White Paper summary
This month, the Government introduced its White Paper, Restoring Control over the Immigration System, outlining proposed reforms to the existing legal framework. The document outlines government ambitions to curb migration and implement stricter UK visa eligibility criteria.
Firstly, it is to be stressed that the release of the White Paper does not introduce any immediate rule changes and therefore does not currently affect individuals already in the UK on a visa. At this stage, the Government has simply released its future policy intentions. There will be further discussions before any of the proposals are implemented, and the current Immigration Rules will remain in force until further notice.
In terms of implementation, it is likely that the changes will be introduced into the Immigration Rules gradually, starting with later this year. Therefore, employers are encouraged to review their list of migrant workers and/or need for migrant work and submit any prospective applications ahead of the changes to avoid becoming subject to new rules.
Changes to the Skilled Worker route
In 2020, the previous Government lowered the minimum skills level threshold to RQF 3 (A level equivalent) roles, which has said to have resulted in almost double the number of visa applications. The White Paper proposed to re-introduce higher thresholds back to RQF 6 (degree level and above). This will reduce the eligible occupations by at least 180 occupations – and will see industries such as the care, hospitality and retail sectors likely being unable to offer sponsorship.
Further, the Immigration Salary List, which is a list where the UK has a shortage of workers, which currently offers eligibility concessions is set to be removed.
The Government also proposes to increase the Immigrations Skills Charge by 32% to bring the rates in line with inflation; the first rise since it was introduced in 2017. This means for large sponsors, this will increase the fee from £1000 to £1320 per year, and for small sponsors, this will increase from £364 per year to £480.48 per year.
The White Paper also proposes to end overseas recruitment for the Social Care visa. However, individuals already in the UK on these roles, will be permitted to extend their visas, and in country switching for those already working in the UK will continue to be permitted for the time being.
The policy currently states that individuals currently in the UK and on the Skilled Worker route, will still be able to renew their visas, switch employers, and take on supplementary employment in occupations that remain eligible below RQF Level 6. However, new applicants from overseas or individuals seeking to switch into the Skilled Worker route from other visa categories will be subject to the revised skill level and eligibility criteria.
The Home Office has also indicated their intention to raise salary thresholds in this route further. No details beyond this have yet been published.
What can employers do?
Business may wish to consider:
- Supporting early visa extension applications before the costs and salary requirements increase.
- Supporting five-year applications (rather than three years).
- Carry out cost modelling to understand the possible implications of needing to sponsor workers for longer.
Temporary Shortage List
The White Paper states that they will introduce a Temporary Shortage List to provide those being sponsored on a lower-skilled role, RQF 3-5 to enter the UK on a Temporary Route, however this will be limited to certain sectors and occupations.
Employers wishing to sponsor workers under this category will be required to have a workforce strategy which aims to maximise the use of the domestic UK workforce as a priority and employers will need to agree training and broader plans with skills organisations – such as Skills England and Devolved Governments.
Employers will need to bear in mind that those being sponsored on the Temporary Shortage List will only be able to work for them in the UK for a limited period of time, and will not lead to Indefinite Leave to Remain.
Global Talent
The White Paper confirms that the Global Talent visa remains open to individuals who can secure endorsement. Under the proposals outlined in the White Paper, the Government aims to simplify and streamline the process, ensuring that highly skilled individuals have greater opportunities to come to the UK, details on how this will be achieved are yet to be seen.
Graduate route
The Graduate route which currently permits international students to remain in the country for two to three years after completing their studies, with unrestricted work rights and no sponsorship requirement, will also be under review.
The White Paper indicates that future Graduate visas will be issued for only 18 months, although it remains unclear whether this reduction will also apply to PhD graduates.
This change would however create an anomaly as the High Potential Individual visa will still offer a two-year visa for those graduating from a top international university – effectively incentivising the best talent to study overseas rather than the UK so further consultation on this change will be needed.
Reforms to the Family route
Before the year ends, the Government intend to introduce a new family policy which will apply to British citizens, those who are settled in the UK, individuals on work routes, and refugees seeking to reunite with family members.
The policy will establish clear relationship requirements to ensure only those in genuine, subsisting partnerships qualify. Financial requirements will also be reviewed, ensuring families can support themselves without recourse to public funds. Finally, the Government has also confirmed they are exploring how to tighten the Suitability Rules to ensure individuals meet the expectations of the good character requirements.
Changes to the English language requirement
The UK Government is introducing a more structured, staged approach to English language proficiency, and for the first time, this will apply to adult dependents.
- Entry Clearance – (A1 Level)
- Extension (A2 Level)
- Settlement (B2 Level)
This progression aims to ensure migrants can actively participate in everyday conversations and are indeed able to demonstrate integration into society.
Earned settlement
The White Paper suggests that the qualifying period for Indefinite Leave to Remain will increase from five years to ten years for most work-based visa categories. Individuals will be able to reduce the qualifying period based on their contributions to the UK economy and society.
However, dependants of British Nationals will still be in a position to qualify after five years in the UK, providing they remain compliant with their requirements.
Individuals who are in the UK qualify for settlement and intend on doing so are encouraged to consider making an application for settlement ahead of the new rules being introduced.
The Home Office has indicated that migrants already in the UK will also become subject to the ten year requirement – applying the rule retrospectively but as significant legal challenge is expected on this point this will likely be a formative part of the consultation process.
This would be a substantial additional cost to employers if they’re required to sponsor for double the duration – see worked example below:
Five year | Ten year | Notes | |
Certificate of Sponsorship | £525 | £1,050 | (Assumes two x five-year applications) |
Immigration Skills Charge | £5,000 | £13,200 | |
Visa application fee | £1,519 | £3,270 | (Assumes one x five-year entry clearance and one x five year Further Leave to Remain) |
Immigration Health Surcharge | £5,175 | £10,350 | Assumes a static rate of £1,035 per year |
Total | £12,219 | £27,870 |
Earned citizenship
Similar to Earned Settlement, individuals will be able to apply for citizenship based on their contributions to the economy and society but are expected to have to wait 11 years to qualify for citizenship (up from the current six-year qualifying period for most migrants).
Ecctis
Earlier this month, Ecctis launched a new Qualification and Language Service (QLS), which replaces the Visas and Nationality Service. The new QLS service will cost £210 and has a processing time of 20 working days. Ecctis have confirmed that there will not be a fast-track option to expedite processing times.
In light of this new service, anyone who is required to provide proof of their English language should consider the new costs, timescales and alternative routes of providing English language – such as siting an approved English language test for which results can be obtained in as little as 72 hours.
Other potential changes
This month, the Government has also suggested that they intend to strike a deal with the EU by introducing a Youth Mobility Scheme for EU Nationals. However, full details of when this might happen, and the terms of the agreement, are yet to be confirmed.
The Home Office has updated its guidance on eVisas
Individuals who were granted leave to remain in the UK before 31 October 2024, and who do not have a valid document, are now eligible to create a UKVI account and access their eVisa. This can be done using the following link: UKVI eVisa Guidance.
Additionally, as a reminder, expired Biometric Residence Permits (BRPs) will not be valid for travel after 1 June 2025. As of now, the Home Office has not announced any policy changes that would allow expired BRPs to be used for entering the UK beyond this date. To prevent travel disruptions, individuals are strongly encouraged to register for an eVisa as soon as possible.
Global talent endorser – Tech Nation
It has been announced that Tech Nation – the endorsing body for Global Talent visa for those with specialist tech’ skills has been re-appointed for a further three years.
The content of this article is for general information only. It is not, and should not be taken as, legal advice. If you require any further information in relation to this article please contact the author in the first instance. Law covered as at May 2025.