And so it begins... first tranche of immigration changes published

Yesterday the Government published its latest Statement of Changes to the Immigration Rules. This follows its recent White Paper, which set out immigration plans aimed at reducing net migration. The majority of the changes, including the rise in skill and salary threshold, will come into effect from 22 July 2025, meaning employers will need to consider the impact of these changes as soon as possible given the 3-week timeframe.

Note that where a Certificate of Sponsorship has been assigned before 22 July 2025, the current rules will apply to that application (even if the subsequent visa application is considered later). Therefore, we would strongly encourage employers to consider whether they are in a position to expedite any applications, to ensure anyone impacted by the change to skill and salary thresholds can be sponsored as a skilled worker.

The statement of changes is not easy reading. Unfortunately the changes spell a significant increase in complexity within the immigration rules, with differing eligibility provisions applying to different groups according to when an individual was sponsored and the role in question. As such, there is far greater scope for errors in assessing eligibility and so sponsorship requests received should be considered carefully in light of this. We have summarised the headline issues below.

Increased skill thresholds

As mentioned in our previous article, White Paper spells significant UK immigration changes for employers - TLT LLP, we are set to see a return to pre-Brexit skills thresholds for skilled worker visas. From 22 July 2025 the skills threshold for skilled worker sponsorship will revert to RQF level 6 or above. This means that, when coupled with other changes (see below), around 111 occupations will no longer be eligible for sponsorship.

RQF level 6 means roles which are typically above bachelor’s degree level, although workers do not have to hold such qualifications. The rationale behind this is that lower skilled roles are considered quicker and easier to train people for, which aligns with the Government’s plans to improve training and upskilling within the UK.

There will be exceptions to this skills threshold increase, namely:

• Those who are currently sponsored as skilled workers in roles which fall below RQF level 6 (or are sponsored in such roles before the rule changes). They will continue to be permitted to renew their visas, change employment as well as take on supplementary employment. However, the Government has confirmed that this arrangement will be reviewed and will not be in place indefinitely.
• Those roles on the Immigration Salary List or the new interim Temporary Shortage List will remain eligible for sponsorship (see below). This will provide a welcome buffer against an immediate recruitment cliff edge for affected employers.

The old Immigration Salary List and the new interim Temporary Shortage List

The Immigration Salary List (“ISL”) will have the same fate as its predecessor the shortage occupation list and be abolished, but not until 31 December 2026. The current ISL will be expanded to include occupations at RQF levels 3-5 which the MAC identified as being in shortage in its 2023 and 2024 reviews. Therefore, two more SOC codes have been added:

• 1232 Residential, day and domiciliary care managers and proprietors; and
• 6131 Nursing auxiliaries and assistants

The rules relating to roles on the ISL will remain the same. Those who are sponsored in roles on the ISL will continue to benefit from the reduced general salary thresholds, although they will still need to meet the full SOC code going rates.

We will also have a new Temporary Shortage List (“TSL”) from 22 July 2025. The TSL will include roles which are RQF levels 3 – 5 and are seen to support the UK's industrial strategy and relevant projects. That will not comprise all roles at RQF levels 3 – 5. The TSL will include some roles which are otherwise being removed from the skilled worker route, including for example:

• 3512 Ship and hovercraft officers
• 3113 Engineering technicians
• 3131 IT operations technicians
• 3133 Database administrators and web content technicians
• 3544 Data analysts
• 4121 Credit controllers
• 5213 Welding trades

The TSL is much more extensive than initially envisioned. This offers some respite for those sectors we believed would be worst hit by the skills threshold increasing, including maritime and construction.

However, a keynote of caution – the TSL is temporary! The Migration Advisory Committee has been commissioned to review it and its occupations, salaries and benefits. Only those roles which the MAC believes should remain on the list will do so. We expect to see the TSL being amended by the end of 2026, so employers may wish to consider length of sponsorship, if pushing forward with sponsoring individuals whose roles fall below RQF level 6. Thereafter, the TSL will be kept under review and the inclusion of roles on the TSL will be time-limited and conditional on workforce strategies being in place. At this stage it is unclear what rules will apply to individuals sponsored in a TSL role if, when they come to extend, their role is no longer on the TSL. Further, it should be kept in mind that the Government intends to increase the continuous residence requirements for settlement, and the finer details of that are still awaited. The Government also reserves the right to bring forward the TSL review date.

