Reading article phone

Next tranche of immigration changes published

On 14 October 2025 the UK Government published a Statement of Changes, amending a number of important areas of the Immigration Rules, which will affect a range of immigration routes.

Here are the key changes UK employers, multinational businesses and business travellers should note.

Increased English language requirements for economic migration routes

The White Paper previously outlined that English language requirements would increase for economic migration routes. This latest Statement of Changes confirms that the English language requirement for the Skilled Worker, High Potential Individual and Scale-up routes will increase from B1 level (intermediate) on the Common European Framework of Reference for Languages to B2 level (upper intermediate).

This proposed change will only apply to individuals who are applying in one of the above routes for the first time on or after 8 January 2026.

Importantly those who already hold visas in these routes prior to this date will not need to meet the increased requirement. In addition, no changes have been made to the English language requirements for dependants at this time.

Whilst this isn’t an unexpected change if there are concerns about whether an individual will meet this increased requirement employers should, where possible, seek to submit the relevant application ahead of this date.

This increase could reduce the number of individuals able to meet the eligibility requirements for these visas, which in turn could make it increasingly challenging for employers to recruit for certain roles.

Reduction of Graduate route permission to 18 months

The intention to reduce the length of the Graduate visa was outlined in the White Paper. The Statement of Changes confirms that where an application for a Graduate visa is submitted on or after 1 January 2027 the visa will now only be issued for 18 months. The only exception to this is for PhD graduates, who will continue to receive 3 years of leave.

The Government is hoping this change will mean graduate visa holders transition to graduate level roles quicker. However, reducing the length of graduate visas could impact the attractiveness of the UK as a further education provider and consequently the talent the UK is able to attract.

It is worthwhile noting that Student visa holders switching directly into the Skilled Worker route are exempt from the Immigration Skills Charge. The proposed shortening of the Graduate route may therefore encourage more employers to switch such individuals directly into the Skilled Worker route. The proposed increase to the Immigration Skills Charge (outlined below) may further encourage such an approach.

Changes to the High Potential Individual route

This is a visa for certain graduates of specific overseas educational establishments, which has to date been similar to the Graduate visa. From 4 November 2025 the list of eligible institutions will double (subject to any exclusions the Secretary of State considers appropriate).

If eligible on this visa route, individuals will be granted permission to stay in the UK for 2 years, or 3 years if they hold a PhD.  Unlike the graduate route, the period that this visa will be granted for is not reducing to 18 months.

There will also be a cap placed on this visa type limiting it to 8,000 applications per year.

The increase to the number of eligible institutions will be welcome news as it will increase the number of individuals eligible for this visa type. Consequently, employers should, when assessing visa options, consider whether this is a visa route that could be utilised, particularly if individuals need time to meet applicable sponsorship requirements for an alternative route.

Students moving to Innovator Founder route

From 25 November 2025 Student visa holders will be permitted to establish a business, where they have completed their course and have made a valid application under the Innovator Founder route.

Imposing a visa regime on nationals of Botswana

Nationals of Botswana are no longer able to apply for an Electronic Travel Authorisation (“ETA”). They will instead need to apply for a visitor visa before travelling to the UK.

There is a transition period in place until 15:00 GMT on 25 November 2025 that will allow nationals of Botswana who held a confirmed travel booking at the time of change (14 October 2025) and an ETA, to travel to the UK without a visit visa. 

If your business has a Botswana national who intends to travel to the UK for a permitted business activity they will be required to apply for a visit visa before travelling (unless they can benefit from the transitional period). The process of obtaining a visit visa is more challenging administratively and will take longer than obtaining an ETA. Businesses will therefore need to ensure this is factored into timescales.

Licence priority fee increase

We are continuing to see an 18-week service standard for post licence priority requests with the priority service oversubscribed. The post licence priority service fee increased from £200 to £350 on 21 October 2025.

The fee for those wishing to seek the priority service when submitting their sponsor licence application has also increased from 21 October 2025 from £500 to £750.

Horizon scanning

There are a number of further significant changes that we expect in the coming months:

  • The Immigration Skills Charge will, subject to approval by Parliament, increase by 32% on 16 December 2025. Following this change large and medium sponsors will need to pay £1,320 per year of visa sought whilst small or charitable sponsors will be required to pay £480 per year of visa sought
  • We also anticipate that the Home Office will continue to implement the additional changes that were outlined in the White Paper, such as the introduction of an English language requirement for dependants. We will continue to monitor the situation and update as required.
  • The Government also unveiled a plan for mandatory digital identity scheme at its latest conference in September 2025, which it believes will curb illegal working and make it easier for employers to carry out right to work checks. The scheme is intended to simplify right to work checks and compliment the new legislation that is to be introduced to expand the illegal working regime. There is to be a consultation on the Digital ID scheme later this year.
  • The Home Affairs Committee is currently calling for evidence as part of the inquiry into the Government’s proposals to extend the qualifying period for indefinite leave to remain from 5 years to 10 years.
  • The Migration Advisory Committee issued stage 1 of its report on the Temporary Shortage List which recommended that 82 of the roles currently on the list go through to stage 2 for further consideration. Stage 2 of their report is expected in July 2026 and employers should consider whether they wish to present evidence of shortages for any roles which are on the list at the moment.

Considerations for business

You should consider all the proposed changes and what these mean for your business going forward. Where there are concerns around the increased English language requirements it would be worth submitting the relevant application in advance of the proposed changes. Similarly, if considering sponsoring an individual it will be worth assessing whether this can be done before the proposed fee increases to the Immigration Skills Charge and potentially for a longer-term to minimise the impact of the increase.

The reduction in the grant of leave for those applying for a Graduate visa, and the impact this may have on those international students wishing to study in the UK, should be considered when assessing graduate recruitment plans.

To date the High Potential Individual route hasn’t been widely used and as such is often overlooked. The increase in eligible organisations will widen the pool of those eligible for this route and consequently it will be worth considering when assessing visa options for recent graduates, particularly as it is a route that doesn’t require visa sponsorship.

Written by Hannah Eades & Megan Anderson 

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

No items found.

No items found.

No items found.
Date published
23 Oct 2025

Managing Partner

Legal insights & events

Keep up to date on the issues that matter.

Follow us

Find us on social media

No items found.
No items found.