Every UK Sponsor Licence requires three named key personnel roles: the Authorising Officer, the Key Contact, and at least one Level 1 User. Getting these appointments wrong — or failing to update them when people leave — is one of the most common reasons licences are downgraded or applications refused. This guide explains who each role is, what their duties are, the eligibility requirements, and what happens when you need to change them.
The Three Required Roles
Authorising Officer (AO)
The most senior person responsible for the recruitment of migrant workers. They are ultimately accountable for the organisation's compliance with sponsor duties.
Typical role: Company director, owner, CEO, or Head of HR.
Requirements: Must be based in the UK, must be a permanent employee or officer of the company, must not have unspent criminal convictions for relevant offences or immigration breaches.
Key Contact (KC)
The main point of contact between your organisation and UKVI. They receive UKVI correspondence and must be available to respond to queries.
Typical role: Often the same person as the AO in smaller organisations. In larger companies, may be the HR director or immigration lead.
Requirements: Same as AO — UK-based, permanent staff member, no disqualifying issues.
Level 1 User
The person who operates the Sponsor Management System (SMS) day-to-day — assigning CoS, filing reports, updating worker records.
Typical role: HR administrator, office manager, or the person who handles immigration paperwork.
Requirements: Must be a paid employee or office holder. The initial Level 1 User on a new licence application must be your own staff — not an external consultant, solicitor or recruitment platform. Additional Level 1 Users (including external parties) can be added after the licence is granted.
Can One Person Hold Multiple Roles?
Yes. In small businesses, the same person commonly holds all three roles — AO, KC and Level 1 User. This is permitted and common. However, UKVI expects that person to genuinely understand and perform all three sets of duties.
Level 2 Users
In addition to the Level 1 User(s), you can add Level 2 Users to the SMS. Level 2 Users have restricted access — they can view records but cannot assign CoS or file reports. They are useful for giving broader team visibility without granting full SMS control.
What Happens When Key Personnel Change
Reporting Obligation
Changes to key personnel must be reported through the SMS within 20 working days. This includes:
• AO leaves the company or changes role
• KC changes
• Level 1 User leaves or changes
• Any key person acquires a relevant criminal conviction
Failing to report key personnel changes is a common trigger for compliance action. If your AO left 6 months ago and you never updated the SMS, that is a compliance breach — even if the new AO is performing the role perfectly.
Eligibility Checks on Key Personnel
UKVI conducts background checks on all named key personnel. Factors that can disqualify someone:
Disqualifying Factors
• Unspent criminal convictions for relevant offences (fraud, immigration, employment)
• Previous involvement in a sponsor licence that was revoked
• Previous immigration breaches as an individual
• Not being based in the UK or not being a permanent member of the organisation
External Representatives
Immigration solicitors, recruitment platforms (like Recruitroo) and consultants can be added as additional Level 1 Users after the licence is granted. They cannot be the sole Level 1 User, and they cannot be the AO or KC. This is a practical consideration for small businesses that want an external partner to handle day-to-day SMS operations.
Key Personnel and the Compliance Visit
During a compliance visit, UKVI will typically interview the AO and the Level 1 User. They expect these individuals to:
What UKVI Expects Them to Know
• What the company's sponsor duties are (monitoring, record-keeping, reporting, preventing illegal working)
• How many sponsored workers the company currently has
• Where right-to-work records are kept and how quickly they can be produced
• How and when reportable changes are filed through the SMS
• The process for conducting right-to-work checks and follow-up checks
How Recruitroo Supports Key Personnel
Recruitroo operates as an additional Level 1 User on our UK clients' Sponsor Licences, handling day-to-day SMS operations — CoS assignment, change reporting, and compliance tracking. Your AO and internal Level 1 retain full oversight through our dashboard, while the operational burden shifts to our platform.
Setting up or changing your key personnel?
We can advise on the best structure for your organisation and handle the SMS update once your licence is active.
Get a QuoteSee Client StoriesThis guide reflects UK Sponsor Licence key personnel rules as of May 2026. UKVI guidance on eligibility and reporting obligations is subject to change.