In our previous blog we highlighted the key points for employers arising out of the White Paper ‘Restoring control over the Immigration System’. The changes will make it more difficult for employers to sponsor staff in the UK as there will be changes to the skills and salary thresholds that need to be met to sponsor an employee under the Skilled Worker visa route.
In addition, employers in the social care sector will not be able to sponsor care workers or senior care workers going forward unless they are already in the Skilled Worker route or have been working for the sponsor for three months as at the date that the Certificate of Sponsorship is assigned.
The Statement of Changes to the Immigration rules dated 1 July 2025 detailing these changes has now been published.
When do the Immigration Rule changes come into force?
Most of the changes will become effective on 22 July 2025. The latest date for assigning a Certificate of Sponsorship under the current rules is 21 July 2025 (Cut Off Date).
For those whose Certificate of Sponsorship is assigned before that date, the current rules will generally apply. The safest approach is also to submit the visa application prior to that date (although provided that the Certificate of Sponsorship is assigned before then, the application should still be subject to the pre-22 July 2025 rules).
Employers therefore have a small window of opportunity for their employees to be sponsored under the more flexible current rules. In some cases, if an employer does not sponsor before the Cut Off Date, an employee may not be able to be sponsored at all due to the changes.
Employers should check if they have any current staff on graduate or other temporary visas who they might want to sponsor before the Cut Off Date (if such individuals will not meet the new salary or skills requirements from 22 July 2025). Similarly, if employers have new recruits who they want to sponsor, they may want to take advice on whether that is possible before the Cut Off Date. For assistance with this process, please contact us.
Key changes to the Skilled Worker route: increase in skills level
From 22 July 2025, the skills threshold for Skilled Worker visas will be increased to graduate level or above (RQF 6 and above). The threshold relates to the skill level of the occupation, rather than any qualifications held by an applicant. This will significantly limit the number of jobs which are eligible for sponsorship (reducing the number of eligible occupations by around 180). Currently some jobs at RQF 3 (A-level equivalent) and above are eligible for sponsorship.
This return to mainly highly skilled jobs being eligible for sponsorship, is a return to the position before the end of the Brexit transition period (when jobs had to be at RGF level 6 and above to be eligible for sponsorship). The Government has indicated that the change is necessary due to an increase in sponsorship levels and concerns about exploitation of overseas workers in jobs which are at a medium skills threshold.
Exceptions will apply (i) for those applicants who are already in the Skilled Worker visa route by the Cut Off Date; (ii) where an occupation is on the Immigration Salary List; or (iii) if a job is on the new interim Temporary Shortage list.
Revised salary requirements
From 22 July 2025, routine updates to salary requirements across the Skilled Worker, Global Business Mobility and Scale-up routes are being made. This is standard practice to ensure salary requirements continue to reflect the latest pay situation for UK workers. Updates are being made to the relevant general salary thresholds and also to the going rates.
Do the new skills levels and salary levels apply to existing employees already sponsored?
Skills levels: transitional arrangements exempt workers who are already in the Skilled Worker route (and include those already sponsored before the Cut Off Date). These transitional arrangements will not be in place indefinitely and will be reviewed in due course.
In relation to salary levels, there are no transitional arrangements relating to the updates to salary requirements. Therefore, individuals must meet the relevant requirements when they come to extend their visa. The Government will commission the Migration Advisory Committee (MAC) to undertake a thorough review of salary requirements (including discounts).
The salary related transitional arrangements for those sponsored before 4 April 2024 are still in place, but the applicable salaries have also been reviewed and updated.
Immigration Salary List and New Temporary Shortage List
The Immigration Salary List contains occupations eligible for Skilled Worker visas which the MAC have identified as having labour shortages and where it is sensible to offer a discounted salary. The Immigration White Paper sets out that this list would be replaced by a Temporary Shortage List. Occupations below RQF level 6 must be listed on the Temporary Shortage List in order to gain access to the immigration system.
The Statement of Changes clarifies that there are interim measures in place under which occupations below RQF level 6 continue to be eligible for the Skilled Worker route where they appear on either:
- an expanded Immigration Salary List, containing the existing entries plus occupations at RQF levels 3-5 which the MAC identified as being in shortage; or
- an interim Temporary Shortage List, containing occupations at RQF levels 3-5 which the Department for Business and Trade and His Majesty’s Treasury have identified as being important for the UK’s Modern Industrial Strategy.
The Immigration Salary List will be phased out in future changes to Immigration Rules.
Jobs on the Temporary Shortage List are time-limited and conditional. These changes therefore include removal dates for occupations on both lists.
Workers sponsored in occupations on either list at RQF levels 3-5 will not be able to bring dependants. This does not apply to occupations at RQF 6 or above, or workers sponsored in occupations at RQF levels 3-5 who are already in the Skilled Worker route and able to bring dependants by the Cut Off Date.
Adult social care changes
Entry clearance applications for Skilled Workers sponsored in the care worker and senior care worker job codes will cease from 22 July 2025 unless the individual has been sponsored by the Cut Off Date.
The changes provide for in-country applications, for those switching from other visa routes, to continue for a transitional period until 22 July 2028, at which point these occupations will be removed from the Immigration Salary List or Temporary Shortage List. To be sponsored as a social care worker, if the person is not currently in the Skilled Worker route, they will need to have worked for the sponsor in either of the social care job codes for at least three months as at the date that the Certificate of Sponsorship is assigned to them.
Graduate Visa route change
The Immigration White paper had indicated that the Graduate visa route (which currently allows those who have completed certain degrees / qualifications in the UK to apply for a visa to remain after their studies to look for work, work or take up self-employment) would change to 18 months rather than two years. The date for this change is not yet known as it was not included in this Statement of Changes.
For further information on any of these changes, please contact Elaine McIlroy, Erin McLafferty or Gregor Craig-Murphy from Brodies Employment and Immigration team.
