SMS Level 1 & 2 User Training

The Sponsor Management System (SMS) is the Home Office’s online portal through which UK sponsor licence holders must manage their immigration compliance responsibilities. It is the official platform that connects sponsoring organisations with UK Visas and Immigration (UKVI), and it is used for day-to-day licence management tasks such as assigning Certificates of Sponsorship (CoS), reporting worker details, and updating licence information.

For many organisations, the SMS is a critical compliance tool. However, it is only as effective as the people operating it. Access to the SMS is restricted to approved users within the sponsoring organisation, known as Level 1 and Level 2 users. These individuals play a vital role in ensuring the sponsor licence is properly managed and that all sponsorship duties are fulfilled. Incorrect use of the SMS can lead to compliance breaches, which in turn can risk suspension, downgrading, or even revocation of the sponsor licence.

What this article is about: This article provides a detailed guide for UK employers and HR teams on the training requirements and compliance expectations for SMS Level 1 and Level 2 users. It explains the difference between these roles, the scope of their responsibilities, and the importance of structured training to minimise compliance risks. By the end of this guide, you will understand how to prepare Level 1 and Level 2 users to meet their duties under UK immigration law and to ensure the integrity of your sponsor licence.

Section A: Understanding SMS Roles and Access

The Sponsor Management System (SMS) is designed to ensure that only trusted individuals within a sponsoring organisation can access and manage licence functions. To achieve this, UKVI requires every sponsor licence holder to allocate specific user roles with clearly defined access levels. These roles are known as Level 1 and Level 2 users.

The distinction between the two levels is critical because it reflects the balance between compliance control and practical delegation. The Level 1 user is the main administrator of the SMS and has full responsibility for licence management. By contrast, Level 2 users have restricted access and are limited to performing only certain functions. Together, these roles provide a framework for secure and compliant sponsor licence management.

Level 1 users are central to the sponsor licence structure. They have the highest level of access to the SMS and are responsible for ensuring that the organisation complies with all of its sponsor duties. This includes maintaining accurate licence details, reporting changes to UKVI, and managing Certificates of Sponsorship. A Level 1 user is usually a permanent member of staff who is directly employed by the organisation, although in some cases legal representatives may be appointed. At least one Level 1 user must always be an employee of the organisation, even if a representative is appointed.

Level 2 users are appointed by Level 1 users to assist with specific tasks. They have more limited permissions, such as assigning Certificates of Sponsorship and carrying out some reporting functions. However, they cannot perform high-level tasks such as withdrawing the licence, requesting Defined Certificates of Sponsorship, requesting additional CoS allocations, appointing new key personnel, or making certain changes to the licence structure. This restriction ensures that overall compliance control remains with the Level 1 user while allowing flexibility in day-to-day operations.

Careful allocation of SMS access is essential. Organisations must ensure that both Level 1 and Level 2 users are trained appropriately and understand the limits of their roles. Misuse or neglect by either user level can expose the business to compliance failings, resulting in Home Office scrutiny and possible enforcement action.

Section A Summary: The SMS relies on a two-tier user system to maintain compliance and operational flexibility. Level 1 users are the primary administrators with full licence management responsibilities, while Level 2 users support with specific functions under restricted permissions. Proper role allocation, supported by robust training, is vital to safeguard the organisation’s sponsor licence and to meet UKVI’s compliance requirements.

Section B: Level 1 User Training

Level 1 users are the backbone of sponsor licence compliance. They are granted the highest level of access to the SMS and carry the main responsibility for ensuring the licence is managed in accordance with the Immigration Rules and UKVI guidance. Given the extent of their authority, Level 1 users require comprehensive training to carry out their duties effectively and to avoid errors that could jeopardise the organisation’s sponsor status.

A Level 1 user must usually be an employee, director, or partner within the organisation. In certain circumstances, an appointed legal representative may also act as a Level 1 user, but the Home Office requires that at least one Level 1 user must always be an employee of the organisation. Only Level 1 users can appoint additional Level 1 or Level 2 users, meaning they control access to the SMS and determine who else can perform sponsorship functions.

Training for Level 1 users must cover the full range of tasks that fall within their remit. These include:

• Managing and renewing the sponsor licence.
• Updating licence details and reporting significant organisational changes, such as mergers, takeovers, or changes in address.
• Assigning Certificates of Sponsorship and ensuring they are only issued for genuine vacancies.
• Requesting Defined Certificates of Sponsorship, as this function cannot be performed by Level 2 users.
• Monitoring and reporting the activities of sponsored workers, including start dates, absences, and changes in employment.
• Ensuring compliance with record-keeping and reporting obligations under the sponsor licence.
• Appointing and overseeing Level 2 users to support day-to-day licence operations.

