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Laura Notaro is the Director and Founder of Start-up UK, with over 16 years of experience in the UK immigration sector. She specialises in corporate immigration, helping businesses secure sponsor licences and recruit overseas workers. Based in South London, Laura works closely with clients to provide clear, practical immigration advice and support.
The Level 1 User is responsible for the day-to-day management of the licence using the Sponsor Management System (SMS). This contains information about the company’s licence and acts as a portal between the company and the Home Office.
In order to meet the sponsor duties under the licence, the company must have at least one Level 1 User in place at all times during the life of the licence.
Once the licence is granted, the existing Level 1 User can add additional Level 1 Users on the SMS. The company should consider how many Level 1 Users to appoint to ensure they have enough to cover any periods of leave or sickness, but not appointing more than is necessary for the effective and secure operation of the business.
When applying for a sponsor licence, the company must nominate one Level 1 User, who must be a member of staff. This means an employee, director or partner, or someone engaged as an ‘office holder’ for the company, such as a company secretary, registered director, board member or a trustee.
Any additional Level 1 Users must be employees or office holders if they are from the company. It is also possible to appoint an individual outside the company such as a UK-based legal representative, providing at least one Level 1 User is an employee or office holder of the company. Employees of a third-party company engaged by the licence holder to deliver all or part of the HR functions for the business can also be Level 1 Users.
The Level 1 User must not be any of the following:
The Home Office issues different types of sponsor licence depending on the route under which overseas workers are employed. Each licence carries its own requirements and sponsor duties, but all require a Level 1 User to manage the day-to-day compliance on the sponsorship management system.
The main types of sponsorship licence are outlined below.
This category includes Skilled Worker, Global Business Mobility and other long-term roles where migrant workers are employed in permanent or skilled positions. These routes often involve strict eligibility checks around job title, salary, and skill level.
A Level 1 User plays a crucial role here by assigning Certificates of Sponsorship, ensuring reporting duties are met, and keeping accurate records for UKVI. Without a valid sponsor licence in this category, organisations cannot legally employ overseas workers in skilled roles.
Temporary Worker routes are designed for short-term or specialist roles such as charity workers, seasonal staff, or creative workers. The compliance burden is lighter compared to Skilled Worker routes, but sponsor organisations must still ensure compliance with all its sponsor duties.
Level 1 Users in this category focus on making sure contracts and reporting dates are clear. Even though access to the SMS may involve fewer permissions for Level 2 Users, the Level 1 User remains the only person with full access to manage key compliance updates.
The UK Expansion Worker route is available to international organisations looking to establish a new presence in the UK. In these cases, sponsor licence application requirements are stricter, as the organisation must demonstrate it is trading and that it has appointed the following key personnel roles.
A Level 1 User under the Expansion Worker route is often a UK based representative who takes on day-to-day management of the SMS until the business is fully established. Start-up UK regularly supports overseas directors with this process by providing experienced key personnel who meet the following criteria set by UKVI.
A valid sponsor licence in any category is only as strong as the people managing it. At Start-up UK, we help businesses appoint the right Level 1 Users and provide immigration advice to ensure compliance across all visa categories.
Every sponsor licence requires a set of key personnel to oversee the organisation’s responsibilities and ensure the Home Office has reliable contacts. These roles divide responsibilities between senior oversight, communication, and day-to-day SMS management.
The following key personnel roles are central to the sponsor licence application process and to maintaining compliance.
The Authorising Officer is the most senior person in the organisation responsible for the overall management of the sponsor licence. They must be a settled worker or permanent senior employee who can take overall responsibility for ensuring compliance with sponsorship duties.
Their role is not hands-on with the SMS, but they remain accountable for the decisions made by Level 1 and Level 2 Users. For many organisations, the Authorising Officer and company director can be the same person if they meet the following criteria:
The Key Contact acts as the main point of communication between the sponsor organisation and UKVI. They are responsible for receiving updates, responding to queries, and ensuring all communication channels remain open.
This role does not usually involve SMS access but is essential for smooth liaison with the Home Office. A key contact may be an employee, office holder, or even a legal representative based in the UK.
The Level 1 User is the only person with full access to the sponsorship management system. They handle the day-to-day management of the licence, including assigning CoS, updating company information, and reporting worker activity.
They can also add other SMS users, making them central to the organisation’s ability to carry out its sponsor duties effectively. Every sponsor licence holder must have at least one Level 1 User in place at all times.
