On 9 April 2025, the Home Office released several new sponsor guidance documents. As a sponsor, it is crucial to familiarise yourself with these changes and understand the implications to ensure compliance. This article is your resource to quickly get to grips with what's changed.
Most changes stem from a policy shift announced in last November's ministerial statement. Various measures were introduced, which were aimed at minimising abuse of the immigration system by work route sponsors. Other changes include more detail on other aspects of the sponsorship process.
Salary threshold increases for Skilled Workers
The lowest general salary threshold has increased from £23,200 per year (or £11.90 per hour) to £25,000 per year (or £12.82 per hour). Because of the general minimum salary increase, occupation-based going rates that are lower than £25,000 per year (£12.82 per hour) have been updated.
For more information, see our previous article, Salary rises and other changes to the Skilled Worker route from 9 April 2025.
More immigration routes are impacted by the ban on passing on sponsorship costs to workers
The Sponsor Guidance Part 1: apply for a licence provides examples of fees and other administrative costs that cannot be recouped from sponsored workers and extends the ban on recoupment beyond the Skilled Worker route to more immigration routes. Failure to comply is grounds to revoke a sponsor licence.
For more information, see our article here.
New rules on Skilled Worker salary deductions
The Home Office has introduced a new rule excluding certain salary deductions, repayment of loans by workers and investments made by workers into the sponsoring business from being counted towards meeting Skilled Worker salary thresholds.
If you are a Skilled Worker sponsor, it is vital that you understand and correctly apply the new rule. This is because failure to do so could affect your ability to hold a sponsor licence and could lead to your Skilled Workers' permission being cancelled.
Paying below the minimum salary requirement is also grounds to revoke the sponsor licence.
For more information about this change, please see our article here.
Neonatal care is now a permitted reason for a prolonged absence
Neonatal care has been added to the list of permitted reasons to be absent from work with or without pay, or on reduced pay for more than 4 weeks (according to the worker's normal working pattern). This aligns with other reasons based on employee rights, such as statutory maternity, paternity, parental, shared parental, or adoption leave.
For more detailed information see Sponsor Guidance Part 2: sponsor a worker.
Helpful additional guidance on voluntary work
The updated sponsor guidance clarifies that the following immigration routes allow voluntary work:
- Skilled Worker
- Global Business Mobility routes
- Minister of Religion
- International Sportsperson
- Scale-up
- Charity Worker, provided any additional voluntary work is in the same role as the one for which they are being sponsored and meets the definition of 'eligible charity work' on that route
Voluntary work can be performed in addition to work in the sponsored occupation, and in addition to any authorised supplementary or secondary employment.
A worker who is not sponsored on any of the above immigration routes is only permitted to do voluntary work if that is the role they are being sponsored for (in which case, they can do that voluntary work only).
No payment or benefits in kind can be given to a voluntary worker, but they can be reimbursed for reasonable expenses and accommodation as defined in s44 of the National Minimum Wage Act 1998. For detailed guidance see the HMRC internal manual (section NMWM05090).
It should be noted that voluntary work and volunteering are not the same. For more information, see Sponsor Guidance Part 2: sponsor a worker.
Additional restrictions on who can act as Key Personnel on a sponsor licence
A sponsor licence is normally revoked if an individual was previously listed as Key Personnel at an organisation that has had its licence revoked within the past 12 months. This ground has been extended to trigger revocation if the organisation's application for a sponsor licence has been refused in the last 6 months (exceptions apply).
Action points for sponsors:
- Review the new guidance: We've summarised the main changes in this article, but it is important that you thoroughly read and understand the new sponsor guidance documents released on 9 April 2025.
- Check and plan for salary rises: The lowest salary threshold has increased, so make sure that Skilled Workers who are due to extend, change employer or switch can continue to meet the minimum salary requirement. Read our article for more information.
- Review your existing arrangements for salary deductions, loans and investments: To ensure a Skilled Workers whose CoS is assigned on or after 9 April 2025 are eligible for sponsorship. Read our article for more information.
- Update your internal policies: Make sure any internal policies and procedures are updated to reflect the changes to neonatal care and make sure they correctly reflect the position in relation to voluntary work.
- Review your Key Personnel: Make sure they meet the requirements to perform the role. A simple mistake can have serious consequences.
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.