UKVI has changed the way employers manage access to the Sponsorship Management System.
Multi-factor authentication is now mandatory for SMS users. The Level 2 User role is also being phased out, and employers have not been able to appoint new Level 2 Users since 9 September 2026.
These are operational changes, but they affect something fundamental: who can access and manage the sponsor licence. Employers should check their SMS users now rather than waiting until somebody needs to assign a Certificate of Sponsorship or report a change.
Multi-factor authentication is now mandatory
UKVI's updated sponsor guidance on multi-factor authentication, published on 28 August, introduced mandatory MFA for SMS users from 3 September 2026, rolling out across licences over the following weeks.
Employers need to make sure the people responsible for sponsorship can actually access their accounts under the new arrangements.
The person who originally set up the sponsor licence may no longer be the person dealing with sponsorship today. Some businesses also have several users who were added over time but rarely access the system. That needs checking, because UKVI's guidance now specifically requires SMS users to access their accounts regularly and keep their details up to date.
Level 2 Users are being phased out
From 9 September 2026, sponsors can no longer appoint new Level 2 Users.
Existing Level 2 Users can continue for the time being, but the role will be abolished after 8 March 2027. Employers will need to upgrade eligible Level 2 Users to Level 1 or deactivate their accounts by then.
There is no reason to wait until March. A sponsor should establish now who currently has Level 1 access, whether there are any Level 2 Users, which users still need access, whether the people with access are still employed by or connected with the organisation in the appropriate capacity, and whether there is enough cover if the main Level 1 User is absent or leaves. That last point matters particularly for smaller businesses where one person may have managed the licence for years — a risk our sponsor licence compliance reviews commonly pick up.
Inactive SMS accounts can put the licence at risk
The updated guidance also introduces a process for managing inactive SMS user accounts. Sponsors are expected to retain active users who can manage the licence, and an organisation should not discover that its access arrangements are defective when it urgently needs to report a change or assign a CoS.
The Home Office has also added guidance encouraging organisations that no longer use their sponsor licence to surrender it. So employers should decide whether the licence is genuinely active and, if it is, make sure somebody is actually managing it.
Sponsor management is an ongoing responsibility
SMS access is only one part of the employer's duties. The current sponsor duties and compliance guidance requires employers to report specified changes affecting sponsored workers, generally within 10 working days. Significant changes to the organisation are generally reportable within 20 working days, and that can include changes to key personnel, company details, branches or sites, organisational structure, business size and certain mergers or takeovers.
The person managing the SMS therefore needs information from the rest of the business. If HR knows that a sponsored worker's circumstances have changed but the sponsor licence team does not, the system can fail. The same problem arises where directors make a corporate change without considering whether UKVI needs to be told.
Worker welfare is also part of sponsor compliance
The August 2026 sponsor guidance expressly addresses the employer's responsibility to comply with UK employment law and promote the workplace welfare of sponsored workers, including matters such as minimum wage rights, working time, statutory leave and pay, health and safety, equality rights and access to grievance procedures. Sponsors must have HR systems or processes showing that sponsored employees have been given this information, and evidence must be retained.
This deserves attention because sponsor compliance is wider than immigration paperwork. A technically correct Certificate of Sponsorship will not cure poor employment practices.
Separately, the government has laid new Immigration Rules to protect Skilled Workers confirmed as victims of modern slavery. Under those changes, qualifying workers will be able to work for another employer for the remainder of their existing permission instead of remaining restricted to the job for which they were sponsored. This has not been introduced as a general right for sponsored workers to change employers — it applies only in the specific circumstances set out in the new Rules.
What should sponsor licence holders do this week?
Log into the SMS and check the account rather than assuming it is in order. Confirm the Authorising Officer, Key Contact and Level 1 Users. Identify any Level 2 Users and decide whether they should eventually become Level 1 Users. Check that users can access the system under the new MFA arrangements, and remove access that is no longer required.
Then look beyond the SMS. Check whether UKVI has been told about recent changes to the business, and whether sponsored-worker records are reaching the person responsible for reporting. The sponsor licence depends on those systems continuing to work after the licence has been granted, as we set out in our earlier note on sponsor licence compliance.
How Flashpoint Legal can help
Flashpoint Legal advises employers on sponsor licences, Skilled Worker sponsorship and ongoing sponsor compliance.
We can review your SMS arrangements, key personnel, sponsored-worker records and reporting procedures, and identify changes that need to be made. If your business holds a sponsor licence and you have not reviewed your SMS users following the September changes, contact Flashpoint Legal to arrange a sponsor compliance review.
Important: This article provides general information and is not legal advice. Immigration Rules and sponsor guidance change regularly. Advice should be based on the circumstances of the employer and sponsored worker.