Authorising Officers

When applying for a sponsor licence, it is essential to understand the role and responsibilities of the Authorising Officer. This individual is the most senior figure within the organisation responsible for overseeing the recruitment of migrant workers and ensuring that all sponsor duties are met in accordance with Home Office requirements.

The Authorising Officer must be a paid employee or office-holder who is permanently based in the UK. Eligibility criteria apply, and individuals with specific criminal convictions or a history of non-compliance may be prevented from holding this position.

Many employers ask: Who is eligible to be an Authorising Officer? Are there any exceptions to the rules? Below, we explore the criteria in more detail to help clarify the position and its requirements.

As part of the sponsor licence application process, organisations must appoint key personnel to manage and supervise their sponsorship activities. One of the mandatory roles is the Authorising Officer.

An Authorising Officer acts as the primary point of contact between the sponsoring organisation and UK Visas and Immigration (UKVI). Their responsibility includes overseeing sponsorship operations, ensuring full compliance with immigration law, and managing the organisation’s sponsor obligations on an ongoing basis.

This role requires an individual with strong knowledge of the Sponsor Management System (SMS), as it is used to report organisational updates, assign Certificates of Sponsorship (CoS), and maintain compliance records.

When selecting a candidate, businesses should assess their reliability, ability to maintain regulatory compliance, and capacity to remain updated on changes to immigration policies. The position is generally held by someone in a senior leadership role who has the authority to make decisions and manage legal responsibilities effectively.

Ultimately, the Authorising Officer is central to the operation and integrity of a sponsor licence. Choosing the right person is crucial to ensuring a compliant and well-managed sponsorship system.

To qualify for the role, the individual must meet specific eligibility requirements. In most circumstances, the Authorising Officer must be the most senior person responsible for recruitment and compliance within the organisation. This ensures that they possess the authority, oversight capability, and knowledge needed to fulfil the duties of the role appropriately.

When applying for a sponsor licence, it is essential to be aware of who may be disqualified from holding the role of Authorising Officer. UK Visas and Immigration (UKVI) assesses candidates carefully, reviewing their history, conduct, and compliance record before approval.

An Authorising Officer must satisfy all eligibility requirements and must not have any unspent criminal convictions for relevant offences, including those connected to immigration breaches. UKVI also prohibits individuals with a history of non-compliance with sponsor duties from taking up this position, as adherence to sponsorship obligations is a core requirement.

In addition, a person cannot act as Authorising Officer if they previously held a key role within an organisation that had its sponsor licence revoked within recent months. Likewise, anyone who has been issued a fine by UKVI is considered ineligible.

Finally, the role cannot be held by someone who has committed immigration violations or who is legally disqualified from acting as a company director.

The Authorising Officer holds a central role in the recruitment of migrant workers and in maintaining full compliance with sponsor responsibilities. They carry overall accountability for the following key functions:

The Authorising Officer is responsible for supervising the recruitment process and ensuring that all necessary checks — including mandatory right-to-work verification are completed in line with immigration regulations. They must also ensure that individuals being recruited hold valid visas and permission to work in the UK.

It is the Authorising Officer’s duty to ensure that the organisation adheres to all sponsor requirements set by the Home Office. This includes maintaining accurate records for sponsored workers, reporting changes where required, and ensuring ongoing compliance with all applicable immigration laws and guidance.

The Authorising Officer must actively monitor sponsored workers and maintain oversight through the Sponsor Management System (SMS). They are required to report relevant updates promptly such as changes to role, salary, working conditions, or any other reportable event.

The Authorising Officer is responsible for managing user access to the SMS. This includes determining how many staff are granted access, assigning permission levels, revoking access where necessary, and ensuring the security and integrity of the system at all times.

By carrying out these responsibilities effectively, the Authorising Officer helps ensure a compliant, well-regulated, and successful sponsorship framework for employing migrant workers in the UK.

The Authorising Officer plays a vital role in managing a sponsor licence; however, access to the Sponsorship Management System (SMS) is not granted automatically. To use the system, the Authorising Officer must also be appointed as a Level 1 User, which enables them to carry out day-to-day sponsorship management tasks.

Once assigned as an SMS Level 1 User, the Authorising Officer can perform key functions such as assigning Certificates of Sponsorship and reporting updates relating to sponsored workers. They are responsible for ensuring the sponsor licence is managed correctly and in compliance with all Home Office regulations.

The SMS also offers a Level 2 User role, which provides more limited access. While Level 1 Users hold broader system permissions, Level 2 Users can only perform restricted functions. The number of users required will depend on the size and operational needs of the organisation.

