With effect from 6 November 2014, any new Sponsor submitting a sponsor licence application must initially appoint an employee as Level 1 user. Once the licence has been approved, the Level 1 user may log into the Sponsor Management System and appoint a legal representative to perform this role if required.

Potential sponsors will need to be aware of Data Protection considerations to ensure the most appropriate person in the organisation is appointed to this role, as the Level 1 user will have access to potentially sensitive information relating to migrants, such as salary.

For existing sponsors who have not appointed an employee to perform this role, they will now be required to appoint one.