22/12/2025
This year has been a pivotal one for immigration law with a major overhaul of the UK immigration system. The Government’s White Paper, published early in the year, signalled a clear policy shift following a sequence of rule changes, with significant implications for sponsoring employers, individuals and HR/compliance teams—particularly within the health and social care sector.
We have set out below a practical summary of the key changes to assist employers with recruitment and budget planning for 2026.
Key changes
1. Skilled Worker route – increase to skill level
Effective date: 22 July 2025
The skill level under the skilled worker sponsorship visa route was increased from RQF level 3 to RQF level 6 (graduate level). Consequently, over 100 occupation codes ceased to be eligible for sponsorship. Transitional arrangements are in place for those already in the UK on a skilled worker visa allowing them to extend and switch employers.
Employers who are sponsors should, at the outset, assess whether the job role being offered is eligible for sponsorship before entering into discussions with any prospective or current employee about sponsorship.
2. Increase to salary thresholds and going rates
Effective date: 22 July 2025
The general salary threshold for a skilled worker visa increased from £38,700 to £41,700. Additionally, the new entrant rate for students and graduate visa holders also increased from £30,960 to £33,400. In parallel, the going rates for most occupation codes increased substantially.
Employers who are sponsors must ensure that the salary offered meets the minimum salary requirement. Careful role-scoping and salary modelling at offer stage is essential where sponsorship is being considered. Due to the transitional provisions, it is imperative that each candidate/employee is assessed on their own merits as the same salary thresholds will not apply to all.
3. Closure of care worker and senior care worker visas to overseas applicants
Effective date: 22 July 2025
Sponsoring employers are no longer able to sponsor new workers from overseas for the roles of Care Workers (SoC code 6135) and Senior Care Workers (SoC code 6136) under the skilled worker route.
Transitional arrangements are in place for those already in the UK and they can switch routes, change employer/job and extend their visa until 22 July 2028, subject to them meeting the visa requirements. For those switching from other visa routes, the requirement to be legally working for their sponsor for at least three months before their skilled worker application will continue to apply.
Employers need to re-evaluate their recruitment strategy and how they source future talent. Early planning and strategic workforce development is essential to maintain continuity and avoid any staff shortages.
4. Operational changes - Expansion of eVisas for out-of-country applicants
Effective date: 30 October 2025
Most applicants (main and dependants) applying from overseas for work, study, family and settlement routes are no longer issued a visa vignette in their passport. Instead, they are being issued eVisas. EVisas have replaced physical immigration documents and act as a digital record of identity and immigration status confirming the conditions attached to the UK visa.
Sponsors should update their onboarding processes to inform their employees that they need to create the UKVI account and access their eVisas before travelling to the UK. HR teams should continue to rely on online right to work checks via the Home Office online share-code service rather than expecting a vignette.
5. High Potential Individual (HPI) – expansion and cap
Effective date: 4 November 2025
Some important changes were introduced to the HPI visa route. The Home Office doubled the current list of eligible institutions (‘the Global Universities List’), with discretion to exclude institutions where appropriate (e.g. national security) and have announced an annual cap of 8,000 applications.
HPI is an unsponsored route hence employers should consider this route as an additional option when considering recruitment of international workers.
6. Immigration Skills Charge (ISC) increased
Effective date: 16 December 2025
The Immigration Skills Charge (ISC) is a mandatory fee that employers pay when hiring skilled workers from overseas, designed to encourage training local staff. The ISC increased by 32% for Certificates of Sponsorship (CoS) assigned from 16 December 2025. For medium/large companies, the ISC increased from £1,000 to £1,320 per year, and from £500 to £660 for each subsequent six-month period. For small companies, the ISC increased from £364 to £480 per year and from £182 to £240 for each subsequent six-month period.
