Guide
Who in a care business is responsible for each sponsor duty?
By Sponsor ComplIANS · 12 November 2026 · 7 min read
The Authorising Officer is the senior person responsible for the licence and for everything done by the people set up to use the Sponsor Management System. But in a care business the work behind each sponsor duty is spread across HR, payroll, coordinators and recruitment, and shared responsibility often means nobody owns the whole process. Give every duty one named owner, a deputy and a reviewer who is not the owner, and write down who the owner hands over to and by when.
What are the licence roles?
- Authorising Officer
Senior and accountable
A paid member of staff or office holder: the most senior person responsible for recruiting sponsored workers and meeting sponsor duties, and responsible for all SMS users' activity (Part 1, L4.31 to L4.37).
- Key Contact
Main point of contact
The Home Office's main point of contact with you. One only (L4.39 to L4.42).
- Level 1 Users
Day-to-day SMS work
Carry out SMS tasks, including reports. At least one primary Level 1 User must be an employee, director or partner and a settled worker (L4.43 to L4.47).
Key personnel must be based in the UK while in the role, and you are responsible for anything done by anyone you set up as an SMS user (Part 1, L4.8 and L4.15). Not having an Authorising Officer or Level 1 User who meets the requirements is a normal revocation ground (Part 3, Annex C2(k) and (m)).
Level 2 Users are being phased out
No new Level 2 Users can be appointed from 9 September 2026, and existing Level 2 Users must be converted to Level 1 or deactivated by 8 March 2027 (Part 1, L4.58 to L4.65). If your structure relies on Level 2 Users, plan the change now.
Who does the work in a typical care business?
The licence roles sit on top of the people who hold the information day to day:
| Duty or task | Owner | Deputy | Reviewer | Hands over to |
|---|---|---|---|---|
| Right to work follow-up checks | HR officer | HR manager | Registered manager | Recruitment, for new starters |
| Absence recording and handover | Coordinator | On-call coordinator | HR manager | HR and payroll, same day |
| Pay checked against the CoS | Payroll lead | Finance manager | HR manager | HR, if pay falls short |
| Deciding on and making SMS reports | HR manager | Compliance lead | Authorising Officer | Level 1 User to submit |
| Planned hours against contract | Coordinator | Deputy coordinator | Registered manager | Payroll, at week end |
| SMS users and licence details | Authorising Officer | Key Contact | Director | Level 1 Users |
Two points to note. The Authorising Officer reviews reporting decisions but does not have to submit every report personally. And coordinators own the absence handover, not the absence decision: HR decides whether an absence is permitted.
How do we agree the map?
- List the dutiesEvery sponsor duty and task the business carries out.
- Set the triggerWhat starts each one, or how often it happens.
- Name the rolesOne owner and one deputy by role, and a reviewer who is not the owner.
- Write the handoverWho the owner hands to, by when, and what evidence shows it was done.
- Agree and reviewAt a 30-minute team meeting, and again whenever someone joins or leaves.
The consultancy support went far beyond basic advice. Recruitment, HR and sponsor duties were aligned into one structured system. It transformed how we manage compliance internally.
The training for our Authorising Officer and sponsored workers was invaluable. We are no longer nervous about scrutiny because we understand our duties properly.
This article gives general information, not legal advice. Guidance checked on 11 November 2026. Check the current guidance and your own circumstances before acting.
Free Working Pack 07: sponsor-duty ownership and handover map
A four-page map that gives every sponsor duty one owner, a deputy, a reviewer and a clear handover. It covers:
- The licence roles and the people who do the work.
- A worked ownership map for a 40-worker care business.
- A blank map for your own duties.
- A 30-minute team meeting agenda.
- Actions and the next review date.
Sponsor ComplIANS Live, 26 November 2026
Sponsor ComplIANS Live is a practical day for payroll, HR, coordinators and managers in care providers that sponsor workers. It covers why care providers are losing sponsor licences, who does what across HR, payroll, recruitment and coordinators, and a full demonstration of the Hub.
- When: Thursday 26 November 2026, 9am to 5pm
- Where: Leicester Marriott Hotel
- Paid by 11:59pm UK time on Thursday 19 November: £699 + VAT for the first attendee and £300 + VAT for each additional attendee booked together
- After that: £999 + VAT and £600 + VAT
Attending does not guarantee compliance or any outcome with the Home Office.
In the Sponsor ComplIANS Hub, each team member has a role with access to match. Each reporting duty and absence follow-up can be given a named owner, and only an Authorising Officer, HR manager or owner records a duty as reported. The Hub does not choose owners for you: a manager assigns each duty. See the Compliance Hub
Related questions
Does the Authorising Officer have to do every SMS task?
No. Level 1 Users carry out SMS tasks. The Authorising Officer is responsible for everything SMS users do, so they should review key decisions.
Can we still appoint Level 2 Users?
No. New Level 2 Users cannot be appointed from 9 September 2026, and existing ones must be converted to Level 1 or deactivated by 8 March 2027.
Can one person hold more than one licence role?
Some roles can be held by the same person, depending on your organisation. Check Part 1 of the sponsor guidance for the requirements of each role.