Setting Up the Sponsor Management System and Training Key Personnel: Practical Steps for Compliance and Operational Readiness

You need a clear system and trained people to run your sponsor licence without risking fines or suspension. Set up the Sponsor Management System (SMS) correctly and appoint trained key personnel so you can assign Certificates of Sponsorship, report changes, and keep your licence compliant.

This guide shows how to configure SMS, meet sponsor licence rules, train your team, and prepare for audits so your organisation stays on track. Follow practical steps that make the process manageable and reduce the chance of costly mistakes.

Configuring the Sponsor Management System

Set up the SMS so roles, access and internal links match how your organisation works. Assign clear responsibilities, secure logins and join SMS actions to your day-to-day processes to reduce compliance risk.

Assigning Key Personnel Roles

Identify and record your Authorising Officer, Key Contact and Level 1 and Level 2 users in the SMS. The Authorising Officer signs licence applications and needs senior authority; make sure their details match your corporate records. The Key Contact handles communications with UKVI and should be someone who reads the SMS message board and acts on alerts promptly.

Level 1 users can make most changes and assign Certificates of Sponsorship (CoS). Level 2 users have more restricted functions, such as viewing records or completing routine actions. Document each person’s role, their primary responsibilities and a backup. Keep a simple table with name, role, contact, and backups so you can show this during an internal audit.

Establishing User Access and Credentials

Create individual SMS accounts for each user; never share logins. After first login, require password changes and enable multi-factor authentication where available. Store login credentials in a secure password manager and log every change to access rights.

Set role-based permissions in the SMS to match Level 1 or Level 2 functions. Review access monthly and revoke accounts when staff leave or change role. Use the SMS guide and SMS user manual to check exact permission settings and to follow UK employer best practice for security.

Integrating SMS with Internal Processes

Map SMS activities to your HR, onboarding and compliance workflows. For example, tie right-to-work checks and CoS requests into the HR recruitment form so you collect required documents before raising a CoS in the SMS. Add SMS tasks to your internal audit schedule and assign owners to run audits against SMS records.

Use the SMS message board and regular reports to trigger actions: alerts for licence changes, upcoming checks and reporting duties. Train your teams on how SMS tasks appear and who must act. Keep procedures in one place and reference the SMS guide when updating your processes so your system stays aligned with UKVI rules.

Understanding Sponsor Licence Compliance Requirements

You must keep accurate records, follow reporting duties, and train the right people to avoid licence problems. The Home Office expects clear processes for assigning Certificates of Sponsorship (CoS), checking right to work, and reporting changes on time.

Sponsor Duties and Obligations

You must act as a genuine employer and use the Sponsorship Management System (SMS) correctly. Assign an Authorising Officer, Key Contact and Level 1 User who understand tasks like assigning CoS, monitoring sponsored workers and keeping sponsorship records.

Only issue CoS for roles that meet skill and salary rules — for example the Skilled Worker route with the correct SOC code and minimum salary threshold or routes for settled workers where applicable.

Keep HR systems able to show lawful trading and genuine vacancies. Train staff to check the candidate’s eligibility, match job roles to the Appendix Skilled Occupations where needed, and record why a vacancy is genuine. Maintain logs of training and internal audits to show ongoing licence compliance.

Reporting Changes and Deadlines

You must report certain events to the Home Office via the SMS within strict timeframes. Reportable changes include dismissal or long-term sickness of a sponsored worker, change of job role, significant drop in salary, extended unauthorised absence, or closure of the business. Also report personnel changes in key roles and changes to work location or business structure.

Assign responsibility for monitoring deadlines and set automated reminders. Some reports must be made within 10 working days; others require immediate action. Failure to report on time can lead to licence suspension or revocation. Keep a log of each report, the date made, and any supporting evidence.

Right to Work Checks and Record-Keeping

You must carry out right to work checks before work starts and repeat checks when a worker’s right to work document or visa changes. Use the Home Office online check where available and retain copies of documents or digital check records. For sponsored workers, link checks to the CoS, visa application outcomes and any leave to remain that affects their right to work.