The Level 2 User has limited access to the SMS. Their role is to assist the Level 1 User by carrying out routine tasks such as assigning Certificates of Sponsorship but without the ability to make broader changes to organisation details.
This role is particularly useful for spreading workload and supporting compliance, while keeping control firmly with the Level 1 User and Authorising Officer.
The Home Office takes the appointment of key personnel seriously, and any errors can delay or even block a sponsor licence application. At Start-up UK, we provide guidance and even act as a UK based representative where needed, ensuring our clients have reliable personnel in place to manage their licence with confidence.
The Home Office expects the Authorising Officer to be the most senior person within the organisation responsible for the sponsor licence. In most cases, this means they must be a paid staff member or office holder who is permanently based in the UK.
While some functions can be outsourced to a third party organisation or a UK based representative, the role of Authorising Officer is reserved for someone who has overall responsibility for the business. This ensures there is a direct line of accountability for all its sponsor duties.
In certain cases, the same person may act as both the Authorising Officer and company director, provided they meet the eligibility requirements. What matters most is that the organisation responsible for the licence can demonstrate it has a senior person in place at all times.
Start-up UK advises clients on appointing the right individual to act as Authorising Officer and provides guidance on how this role interacts with other key personnel. Our expertise ensures businesses meet the sponsor licence application process requirements without unnecessary delays or risks of non compliance.
When applying for a sponsor licence, the company must nominate at least one Level 1 User who is a member of staff. This includes an employee, director, partner or someone engaged as an office holder such as a company secretary or trustee.
Additional Level 1 Users may also be appointed from within the company, provided they are employees or office holders. A UK-based legal representative or an employee of a third party organisation engaged to deliver HR functions can also act as a Level 1 User, but at least one must always be a paid staff member or office holder of the sponsor organisation.
The key is that the Level 1 User must be based in the UK and able to manage sponsor licence duties reliably. They serve as the person responsible for full access to the sponsorship management system, ensuring the business remains compliant at all times.
While the sponsor licence requires at least one Level 1 User, the Home Office applies strict rules about who cannot take this role. These restrictions are in place to make sure the organisation responsible for the licence has a reliable, permanent representative with full access to the sponsorship management system.
The Level 1 User must not be any of the following:
These exclusions show the Home Office’s focus on appointing only trustworthy, UK-based individuals who can ensure compliance. Choosing the wrong person risks non-compliance and can even put a valid sponsor licence at risk.
In order to meet the sponsor duties under the licence, the company must have at least one Level 1 User in place at all times during the life of the licence.
Once the licence is granted, the existing Level 1 User can add additional Level 1 Users on the SMS. The company should consider how many Level 1 Users to appoint to ensure they have enough to cover any periods of leave or sickness, but not appointing more than is necessary for the effective and secure operation of the business.
Relying on only one Level 1 User can create risks for the sponsor licence holder. If that person resigns or is unavailable for a long period, the business may struggle to access the SMS and keep up with its reporting duties, which can affect the validity of the licence.
On the other hand, appointing too many users with full access to the sponsorship management system can weaken security and make compliance harder to control. The best approach is to strike a balance, ensuring continuity without giving unnecessary access to individuals who do not need it.
The Level 1 User holds full access to the sponsor management system, giving them authority to carry out essential tasks that keep the sponsor licence active and compliant. Their role is hands-on and crucial for the organisation’s ability to sponsor overseas workers.
In practice, a Level 1 User can:
These functions show why the Level 1 User is the only person within the organisation trusted with full access to the SMS. At Start-up UK, we guide companies through this process, ensuring they have the right personnel in place to manage these duties effectively and avoid risks of non compliance.
The Level 1 User plays a central role in ensuring that the sponsor organisation meets all its sponsor duties. They manage the sponsor management system (SMS) on a daily basis, keeping records accurate and responding to Home Office requirements without delay.
To understand this role fully, it is helpful to break down the main responsibilities that a Level 1 User is expected to carry out.
One of the most important duties is keeping the SMS updated with the correct company information. The Level 1 User must ensure the sponsor licence always reflects current details such as registered address, key personnel roles, and contact information.
Any changes to business structure, trading name, or senior person within the organisation must be reported to UKVI through the SMS. Failing to update these details could be seen as non compliance, which risks the licence being downgraded or revoked.