Because Level 1 users hold responsibility for compliance, training should also cover the risks associated with mismanagement. Failure to report changes on time, assigning CoS for ineligible roles, or failing to monitor migrant workers properly can all lead to enforcement action, including suspension or revocation of the licence. Level 1 users must therefore be trained to not only perform the technical SMS functions but also to understand the wider compliance framework.

Training is best delivered as a structured programme that combines system navigation with scenario-based compliance exercises. This helps Level 1 users to build both the technical and strategic knowledge needed to manage the licence effectively. Employers should also provide refresher training to ensure that Level 1 users remain up to date with changes in Home Office guidance.

Section B Summary: Level 1 users carry ultimate responsibility for sponsor licence compliance and control access to the SMS. Their training must equip them with both the technical skills to manage the system and the knowledge to apply immigration compliance rules correctly. Without adequate training, Level 1 users risk breaching sponsor duties, which can have severe consequences for the organisation’s ability to sponsor overseas workers.

Section C: Level 2 User Training

While Level 1 users hold overall responsibility for licence management, Level 2 users play an important supporting role in the operation of the Sponsor Management System (SMS). Their access is deliberately restricted to limit risk, but they are still involved in day-to-day sponsorship tasks. This makes their training essential to ensure that their activities align with the sponsor’s compliance obligations.

A Level 2 user is usually appointed to help with operational workload. For example, HR officers, line managers, or other staff involved in recruitment may be designated as Level 2 users so that they can assign Certificates of Sponsorship (CoS) or carry out certain reporting functions. However, their authority is limited, and they cannot make fundamental changes to the sponsor licence or manage other users.

Training for Level 2 users should focus on the practical aspects of the SMS that fall within their permissions. These include:

• Assigning Certificates of Sponsorship where authorised and appropriate.
• Reporting migrant worker details such as start dates, absences, and changes in employment within required UKVI timescales (typically within 10 working days, unless guidance specifies otherwise).
• Monitoring and recording compliance events accurately within the SMS and maintaining required records.
• Recognising when to escalate matters to a Level 1 user for higher-level decisions or where authority is lacking.

Level 2 users have explicit restrictions. They cannot withdraw a sponsor licence, appoint other users, change key personnel details, request additional CoS allocations, or request Defined Certificates of Sponsorship. They operate under the oversight of a Level 1 user, which helps safeguard licence integrity while allowing administrative responsibilities to be shared.

Training must emphasise the importance of accuracy and timeliness in SMS reporting. Even though Level 2 users do not carry the same strategic responsibilities as Level 1 users, errors at this level can still result in compliance failings. Late or incorrect reporting of worker absences or employment changes can trigger Home Office action. Level 2 users must therefore be trained to recognise the limits of their authority and to seek guidance from a Level 1 user where needed.

Employers should also ensure that Level 2 users receive refresher training and updates when UKVI amends its guidance. This is particularly important for organisations with high staff turnover, where new Level 2 users may need to be onboarded quickly and consistently.

Section C Summary: Level 2 users provide operational support within the SMS, handling day-to-day sponsorship functions under the supervision of a Level 1 user. Their training must focus on authorised tasks, accurate and timely reporting, and escalation procedures. Effective training reduces the risk of compliance breaches and ensures consistent licence management across the organisation.

Section D: Compliance and Best Practice

Training Level 1 and Level 2 users is not only about navigating the Sponsor Management System (SMS). It is about embedding a culture of compliance where users understand that sponsorship duties arise from the Immigration Rules, the sponsor guidance, and the conditions of the sponsor licence. UKVI expects sponsors to be proactive and to keep accurate, timely records and reports. The organisation is accountable for the actions of its SMS users, so governance and oversight must be deliberate and documented.

To meet UKVI expectations, sponsors should structure their training and controls around clear responsibilities, timely reporting, and auditable records. Most reportable events must be notified within 10 working days unless the guidance specifies a different timescale. Set internal deadlines shorter than UKVI’s to create a compliance buffer, and evidence that users follow these rules in practice.

Best practice controls for SMS users

• Clear role definitions: Document what Level 1 and Level 2 users can and cannot do. Confirm that at least one Level 1 user is an employee of the organisation.
• Access governance: Apply least-privilege access. Review user access quarterly. Remove access immediately when staff leave or change roles.
• Maker–checker on key actions: Use dual control for sensitive steps such as CoS assignment and changes to licence details, with a Level 1 review before submission.
• Timely reporting discipline: Build checklists around the 10-working-day reporting window (or tighter internal targets). Escalate overdue items to the Authorising Officer.
• Training lifecycle: Provide onboarding, role-specific modules (Level 1 vs Level 2), and scheduled refreshers following UKVI guidance updates or internal audits.
• Record-keeping: Maintain evidence required by Appendix D (right to work, salary, work location, absences, etc.). Keep an auditable trail of who did what and when in the SMS.
• Internal audits: Run periodic spot checks on CoS accuracy, reporting timeliness, and personnel files. Track findings to remediation with target dates and owners.
• Incident handling: Define how users report errors, who assesses risk, and how corrective notifications to UKVI are made. Record root-cause and preventive actions.
• Representative oversight: Where a legal representative is appointed, retain at least one in-house Level 1 user and keep clear approval thresholds and monitoring over representative activity.
• Data protection & security: Apply secure storage for immigration data, control exports of SMS information, and restrict local downloads to business need.