One of the biggest changes will be that those who are sponsored for the first time from 22 July 2025 in a role on the ISL or TSL will no longer be permitted to bring dependents to the UK, subject to certain exceptions, mirroring the approach taken to care workers in March 2024. We note that some roles appear on both the ISL and the TSL and how these lists will interplay remains unclear, particularly in terms of any general salary threshold discount.

So, essentially from 22 July 2025 roles below RQF level 6 will only qualify for sponsorship for those new to the skilled worker route if the role appears on either:

• The ISL (as expanded by the new rules); or
• The TSL.

These lists provide some employers with a welcome and unexpected stay of execution for at least a short period. However, some roles that fall below RQF level 6 are being removed entirely including:

• 3560 – public service professionals
• 3582 – health and safety managers and officers
• 4124 – finance officers
• 4134 – transport and distribution clerks and assistants

Those already sponsored in SOC codes being removed, will for a limited time be able to extend their permission. However, this has been confirmed to be a temporary measure and the transitional provisions will not be in place indefinitely.

Increased salary requirements

We now have sight of the increased salary thresholds which will come into effect from 22 July. All salary thresholds are increasing to align with the 2024 Annual Survey of Hours and Earnings. Whilst not as significant as those we saw for skilled workers in April 2024, the rise will no doubt still be enough to deem some ineligible for sponsorship. Our recommendation is that employers consider whether to bring applications forward to ensure they are not priced out by the increases.

The general skilled worker threshold for those sponsored after 4 April 2024 will increase from £38,700 to £41,700. Those who are looking to rely on new entrant tradeable points after 4 April 2024, will also see an increase from £30,960 to £33,400. Other tradeable points options will also face similar increases.

Those who benefit from the transitional provisions, having been sponsored before 4 April 2024, will also see increases, with the general threshold increasing from £29,000 to £31,300. These changes will bite for extensions and changes of employment.

We will also see increases to the Global Business Mobility and Scale Up Worker routes, in line with the 2024 Annual Survey of Hours and Earnings.

Adult Social Care

From 22 July 2025, those applying for entry clearance under SOC code 6135 care workers and SOC code 6136 senior care workers will no longer be eligible for sponsorship.

Those already in the UK will still be permitted to switch into this route under those SOC codes until 22 July 2028, as long as they have already worked for the sponsor for three months prior to the application. From 22 July 2028 these roles will be removed from the ISL. This transitional provision will be kept under review in light of any further compliance concerns in the sector.

What are we waiting for?

The Government confirmed in a press release that we will see the increased English language requirements and the increased immigration skills charge by the end of the year. We will continue to keep an eye on these changes, as they will impact all sponsored or potentially sponsored workers. We also have no further news in relation to the shortening of the graduate route or the changes to settlement eligibility. There is some suggestion that following consultations in the coming months we will see those changes come to fruition.

Practical tips for employers

The main takeaway here for employers is that if you have concerns that a role may be below RQF level 6, or that an individual’s salary may not meet the increased thresholds, you should consider whether you are able to bring sponsorship forward. Those sponsored before 22 July will be considered under the current rules, even if their visa application is not considered until after that date. For now, those sponsored before 22 July 2025 will be shielded from the main impact of these changes by transitional provisions. Whilst the ISL and TSL may provide a temporary ability to sponsor some roles below RQF level 6 from 22 July 2025, the future ability for such individuals to extend or change employment at such a level remains unknown at this stage. Some roles are being removed from the rules entirely and will no longer be eligible, so this should be considered as a priority.

If expediting applications, at this stage consider whether you have a CoS allocation for in country applications, or whether you will need to request this from the Home Office and pay to fast-track the request given the timeframes. For out of country applications, we recommend ensuring defined certificates of sponsorship are requested in ample time given the potential for an uptick in requests ahead of these changes to impact processing times.

Further, when we saw the last significant changes in April 2024, the sponsorship management system was shut down in advance of the deadline to enable updates to reflect the new rules. This meant that CoS had to be assigned before the deadline of 3 April. It is possible the same thing may happen with these latest changes and so we recommend acting quickly to get any CoS assigned before 21 July. As we enter summer holiday season it will be important to ensure those with access to your sponsor licence are available to support your sponsorships within this period.

Please contact our Business Immigration team if you have any queries on how these changes may impact your business.

Authors: Joanne Hennessy and Megan Anderson

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at June 2025. Specific advice should be sought for specific cases. For more information see our terms & conditions.