Level 1 Users are the only personnel with full access to assign CoS to migrant workers. This includes allocating unrestricted and defined certificates, as well as reporting on how each CoS has been used.
They must also ensure that CoS allocation requests are made when needed and that every certificate is issued only for genuine vacancies that meet Home Office criteria. A clear record of cos assigned helps demonstrate that the business is a responsible sponsor licence holder.
Another responsibility is to monitor sponsored workers and report their activity within the SMS. This includes start dates, role changes, absences, and contract terminations.
Some examples of worker activity that must be reported include:
By reporting worker activity promptly, the Level 1 User ensures compliance and protects the business against allegations of abuse of the sponsorship system.
The Level 1 User has to make sure the sponsor organisation keeps complete records of every sponsored worker. This involves storing copies of passports, right to work checks, contracts, and contact details.
They are also expected to prepare the business for compliance checks from UKVI. Regular internal reviews, accurate records, and secure systems are essential to meet all its sponsor duties. Neglecting these responsibilities could lead to serious compliance issues.
Once the licence is approved, the Level 1 User can add additional SMS users, including Level 2 Users. This helps spread workload but must be done carefully, since only trusted individuals should be given access to the sponsorship management system.
Managing SMS users includes removing access for staff who leave the organisation or no longer require it. This reduces security risks and helps maintain control over the sponsorship management roles within the business.
At Start-up UK, we support businesses by providing trained and trustworthy key personnel who understand these responsibilities in detail. With our guidance, overseas employers and directors can feel confident that their valid sponsor licence is managed correctly, avoiding the risk of non compliance and keeping their workforce secure.
While both roles are part of the sponsor management system, there are key differences in their level of authority and the tasks they can carry out. Understanding these differences helps businesses decide how best to manage their sponsor licence and allocate responsibilities.
The table below highlights the main distinctions between a Level 1 User and a Level 2 User:
Feature / Task | Level 1 User | Level 2 User |
Access rights | Full access to the SMS | Limited access only |
Appointing users | Can add or remove Level 1 and Level 2 Users | Cannot add or remove users |
Assigning CoS | Can assign and request additional CoS allocations | Can assign CoS but cannot request new allocations |
Managing company details | Can update organisation details, key personnel roles, and structure | No access to update organisation details |
Compliance reporting | Responsible for all reporting duties to UKVI | Can report worker activity but with fewer permissions |
Overall responsibility | Acts as the organisation’s main point of control for sponsorship | Supports Level 1 User with day-to-day CoS functions |
The main point is that the Level 1 User is the most senior person with overall responsibility for sponsor duties. The Level 2 User has a narrower scope, making them useful for sharing workload without compromising security.
At Start-up UK, we help businesses appoint the right mix of Level 1 and Level 2 Users, ensuring compliance is maintained while giving companies flexibility to manage overseas workers effectively.
Before the Skilled Worker route was introduced, UK employers applied for what was known as a Tier 2 sponsor licence. This allowed organisations to hire skilled migrant workers under the points-based immigration system.
Although the terminology has changed, the principles remain the same. Employers must hold a valid sponsor licence to recruit overseas workers, and they must meet strict compliance duties to keep that licence in good standing. Today, Tier 2 has been replaced by the Skilled Worker route, but many businesses still use the older term when discussing sponsorship.
A Level 1 User under the Skilled Worker licence performs the same role as they did under Tier 2: managing the sponsorship management system, assigning Certificates of Sponsorship, and reporting changes to migrant workers. The shift is mostly in name and updated eligibility criteria, rather than in how key personnel manage the licence.
At Start-up UK, we guide businesses through the sponsor licence application process, ensuring they understand both historic terms such as Tier 2 and the current Skilled Worker framework. This clarity helps clients remain confident in meeting all their sponsorship duties.
Employers in the UK who want to hire overseas workers must hold a valid sponsor licence. This licence proves to the Home Office that the organisation is capable of carrying out all its sponsor duties, from record-keeping to reporting. Without it, businesses cannot legally employ migrant workers.
Holding a sponsor licence also brings with it significant responsibilities. The organisation responsible must appoint key personnel to manage the process, with the Level 1 User taking on day-to-day duties through the sponsorship management system. This ensures sponsored workers have valid entry clearance and that the employer can continue sponsoring workers without interruption.