Operational playbook for day-to-day compliance

• Pre-assignment checks: Verify SOC code, salary, genuineness, and current CoS allocation. Confirm whether a Defined CoS request (Level 1 only) is required.
• Onboarding reporting: Report worker start date and any changes of work location or job details within required timescales.
• Change management: Route organisational changes (merger, takeover, address, ownership) to Level 1 for UKVI notification and evidence collation.
• Absence monitoring: Keep accurate attendance and leave records; escalate unexplained absences for timely reporting where required.
• Leaver process: Record last day of employment and update the SMS promptly; withdraw or cancel as appropriate and retain evidence.
• MI & oversight: Provide monthly management information on open actions, deadlines due, and upcoming licence renewals to the Authorising Officer.

Section D Summary: Effective compliance comes from trained users operating within robust controls. By defining roles, enforcing least-privilege access, applying maker–checker review on key actions, evidencing Appendix D records, and meeting the 10-working-day reporting window, sponsors demonstrate accountability and reduce enforcement risk. Regular refreshers and internal audits keep the licence compliant and the SMS dependable.

FAQs

What is the difference between Level 1 and Level 2 SMS users?

A Level 1 user has full administrative access to the Sponsor Management System and is responsible for overall licence management, including reporting organisational changes, assigning Certificates of Sponsorship (CoS), appointing and removing users, and requesting Defined CoS. A Level 2 user has restricted access, typically limited to assigning CoS and carrying out basic reporting functions; they cannot manage users, change key personnel, request additional CoS allocations, or submit Defined CoS requests.

Can a business have more than one Level 1 user?

Yes. Sponsors can appoint multiple Level 1 users to ensure coverage and resilience. However, at least one Level 1 user must always be an employee of the organisation, even if an external legal representative is appointed as a Level 1 user.

Who can be appointed as a Level 1 user?

Typically an employee, partner, or director of the sponsoring organisation. A legal representative can also be appointed as a Level 1 user, but the sponsor must retain at least one in-house Level 1 user who is an employee. All Level 1 users must meet suitability and compliance criteria set out by UKVI.

How should Level 2 users be trained and supervised?

Provide role-specific training focused on the tasks Level 2 users are permitted to perform (e.g. assigning CoS and routine reporting). Establish clear escalation routes to Level 1 for actions outside their authority. Deliver refresher training when UKVI guidance changes or when audits identify gaps. Maintain oversight through maker–checker reviews and periodic access reviews.

What happens if a Level 1 or Level 2 user makes an error?

The sponsoring organisation, not the individual user, is accountable for SMS actions. Depending on severity, UKVI may issue warnings, conduct a compliance visit, downgrade, suspend, or revoke the licence. Prompt corrective action, accurate record-keeping, and timely notifications (generally within 10 working days unless guidance specifies otherwise) help mitigate risk.

Can Level 2 users request Defined CoS or additional CoS allocations?

No. Requests for Defined Certificates of Sponsorship and additional CoS allocations are Level 1 functions. Level 2 users must escalate such needs to a Level 1 user.

What reporting timescales should users follow?

Most reportable events must be notified within 10 working days unless UKVI guidance specifies a different timescale. Set internal targets shorter than UKVI’s to create a compliance buffer and audit adherence to these targets.

Conclusion

The Sponsor Management System is at the heart of sponsor licence compliance. By granting controlled access to Level 1 and Level 2 users, the Home Office places significant responsibility on employers to manage their sponsorship duties accurately and transparently. However, the effectiveness of the SMS depends on the knowledge and competence of the individuals using it.

Level 1 users act as the primary guardians of the sponsor licence, while Level 2 users provide essential support with day-to-day functions. Without structured training, even routine actions such as reporting absences or assigning Certificates of Sponsorship can expose the business to compliance risks. For this reason, organisations must invest in training programmes that equip both Level 1 and Level 2 users with the skills to manage the SMS confidently and lawfully.

By embedding best practices such as regular refresher training, clear internal policies, and audit readiness, employers can protect their sponsor licence and reduce the risk of enforcement action. Effective training ensures that the SMS is not just a technical platform but a reliable compliance tool that supports sustainable overseas recruitment.

Glossary

Useful Links