Every sponsor licence application names "key personnel": the people who will manage the licence. Section L4 of Part 1 of the sponsor guidance sets out the roles, who can fill them and the checks UK Visas and Immigration (UKVI) makes. Section L4 was updated in the version published on 28 August 2026, with changes taking effect in September 2026. This guide summarises it. It does not assess whether any named person is suitable for a role.
The three required roles
An application must nominate people for three roles (L4.2):
- Authorising Officer: a senior person with overall responsibility for the organisation's activity as a licensed sponsor
- Key Contact: the main point of contact with UKVI
- Level 1 User: responsible for day-to-day sponsorship activity in the sponsorship management system (SMS), such as assigning and requesting Certificates of Sponsorship and reporting changes
One person can fill all three, or they can be split between people. There can be only one Authorising Officer and one Key Contact at a time, but several Level 1 Users (L4.3). A sponsor must have an eligible Authorising Officer and at least one Level 1 User throughout the life of its licence; if it does not, Part 1 says the Home Office will revoke the licence (L4.6).
The Authorising Officer and Key Contact have no SMS access unless they are also appointed as Level 1 Users (L4.5).
Requirements for everyone
Each person named as key personnel must (L4.8):
- be based in the UK for the period they fill the role, with an exception for the UK Expansion Worker route
- have a valid National Insurance number, unless exempt
- normally come from within the organisation
- not be a contractor or consultant engaged for a specific purpose
- if an SMS User, access their account regularly and keep their details up to date
- meet the suitability requirements and the requirements for their role
Naming someone who does not meet these makes refusal likely, or revocation for an existing sponsor. UKVI may instead let the organisation nominate someone else, or limit its certificate allocation (L4.9, L4.10).
Who can fill each role
Authorising Officer. A paid member of staff or office holder, and the most senior person responsible for recruiting sponsored workers and meeting sponsor duties (L4.32, L4.33). A representative or someone from another organisation cannot fill this role, except an insolvency practitioner when the sponsor is in administration (L4.32, L4.22).
Key Contact. A paid member of staff or office holder, or a UK-based representative (L4.41).
Level 1 User. At least one Level 1 User, the "primary" one, must be both an employee, director or partner of the organisation and a "settled worker" as defined in section S1 of Part 2 (L4.45). There are exceptions to the settled worker requirement, for example where the Authorising Officer holds permission as an Innovator Founder, Global Talent migrant or UK Expansion Worker (L4.52). Sponsors licensed before 1 January 2025 have a transitional arrangement (L4.54).
After a licence is granted, additional Level 1 Users can be staff, employees of an organisation that delivers the sponsor's HR function, or a UK-based representative (L4.49). A representative cannot be a Level 1 User at the application stage (L4.18).
People from outside the organisation
From 9 September 2026, workers supplied by an employment business can no longer be appointed as key personnel (L4.14). A UK-based representative should be suitably qualified to give immigration advice or services (L4.19). The sponsor is responsible for anything done by its SMS Users, including outsiders, and UKVI treats their actions as the sponsor's own (L4.15).
Level 2 Users are being phased out
From 9 September 2026, no new Level 2 Users can be appointed. Existing Level 2 Users must be converted to Level 1 Users, if eligible, or deactivated by 8 March 2027. After that date UKVI deactivates any that remain (L4.58, L4.59). Agency staff who are Level 2 Users cannot be converted (L4.65). The GOV.UK sponsorship management roles page still describes the Level 2 User as optional; Part 1 is the later text.
Suitability checks
UKVI checks key personnel against its records and the Police National Computer, and may repeat the checks at any time (L4.23). It will refuse an application, or revoke a licence, if anyone covered by the guidance's definition of "you" has an unspent conviction for an offence in Annex L4, a relevant civil penalty, or is legally barred from being a company director (L4.25). Paragraph L4.26 lists further circumstances that will normally lead to refusal, such as having been key personnel at a sponsor whose application was refused in the last 6 months or whose licence ended through revocation in the last 12 months.
Multi-factor authentication and inactive accounts
Mandatory multi-factor authentication for SMS Users began on a phased basis on 3 September 2026, and UKVI expects it to cover all sponsors by November 2026 (L4.67). Level 1 Users receive a one-time passcode by text message, so their mobile number, email address and date of birth must be correct on the licence (L4.68, L4.69, L4.84).
An account not used for 12 months or more is inactive. UKVI contacts the Authorising Officer, and Level 1 Users then have 3 months to log in and check their details (L4.72 to L4.74). If a sponsor is left with no active Level 1 User, UKVI suspends the licence and allows 28 days to nominate one, failing which UKVI will normally revoke the licence (L4.78).
Common questions
Can one person be all the key personnel?
Yes. Part 1 (L4.3) allows the roles to be filled by the same person, provided they are suitable and eligible for each.
Can our immigration solicitor be the Key Contact?
A UK-based representative can be the Key Contact (L4.41). They cannot be the Authorising Officer, and cannot be a Level 1 User until after the licence is granted (L4.17, L4.18).
Do key personnel have to be British?
Part 1 does not say that. It requires the primary Level 1 User to be a settled worker unless an exception applies (L4.45, L4.52), and everyone to be based in the UK.
Where are the duties these people manage listed?
The compliance checklist lists sponsor duties with their guidance references. For your own arrangements, speak to a regulated adviser.