Sponsor Licence Management: The Importance of Proper Handling of Key Personnel
Sponsor Licence is an authorisation granted by the UK Home Office to companies in the UK to be able to employ international talent and give them right to work in the UK. However, obtaining and maintaining a Sponsor Licence is difficult as companies are not only required to meet the eligibility criteria, but be in compliance with the structure and correct management of key personnel throughout their entire licence.
Understanding the Sponsor Licence
In order to get a Sponsor Licence, the company needs to demonstrate to the Home Office that they are self-sufficient, with having the correct structure and system in place. This can be demonstrated by the following documents:
- Recent audited accounts.
- Employer’s liability insurance certificate.
- VAT registration certificate.
- Corporate bank statements from the last year.
- HMRC registration documentation.
- Cover letter detailing the purpose, details, and specific information about the structure of the business.
After the company obtains the sponsor licence, they can then apply a Certificate of Sponsorship (CoS) to hire Skilled Workers.
The Role of Key Personnel in Sponsor Licence Management
In order to obtain, and maintain your Sponsor Licence, it requires the appointment of key personnel to oversee and manage aspects of the compliance. These roles include the Authorising Officer, the Key Contact, and the Level 1 User.
The Level 1 User holds significant responsibility as they manage the day-to-day operations of the licence through the Sponsor Management System (SMS). The importance of the Level 1 User cannot be overstated, as they act as the primary link between the sponsoring organisation and Home Office. The Authorising Officer oversees the management of sponsored employees and ensures that all reporting and keeping record obligations are met. The key contact acts as the main liaison between the company and UK Visas and Immigration (UKVI), ensuring communication and quick responses to any regulatory updates. While each of these roles includes slightly different responsibilities, the Authorising Officer, Level 1 User, and Key Contact can be the same person within a company.
To be considered for any of these roles, individuals must typically be British citizens or hold settlement status, whilst holding a senior role within the organisation. However, it is often overlooked that individuals on Innovator or Global Talent visas also qualify for these positions.
If there are no active users in these key roles at any time, the organisation risks having its licence suspended or revoked. Therefore, it’s essential to always have the necessary personnel in place to manage the Sponsor Licence effectively.
In Practice: A Case Study
Recently, our highly specialised immigration lawyer, Alexandra Mokrova, successfully handled a complex case involving the change of an Authorising Officer. In this case, the Authorising Officer was on an Innovator visa and decided to switch to another migrant category.
To ensure compliance with sponsor duties and prevent potential issues such as licence revocation, a subsequent change in key personnel in the SMS system was necessary. This involved replacing the Authorising Officer and the Level 1 User roles.
Instead of replacing the Authorising Officer with a new employee — a process that usually involves significant delays and might take up to 18 weeks — Alexandra Mokrova decided to first add a new Level 1 User to the system. The change was made in less than 24 hours. Afterward, we requested the existing Authorising Officer to be replaced by this new Level 1 User, a transition that occurs almost automatically when the person is already in the system.
In total, all the changes were completed in less than two days.
This decisive action ensured compliance with regulations and safeguarded the Sponsor Licence. Through quick thinking, our team showcased unmatched expertise by delivering fast, strategic solutions under pressure.