Authorising Officer leaves: what must a sponsor licence holder do?

01 · Continuous appointment

The licence must have an eligible Authorising Officer throughout.

Sponsor guidance Part 1 states that an organisation must have an eligible Authorising Officer and at least one Level 1 User throughout the life of its licence. It further states that the Home Office will normally revoke a licence where the sponsor has no suitable Authorising Officer or has failed to report a change in that role.

Part 3 contains a general requirement to report specified organisational changes no later than 20 working days after the change. The text expressly begins with an exception for replacement of the Authorising Officer or Key Contact. That exclusion matters: the ordinary 20-working-day period should not be converted into a vacancy allowance that the guidance does not state.

Where a departure is planned, the replacement should therefore be selected, checked and submitted before the outgoing office holder leaves. Where the departure is immediate or has already occurred, the sponsor should address the vacancy at once and preserve an accurate chronology of what happened and what was done in response.

02 · Role map

One departure can remove several sponsor controls at once.

The Authorising Officer may also be the Key Contact, the only Level 1 User, a director, the head of HR or the person who approves Certificates of Sponsorship. Removing the name without mapping those functions can leave the sponsor with an appointed successor but no practical control of the licence.

The first exercise is therefore a role and access map. Record whether the departing person holds each sponsor role, which SMS permissions they use, what information reaches them, which decisions they approve and whether any other eligible Level 1 User can operate the system lawfully during the transition.

The employment and corporate position should also be fixed. The date of resignation, last working day, garden leave, termination of office and loss of authority may not be the same date. The sponsor needs a defensible account of when the person ceased to perform the function, rather than a convenient date selected after the event.

03 · Successor eligibility

Seniority on an organisation chart is necessary, but not sufficient.

The Authorising Officer must normally be a paid member of staff or an office holder based in the UK. The role cannot ordinarily be held by a representative, contractor, consultant or other external person. The guidance also expects the Authorising Officer to be the most senior person responsible for recruiting sponsored workers and ensuring that the organisation meets its sponsor duties.

The proposed successor must satisfy the current key-personnel eligibility and suitability requirements. Those include the relevant UK-based connection, an appropriate role within the organisation and, unless an exception applies, a valid National Insurance number. Past immigration offending, sponsor non-compliance or specified criminal conduct can disqualify a person.

A legal representative can advise on the transition and may act as Key Contact or an additional Level 1 User where the guidance permits. An external solicitor cannot be installed as the organisation's Authorising Officer simply because the internal appointment is difficult. Responsibility must remain inside the sponsor.

04 · Planned departure

A controlled succession should be completed while authority and access still exist.

Where notice has been given, the organisation should use that period to approve the successor internally, verify eligibility, update the responsibility matrix and submit the replacement through an existing Level 1 User. The outgoing Authorising Officer should remain involved only to the extent that they still hold genuine authority and the organisation's security arrangements allow it.

The succession record should identify who approved the appointment, why the successor is the most senior appropriate person, when responsibility passes and how the new Authorising Officer will oversee SMS use, reporting and sponsor compliance. This is more valuable than a bare board minute that records a title without defining the function.

No one should continue to use the departing person's credentials. SMS accounts are personal. Access should be removed when it is no longer required, but only after the organisation has protected the eligible access needed to complete the transition and continue meeting its duties.

05 · Replacement request

The online change is followed by a signed evidence step.

An existing Level 1 User should use the 'Replace your Authorising Officer' function in the Sponsor Management System. Where the same person is also being appointed as Key Contact, the SMS process can record both roles in the replacement request.

Submission of the online declaration generates a submission sheet. Current guidance requires the signed sheet, declaration and supporting documents to be sent to the address stated on the sheet within 5 working days. Failure to provide the required material can result in the request being refused and can expose the licence to further action.

A replacement may update automatically where the licence is fully active, A-rated and the new Authorising Officer's postcode matches the sponsor's main or head-office address. That administrative outcome does not remove the document requirement, the Home Office's ability to conduct checks or the sponsor's responsibility for the appointment.

06 · Loss of access

The absence of a Level 1 User changes the route to replacement.

If the departing Authorising Officer was also the only Level 1 User and no eligible person retains SMS access, the sponsor cannot complete the ordinary online replacement process. Current guidance directs the organisation to the sponsorship change-of-circumstances form, including where the new Authorising Officer will also become the sole Level 1 User.

The sponsor should not ask a former employee to log in, share credentials or operate the account after their authority has ended. That may compound the governance problem and weaken the reliability of the system audit trail.

Part 3 requires at least one Level 1 User throughout the life of the licence unless the sponsor is surrendering it. The organisation should therefore treat loss of the sole Level 1 User as a connected compliance failure requiring immediate correction, not as a reason to postpone the Authorising Officer replacement.

07 · Existing vacancy

An historic gap should be reconstructed, not backdated.

If the Authorising Officer has already left, record the actual departure date, when the sponsor identified the vacancy, which other users retained access and every action taken since discovery. Appoint an eligible successor and submit the correct request without manufacturing an earlier appointment date or concealing the gap.

The review should extend beyond the personnel record. Check whether any Certificate of Sponsorship was assigned, report made, organisational change omitted or worker event handled during the period without effective oversight. Confirm that obsolete SMS access has been removed and that the new Authorising Officer can account for the current sponsored population and open compliance decisions.

The explanation should distinguish the cause of the departure from the sponsor's response. Immediate resignation, illness, dismissal and an overlooked historic change may require different evidence, but none removes the need for an accurate chronology, functioning control and proportionate remediation.

08 · Continuing control

Replacement restores the role; it does not prove that the role is working.

The Authorising Officer is responsible for the activities of SMS users and the organisation's sponsor arrangements. Part 1 recommends a monthly check of Certificate of Sponsorship activity. A new appointment should therefore lead to a substantive handover covering sponsored workers, pending reports, outstanding applications, work locations, payroll exceptions and previous Home Office contact.

The organisation should maintain a key-personnel register, a leaver trigger, at least one resilient route to Level 1 access and a named person responsible for escalating planned and unplanned departures. Periodic review should test whether the Authorising Officer still has sufficient seniority, information and time to exercise the function.

A replacement request closes an administrative change. A functioning governance model demonstrates that the sponsor can continue to control the licence after the individual who once held the knowledge has gone.

Practical questions.