The Immigration White Paper announced a number of changes affecting UK employers and their sponsored workers. Our earlier note summarises the proposals in the Immigration White Paper published on 12 May 2025.

Reflecting on these changes, we now provide our thoughts on what these mean for Skilled Worker visa sponsors and employers. Companies from different industries will be impacted in different ways but here are key takeaways to prepare for the changes to come. 

While the details of how some of the changes will be implemented remains unknown, there are opportunities for sponsors to review their position internally to better support their workforce. We have made some suggestions below.

A summary of the key changes impacting companies includes:

1. an increase to the minimum skill level and salary thresholds to be eligible for a Skilled Worker visa;
2. an increase to Immigration Skills Charge;
3. an increase to the qualifying period to settlement;
4. a reform to the Global Talent and High Potential Individual visas; and
5. workforce strategy plans.

Skilled Worker minimum skill level and salary thresholds

The Government has confirmed that they intend to raise the skill level for eligible occupations under Skilled Worker from the current RQF level 3 (school-leaver, A-Level) to RQF level 6 (roughly translates as graduate/Bachelor’s level). This is a return to the pre-December 2020 requirements under Tier 2 (General), the predecessor to the Skilled Worker visa.

While a Temporary Shortage List will be published to allow temporary access for roles below this level, this change will mean that approximately 180 occupations will no longer be eligible for sponsorship under Skilled Worker. 

The announcements provide some assurance that transitional provisions will be brought in to allow existing Skilled Worker visa holders to renew their visa, change employment and take supplementary employment in currently eligible occupations below RQF level 6. However, applicants from overseas, or those applying to switch to the Skilled Worker route from within the UK, will have to follow the new measures. The White Paper was silent on whether those benefitting from the transitional arrangements will be able to obtain settlement if they are in a role below RQF level 6 when they apply. This is likely to be the case but we await formal announcements.

At this stage, it would be prudent for employers to review the occupation codes they have used historically to determine how much the company relies on workers in roles below RQF level 6. If there are commercial and operational reasons to sponsor low skilled roles, thought should be given as to whether they can recruit these roles from the pool of UK-based applicants. In tandem, employers should consider what training or further education can be provided to new or existing UK-based employees to prepare them for these roles.

The current minimum salary for Skilled Worker visas is £38,700 per year, which is based on the median salary for occupations currently eligible (RQF level 3 and higher). There is also a minimum salary requirement applicable to each occupation which may be higher than £38,700 that will also need to be met. The White Paper confirms that the salary threshold will rise, but it does not confirm the new figure.

Employers should also review their sponsored workers’ salaries, especially those that are only slightly higher than the current minimum (based on the general visa or occupation thresholds), so employers can consider the future salary requirements of the visa.

Immigration Skills Charge (ISC)

The ISC was introduced in 2017 as a deterrent for over-reliance on the sponsorship system and to provide the Government with funds to upskill the domestic workforce. The fee is currently £364 per year for small or charitable sponsors, and £1,000 per year for medium or large sponsors. The announced 32% increase will mean new fees of £480.48 per year or £1,320 per year, respectively. Therefore, sponsors will need to consider this in their workforce planning and weigh up whether sponsoring workers bring sufficient value for the company to justify these costs. 

ISC costs cannot be passed to employees and must always be borne by the sponsor. This change will affect employers’ immigration budgeting and must be factored when projecting future immigration costs.

At this stage, employers should refer to their historical figures and estimate what are the additional costs if their sponsorship patterns remain the same.

Qualifying period for settlement and citizenship

The Skilled Worker visa route gives a path to settlement in the UK, also known as Indefinite Leave to Remain (ILR). At present, Skilled Worker visa holders can obtain ILR after five years of continuous residence in the UK.

The White Paper proposes to raise the qualifying period for ILR to 10 years, with an emphasis on “earned settlement”. There is the notion that individuals should contribute to the economy and society before gaining ILR and the new proposals are intended to address this. Individuals will have the opportunity to reduce the qualifying period based on a “points based” assessment of their contributions to the UK economy and society. It is not yet clear what this means in practice but factors such as salary or other economic benefit will likely be considered. The Government intends to consult on these changes over the course of this year.