For many employers, the challenge lies in balancing recruitment needs with compliance requirements. Assigning CoS correctly, reporting worker activity on time, and ensuring compliance across all visa categories are essential to avoid penalties or even having the licence revoked.
Start-up UK provides immigration advice and support for employers who want to bring overseas workers into their business. From the sponsor licence application process to ongoing compliance, our team helps companies meet their obligations while focusing on growth and staffing needs.
Every sponsor licence must have at least one Level 1 User in place at all times. If the only person with full access to the sponsorship management system leaves the business, falls ill, or becomes unavailable, the organisation can quickly fall into non compliance.
Without a functioning Level 1 User, the sponsor organisation may be unable to assign CoS, update company details, or report worker activity. This gap puts the entire licence at risk, and in serious cases the Home Office may suspend or even revoke it.
Replacing a Level 1 User is possible, but delays or errors in doing so can create disruption for both the business and its sponsored workers. Continuity is essential, which is why companies often appoint more than one user to reduce this risk.
At Start-up UK, we help clients avoid these problems by providing trained personnel or acting as a UK based representative. This ensures there is always someone with the right access and expertise to manage the sponsor licence effectively.
Managing a sponsor licence comes with ongoing responsibilities, and the way the Level 1 User approaches these tasks can make the difference between smooth compliance and costly mistakes. Best practices are about building reliable processes that reduce risks and keep the organisation secure.
Below are some recommended practices for SMS Level 1 Users that help ensure compliance and protect the validity of the sponsor licence.
Accurate record-keeping is at the heart of sponsorship management. The Level 1 User should make sure the organisation keeps copies of passports, right-to-work checks, employment contracts, and contact details for every sponsored worker.
These records need to be updated whenever worker activity changes, such as when job titles or salaries are amended. Keeping this information current not only meets sponsor duties but also helps the organisation prepare for compliance visits from UKVI.
Routine internal reviews help identify compliance gaps before they become major problems. A Level 1 User who regularly audits SMS entries and HR records will spot issues early and resolve them quickly.
This is particularly useful when multiple SMS users are appointed. By checking for accuracy and consistency, the Level 1 User ensures the organisation remains aligned with all its sponsor duties.
Managing access to the SMS is one of the most important responsibilities of the Level 1 User. Only trusted staff should be added as Level 2 Users, and access should be removed immediately when someone leaves the organisation.
To handle this effectively, it helps to adopt a simple set of rules:
This approach keeps the system secure and reduces the risk of unauthorised changes or errors.
UK immigration rules are updated frequently, which means Level 1 Users must keep their knowledge current. This includes staying informed about changes to visa categories, CoS allocation rules, and reporting requirements.
Training sessions or external support can help Level 1 Users meet this expectation. At the very least, organisations should ensure their key personnel are aware of Home Office updates and guidance.
The Home Office may conduct compliance visits at any time, and Level 1 Users should be ready. This means making sure records are organised, processes are clearly documented, and all sponsor duties can be demonstrated in practice.
Being prepared not only reduces the risk of licence suspension but also gives UKVI confidence that the sponsor organisation is reliable and trustworthy.
At Start-up UK, we help businesses put these best practices into action by supporting their key personnel with relevant training regarding sponsorship duties and compliance. This guidance gives our clients peace of mind, knowing their valid sponsor licence is being managed to the highest standards.
The Home Office regularly updates sponsor guidance, and Level 1 Users must stay informed about these changes. Rules around job titles, salary thresholds, or CoS allocation can shift, and failure to act on updates is a common source of non compliance.
Practical ways to stay informed include subscribing to Home Office alerts, joining professional networks, or assigning responsibility for monitoring policy changes to the Level 1 User. This ensures the organisation always works with the latest guidance.
Managing a sponsor licence requires consistency and precision, yet many organisations fall into avoidable traps. These mistakes can lead to compliance issues, financial penalties, or even the licence being suspended. By understanding the most common pitfalls, Level 1 Users can take practical steps that protect the business and keep the licence secure.
Below are the issues that cause the most difficulties for sponsor organisations, along with practical steps to avoid them.
One of the biggest risks for any sponsor organisation is not updating the sponsorship management system when changes occur. The Home Office expects the SMS to reflect the latest company details, including addresses, directors, and key personnel roles.
When the SMS is out of date, it creates a clear case of non compliance. The solution is simple: the Level 1 User should review the SMS regularly and make updates promptly after changes happen.
