2025 has seen the most extensive and stringent immigration measures introduced in decades, primarily driven by the government’s publication of the Restoring Control Over the Immigration System White Paper.
Below we have summarised the most relevant developments implemented in the past few months in addition to some of the key upcoming policy adjustments set to take effect in 2026 and 2027.
1. The Skilled Worker Visa overhaul
The Skilled Worker route underwent its most significant transformation, effectively raising the bar for eligible roles and salaries.
Higher skills and salaries (Effective 22 July 2025)
Minimum Skill Level Increased: The minimum required skill level for sponsored roles was raised from RQF Level 3 (A-level equivalent) to RQF Level 6 (degree-level equivalent) This change removed a substantial number of medium-skilled occupations from eligibility.
General Salary Threshold Raised: The main annual minimum salary threshold for new applicants (or those applying for a CoS after this date) increased from £38,700 to £41,700, or the applicable 'going rate' for the job, whichever is higher.
Transitional Salary Uplift: For individuals who were already sponsored under the Skilled Worker route before April 4, 2024, the lower transitional salary floor for extensions and new employer applications rose from £29,000 to £31,300.
New shortage lists and dependant ban
The Temporary Shortage List (TSL), introduced on 22 July 2025, is currently scheduled to expire on 31 December 2026:
This list was introduced to cover critical RQF Level 3-5 roles, but it comes with a major restriction.
Dependant Ban for TSL Roles: Workers sponsored for roles on the Temporary Shortage List (TSL) are NOT allowed to bring dependants This restriction does not apply to individuals whose CoS was issued before July 2025.
Higher English language requirement (Effective 8 January 2026)
The required English language level for new Skilled Worker applicants will increase from B1 to B2 level.
2. Closure of social care recruitment (Implemented July 2025)
The Health and Care Worker visa route was severely restricted for the adult social care sector:
End to Overseas Recruitment: The route was closed to new overseas applications for care worker roles (SOC 6135) and senior care worker roles (SOC 6136) from 22 July 2025.
Switching Restrictions: While existing care workers can still apply for extensions, there is a new requirement for those in the UK switching into the route to demonstrate at least three months of prior employment with the sponsoring company.
3. Cost increases and compliance enforcement
2025 saw significant financial increases and legislative changes to toughen compliance measures:
Immigration Skills Charge (ISC) Increase (Effective 16 December 2025): The charge payable by sponsors when assigning a Certificate of Sponsorship (CoS) increased by 32% for both the initial fee and subsequent annual payments.
Sponsor Licence Priority Service: The Home Office has significantly increased the costs for the fast-track sponsor services.
The Pre-licence Priority Service, which targets a 10-working-day decision on a new sponsor licence, has risen from £500 to £750. Similarly, the Post-Licence Priority Change of Circumstance Service for existing sponsors to expedite urgent changes (e.g., additional allocation requests) in 5 working days has increased from £200 to £350.
4. Forthcoming changes to note
Expanded illegal working penalties to be implemented
The Border Security, Asylum and Immigration Act 2025 has been approved, officially making its severe overhaul of the illegal working regime law.
While the Act received Royal Assent on 2 December 2025, the new, expanded enforcement powers are not yet fully implemented.
They will be brought into force on a date to be confirmed following the finalisation of new Right to Work guidance. The key change is the expansion of liability beyond direct employees to include all "other working arrangements," such as self-employed contractors, gig workers, and supply chains.
This new scope carries the government's significantly increased penalties, which can be up to £60,000 per illegal worker for repeat breaches. Businesses must urgently review and update their compliance processes for all non-employee workers now, in anticipation of the new rules taking effect soon.
Earned settlement
This is a critical proposal that is being laid before Parliament for consultation early in the first part of 2026.
The UK government's "Earned Settlement" model is a proposed overhaul of the Indefinite Leave to Remain (ILR) system, aiming to move from an automatic, residence-based right to a privilege that must be actively earned through contribution, integration, and compliance.
The central proposal is to increase the baseline qualifying period for most migrants from five to ten years. This baseline can be reduced for those who demonstrate higher value, such as through high taxable earnings (e.g., qualifying for settlement in three to five years with high salaries) or working in specified public service roles. Conversely, the period can be extended for negative factors like claiming public funds or immigration breaches. The consultation, titled "A Fairer Pathway to Settlement," is open until 11:59 pm on February 12, 2026.
You can access the consultation details and response form here: Earned settlement - GOV.UK.
Webinar Announcement: Navigating the New Immigration Landscape
Given the complexity and pace of these changes, we will be hosting a dedicated refresher webinar to discuss the cumulative impact of the 2025 updates and prepare for the 2026 requirements.
We strongly encourage all Licenced Sponsors, Migrant Workers, and their Dependants to attend.
Webinar Details:
- Date: Thursday 29th January 2026
- Time: 11:00 – 12:30 GMT
- Registration: To secure your place, please register to attend by clicking the button below.
Key Contact
Adam Haines
Employment Law and Business Immigration Partner
Adam is a Partner in our Employment Law team, currently working out of the Altrincham office.
