UK Immigration: Recent and expected developments in 2026

We summarise recent changes made to digital permission for visa nationals travelling to the UK, a sharper focus on enforcement of Electronic Travel Authorisation (ETA) requirements and highlight some expected developments for 2026.

1. Digital Permission to enter the UK for Visa National Visitors

For UK Visitor visa applications paid for on or after 25 February 2026, successful applicants may not receive a visa vignette sticker and will instead receive an eVisa. Currently the announcement is couched as may not receive a visa vignette and realistically the physical visa vignette is likely to be phased out gradually by the middle of 2026. In practice the new process provides a more streamlined system whereby applicants attend the Visa Application Centre (VAC) only once to confirm identity, and their passport will be returned at the end of their appointment. The new framework is entirely separate to the ETA for which Visa nationals remain ineligible and applications will continue to be assessed under the framework of permitted activities under the UK Immigration Rules. 

Notwithstanding that after 25 February 2026 some may still be issued with visa vignettes for the immediate short term, all those travelling to the UK should ensure they have created a UKVI account to check their eVisa, update passport details and that they are able share their status. They must link their current passport to their eVisa to avoid any delays or additional checks. Where eVisa updates need to be made before travel to the UK, they will be made via this website. If updating their name, date of birth or nationality, individuals will need to upload a compliant identity document proving the change.

2. More robust enforcement of ETA requirements / Dual British and ETA eligible nationals

There are no substantive changes to ETA criteria but there will be increased enforcement of the mandatory requirement by Carriers and a zero-tolerance approach for those without an ETA arriving at any UK Port of Entry. In addition to UK and Irish passports holders, British Overseas Territory Citizens and British Nationals Overseas are exempt from ETA requirements. Currently those arriving in the UK on "outside transit" to London and Manchester airports are ETA exempt.

Dual British / Irish and ETA eligible nationals

From 25 February 2026, any UK and Irish citizens will not be eligible for ETA based on their dual eligible nationality, and for travel to the UK they will need to hold valid UK/ Irish Passports or other national passport endorsed with a Certificate of Entitlement to the Right of Abode. In extenuating circumstances, for example where a UK/ Irish passport holder's passports are lost or stolen overseas and there are no other options - whilst not ideal, they should apply for an ETA based on their dual eligible passport for the purposes of boarding. However, upon entry to the UK they will need to undergo additional identity checks until their UK or Irish nationality is verified, which may result in delays.

3. Ongoing consultations

(i) Earned settlement

The consultation ends at midnight on 12 February 2026 and any new law is expected to be implemented from April 2026, albeit subject to potential delay. Our advice of current “messaging” to share with employees regarding eligibility periods for ILR remains the same as our October 2025 Immigration update (here).

(ii) Temporary Shortage List (TSL)

The current TSL is valid for CoSs assigned on or before 31 December 2026. The Migration Advisory Committee are currently reviewing the TSL, and any changes are likely to be published in July 2026. Individuals with CoSs assigned under the present TSL will continue to benefit from Transitional Arrangements beyond 31 December 2026.  

4. Employers' Civil and Criminal responsibilites for Right to Work (RTW) of non-employees

The Border Security, Asylum and Immigration Act 2025 received royal assent in December 2025, extending right to work requirements to a broader range of non-“employee” working models. These now include agency and gig-economy workers, self-employed individuals, casual or temporary workers under a worker’s contract, individual sub-contractors, and online matching services that connect service providers with clients or customers for remuneration. However, these changes are yet to be implemented and realistically will first require amendment to the Code of Practice on Illegal Working and provisions under the Immigration (Restrictions on Employment) Order 2007.  

For further information please contact Jonathan Chaimovic, Alicia Percival or your usual Clyde and Co contact