Sponsor Management System Changes 2026: What Sponsor Licence Holders Need to Know

1. Multi-Factor Authentication for SMS Users

From 3 September 2026, the Home Office began introducing mandatory multi-factor authentication (MFA) for SMS users.

Once enabled, users will need more than their username and password to access the system.

For businesses, this is more than a security update.

The SMS is used to assign Certificates of Sponsorship (CoS), report relevant changes and manage key personnel. If the person responsible for the licence cannot access the system when required, the organisation could encounter difficulties meeting time-sensitive sponsor duties.

Sponsors should therefore ensure that user details are current, authentication methods remain accessible and responsibility for the licence is not unnecessarily dependent upon one individual.

2. 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 during the transitional period, but sponsors will need to consider whether those individuals should become Level 1 Users, where eligible, or whether their access should be removed. This action must be taken by 8 March 2027.

Businesses should review:

• Who currently has Level 1 and Level 2 access
• What responsibilities each user performs
• Whether existing Level 2 Users require continued access
• Whether additional Level 1 Users may be appropriate

A sponsor must have at least one Level 1 User in place at all times.

For organisations that have historically relied on Level 2 Users for day-to-day sponsorship activities, now is the time to review how those responsibilities will be managed going forward.

3. Inactive SMS Accounts

The Home Office is also introducing measures to deal with inactive SMS user accounts.

This reinforces the importance of actively managing a sponsor licence throughout its lifetime.

Businesses often accumulate SMS users as employees change roles or leave the organisation. Sponsors should regularly review their users, remove access that is no longer required and ensure that current users remain appropriately authorised.

Importantly, where a sponsor licence is revoked solely as a result of the inactive SMS user process, the usual cooling-off period will not apply before a fresh sponsor licence application can be made.

Nevertheless, losing a sponsor licence can have serious consequences for a business and its sponsored workers. Allowing SMS access arrangements to become inactive should therefore be avoided.

4. Could Your Business Access the SMS Tomorrow?

This is perhaps the most important practical question arising from these changes.

If the person who normally manages your sponsor licence became unexpectedly unavailable tomorrow, could somebody else within the organisation:

• Access the SMS?
• Complete the authentication process?
• Assign a Certificate of Sponsorship correctly?
• Deal with an urgent reporting requirement?
• Respond appropriately to a Home Office request?

If the answer is no, your organisation may be too dependent upon one individual.

Good sponsor licence management should include sufficient oversight and contingency arrangements to ensure that the organisation can continue meeting its duties when key personnel are unavailable.

5. What Should Sponsors Do Now?

Sponsor licence holders should use these changes as an opportunity to review their current SMS arrangements.

In particular, businesses should:

• Review all existing SMS users
• Identify existing Level 2 Users and decide what action is required
• Check that Level 1 User arrangements remain appropriate
• Remove obsolete or unnecessary accounts
• Ensure user contact information is current
• Prepare relevant users for multi-factor authentication
• Review who is responsible for day-to-day sponsor licence management
• Ensure appropriate cover exists if a key user is unavailable

This does not need to be a complicated exercise, but it should form part of an organisation’s wider sponsor compliance procedures.

Final Thoughts

A sponsor licence is not something that should simply sit in the background until a business needs to sponsor a worker.

The latest SMS changes reinforce the Home Office’s expectation that licences are actively and properly managed.

For employers, the practical message is simple: know who has access to your SMS, ensure those arrangements remain current and make sure your organisation is not dependent upon a single person to maintain its sponsor licence obligations.

Contact ORSAYA

ORSAYA assists businesses with sponsor licence applications, ongoing sponsor compliance, Sponsor Management System matters and the sponsorship of overseas workers.

Whether your organisation already holds a sponsor licence or is considering applying for one, we provide clear, practical immigration advice tailored to the needs of your business.

To discuss your organisation’s sponsor licence or immigration requirements, please contact ORSAYA.

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