Long-awaited immigration white paper – what employers need to know

The UK Government has published its long-awaited immigration white paper this week, with the core aim of reducing net migration. Whilst the white paper does not signal immediate changes to legislation or to the immigration rules, it is important for businesses to understand its content and possible implications of these proposals. For employers, the proposed changes could lead to a narrower talent pool, higher costs of sponsorship, and stricter eligibility requirements. Sectors already struggling with workforce shortages — such as health and social care — are likely to be most affected.

A summary of the key proposals are as follows:

Work routes

• Raising the skilled worker visa threshold to RQF 6 (degree level) from RQF 3 (A-level), with salary thresholds set to increase in line with the higher skill level

The skilled worker visa was introduced in 2020, replacing its predecessor, the Tier 2 route. When introduced, the skilled worker route reduced the skilled level for eligible occupations from RQF level 6 to RQF level 3.  Under proposals set out in the white paper, the minimum skill level will return to pre-Brexit levels. The Government estimates that this will reduce the number of roles eligible for sponsorship by around 180.

Employers will need to review their current sponsored roles to assess whether they will continue to qualify for sponsorship if the reforms proceed as planned. Organisations will also need to prepare for higher salary thresholds and budget for these changes.

• Abolishing the Immigration Salary List (ISL) and 20% salary discount for shortage occupations

The ISL was introduced in April 2024, as a replacement to the Shortage Occupation List. It provides a 20% salary discount to the general salary threshold of £38,700 for eligible occupations. To provide for some degree of flexibility within the immigration system, the Government proposes the introduction of a Temporary Shortage Occupation List for RQF 3-5 level roles.

• Creating a Temporary Shortage Occupation List (RQF 3–5 roles) allowing for time limited access to the points-based immigration system. Access to this route would depend on several factors, including:
  • Occupations where there have been long-term shortages;
  • The Migration Advisory Committee (MAC) have advised it is justified;
  • There is a workforce strategy in place; and
  • Where employers seeking to recruit from abroad are committed to playing their part in increasing recruitment from the domestic workforce.
• Ending overseas recruitment of care workers

Despite reports of there currently being more than 130,000 vacancies in the care sector, the Government has stated its intention to end the overseas recruitment of care workers. There will be transitional provisions in place until 2028 permitting extensions and in-country switching for those already in the country with working rights, but this will be kept under review.

In its Net Migration report, the MAC has cautioned Government against looking at immigration policy in isolation, noting that a cap on the number of care workers may decrease net migration, but questions the impact on the social care sector.

• 32% hike in Immigration Skills Charge

At present, employers need to pay the Immigration Skills Charge (ISC) when assigning a certificate of sponsorship (CoS). The ISC is charged at £364 per year of sponsorship for small companies and charities or £1,000 per year for medium and large companies.  This increase follows a recent rise in the CoS fee, and visa application fees.

• Restricting dependants for lower-skilled roles

The ability of migrants to be joined by their dependants has been restricted in recent years for certain categories, such as students and care workers. The proposals suggest extending this restriction to lower skilled roles on the Temporary Shortage List.

Graduates

• Reduction in the time international students who have successfully completed their course of study in the UK can remain for post study work from two years to 18 months
• Doubling the number of eligible institutions for the High Potential Individual (HPI) visa route – a two-year work route for graduates from the top 50 ranked overseas universities

It had been feared that the Graduate route would be closed altogether so the fact that the route will remain open, albeit with a shorter period of leave, is welcome news. The route is often a stepping stone for the both the individual and the employer, allowing the individual to gain valuable experience and for the employer to decide whether the employee is a good fit for the role and organisation before committing to visa sponsorship.

With the expansion of the HPI route and retention of its two-year visa term, the proposals suggest a two-tier system, with overseas graduates appearing to be treated more favourably than UK graduates. This could have a negative impact on the overall attractiveness of the UK as a study destination for international students.

English language requirements

• Increase the English language requirements for skilled workers and other work routes subject to an English language requirement from level B1 to B2 of the Common European Framework of Reference for Languages (CEFR)

• Introduce an English language requirement for adult dependants of workers and students; level A1 for initial applications and A2 for extensions
• Increase the English language requirement for settlement applications from B1 to B2

Earned settlement and citizenship

• Qualifying period for settlement doubling from five to 10 years
• Qualifying period for settlement for dependants of British citizens to remain five years
• Qualifying period for citizenship to increase in line with settlement requirements
• Accelerated settlement and citizenship options based on contribution to UK economy and society

Another big change announced is the doubling of time it takes most migrants to reach settlement from five to 10 years. There will however be the possibility of accelerated settlement, but we do not yet know the detail of these plans.

Whilst the white paper was silent on whether this proposed change would apply to migrants already in the UK, the BBC has since reported that, subject to a public consultation, the changes will apply to those already in the UK. It will therefore be important for those nearing their current five-year qualifying period for settlement to make applications as soon as they are able to avoid being caught out by these changes.

Conclusion

The immigration white paper outlines bold changes, many of which will reshape the future of overseas recruitment and workforce planning. While much remains subject to consultation, the direction of travel is clear: a more restrictive system with higher thresholds and reduced flexibility. Employers should:

• Monitor government updates and MAC consultations;
• Audit their current and future workforce needs;
• Assess sponsorship costs and visa eligibility risks;
• Plan ahead for staff nearing settlement.

We will continue to provide updates as the proposals develop and are implemented.