Further proposals set out in the Immigration White Paper are
expected to be implemented by the end of 2025 at the latest.
Businesses should consider how the upcoming changes to the
immigration system could impact them and take actions now to
mitigate.
Some of theGovernment’s Immigration White Paper
proposalsrelating to work routes wererolled out from 22 July 2025.
These have already produced a significant impact on businesses by
making sponsorship more costly and by removing the eligibility of
most occupations below bachelor degree skill level.
The Government has promised a raft of further changes before the
end of the year, however some could come earlier, especially as
there is usually an Autumn update to the Immigration Rules.
In this article, we analyse the potential impact of these
changes on you as a business and suggest actions to mitigate them.
The recommended immediate actionsoutlined in our earlier
articlealso continue to apply, noting that the
processing times for sponsor licence requests (including for
additional Certificate of Sponsorship (CoS) allocations) are taking
time to be processed and you may need to use the priority
service.
Immigration Skills Charge rise
The Immigration Skills Charge (ISC) for Skilled Worker and
Senior or Specialist Worker sponsors is due to rise by 32 per
cent.
This will mean an uplift:
From £364 to £480 per year for small and charitable
sponsors; and
From £1,000 to £1,320 per year for medium and large
sponsors.
Potential impact:
Adding up to £1,600 to the cost of sponsoring a five-year
visa under the affected routes.
Suggested actions:
Review your sponsorship pipeline
Make applications early (if an applicant is not exempt from
ISC)
Sponsor for the longest term appropriate to the contract (up to
a maximum of five years).
Especially at this time of year, workers with Student route
permission may be asking you to consider sponsorship. Individuals
switching from the Student route to Skilled Worker are ISC exempt,
but those who are switching from the Graduate route are not.
Higher English language requirements for work route
applicants and dependants
For main applicants on work routes with an English language
requirement, the proficiency threshold will increase from level B1
(intermediate) on the Common European Framework of Reference for
Languages (CEFR), to level B2 (upper intermediate).
Adult work route dependants will be required to meet stepped
English language proficiency criteria. This will be CEFR level A1
(beginner) for their initial application, rising to level A2
(elementary) at extension stage and level B2 (upper intermediate)
at settlement.
Potential impact:
Delayed or halted applications where applicants are unable to
meet the English language requirement in the first instance, for
example if they fail an English language test; and
Concerns that dependants may not meet the new English language
requirements may affect the worker’s decision to relocate to
the UK.
Suggested actions:
Review your recruitment pipeline and consider making
applications ahead of the changes. This will remove the immediate
risk, and will also maximise the likelihood of the individuals will
fall within the scope of any transitional arrangements that may
apply;
Sponsor for the longest term appropriate to the contract (up to
a maximum of five years) to give any affected dependants the
maximum possible time to improve their proficiency; and
Consider using the Senior or Specialist Worker route (which
does not have an English language requirement) as an alternative on
a case-by-case basis.
New requirements for work route dependants
The White Paperconfirms that
a new family route policy will be unveiled before the end of the
year. This will cover (among other groups) the family members of
individuals on work routes.
Potential impact:
Changes to the relationship requirements, with more scrutiny of
whether the relationship is genuine and subsisting;
Higher English language requirements (see section above for
more detail);
Increased financial requirements, with a view to aligning these
across family routes; and
Tightening the suitability requirements for dependants (hese
broadly cover issues of criminality and past conduct).
The full impact will only be known once the specifics of the new
family policy have been published.
Suggested actions:
Consider making any upcoming applications involving dependants
as soon as possible under the existing Rules – doing so will
also ensure that any affected individuals can benefit from any
transitional arrangements that are implemented.
Earned settlement and earned citizenship
The default qualifying period for settlement in most routes is
due to rise (with some exceptions) from five years to ten years.
Individuals who can meet points-based criteria relating to their
contributions to society and the economy may be eligible to settle
earlier than ten years. The criteria for citizenship eligibility
will be amended to align with the implementation of earned
settlement.
The consultation process is due to begin sometime during the
Autumn, and any changes likely to be implemented next year.
Potential impact
The proposals on earned settlement and earned citizenship have
not yet been formulated, and there is no clarity on what
transitional arrangements may apply. However, the following
potential impacts are already clear:
There may be a need to sponsor affected workers for longer,
which will create an additional cost burden for your business;
Your sponsored workers and their families will need to pay more
immigration-related fees due to the additional extensions required
to meet the qualifying period for settlement;
Immigration restrictions associated with the affected
individuals’ immigration status may be extended, potentially
limiting access to financial products (such as mortgages), career
opportunities and higher education; and
A delay to achieving settlement will, in many cases, lead to a
corresponding delay in qualifying for British citizenship.
Suggested actions:
Review your internal policies on whether and how you support
applications for settlement;
Consider encouraging those who are eligible for settlement (or
citizenship, if this is the individual’s ultimate goal) to
apply as soon as they can;
Consider responding to the planned consultation opportunities;
and
Consider flagging the changes and consultation opportunities to
affected staff– this may help them to plan their path to
settlement and citizenship most efficiently.
Note that EU Settlement Scheme (EUSS) participants will not be
affected by the earned settlement proposals, but may be affected by
the implementation of earned citizenship. They may therefore wish
to apply for settled status and/or citizenship as soon as they are
eligible. For further information on a recent change that means
more EUSS participants are now eligible for settlement, see our
separate article here.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.