Level 2 users are being phased out: What sponsors need to do now

A significant change to the Sponsor Management System (SMS) took effect from 9 September 2026, when sponsors will no longer be able to appoint new Level 2 Users.

For many organisations, Level 2 Users may have provided a useful way to support day-to-day sponsor licence administration. However, the Home Office is now moving away from this user category and requiring sponsors to review their existing SMS user structure.

Sponsors that currently have Level 2 Users will have until 8 March 2027 to either:

• Upgrade eligible individuals to Level 1 User status; or
• Deactivate those accounts.

While March 2027 may seem some way off, organisations should begin reviewing their SMS users now. 

This change also presents a valuable opportunity to undertake a wider review of sponsor licence governance. Sponsors should consider whether current SMS users remain appropriate, whether access levels align with operational requirements, and whether key personnel records are up to date.

As the Home Office continues to strengthen sponsor compliance requirements, maintaining a robust and well-managed SMS structure is becoming increasingly important.

If you are unsure how these changes affect your organisation, or would like support reviewing your SMS users and sponsor licence arrangements, please contact our Immigration Team. We would be pleased to help you prepare ahead of the March 2027 deadline.