Immigration update – April 2026

Duty to access sponsor management system regularly

The UKVI has updated approval letters for new sponsorship licences to formally confirm that sponsors are expected to access the Sponsorship Management System (SMS) at least once a month. This is to ensure licence details are routinely reviewed, including allocations of Certificates of Sponsorship, the status of requests or applications, and the submission of any required reports relating to sponsored workers.

This means that all users should be logging in monthly – if you have a senior employee/executive who is the authorising officer but not a regular user, they will need to be reminded how to access the licence and the importance of doing so. Failure to regularly access the licence could be seen as an indication of lax sponsor management and lead to a compliance review/an enforcement visit.

Sponsors must therefore continue to ensure that robust processes and systems are in place at all times to meet their ongoing compliance and reporting obligations.

Differences between the Temporary Shortage List and the Immigration Salary List

There remains widespread confusion among employers and visa applicants about the distinction between Temporary Shortage List roles and Immigration Salary List roles — but it is important.

Where a role’s Standard Occupation Classification (SOC) code appears on the Immigration Salary List, a reduced visa application fee applies (£628 rather than £943 for in‑country applications of up to three years).

Temporary Shortage List roles do not attract this application fee discount. In these cases, the full standard visa application fee must be paid.

This misunderstanding commonly arises at the application stage and often leads to applicants being asked to make a top‑up payment, resulting in avoidable stress and unnecessary delays.

Employers and applicants should therefore take care to confirm the correct list at the outset, as this can have a direct impact on application costs and processing times.

Confusion is also rife in respect of roles being eligible for a discount on the minimum applicable salary levels required to be eligible for sponsorship. Roles on the ISL do benefit from a 20% salary discount, and the default minimum salary requirement is £33,400 per annum, whereas roles on the TSL must meet the standard minimum salary requirement of £41,700 per annum.

Increase in the number of priority slots for sponsor licence updates

The UKVI has confirmed that it has increased the availability of the priority service for post-licence requests by 20% (exact number unknown), with a view to further increases throughout the financial year.

The priority service line is open from 7 am and continues to be a ‘fastest fingers first’ service. Successful applicants who obtain a priority slot will benefit from a decision on their request within 5-7 working days of payment.

Expanding the scope of right to work checks

Many organisations still treat right to work checks as a routine HR onboarding step, focused only on employees. Following changes to Home Office guidance, since 8 April 2026, that approach is unlikely to be deemed sufficient for sponsor licence holders and is increasingly risky for all employers.

Updated sponsor guidance now makes clear that sponsors are expected to carry out right to work checks across a much wider population. This includes not only sponsored workers, but anyone they employ or directly engage in the business, as well as British citizens and settled workers. In practice, this may extend beyond employees to contractors, consultants, agency or freelance workers, and others engaged directly.

‘Directly engaged’ hasn’t been defined in the guidance, and this therefore leaves the scope of those caught by the new requirements unclear. Sponsors are advised to take a cautious and conservative approach to the interpretation of this and should note that the implementation date of this change is immediate.

This represents a significant shift from the historic legal position, which has focused on traditional employment relationships. While wider legislative reform is expected to extend right to work obligations for all employers in due course, the Home Office position for sponsors is that these expectations apply now, from 8 April 2026, as part of sponsor compliance duties.

This creates real practical challenges. A compliant right to work check must normally be carried out before work starts and cannot be recreated retrospectively. Where historic checks are missing, businesses can take mitigating steps, such as carrying out current status checks, but gaps cannot be fully corrected after the event.

The risk is material. Failure to meet sponsor duties can lead to licence downgrading, suspension or revocation, and Home Office audits are increasingly examining historic right to work records.

The key message for HR teams is clear. If your organisation holds a sponsor licence and only carries out right to work checks on employees, that model is no longer enough from 8 April 2026 and urgent review is required.

Band 3 NHS salary increase brings SOC 6131 roles within Skilled Worker salary thresholds

As of 1 April 2026, Band 3 salaries for NHS workers in England will increase to £25,760. As a result, NHS healthcare support worker roles aligned to SOC code 6131 (nursing auxiliaries and assistants) will now meet the minimum salary requirements for both in‑country and out‑of‑country Skilled Worker applicants.

This change arises because the new Band 3 salary meets and exceeds the £25,000 minimum salary threshold under Skilled Worker Points Option K, which applies to listed health and education occupations paid in line with national pay scales.

However, sponsors should note that SOC code 6131 is currently included on the Immigration Salary List, which is scheduled to close on 31 December 2026. At this stage, there has been no confirmation of transitional arrangements for individuals already holding visas once the Immigration Salary List ends.

In the absence of further government announcements, this creates a time‑limited recruitment and sponsorship window for these roles, running from 1 April to 31 December 2026. Employers should therefore review workforce plans and sponsorship strategies carefully to ensure they take full advantage of this limited window, while remaining alert to further government guidance.