Keep clear, organised records for at least the period required by the Home Office, including CoS assignment data, start and end dates, reporting history, salary evidence, contact details, and absences. Store records securely and make them available for digital compliance checks or audits. Good record-keeping reduces risk and speeds up responses to Home Office enquiries.

Training and Managing Key Personnel

You must name and train the people who will use the Sponsorship Management System (SMS) and keep records ready for audits. Focus on practical tasks: assigning Certificates of Sponsorship (CoS), updating personnel details, and keeping the licence compliant.

Role-Based Training for SMS Users

Train each role on specific SMS tasks. The Authorising Officer should learn licence-level duties, how to check audit trails, and spot compliance risks such as undisclosed or unspent criminal convictions. The Key Contact must handle communications with UKVI and know where to find casework and correspondence in SMS.

Level 1 users need rights to assign CoS, create and manage sponsored worker records, and submit reports. Level 2 users should be trained for day-to-day tasks only, like updating worker details and uploading evidence.

Use short, practical sessions and written checklists. Include step-by-step guides for common workflows, such as creating a CoS or reporting a worker’s absence. Run hands-on drills in a test SMS environment. Track completion, retrain yearly, and log attendance for audit readiness.

Updating and Replacing Key Personnel

Keep your SMS current. When staff move roles or leave, update key personnel in SMS immediately. The Authorising Officer must approve changes and confirm identities. Remove access for leavers and add new users with role-appropriate levels. Record reasons for replacements and keep a dated change log for audits.

If someone has an unspent criminal conviction, review whether they can hold a key role; report any relevant issues per guidance. Use formal handover meetings that include passwords, authorised tasks, and a run-through of open sponsorship actions. Notify UKVI where required and keep evidence of the notification in your records.

User Management and Security Best Practices

Control access strictly. Assign the minimum level of permission: Level 1 users for CoS and licence actions, Level 2 users for routine updates. Use unique accounts for each user; do not share logins. Require strong passwords and two-step verification where possible.

Maintain an access register showing each user’s role, start date, and authorised tasks. Audit this register quarterly and reconcile it with SMS records. Log changes and hold digital copies of identity checks and right-to-work documents. These steps reduce errors, help detect misuse, and support audit readiness.

Effective Oversight and Audit Preparation

You need clear processes for audits, record keeping, and licence actions. Focus on staff readiness, document control, and prompt Home Office communication to reduce risk and speed responses.

Preparing for Home Office and Internal Audits

Train named staff on the specifics the Home Office looks for: who holds the Sponsor Licence, who signs Certificates of Sponsorship (CoS), and how you allocate CoS and request increases. Run mock compliance audits quarterly that mirror Home Office questions.

Use role-based interview practice for HR, immigration, payroll and hiring managers so they can answer about right-to-work checks, genuine vacancy evidence and record retention.

Keep an audit pack ready with the licence summary, staff authorisation lists, CoS logs, and recruitment records. Assign one audit lead to liaise with the Home Office and to log every communication. Schedule internal audit reports and corrective action logs in your Sponsor Management System so you can show prompt resolution.

Maintaining an Audit Trail

Maintain a single source of truth for all sponsorship records. Store digital copies of right-to-work checks, contracts, CoS issued and used, and training records with clear timestamps and user IDs. Ensure version control so you can show who changed what and when.

Use an access-controlled system that logs edits and exports easy-to-read audit reports. Keep paper originals where required, but index and scan them within 48 hours. Retain records for the Home Office retention period and flag expiry dates for review. Regularly back up your audit trail and test restores to prove data integrity during a compliance audit.

Licence Renewal and Suspension Management

Plan licence renewal at least six months ahead. Review your licence summary, COS allocation trends and compliance gaps before renewal submission. Populate your renewal dossier with evidence of continuous monitoring, training records and corrective actions from internal audits.

If the Home Office raises concerns or threatens licence suspension, notify senior leaders and legal counsel immediately. Prepare a clear remediation plan with deadlines, responsible owners and evidence of fixes.

Keep communication with the Home Office factual and timely; log every exchange. If you need a CoS allocation increase, submit full justification with recruitment plans and workload forecasts to avoid delays or refusal.

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