Another frequent problem is the mismanagement of Certificates of Sponsorship. Assigning CoS to ineligible workers, using the wrong category, or failing to report when a CoS is unused can all lead to compliance issues.
To reduce risks, Level 1 Users should:
Keeping a transparent record of CoS activity shows the sponsor organisation is acting responsibly and within Home Office rules.
Incomplete or outdated records remain one of the most common failings during compliance visits. Documents such as contracts, right-to-work checks, or salary evidence are often missing or stored inconsistently.
The best way to avoid this is to create a clear checklist for every sponsored worker. Each file should contain all required evidence and be updated whenever changes occur. This not only ensures compliance but also makes it easier to demonstrate processes during a Home Office inspection.
Some businesses appoint too many SMS users without controlling access. This creates a security risk, as individuals with fewer permissions may still make errors, or a former employee might retain access by mistake.
To avoid this, the Level 1 User should manage access carefully:
This approach ensures that full access and limited access remain under strict control.
Reporting worker activity on time is essential, but many organisations fail to meet deadlines. This includes late reporting of start dates, prolonged absences, or contract changes. These delays send a signal to UKVI that the organisation is not fulfilling all its sponsor duties.
The solution is to create an internal system for reporting. The Level 1 User should receive timely updates from HR or line managers and log them in the SMS without delay. A simple reporting checklist can help ensure no event is overlooked.
Some organisations depend on only one Level 1 User, which becomes a major risk if that person is absent or leaves the business. Without access to the SMS, the licence can quickly fall into jeopardy.
To avoid this, organisations should appoint at least two Level 1 Users. While the Home Office requires one to be a staff member or office holder, others can include legal representatives or trusted employees. This ensures business continuity even during staff changes or emergencies.
When the Home Office conducts a compliance visit, many organisations are caught off guard. A lack of preparation often reveals gaps in processes, poor record-keeping, or unclear reporting duties.
The best approach is for the Level 1 User to treat compliance as ongoing rather than occasional. Regular reviews, organised records, and a clear audit trail mean the sponsor organisation is always ready to demonstrate compliance.
UKVI checks the Police National Computer to confirm that the Level 1 User has no relevant criminal convictions. Serious offences, especially those linked to fraud or immigration breaches, can disqualify someone from acting in this role.
Employers must therefore be confident that their nominated personnel can meet the Home Office’s standards of honesty and reliability. A clean record provides reassurance that the individual can manage day-to-day sponsor duties without raising concerns.
Financial reliability is another area reviewed by the Home Office. Anyone subject to a bankruptcy restriction order or debt relief restriction order cannot be appointed as a Level 1 User.
This rule exists to prevent individuals with financial instability from controlling a valid sponsor licence. Organisations should check the financial standing of their key personnel before submitting the sponsor licence application process to avoid delays or refusals.
Beyond criminal and financial checks, the Home Office also considers professional suitability. For example, an insolvency professional under investigation or a person legally prohibited from acting as a company director would not be eligible.
This ensures that only those with the right standing and credibility are allowed to act as key personnel. The Level 1 User must be able to demonstrate competence and reliability when managing access to the SMS and fulfilling reporting duties.
At Start-up UK, we help businesses select and prepare the right people for these roles. By reviewing eligibility against the following criteria and guiding clients through background checks, we make sure the sponsor licence application runs smoothly and avoids unnecessary complications.
Holding a sponsor licence gives organisations the legal right to employ overseas workers, but it also places them under strict obligations. When those obligations are not met, the Home Office takes enforcement action. Non compliance can harm the business, its workforce, and its reputation, with penalties ranging from financial fines to the licence being revoked altogether.
To understand the seriousness of these outcomes, it is important to look at the most common consequences of failing to meet sponsorship duties.
One of the first penalties an organisation might face is a downgrade of its sponsor licence rating. A sponsor licence usually begins with an A-rating, which allows full access to sponsor migrant workers. If compliance issues are found, this can be downgraded to a B-rating.
A B-rating limits the ability to sponsor new workers until the business has completed an action plan set by UKVI. While not as severe as having the licence revoked, it places the sponsor organisation under increased scrutiny and often delays recruitment. The Level 1 User plays a vital role in avoiding this outcome by ensuring compliance is maintained at all times.
