Further proposals set out in the Immigration White Paper are expected to be implemented by the end of 2025 at the latest. Businesses should consider how the upcoming changes to the immigration system could impact them and take actions now to mitigate.
Some of theGovernment's Immigration White Paper proposalsrelating to work routes wererolled out from 22 July 2025. These have already produced a significant impact on businesses by making sponsorship more costly and by removing the eligibility of most occupations below bachelor degree skill level.
The Government has promised a raft of further changes before the end of the year, however some could come earlier, especially as there is usually an Autumn update to the Immigration Rules.
In this article, we analyse the potential impact of these changes on you as a business and suggest actions to mitigate them. The recommended immediate actionsoutlined in our earlier articlealso continue to apply, noting that the processing times for sponsor licence requests (including for additional Certificate of Sponsorship (CoS) allocations) are taking time to be processed and you may need to use the priority service.
Immigration Skills Charge rise
The Immigration Skills Charge (ISC) for Skilled Worker and Senior or Specialist Worker sponsors is due to rise by 32 per cent.
This will mean an uplift:
- From £364 to £480 per year for small and charitable sponsors; and
- From £1,000 to £1,320 per year for medium and large sponsors.
Potential impact:
- Adding up to £1,600 to the cost of sponsoring a five-year visa under the affected routes.
Suggested actions:
- Review your sponsorship pipeline
- Make applications early (if an applicant is not exempt from ISC)
- Sponsor for the longest term appropriate to the contract (up to a maximum of five years).
Especially at this time of year, workers with Student route permission may be asking you to consider sponsorship. Individuals switching from the Student route to Skilled Worker are ISC exempt, but those who are switching from the Graduate route are not.
Higher English language requirements for work route applicants and dependants
For main applicants on work routes with an English language requirement, the proficiency threshold will increase from level B1 (intermediate) on the Common European Framework of Reference for Languages (CEFR), to level B2 (upper intermediate).
Adult work route dependants will be required to meet stepped English language proficiency criteria. This will be CEFR level A1 (beginner) for their initial application, rising to level A2 (elementary) at extension stage and level B2 (upper intermediate) at settlement.
Potential impact:
- Delayed or halted applications where applicants are unable to meet the English language requirement in the first instance, for example if they fail an English language test; and
- Concerns that dependants may not meet the new English language requirements may affect the worker's decision to relocate to the UK.
Suggested actions:
- Review your recruitment pipeline and consider making applications ahead of the changes. This will remove the immediate risk, and will also maximise the likelihood of the individuals will fall within the scope of any transitional arrangements that may apply;
- Sponsor for the longest term appropriate to the contract (up to a maximum of five years) to give any affected dependants the maximum possible time to improve their proficiency; and
- Consider using the Senior or Specialist Worker route (which does not have an English language requirement) as an alternative on a case-by-case basis.
New requirements for work route dependants
The White Paperconfirms that a new family route policy will be unveiled before the end of the year. This will cover (among other groups) the family members of individuals on work routes.
Potential impact:
- Changes to the relationship requirements, with more scrutiny of whether the relationship is genuine and subsisting;
- Higher English language requirements (see section above for more detail);
- Increased financial requirements, with a view to aligning these across family routes; and
- Tightening the suitability requirements for dependants (hese broadly cover issues of criminality and past conduct).
The full impact will only be known once the specifics of the new family policy have been published.
Suggested actions:
- Consider making any upcoming applications involving dependants as soon as possible under the existing Rules – doing so will also ensure that any affected individuals can benefit from any transitional arrangements that are implemented.
Earned settlement and earned citizenship
The default qualifying period for settlement in most routes is due to rise (with some exceptions) from five years to ten years. Individuals who can meet points-based criteria relating to their contributions to society and the economy may be eligible to settle earlier than ten years. The criteria for citizenship eligibility will be amended to align with the implementation of earned settlement.
The consultation process is due to begin sometime during the Autumn, and any changes likely to be implemented next year.
Potential impact
The proposals on earned settlement and earned citizenship have not yet been formulated, and there is no clarity on what transitional arrangements may apply. However, the following potential impacts are already clear:
- There may be a need to sponsor affected workers for longer, which will create an additional cost burden for your business;
- Your sponsored workers and their families will need to pay more immigration-related fees due to the additional extensions required to meet the qualifying period for settlement;
- Immigration restrictions associated with the affected individuals' immigration status may be extended, potentially limiting access to financial products (such as mortgages), career opportunities and higher education; and
- A delay to achieving settlement will, in many cases, lead to a corresponding delay in qualifying for British citizenship.
Suggested actions:
- Review your internal policies on whether and how you support applications for settlement;
- Consider encouraging those who are eligible for settlement (or citizenship, if this is the individual's ultimate goal) to apply as soon as they can;
- Consider responding to the planned consultation opportunities; and
- Consider flagging the changes and consultation opportunities to affected staff– this may help them to plan their path to settlement and citizenship most efficiently.
Note that EU Settlement Scheme (EUSS) participants will not be affected by the earned settlement proposals, but may be affected by the implementation of earned citizenship. They may therefore wish to apply for settled status and/or citizenship as soon as they are eligible. For further information on a recent change that means more EUSS participants are now eligible for settlement, see our separate article here.
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.
