Tier 2 sponsor licence: Key
personnel roles explained

When a company applies for a Tier 2 sponsor licence, they are required to nominate certain members of staff within their organisation to take on a number of key roles relating to the licence. The Home Office refers to these nominated individuals as “key personnel”.

The key personnel are responsible for managing the sponsorship process once the licence has been granted, and some or all of these people will have access to the Sponsorship Management System (SMS), the online platform for carrying out day-to-day administration relating to the licence.

There are four key personnel roles, each with set responsibilities and varying levels of access to the SMS. The Home Office also sets out certain eligibility requirements that all key personnel must meet in order to qualify for the roles.

What are the roles?

Authorising officer

The authorising officer is the person ultimately responsible for the licence and ensuring the organisation is compliant with its sponsor licence duties. For this reason, this role is usually allocated to a senior member of staff, often someone involved in HR or recruitment.

The authorising officer is responsible for the actions of all staff who use the SMS, including managing who has access to the system and what level of permissions they have. In order for an authorising officer to access the SMS themselves, they must also be set up as a level 1 user.

Key contact

This individual will act as the main point of contact with the Home Office and is responsible for answering queries relating to the application, documentation or payments. This role can be appointed to a legal representative outside of your organisation who will then be able to liaise with the Home Office and chase your application on your behalf.

If the key contact requires access to the SMS, they must also be set up as a level 1 or level 2 user.

Level 1 user

This role is responsible for all day-to-day management of your sponsor licence and has full access to the SMS. When applying for a licence, you can only appoint one level 1 user, and this must be one of your employees. However, once the licence has been secured, you can appoint further individuals as additional level 1 users, including representatives outside of your organisation.

Level 2 user

A level 2 user is an optional, additional role which can only be filled once the licence has been granted. At this stage, a licence holder can appoint as many level 2 users as they need. These users have access to the SMS but with fewer permissions than a level 1 user.

What is the eligibility criteria?

It is important to select nominees carefully, as part of the licence application process will involve background checks conducted by the Home Office to ensure key personnel are suitable for the roles.

Applications may be rejected if these checks uncover anything about a nominee’s background that the Home Office would consider a risk to immigration control. This could include records of previous adverse involvement with the Home Office, criminal convictions for related offences, or financial risk factors such as bankruptcy or debt relief restrictions.

As well as passing the background checks, each individual appointed to a key personnel role must:

  • Be permanently based in the UK for the duration of the time they are in the role
  • Have a National Insurance Number
  • Be a paid member of staff or an office holder, not a contractor or a consultant hired for a specific project

Other considerations

Once your organisation has been granted a Tier 2 sponsor licence, it is valid for a four year period after which you must apply for a renewal. As much can change within a business in four years, it is crucial to keep on top of reporting any changes to your circumstances or key personnel that may affect your licence.

Failure to report significant changes to your business, such as replacing your authorising officer or key contact, could result in your licence being reviewed by the Home Office. For this reason, ensuring your key personnel are kept informed of organisational and staffing changes as they happen can go a long way to helping you remain compliant.

Get support with your sponsor licence application

From January 2021, the UK’s immigration system will treat EU and non-EU citizens equally. In order to continue sponsoring skilled migrants from January, including workers from the EU, your business will need a Tier 2 sponsor licence. If you do not already have one, you may want to consider applying now.

Smith Stone Walters has helped hundreds of companies successfully obtain a Tier 2 sponsor licence. If you have any questions about the process or need some support with your application, we’d be delighted to help. Contact us today for a friendly discussion with one of our immigration experts.

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