To maintain a smooth and compliant sponsorship operation, it is important to appoint the appropriate number of Level 1 and Level 2 Users. Regular use of the SMS by the Authorising Officer is essential, as it ensures they remain up to date with UKVI messages, system notifications, and any changes to sponsorship guidance or requirements.

If an Authorising Officer is leaving the organisation, it is essential to appoint a replacement without delay. To report this change, you must use the “Request changes to licence details” function in the Sponsorship Management System (SMS). Only an authorised Level 1 SMS User can complete this process.

When submitting the request, all mandatory fields must be accurately completed with the personal details of the new Authorising Officer. It is crucial to review all information carefully before submission, as changes cannot be edited once submitted according to sponsor licence guidance.

After submission, you must print the submission sheet, fill in any additional required details, and send it to UK Visas and Immigration (UKVI) along with any supporting documentation.

You can monitor the progress and outcome of the request through the SMS, ensuring that you remain fully informed of any updates or decisions regarding the replacement of the Authorising Officer.

Failure to comply with sponsor duties can have serious consequences for the sponsor licence holder, including the potential revocation, suspension, or downgrade of the licence. Such breaches may be committed not only by the Authorising Officer but also by any authorised users within the organisation.

Licence revocation is generally applied in cases of serious or repeated breaches that present a significant risk to immigration control. In these situations, the Home Office may determine that the sponsor licence holder can no longer be trusted to meet their sponsor obligations.

In less severe cases, a sponsor licence may be downgraded instead of revoked. A downgrade usually comes with a time-limited action plan and associated costs. It serves as both a warning and an opportunity for the organisation to correct compliance issues and demonstrate their commitment to fulfilling sponsor duties.

Non-compliance can also lead to civil penalties. For example, if an employer fails to carry out proper right-to-work checks and employs illegal workers, they may face financial penalties that can significantly affect their business.

In addition to the Authorising Officer, a sponsor licence requires the appointment of other key personnel. These roles are vital for ensuring the sponsorship process operates smoothly and that all sponsor duties are met. Key personnel typically include:

Having a Key Contact, Level 1 User, and Level 2 User in place ensures the organisation maintains a well-structured team to manage day-to-day sponsorship activities efficiently. Each role carries specific responsibilities, and together they support the effective and compliant operation of the sponsor licence.

When appointing an Authorising Officer for your organisation, it is important to carefully consider certain eligibility criteria to ensure compliance and effective management of your sponsor licence.

The individual selected as the Authorising Officer should be the most senior person within your organisation who is responsible for both recruitment of migrant workers and ensuring compliance with sponsor duties. This ensures that the person appointed has the necessary authority and oversight to fulfil the role effectively.

It is crucial to note that only one person can be appointed as the Authorising Officer. This means that the role cannot be outsourced to a third-party organisation or an external legal representative. Having a single designated individual facilitates clear accountability and streamlines the management of your sponsor licence.

Meeting the eligibility criteria set by UK Visas and Immigration (UKVI) is essential for the Authorising Officer role. The individual appointed must not have any criminal convictions, be legally prohibited from being a company director, or have a history of non-compliance with sponsor requirements. This ensures that the appointed individual is trustworthy and capable of fulfilling the responsibilities associated with the position.

The Authorising Officer must be based in the UK most of the time and be either a paid member of staff or an office holder within your organisation. This helps maintain the necessary level of oversight and ensures that the person appointed has a genuine connection to the organisation and its operations.

By carefully considering these factors when appointing an Authorising Officer, you can help ensure that your organisation remains compliant with sponsor duties, effectively manages the recruitment of migrant workers, and maintains a valid and secure sponsor licence.

For an Authorising Officer, having regular access to the Sponsorship Management System (SMS) is essential to ensure compliance with sponsor duties and to efficiently manage day-to-day sponsor licence activities.

One key reason for frequent SMS access is to stay informed of the latest sponsor guidance. The Home Office regularly updates this guidance with critical information and instructions for sponsors. By keeping up to date, you can ensure your organisation’s processes align with current regulations and requirements.

Regular SMS use also enables the Authorising Officer to manage licence details accurately, making timely updates where necessary. This prevents potential issues caused by outdated or incorrect information, maintaining compliance and operational integrity.

Additionally, the SMS provides updates, messages, and announcements from UK Visas and Immigration (UKVI). By accessing the system regularly, the Authorising Officer can respond promptly to changes in immigration policy or guidance, helping the organisation adapt its practices accordingly.

Finally, consistent SMS access is crucial for managing key personnel changes. If any key roles, including the Authorising Officer, change within the organisation, the SMS can be updated immediately. This ensures that records are accurate and transparent, maintaining compliance and accountability across all sponsor duties.

Download our full PDF guide to understand the process, criteria, documents, timelines, and expert support available for your Authorising Officers.