If more serious issues arise, the Home Office can suspend the licence while investigating. During suspension, no new Certificates of Sponsorship can be assigned, and the business must demonstrate that it is correcting its compliance issues.
Suspension disrupts recruitment plans and can damage the organisation’s standing with migrant workers already employed. This stage often results from failures to update the SMS, poor record-keeping, or delays in reporting worker activity. A proactive Level 1 User can prevent this by making sure updates are handled on time.
The most severe penalty is having the sponsor licence revoked. This means the organisation permanently loses the right to sponsor overseas workers and must end the employment of current sponsored staff.
Common reasons for revocation include:
Once a licence is revoked, the business must wait before reapplying, and there is no guarantee a new application will be approved. This consequence demonstrates why maintaining a valid sponsor licence should always be a priority.
In addition to licence action, the Home Office can issue civil penalties to businesses that employ workers illegally. These fines can reach thousands of pounds for each breach, and details of penalties are often published publicly, damaging the organisation’s reputation.
Civil penalties are not only financial; they can affect an organisation’s ability to apply for future licences or to work with government bodies. A strong system of compliance, managed by the Level 1 User, is the best protection against such outcomes.
In the most serious cases, organisations or their personnel may face criminal charges. For example, knowingly employing someone without the right to work, or deliberately falsifying information on the SMS, can lead to prosecution.
The Home Office takes these cases seriously, and they can result in long-term damage to the business and its directors. Criminal liability highlights why it is essential that the Level 1 User is trustworthy, reliable, and fully aware of the sponsor licence requirements.
The consequences of non compliance are not limited to the organisation. Sponsored workers may also lose their visas if the licence is suspended or revoked. This disrupts careers, causes stress for families, and damages the employer’s reputation as a reliable sponsor.
For businesses that rely heavily on migrant workers, losing the trust of current and future employees can have long-term consequences. Ensuring compliance protects not only the business but also the people it employs.
Beyond financial penalties and immediate disruptions, non compliance can cause lasting reputational harm. Clients, investors, and partners often view sponsor licence issues as a sign of poor management or weak governance.
Rebuilding trust after a licence has been downgraded or revoked can take years. By contrast, demonstrating a strong record of compliance can become a positive selling point, showing that the organisation is responsible and professional in managing its workforce.
The risks of non compliance are significant, but they can be avoided with the right processes. This includes:
Each of these measures ensures compliance and reduces the risk of enforcement action. The Level 1 User, as the individual with full access to the SMS, plays the lead role in putting these measures into practice.
At Start-up UK, we understand how high the stakes are for businesses that sponsor overseas workers. Our team provides guidance, training, and experienced key personnel to ensure compliance at every stage. With our support, organisations can protect their valid sponsor licence, avoid costly penalties, and continue sponsoring workers with confidence.
By keeping the sponsor licence valid and free of compliance issues, the Level 1 User contributes to the company’s reputation. This trust helps attract investment, win contracts, and reassure stakeholders that the organisation can grow responsibly.
Applying for and managing a sponsor licence can be challenging, particularly for overseas entrepreneurs who are new to the UK system. From the initial application through to appointing key personnel, there are several steps that must be handled correctly to secure and maintain a valid sponsor licence.
At Start-up UK, we support businesses at every stage of the sponsor licence application process and beyond. Our focus is on helping clients meet the Home Office requirements and ensuring their licence remains compliant.
One of the most difficult parts of the process is appointing key personnel. A sponsor licence requires roles such as an Authorising Officer and Level 1 User, but overseas entrepreneurs often face a catch-22 situation.
Start-up UK can provide a trusted individual to act as key personnel, filling the position of Authorising Officer or Level 1 User where needed. This service helps businesses ensure compliance with their sponsor licence when they cannot appoint someone suitable from within their own team.
Our sister company Synergy Immigration Solutions assist with preparing and submitting sponsor licence applications. This includes ensuring the correct documents are provided and that the organisation meets the Home Office’s criteria. Allowing Synergy Immigration to support this process, will reduce the risk of applications being delayed or refused, allowing businesses to progress with sponsoring workers more efficiently.
With a team of experienced advisers who specialise in UK immigration matters, we provide clear advice to businesses that want to employ overseas workers. This includes guidance on the sponsor licence requirements, key personnel roles, and how to remain compliant once the licence is granted.
This advice helps clients understand their obligations and avoid common pitfalls that can lead to non compliance or even a licence being revoked.
