Skilled Worker route applications should be prioritised for review and submission as soon as possible under the current arrangements, ahead of expected mid-year Immigration Rule changes.
The Government's Immigration White Paper proposals are wide-ranging, including reforms to work routes, the Graduate route, settlement and citizenship. For further details of the main changes affecting businesses and workers, see our earlier article here. In this article, we provide a summary of why any Skilled Worker applications that are in the pipeline should be submitted as soon as possible.
Why should intending Skilled Worker applicants apply soon?
The White Paper, which was published on 12 May 2025, indicates that changes to sponsored work routes will be prioritised for implementation 'in the coming weeks'. This means we can expect changes to the Immigration Rules imminently.
As the overarching aim of the White Paper proposals is to reduce net migration, it is possible that very limited transitional arrangements may apply to exclude a rush on submissions for individuals who are entering the Skilled Worker route for the first time. For example, transitional arrangements may only extend to individuals with a Skilled Worker Certificate of Sponsorship assigned to them before the date the Rules are laid.
To avoid the situation where an intending applicant cannot apply because they are no longer eligible, we would suggest that entry clearance and switching applications to enter the Skilled Worker route should be submitted without delay.
We would also suggest that extension applications should be submitted as soon as possible for individuals who are close to the current salary thresholds, due to the likelihood of these rising.
How might the Skilled Worker route be changed?
The Skilled Work route is due to include the following changes, which could significantly disrupt existing recruitment plans and/or result in additional cost:
- Raising the minimum skills threshold from RQF Level 3 (A-level) to RQF Level 6 (bachelor degree level) – this will remove approximately 180 medium-skilled occupations from eligibility unless they are included on a new Temporary Shortage List;
- Introducing a new Temporary Shortage List (TSL) catering for medium-skilled shortage occupations – it is not yet known which occupations will be included, and whether there will be additional restrictions for workers and their family members imposed at the time the list is launched;
- Increasing the Skilled Worker general and going rate salary thresholds, both to reflect the new RQF Level 6 minimum skills level, and to adjust for updated annual wage data figures;
- Removing carers and senior carers from being eligible for Skilled Worker entry clearance (but allowing in-country switches and extensions up to 2028, and subject to a further review);
- Increasing the English language requirement for main applicants from CEFR Level B1 (intermediate) to B2 (upper intermediate);
- Introducing a stepped English language requirement for adult dependants, starting at CEFR Level A1 (beginner) at the first application, rising to CEFR Level A2 (elementary) at extension and to CEFR Level B2 (upper intermediate) at settlement; and
- Increasing the Immigration Skills Charge by 32%, i.e. to £1,320 per year for medium or large sponsors, or £480 per year for small or charitable sponsors.
It is not yet known which of the proposed changes may be included in a mid-year Immigration Rules update; however, early action will ensure that the impact of any potential changes can be avoided.
The Government is also intending to require a workforce strategy to be in place for sectors using the TSL, and is also considering this measure for RQF Level 6+ roles where there is evidence of over-reliance on immigration. These changes will, however, require consultation with the newly-established Labour Market Evidence Group (LMEG), so are not expected to be included in the next set of Immigration Rule changes.
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.
