Officer oversees the proper use of the Sponsorship Management System (SMS), monitors internal compliance processes, and ensures that recruitment and record-keeping for sponsored workers meet the required standards. Their role provides a vital layer of accountability, giving both the organisation and UKVI confidence that sponsored workers are supported appropriately and that legal obligations are consistently met.

Equally important is understanding what happens if the Authorising Officer leaves the business and how to appoint a replacement. A gap in this role can create compliance risks, disrupt the management of Certificates of Sponsorship (CoS), and potentially affect the organisation’s ability to maintain its licence. Appointing a new Authorising Officer requires careful consideration of eligibility, seniority, and suitability, alongside timely communication with UKVI to ensure continuity. In 2025, maintaining this oversight remains a key element of smooth sponsor licence management and protecting the organisation from avoidable regulatory issues.

What Is the Authorising Officer?

The Authorising Officer is one of the three Key Personnel roles that must be named when applying for a sponsor licence. The other two are the Key Contact and the Level 1 User.

• The AO is a senior person in your organisation who holds ultimate responsibility for the way the sponsor licence is used. This includes ensuring your business meets its duties under the sponsor guidance.
• The AO does not automatically have access to the Sponsorship Management System (SMS). If they need to perform day-to-day tasks via SMS, they must also be appointed as an SMS Level 1 User (or Level 2 in some cases) in addition to being the AO.

Authorising Officer: Duties, Eligibility, Risks, and Replacement

• Responsibilities: The Authorising Officer is the senior person responsible for the organisation’s overall sponsorship licence activity. They oversee staff using the Sponsorship Management System (SMS), ensure compliance with sponsor duties, ensure recruitment processes are legitimate, monitor, record-keeping, reporting changes, etc.
• Eligibility criteria: Must be a paid member of staff or office-holder, based in the UK, with senior responsibility for recruitment and compliance; must meet suitability (no recent serious immigration/sponsorship breaches, unspent criminal convictions, etc.). Only one AO permitted at a time.
• Risks if the AO leaves the business: If you don’t have a suitable AO in place, or fail to tell UKVI, your licence may be revoked. Also, non-compliance in past by the AO can affect your rating; potential disruption to CoS issuance, compliance audits, and risk to sponsor licence status.
• How to appoint a replacement: Must nominate a new AO when applying (or change the AO later via the SMS and follow UKVI guidance), ensuring the person meets eligibility, notifying UKVI of the licence details, ensuring documentation, supporting evidence that the replacement is suitable, etc.

Eligibility Criteria

To be eligible as an Authorising Officer under the 2025 guidance (Workers and Temporary Workers), these are required:

• Be a paid member of staff or office-holder of the organisation. Cannot be a contractor or consultant for specific projects.
• Based in the UK most of the time; this person needs to be physically present enough to fulfil their oversight duties.
• Be senior enough to oversee recruitment of sponsored workers and compliance obligations. If they are not directly hiring, then they must be the most senior person responsible for your activities as a sponsor.
• Suitability checks: The AO must pass specific Home Office checks: no unspent criminal convictions for relevant offences, not have been involved in non-compliance, must not have been at a sponsor whose licence was revoked in the last 12 months, must not have been fined by UKVI recently, etc.

Responsibilities of the Authorising Officer

Some of the key responsibilities include:

1. Ensuring overall compliance with sponsor duties
   The AO must ensure the business follows all the duties set out in Sponsor guidance Part 3: Duties and compliance — making sure that sponsored workers have genuine roles, salaries meet the rules, monitoring, reporting of worker changes (e.g. change of job role, unpaid leave, etc.), right to work checks, etc.
2. Overseeing the use of the SMS
   Deciding how many employees are SMS Users, defining their permission levels, revoking or granting access as needed. Making sure SMS users act correctly (reporting, assigning CoS, maintaining records) and periodically reviewing activity.
3. Recruitment & Right to Work Checks
   Ensuring all overseas (and domestic, where relevant) recruitment is compliant, that right-to-work (RTW) checks are done properly, foreign workers sponsored correspond to the job roles as described, etc.
4. Reporting changes
   Keeping UKVI up to date with any material changes in your business that could affect your licence — structure, ownership, senior personnel changes, etc. Also reporting a change of Authorising Officer if it happens.
5. Ensuring senior endorsement and awareness
   The AO must understand its legal obligations, ensure that senior management is aware of sponsor duties, and ensure training or guidance for staff who assist with sponsorship duties. Reviewing internal controls.
6. Annual/regular monitoring
   For example, the guidance recommends that CoS issued are reviewed periodically (e.g. once a month) to check for anomalies. Also, ensuring record keeping and audits internally.

Risks if the Authorising Officer Leaves

When the Authorising Officer leaves the organisation (or is no longer eligible), risks include:

• Licence Revocation or Downgrade: If there is no eligible AO, or the organisation fails to notify UKVI of a change, the licence may be revoked, suspended, or downgraded.
• Compliance Breach: Without a competent AO, oversight of SMS users might lapse, resulting in missing reports, incorrect CoS assignments, RTW issues, or failure to report changes. These are significant compliance breaches.
• Operational Disruption: Without a nominated AO, day-to-day tasks (via SMS) might not have proper senior responsibility, resulting in delays or mistakes in CoS issuance or responding to UKVI queries.
• Legal or Financial Consequences: Non-compliance can lead to fines, penalties, or loss of the ability to sponsor workers until the matter is fixed. The reputation risk is also high.

How to Appoint a Replacement Authorising Officer?

If your current Authorising Officer is leaving or becomes ineligible, here is how to appoint a replacement under the 2025 guidance:

1. Identify a Suitable Person: The replacement must meet the eligibility criteria above, paid staff/office holder, senior, based in the UK, no disqualifying history.
2. Nominate in Your Sponsor Licence Application or Change via SMS:
   • If applying for a new licence, you nominate AO in the application form.
   • If replacing AO during the licence’s life, you must tell UKVI via the Sponsorship Management System (SMS), using the relevant function (Request to change licence details).
3. Submit Supporting Information / Documents: UKVI may require evidence that the new AO is eligible (e.g. proof of role, status, background) as part of the change.
4. Ensure Continuity: Make sure that there is no gap — the organisation must maintain a suitable AO at all times. It cannot operate without one in place.
5. Internal Communication & Training: The new AO must be familiar with all sponsor duties and the organisation’s compliance processes. They must understand how SMS works, what the reporting requirements are, etc.

Key Changes and Emphases for 2025

Official UKVI guidance version confirms that:

• The requirement for having an eligible AO throughout the life of your sponsor licence is non-negotiable. A licence may be revoked if you do not have one, or if you fail to notify UKVI about a change.
• There is increased emphasis on oversight: UKVI expects AOs to regularly check SMS user activity, to ensure CoS assignments are legitimate, and reporting obligations are met.
• Greater clarity is given in the 2025 updates about who cannot serve as AO (history of non-compliance, criminal convictions, involvement in revoked licences) and confirms that contractors are not acceptable.

Conclusion!

The Authorising Officer remains a central figure in the UK sponsorship system in 2025. Their role is not just ceremonial or administrative; it is crucial for ensuring that a sponsor licence is used correctly, that all sponsor duties are met, and that the organisation stays compliant with UKVI rules.

For businesses that sponsor Skilled Workers, Temporary Workers, or Global Business Mobility staff, ensuring that your AO is eligible, well-informed, and always in place is not optional — it’s essential.

Need clear updates, guidance, and practical resources on sponsor licence compliance and key personnel roles like the sponsor licence authorising officer? Follow SponsorLicenceHub for the latest, reliable guidance.