UK Immigration Update

Further to our recent Bulletin, we summarise the current status of the proposed changes foreshadowed by the Government’s White Paper in May 2025 as updated by the Statement of Changes published on 15th October 2025. As always, our principal focus is on the main “ employee” work routes.

Implementation Dates for some changes;

Increase to the Immigration Skills Charge (ISC)

• Effective for CoSs assigned on or after 16th December 2025, ISC will increase by 32% to £1,320 for Large Sponsors and to £480 for Small Sponsors;
• Current exemptions will remain including for CoSs assigned for 6 months or less and for those transitioning directly from Student to Skilled Worker Visas and;
• No transitional arrangements post 16th December 2025 for those extending Skilled Worker Visas / Change of Employment applications, i.e. all will be subject to the new ISC threshold.

Increased English Language Requirements;

• Effective for Skilled Worker Visa applications  submitted on or after 8th January 2026 the threshold will increase from B1 to B2 ( CEFR level). Changes will also apply to applicants under the High Potential Individual ( HPI) and Scale – up Visa routes;
• As things stand no requirement for Skilled Workers’ Dependents however imminent changes  likely which will require adult dependents to meet an albeit lower threshold;
• Transitional arrangements  apply to those currently in the UK under the Skilled Worker Visa route basis the B1 threshold and;
• Exemptions will continue to apply for nationals of designated English Language speaking countries and those applying under the Senior/ Specialist routes.

Changes to Graduate Visa 

• For applications submitted on or after 1 January 2027 non PhD  Graduate Visas will be reduced from 2 years to 18 months. PhD Graduates will remain eligible for a 3 years’ visa duration and;
• The 2 years’ Visa duration will continue to apply for those applying prior to 1 January 2027.

Changes to the HPI Visa route

• Effective for applications submitted on or after 4th November 2025;
• Increase to English Language threshold as above from B1 to B2 ( CEFR Level );
• Doubling of eligible universities from 50 to 100 and;
• Introduction of annual cap ( 1st November to 31st October) of 8,000.

Ongoing Consultations;

Eligibility for ILR

• Increase to ILR eligibility from 5 to 10 years for most routes. No further details to potential “Earned Settlement" criteria for which the 5 years’ eligibility period will continue to apply beyond those foreshadowed by the Home Secretary i.e. work status throughout a 5 year period, levels of National Insurance Contributions, “immaculate“ good character, amount of benefits received over qualifying period, and local community / charitable contributions;
• Contrary to indications by the former Home Secretary, as yet undefined Transitional Arrangements will apply to those currently on routes with a 5 year eligibility period and;
• Spouses of UK Citizens and individuals holding status under the EU Settlement Scheme will be unaffected by any changes with continued eligibility after 5 continuous years.

Expanded Right to Work (RTW) obligations for non employees;

• Current position applies Civil and Criminal Liability to sponsored “ employees “ only albeit “ best practice “ to ensure RTW of all non sponsored Contractors and;
• Potential extension of Civil and Criminal Liability to Contactors, for example personnel provided via IT / Cleaning / Catering arrangements.

Strategic considerations;

Skilled Worker Visa holders;

• Identify current Skilled Worker visa expiry dates on or before 15th March 2026 to facilitate assignment of CoSs at lower ISC levels;
• Identify new joiners pre 15th March 2026 to facilitate CoS assignment at lower ISC levels;
• Initiate pre 7th April 2026 new joiners to benefit  from lower English Language thresholds AND if viable, in advance of implementation of English Language requirements for adult dependents.

Current “messaging” to employees regarding eligibility periods for ILR;

• Currently in the Consultation phase and no defined eligibility criteria for “ Earned Settlement “ retaining current 5 years’ qualifying period;
• Current 5 years’ qualifying period will be retained for those  applying under the UK Spousal route and those with status under the EU Settlement Scheme;
• Transitional arrangements, as yet undefined, to apply for those currently holding status under routes with 5 years’ qualifying periods and;
• Further substantive details  unlikely prior to February 2026.

Current cohort of Contractors?

At this stage we recommend clients collate details of  current number of Contractors for example IT, Cleaning, Catering suppliers to better understand numbers and ensure coverage as an when changes are to be implemented.

If you have any queries, please contact Jonathan Chaimovic or your regular contact within the team.