The costs rise in sponsoring workers has increased the overall cost of sponsorship, and it is likely to place an additional cost burden on employers that need to be budgeted for in future recruitment of international workers
What’s on the horizon
1. English language threshold raised from B1 to B2 level for economic migration routes (for first-time grants)
Effective date: 8 January 2026
Sponsored workers are required to prove their knowledge of the English language as part of the eligibility requirements for skilled worker sponsorship. The English language requirement for skilled workers and other economic migration routes will increase from the current Common European Framework of Reference for Languages scale (CEFR) level B1 to B2 for initial applications submitted on or after 8 January 2026. Transitional protection applies and where applicants are extending on the same route and who were granted permission subject to B1 level, will continue to be assessed at the same level.
Employers should factor this into the recruitment timeline and advise recruiters and/or new hires about the higher English language threshold in preparation for 2026.
2. Graduate route shortened to 18 months (PhD unchanged)
Effective date: 1 January 2027
The UK Graduate visa enables students to stay and work in the UK after finishing their degree offering them an unsponsored work route, giving employers a low-risk and cost-effective way to access skilled international talent without needing to sponsor them or meet the skill and salary threshold. The period of permission granted under the Graduate route will be reduced from the current two years to eighteen months for applications made on or after 1 January 2027. PhD or doctoral graduates will however continue to receive three years permission.
Employers relying on the Graduate route as a bridge to skilled worker permission will need to adjust workforce planning and check that switching under the UK’s points-based system remain viable.
3. Extension of right to work checks to non-employment arrangements
Effective date: To be confirmed
The Border Security, Asylum and Immigration Act 2025 received Royal Assent on 2 December 2025. Section 48 of the Act expands the current illegal-working regime by extending the right to work checks beyond traditional contracts of employment to ‘other working arrangements’ such as self-employed workers, contractors, sub-contractors or individuals engaged via online platforms.
The Home Office ran a consultation on this reform which closed on 10 December 2025. Employers can expect further operational guidance in 2026.
4. Earned settlement consultation
The Home Office has published the long-awaited consultation on reforming settlement (Indefinite Leave to Remain) through an “earned settlement” model. While these are only proposals at this stage, the direction of travel is clear: the residential qualifying period to settlement would no longer be an automatic five years. Instead, a ‘time adjustment’ model would apply where the qualifying period could be adjusted up or down according to defined factors.
The default qualifying period for settlement will increase from 5 years to 10 years for most economic migrants (including skilled workers). It will be 15 years for roles below RQF level 6 (e.g. many health care roles) or where an individual has been in receipt of public funds.
Those sponsored workers who earn a salary of £125,140 plus for the three years immediately prior to their settlement application, and holders of Global Talent or Innovator Founder visas should be eligible to settle after an accelerated period of 3 years. Sponsored workers earning a salary of £50,270 plus for three years immediately prior to their settlement application, and specified public-service workers should still be able to settle at 5 years.
We strongly recommend that employers engage with and respond to the consultation that closes on 12 February 2026.
Conclusion
To summarise, the 2025 reforms, still in motion, are re-shaping the UK’s immigration system by tightening access to skilled workers through increasing skill and salary levels as well as increasing visa costs. Employers must engage now and review recruitment pipelines to ensure that roles that are reliant on overseas workers, continue to be eligible for sponsorship - particularly in adult social care given the overseas closure of care worker visas.
It is recommended that employers engage with the ‘earned settlement’ consultation and review their workforce to understand how they will be impacted by the settlement proposals and help design a system that works in practice. It is vital that future policy reflects future workforce needs and commercial realities so business should have their say while they can.
As the Home office has ramped up compliance inspections increasing both frequency and intensity through introducing digital compliance checks, employers should consider conducting internal mock audit in early 2026 to mitigate any enforcement risk. Early workforce planning, targeted training for HR, recruitment teams and line managers will mitigate enforcement risk and protect workforce continuity in 2026.
For further information or assistance to navigate the changes to the Immigration Rules, please contact our Employment, Pensions & Immigration team.
