Essential information for employers – less than three weeks to act on important changes to immigration law

The Home Office has published a statement of changes to the immigration rules which implements proposals set out in the recent Immigration White Paper. The changes are due to come into force on 22 July 2025.  These major changes will see over 100 occupation codes falling out of scope of the skilled worker route. The minimum general salary threshold is also increasing. Note that where a Certificate of Sponsorship (CoS) has been assigned before 22 July 2025, the current immigration rules will apply to those applications, even if the visa application is considered after this date. Sponsors need to urgently review their sponsorship requirements and ensure that any CoS for occupations becoming ineligible for sponsorship are assigned before 22 July 2025.

Summary of changes

Major changes to the skilled worker route are imminent, coming into force on 22 July 2025. The changes will result in the minimum skill level for sponsorship increasing to pre-Brexit levels and further increases to the minimum salary threshold for sponsorship. A summary of the key changes is set out below:

An increase to the minimum skill level

New applicants to the skilled worker route will need to be sponsored in a role assessed by the Home Office as being at RQF level 6 (degree level), up from the current RQF level 3 (A-Level). Whilst eligible roles will be required to be degree level roles, the skilled workers themselves do not have to hold a degree level qualification.

These changes apply to new applicants. There are transitional provisions to protect workers already in the UK on the skilled worker route. As such, skilled workers currently sponsored in roles which fall below RQF level 6 will continue to be able to renew their visas, change employment and take supplementary employment, in occupations below RQF level 6. The government does however warn that these transitional arrangements will not be in place indefinitely and will be reviewed in due course.

Immigration Salary List and Temporary Shortage List

Further exceptions to the increased skilled level are provided for by amendments to the existing Immigration Salary List (ISL) and the introduction of a new Temporary Shortage List (TSL). The ISL contains occupations which the Migration Advisory Committee (‘MAC’) have identified as having labour shortages and where it is sensible to offer a discounted salary. Whilst the ISL is to be discontinued by the end of 2026, interim measures will see occupations at RQF level 3-5 continue to be eligible for the Skilled Worker route where they appear on either:

• the expanded ISL, containing the existing entries plus occupations at RQF levels 3-5 which the MAC identified as being in shortage in its 2023 and 2024 reviews; or
• the interim TSL, 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.

52 occupation codes have been included on the new TSL. These roles are not immune from the increase to salary thresholds; there will be no salary discount for these roles as had previously been the case for roles on the predecessor Shortage Occupation List. Furthermore, main applicants in these roles will no longer be eligible to bring their dependants to the UK, which may deter applicants coming to the UK.

Increase to salary thresholds

The salary thresholds are also changing. The going rates are being amended in line with the latest (2024) Annual Survey of Hours and Earnings (ASHE) data, and the general salary thresholds are increasing. For those assigned a CoS from 4 April 2024, the general salary threshold is increasing from £38,700 to £41,700. The lower salary threshold for new entrants will also increase from £30,960 to £33,400. There are transitional provisions in place for those skilled workers who were sponsored before 4 April 2024, with their general salary threshold increasing from the current £29,000 to £31,300 when applying to extend or change employer.

Care Sector

The changes are bad news for the care sector. As indicated in the white paper, sponsorship of overseas care workers is to end. This change will come in effective from 22 July 2025; sponsors will no longer be able to bring in care (SOC 6135) or senior care workers (SOC 6136) from overseas from this date.

In-country applications will continue to be permitted until 22 July 2028, at which point these occupations will be removed from the Immigration Salary List or Temporary Shortage List. However, the proposed skilled worker will need to employed legally by the sponsor for at least three months on the date the CoS is assigned.

Action for sponsors  

Sponsors should review their current recruitment plans, particularly where sponsorship is being considered. For roles which will no longer be eligible, employers should consider whether it is possible to bring forward assigning the CoS to before 22 July 2025 as visa applications by these individuals will be considered under the current rules.

Please get in touch with a member of our business immigration team for advice and assistance in relation to these changes and how they might affect your business.