There have been some suggestions that the Government intends to apply this change retrospectively to Skilled Workers already in the UK on a path to settlement. In the past, changes to the Immigration Rules would typically apply to those entering a UK visa route after the changes comes into force and would not normally apply retrospectively to applicants already in the UK on an existing visa route. This would be the expected legal position but this is still subject to consultation which we know will be happening in the coming months. We can expect further details to be provided later this year.

If the Government insists on applying this change retrospectively, it would be prudent to introduce transitional arrangements, such as allowing applicants to apply for settlement under the five-year route by a certain deadline before the 10-year requirement kicks in. This would give applicants a fair opportunity to apply under the current rules. It remains to be seen whether this will be implemented and we expect that individuals or invested organisations will seek to challenge the position if the Government do not put in place transitional arrangements at the very least.

For employers, the obvious impact will be that costs will double to sponsor individuals for 10 years instead of the current five.

Employers should take the opportunity to engage with the Government consultations once announced and to provide any empirical evidence of the impact of this change, both on their employees and the wider business (such as increased costs). Employers should also review their current immigration policies, specifically in relation to the support they provide to employees at present. For example, if their policy covers the costs of dependants, this will mean a significant increase to cover those in the future and employers can consider limiting such a benefit for employees.

Alternative visa routes – Global Talent and High Potential Individual visas

The Global Talent visa route is for individuals deemed leaders, or potential leaders, in the STEM, academia and arts sectors to obtain visas. The route often leads to settlement after three or five years. The White Paper states that they intend to increase places for research interns, including those working in the field of artificial intelligence, to allow businesses access to additional promising young talent. They also intend to make it simpler and easier for top scientific and design talent to use the Global Talent visa. This is a positive change and may make more individuals eligible for the visa. If so, we would encourage employers to use this route for the relevant workers to reduce the economic burden placed on hiring under the Skilled Worker visa route.

The High Potential Individual (HPI) visa allows for recent graduates of top global universities to obtain a two-year visa in the UK. The White Paper confirms they intend to double the number of eligible global universities, meaning this route will now likely be accessible to a wider pool of applicants. Similar to the positive impact of the Global Talent visa changes above, it will likely mean a reduced cost to employ individuals under this visa. However, it’s important to note that the HPI visa does not lead to settlement, so individuals will need to switch to another visa category before that expires to maintain their right to reside and work in the UK. Therefore, this may be suitable for staff on short term contracts or roles which are not permanent. 

The current usage of these routes may increase due to the above and employers should, in the future, consider these alternative visa options before proceeding down the Skilled Worker visa route.

Workforce strategies

The Government believes that a lack of comprehensive workforce plans has limited the ability of certain sectors to address the underlying drivers of staff shortages within the domestic workforce (namely skills, training and conditions), meaning they rely more on overseas workers.

To address this, key sectors where there are high levels of recruitment from abroad will need to produce, or update, a workforce strategy with which employers will be expected to comply. This will detail steps to be taken on “skills, training, and broader conditions, as well as engagement of the economically inactive domestic labour force”.

It is too early to understand what type of burden will be imposed on employers to meet this as the policy will be dictated by findings and recommendations by the soon-to-be-created Labour Market Evidence Group.

At this stage, employers should take stock of what steps they already undertake on addressing shortages amongst the domestic workforce, such as outreach or training programmes targeting UK-based individuals.

Conclusions

In summary, the forthcoming changes outlined in the Immigration White Paper represent a significant shift for UK employers who sponsor overseas workers. The increase in skill and salary thresholds, higher Immigration Skills Charge, extended qualifying period for settlement, and reforms to alternative visa routes will all have a direct impact on workforce planning, recruitment, and budgeting. Employers will need to carefully assess their current reliance on roles below RQF level 6, review salary structures, and anticipate increased costs associated with sponsorship and settlement. Additionally, the emphasis on comprehensive workforce strategies and the expansion of alternative visa routes such as Global Talent and High Potential Individual visas present both challenges and opportunities for employers to diversify their approach to talent acquisition.

These changes provide an excellent opportunity for employers to review their existing immigration processes, workforce strategies, and internal policies. Proactive planning now will help ensure compliance, manage costs, and maintain access to the skills the business needs.