The Authorising Officer is the senior person accountable for how an organisation uses its sponsor licence. GOV.UK describes the role as "a senior and competent person responsible for the actions of staff and representatives who use the SMS". This guide collects what Parts 1 and 3 of the sponsor guidance say the Authorising Officer must be and do. It explains the published role; it does not assess whether a particular person is suitable.
Who can be the Authorising Officer
An organisation must nominate an eligible Authorising Officer when it applies, or the application is refused (L4.31). The Authorising Officer:
- must be a paid member of staff or an office holder within the organisation (L4.32)
- cannot be a representative or someone from another organisation, except an insolvency practitioner while the sponsor is in administration (L4.32, L4.22)
- must be the most senior person responsible for recruiting all sponsored workers and for meeting all sponsor duties; if the organisation does not recruit the workers it sponsors, the most senior person responsible for its sponsorship activity (L4.33)
- must meet the general requirements for key personnel, including being based in the UK and holding a National Insurance number unless exempt (L4.8)
- must pass the suitability checks in L4.25 and L4.26
There is only one Authorising Officer at a time. Where several people could fill the role, the organisation chooses, and Part 1 notes that the organisation is responsible for the Authorising Officer's actions (L4.34). On the UK Expansion Worker route, the Authorising Officer can be based overseas until they enter the UK on that visa (L4.12).
Responsibility for SMS Users
The Authorising Officer decides how many staff need access to the sponsorship management system (SMS) and at what level. They are responsible for the activities of all SMS Users and must comply with the rules for using the system; if they do not, UKVI will take action against the sponsor (L4.35).
Because of this, the sponsor must have a system for checking what SMS Users do. Part 1 recommends that the Authorising Officer checks the certificates assigned to workers at least once a month (L4.37). It also recommends not having more Level 1 Users than are really needed (L4.50).
The Authorising Officer has no automatic SMS access. To use the system they must also be appointed as a Level 1 User (L4.36).
What the Authorising Officer signs and receives
Several steps in the guidance run through the Authorising Officer:
- The submission sheet. After the online application, the Authorising Officer signs and dates the submission sheet, which includes a declaration that the organisation agrees to meet all sponsor duties (L6.27).
- Requests during the application. UKVI always emails the Key Contact for more information and may also email the Authorising Officer, so both should be available while the application is considered (L6.32).
- The decision. Decision letters go by email to the Authorising Officer named in the application. Original documents are returned by post to the Authorising Officer's address (L9.2).
- SMS log-in. On a grant, UKVI posts the Level 1 User's user name to the Authorising Officer and emails the password to the Level 1 User (L10.5). SMS guide 1 says the Authorising Officer is responsible for passing the log-in details on.
- Adding routes. When a Level 1 User applies to add routes, the Authorising Officer must approve it, and the Level 1 User keeps evidence of that approval (L10.12).
- Inactive accounts. If UKVI finds inactive SMS Users, it contacts the Authorising Officer and any inactive Level 1 User (L4.73).
The duties the Authorising Officer oversees
Part 3 (C1.11) lists a sponsor's duties: reporting, record keeping, complying with immigration law and the sponsor guidance, complying with wider UK law, and not behaving in a way that is not conducive to the public good. Reporting deadlines are 10 working days for most changes about sponsored workers and 20 working days for most changes about the organisation (C1.13). The compliance checklist lists each duty with its reference.
If the role is vacant or the person changes
A sponsor must have an eligible Authorising Officer in place throughout the life of its licence. Part 1 says UKVI will normally revoke the licence if a sponsor does not have a suitable and eligible Authorising Officer, or fails to report a change of Authorising Officer (L4.38). Changes to key personnel are made through the SMS; the priority change of circumstances service can be used to replace or amend the Authorising Officer for a fee of £350.
There can be only one Authorising Officer on a licence. An organisation that wants different people as Authorising Officer and Key Contact for a new route must apply for a separate licence and pay the full fee (L10.14).
Common questions
Can the Authorising Officer also be the Level 1 User?
Yes. Part 1 allows one person to fill several roles (L4.3, L4.44), and appointing the Authorising Officer as a Level 1 User is how they get SMS access (L4.36).
Can a director who lives abroad be the Authorising Officer?
Part 1 requires key personnel to be based in the UK while they fill the role (L4.8), with an exception for UK Expansion Worker applicants (L4.12).
What if our Authorising Officer leaves?
The sponsor must report the change and have an eligible replacement; failing to report a change of Authorising Officer normally leads to revocation (L4.38). For your own arrangements, speak to a regulated adviser.
Where is the register of licensed sponsors?
GOV.UK publishes it, and the sponsor licence check searches it by organisation name.