Sponsor Licence Duties
Key Personnel: Authorising Officer and Level 1 / Level 2 Users
The people named on your licence carry real responsibility for how it is managed.
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What the issue is
A sponsor must appoint Key Personnel, including an Authorising Officer responsible for the activity of users, and Level 1 or Level 2 users who operate the sponsor management system.
Why it matters
Key Personnel must meet suitability requirements and stay up to date. Departures or changes need to be reflected promptly; unattended accounts and unclear responsibility are a recognised risk.
Practical point
Make sure more than one appropriate person understands the system so that absences do not cause missed reporting.
Common failures
- A Key Person leaving without the licence being updated.
- Sharing system log-in details.
Evidence to keep
Examples to consider where relevant — not a complete or mandatory list.
- A current list of Key Personnel and their roles.
- Records of changes notified.
Practical preventative steps
- Review Key Personnel whenever staff change.
- Provide training to system users.
Official rules and guidance
Rules and guidance change. Check the current official sources before relying on this information.
This is general legal information for organisations, not advice on your circumstances. Duties depend on your business, workers and the rules and guidance in force at the relevant time. No outcome is guaranteed.
Andrew Williams Solicitors provides regulated legal advice, legal review, representation and solicitor-led compliance support. Compliance monitoring and workflow technology (such as ICMS and ComplianceWatch) is provided separately by Ibiab Systems and is not legal advice.
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When solicitor advice may be appropriate
Speak to Andrew Williams Solicitors about your organisation's position, a Home Office visit, a penalty notice or a licence concern. Scope and fees are agreed in writing before substantive work begins.