By David Winnie
April 9, 2025
On 12 May 2025, the UK government released a comprehensive Immigration White Paper, marking a major change in its migration strategy. The new policy framework is designed to lower net migration, strengthen the development of the domestic workforce, and better align immigration with the country’s economic and social priorities.
As part of the Home Secretary’s foreword in the Paper, she states that the plan will “restore order, control and fairness to the system, bring down net migration and promote economic growth”.
Whilst the proposals signal a marked tightening of the UK’s approach to both legal and illegal migration (or so it states), the Paper lacks much of the detail which would be required to substantiate that.
As ever however, the devil will be in the detail. But it is not yet clear how or when these new measures will be introduced (they are described merely as ‘plans’ throughout the Paper).
We have summarised the key points below and how these changes are likely to affect UK businesses:
Skilled Worker Route: Elevated Skill Threshold and Reduced Eligible Occupations
The minimum qualification level for Skilled Worker visa eligibility will rise from RQF Level 3 (A-level equivalent) to RQF Level 6 (bachelor’s degree equivalent). As a result, approximately 180 occupations will be removed from the list of eligible roles.
This change will not affect existing Skilled Worker visa holders, who will remain eligible to extend their visas, change employment, and undertake supplementary work, including in roles below RQF Level 6 that are currently permitted. However, new applicants from overseas and those seeking to switch into this route from within the UK will be required to meet the elevated skills threshold.
While salary thresholds will be revised in line with this increase, no specific figures have yet been provided. These changes could be implemented swiftly; employers intending to sponsor lower-skilled roles, including current Graduate visa holders, are advised to expedite applications wherever possible.
Temporary Shortage List: Restrictive Use of Lower-Skilled Occupations
Only roles at RQF Levels 3-5 will qualify for sponsorship where they are included on a newly established Temporary Shortage Occupation List, subject to:
- Demonstrated long-term labour shortages;
- Endorsement by the Migration Advisory Committee (MAC);
- An established workforce strategy;
- A clear employer commitment to investing in the domestic labour market.
Employers sponsoring roles at RQF Level 6 or above will not be subject to additional training or workforce development obligations.
Increase in the Immigration Skills Charge (ISC)
The Immigration Skills Charge – currently £1,000 per year for medium/large sponsors and £364 per year for small sponsors – will be increased by 32%. This fee is payable upfront at the time of application. As with other reforms, this change may take effect at short notice; early submission of applications is advised to avoid additional costs.
English Language Requirements: Stricter Standards Across the Board
- Skilled Worker and applicable categories: Minimum proficiency level will rise from B1 to B2 (Independent User) under the Common European Framework of Reference for Languages (CEFR).
- Adult dependants of workers and students: A new requirement at A1 level (Basic User) will apply, aligning with partner visa routes.
- Visa extensions and settlement: Progression to A2 (for extensions) and B2 (for settlement) will be required.
- Settlement routes more broadly: Most will see their language requirement raised from B1 to B2.
These changes may necessitate longer lead-in times for employers recruiting non-native English speakers, especially where dependants are involved.
Graduate Visas: Reduced Duration
The Graduate visa route – currently granting two years of post-study work rights – will be reduced to 18 months.
Compliance and Enforcement Measures
The White Paper outlines a broad commitment to strengthening compliance mechanisms, including:
- Financial penalties and sanctions;
- Establishment of a Fair Work Agency to target exploitative employers;
- Enhanced civil penalties;
- Greater investment in preventing illegal working;
- Use of biometric technology and digital visa systems to support enforcement activity.
However, no detailed implementation framework has yet been published.
Indefinite Leave to Remain (ILR): Earned Settlement Model
The residency requirement for ILR will be doubled from five to 10 years for Skilled Worker visa holders. That said, accelerated settlement may still be available to individuals contributing significantly to the UK’s economy or society.
The government has stated its intention to consult on these reforms later in 2025, so implementation is not expected in the immediate term.
Closure of the Social Care Visa Route
The Social Care visa route will no longer be open to new overseas applicants. A transition period until 2028 will allow in-country visa extensions and switching for existing care workers with valid working rights. This arrangement is subject to ongoing review.
Labour Market Evidence Group (LMEG)
A new Labour Market Evidence Group will focus on sectors integral to the UK’s industrial strategy and currently dependent on migrant labour. The group will:
- Identify sectors requiring tailored workforce strategies;
- Recommend measures addressing skills, training, and employment conditions;
- Support re-engagement of economically inactive UK workers;
- Require relevant employers to comply with sector-specific workforce strategies.
Global Talent and High Potential Routes
The government has expressed broad support for attracting “the brightest and best” via:
- Expansion of high-talent migration routes;
- Acceleration of entry for individuals with critical skills;
- A targeted, capped expansion of the High Potential Individual (HPI) route, including a proposed doubling of qualifying institutions.
However, specific policy details remain undefined at this stage.
Recommended Employer Actions
In light of the proposed reforms, employers are advised to:
- Review the skills profile of current and prospective sponsored workers and consider early application where appropriate.
- Adjust recruitment budgets and forecasts in anticipation of increased ISC fees and the extended sponsorship period for settlement.
- Participate in Migration Advisory Committee (MAC) consultations, particularly where sectoral impacts are likely. Professional assistance is available to support submission of evidence.
- Monitor updates to the Immigration Rules expected in the coming months and be prepared to act swiftly as new provisions take effect.
Further detail is expected throughout the coming months via updated Immigration Rules.
In the meantime, should you have any questions or queries regarding the above, please contact David Winnie, Head of Immigration.
Find out more about our Immigration services here.
| David Winnie Partner, Head of Sports & Immigration | ||||
|
The information and opinions contained in this blog are for information only. They are not intended to constitute advice and should not be relied upon or considered as a replacement for advice. Before acting on any information contained in this blog, please seek solicitor’s advice from Gilson Gray.
