Sponsor licence key personnel: Authorising Officer, Key Contact and Level 1 users explained
Who can hold each key personnel role, what each one is responsible for, why Level 2 users are being phased out by March 2027, and how to change key personnel without a gap that puts your licence at risk.
Published 22 October 2026 · 4 min read
Checked against official guidance on 22 October 2026. This post reflects GOV.UK: Sponsor guidance part 1, apply for a licence, section L4 (version 08/26), and part 3, section C2 (version 08/26). Guidance changes, so check the linked pages for the current version. This is information, not legal advice.
Three roles every sponsor must fill
Every licence needs three key personnel roles (L4.2): an Authorising Officer, a Key Contact, and at least one Level 1 user of the Sponsor Management System (SMS). In a small business one person can hold all three if they are eligible for each (L4.3). There can only be one Authorising Officer and one Key Contact at a time.
These are not honorary titles. The people in them are the ones the Home Office holds responsible for how you sponsor, and their background is checked.
The Authorising Officer
The Authorising Officer is the most senior person in your organisation responsible for recruiting sponsored workers and making sure you meet your sponsor duties (L4.32 to L4.33). They must be a paid member of staff or an office holder such as a director. They cannot be an outside representative, consultant or contractor.
Crucially, the Authorising Officer is accountable for the actions of everyone who uses the SMS on your behalf. They do not get SMS access automatically (L4.36); if you want them to have it, they also need to be a Level 1 user.
Choose someone senior enough to make things happen. If your Authorising Officer cannot stop a manager changing a sponsored worker's job without telling anyone, they cannot do the job the Home Office expects of them.
The Key Contact
The Key Contact is the main point of contact between you and UK Visas and Immigration (L4.41). They can be paid staff, an office holder, or a UK-based legal representative such as a regulated immigration adviser. Many small sponsors keep the Key Contact in-house so that Home Office emails are never missed.
Level 1 users
Level 1 users do the day-to-day work in the SMS: assigning Certificates of Sponsorship, reporting changes, and keeping your details up to date (L4.43 to L4.45). You must always have at least one, unless you are surrendering the licence (C2.16). The primary Level 1 user must be an employee, director or partner, and a settled worker, subject to limited exceptions (L4.51 to L4.53).
A Level 1 user must never assign a Certificate to themselves, a close relative or a partner. If a conflict of interest exists, disclose it through a sponsor note (C1.42). Assigning a Certificate to yourself is a mandatory ground for revocation.
Level 2 users are being phased out
From 9 September 2026 you can no longer appoint Level 2 users. Existing Level 2 users must be converted to Level 1, if they are eligible, or deactivated by 8 March 2027 (L4.4, L4.58 to L4.59). If you have one, decide now which applies, rather than finding out in March that someone has lost access.
Who can hold a role
Section L4.8 sets general requirements for all key personnel:
- They must be based in the UK.
- They must have a valid National Insurance number, unless exempt.
- They must normally come from within your organisation, not be a contractor or consultant (the Key Contact can be a UK-based representative).
- They must not have unspent convictions for the offences listed in Annex L4 of part 1, or certain civil penalties. A licence can be refused or revoked on that basis (L4.25).
- They must not have been key personnel at a sponsor whose licence was revoked in the last 12 months, or 24 months if more than one (L4.26).
Changing key personnel
Changes are reported through the SMS within 20 working days. Replacing the Authorising Officer or Key Contact needs a signed submission sheet (C2.11), and the Home Office runs its standard checks on the new person and may ask for an alternative (C2.12).
The danger moment is when someone leaves. If your only Level 1 user resigns, nobody can report the resignation of a sponsored worker, assign a Certificate for an extension, or update your details. Always have two Level 1 users, and add the replacement before the person leaving loses access.
A simple governance setup for a small sponsor
- Authorising Officer: a director or the owner.
- Key Contact: the person who manages HR day to day, or your immigration adviser.
- Level 1 users: two people who both know the reporting rules, one of whom is the Authorising Officer if they want direct access.
- A shared, private record of every report made and every Certificate assigned, so the knowledge does not live in one inbox.
How Zetta HR helps
Zetta HR records who holds each key personnel role in your sponsor profile, and the licence readiness score flags a missing Authorising Officer or Key Contact. Roles in Zetta HR are separate from SMS access: compliance admins can see and manage sponsorship records without anyone sharing SMS passwords.
Zetta HR does not change your key personnel with the Home Office; that is done in the SMS.
Sources
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