Start-up UK was founded to help overseas entrepreneurs bring their businesses to the UK. By combining company formation support with immigration advice and key personnel services, we make it possible for clients to establish themselves in the UK market and manage their sponsor licence with confidence.
An additional Level 1 User can be added once the sponsor licence has been granted and the initial user has full access to the SMS. This option is available to spread responsibilities or provide cover during periods of absence.
Businesses often add new users when their operations expand, or when they want more than one trusted individual to manage sponsorship duties. The key is to balance continuity with security and avoid appointing more users than needed.
If the only Level 1 User leaves the company, the sponsor licence immediately becomes at risk. Without access to the SMS, no Certificates of Sponsorship can be issued and compliance reporting cannot continue.
The Home Office requires a replacement to be appointed quickly to avoid disruption. Having more than one Level 1 User already in place provides continuity and reduces the chance of the licence being suspended or revoked.
Yes, a UK based legal representative can act as an additional Level 1 User. However, at least one Level 1 User must always be an employee or office holder of the sponsor organisation to meet Home Office rules.
Legal representatives can be particularly useful for overseas businesses that do not yet have settled staff in the UK. They help bridge the gap while ensuring that all sponsor duties are carried out correctly.
The Home Office does not set a fixed schedule, but the Level 1 User should log in regularly to check for updates, review company details, and ensure reporting duties are up to date. Leaving the SMS unused for long periods increases compliance risks.
A practical approach is for the Level 1 User to access the SMS at least once a month and whenever changes occur in the organisation or workforce. This keeps the licence valid and avoids issues during compliance checks.
The same person can act as both the Authorising Officer and the Level 1 User. This is acceptable if the individual meets all eligibility requirements and is permanently based in the UK.
While this arrangement simplifies management, it also concentrates responsibility on one person. Many businesses still choose to separate the roles so that oversight and daily duties are balanced between different key personnel.
SMS access allows a Level 1 User to update records, assign Certificates of Sponsorship, and report worker activity. However, full responsibility for compliance remains with the Authorising Officer, who oversees the entire sponsor licence.
This distinction ensures that even though the Level 1 User has day-to-day control of the SMS, the senior person within the organisation remains accountable to the Home Office for all sponsor duties.
The process of replacing a Level 1 User can take several weeks, depending on the circumstances and whether the organisation already has other users in place. The application for a new Level 1 User must be approved by UKVI before access is granted.
To avoid delays, many businesses pre-emptively appoint more than one Level 1 User. This way, continuity is maintained if one user leaves, and there is no risk of being locked out of the SMS.
Failing to update the Home Office about changes to company structure, addresses, or key personnel is treated as non compliance. Even minor delays can trigger a downgrade or lead to the licence being suspended.
Prompt updates on the SMS protect the organisation from penalties and show UKVI that the sponsor licence holder is reliable. The Level 1 User plays a critical role in making sure these updates are not overlooked.
Yes, organisations with multiple branches can appoint more than one Level 1 User. This allows each branch to manage its own records and reporting duties while maintaining overall compliance across the business.
However, the Authorising Officer must still ensure that all branches meet the same compliance standards. The structure must be clear and well-documented in the SMS.
Start-up UK offers a key personnel introduction service, providing trustworthy individuals who can step in as Level 1 Users or other required roles. This helps overseas entrepreneurs and new businesses overcome the challenge of appointing someone based in the UK.
By bridging this gap, we enable companies to keep their sponsor licence application on track and ensure continuity if an existing user is no longer available. This support reduces the risk of disruption and keeps the licence valid.
Managing a sponsor licence requires more than simply filling in forms. It demands ongoing attention to detail, accurate reporting, and reliable key personnel who can handle the sponsorship management system with confidence.
At Start-up UK, we provide the guidance and services needed to keep your sponsor licence valid. From introducing experienced key personnel to supporting your sponsor licence application, we make sure your organisation can meet all its sponsor duties without unnecessary risk.
Whether you are an overseas entrepreneur setting up in the UK or an established business hiring skilled workers, our team is here to help. With our support, you can focus on growing your business while we manage the complexities of sponsorship compliance.
Contact us today to discuss your requirements and let Start-up UK guide you through every stage of the sponsor licence process.
Discuss how we can support your business. Call us at 07309 240340 , and one of our expert advisers will reach out to you promptly.
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