When did you last log in
to your Sponsorship
Management System
(SMS)?

When a business successfully obtains a Home Office sponsor licence under the Worker or Temporary Worker routes, they will be given access to the Sponsorship Management System (SMS). The SMS is an online tool that allows you to administer your day-to-day sponsorship duties and activities, such as assigning certificates of sponsorship (CoS) and reporting changes to a migrant’s circumstances.

If your business currently holds a valid sponsor licence, at least one of your employees, partners or directors must be set up as a ‘Level 1 user’ with access to the SMS. However, how often this appointed user logs in and uses the SMS may depend on how many migrant workers you are currently sponsoring, and whether you manage the day-to-day administration of your licence in-house or appoint this task to a third party such as an immigration advisor.

Larger employers who maintain a large population of sponsored workers may log-in to the SMS on a weekly or even daily basis, whereas a small business with just a handful of their employees on sponsored work visas may go for months without needing to access the system. However, if you have not logged in for a while, you may wish to do so now as the Home Office is currently reviewing their records and clamping down on those who have not recently been active on the system.

Sponsor compliance and the SMS

Smith Stone Walters has recently begun receiving reports from sponsors who have been contacted by the Home Office compliance team asking them to take action if they have not logged into the SMS in over 12 months. The communications have been made via telephone and email, and have been directed mainly at those who are listed as Level 1 users for the business.

E-mails sent by the Home Office and seen by SSW issue a reminder that sponsors must keep records up to date as a condition of their sponsor licence, and that Level 1 users are advised to access their SMS account at least once a month. Accessing your SMS account regularly allows you to review and update your licence details in a timely manner and keep up to date with the latest news, messages and any upcoming changes.

Who can access the SMS?

When you apply for a sponsor licence, you are required to nominate certain members of staff within your organisation to take on key roles relating to the licence. These nominated individuals are known as “key personnel”. There are four roles:

  • Authorising Officer – Holds overall responsibility for the sponsor licence, as well as responsibility for the activities of all SMS users.
  • Key Contact – Acts as the main contact between the business and the Home Office.
  • Level 1 user – Responsible for carrying out day-to-day sponsorship activities using the SMS.
  • Level 2 user – Can perform certain actions using the SMS, but have fewer permissions than Level 1 users.

Only Level 1 and Level 2 users have access to the SMS. If the Authorising Officer or Key Contact requires access, they must also be set up as a Level 1 or Level 2 user. When you first apply for your licence, you can only appoint one Level 1 user, and they must be an employee, director or partner. However, once your licence has been granted you can appoint more Level 1 users.

If you have more than one Level 1 User, any additional Level 1 Users must be one of the following:

  • A paid staff member or office holder within your organisation
  • An employee of a third-party organisation engaged by you to deliver all or part of your HR function
  • A UK-based representative.

Compliance advice for sponsors

Sponsors who have not yet been contacted by the Home Office and have not logged into the SMS for some time are advised to do so as soon as possible in order to pre-empt a call from compliance officers.

Once logged in, you should also take the opportunity to review your current list of Level 1 users and ensure other records are up to date, such as the contact details of your Authorising Officer and Key Contact. Any amendments should be undertaken on the SMS within the next 10 working days. Going forward, we also advise all Level 1 users to make a note to log-in at least once a month as recommended in the guidance.

As the Home Office appear to be placing a greater emphasis on sponsor compliance in general, sponsors should ensure they are prepared for an in-person compliance visit, which may happen at any time without notice. Smith Stone Walters can work with sponsors to conduct a mock audit to help identify and overcome any potential compliance issues in anticipation of your next visit.

To find out how we can help your business maintain immigration compliance, please contact us today.

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