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Comment & Opinion

Sponsors beware – Major restrictions to skilled worker sponsorship from 22 July 2025

The Home Office published a Statement of Changes to the Immigration Rules on 1 July 2025 which confirms that some of the fundamental changes to the Skilled Worker route outlined in the earlier Immigration White Paper will be implemented this month. The changes are applicable to visa applications submitted with Certificates of Sponsorship (CoS) assigned on or after 22 July 2025, and are complex in part. The key areas sponsors will be interested in are set out below.

Salary increases

  • The general minimum salary requirement will increase from £38,700 to £41,700.
  • The minimum salary requirement for those on the Skilled Worker route before April 2024 will increase from £29,000 to £31,300.
  • The New Entrant rate will increase from £30,960 to £33,400.
  • Going rates for individual occupations will also rise in line with 2024 Annual Survey of Hours and Earnings data, and will need to be met in each case.

There are no transitional arrangements relating to the updates to salary requirements, therefore the increased salaries will take effect from 22 July 2025.

Skill level

  • The skill level will be increased from RQF level 3 (A-level) to RQF level 6 (bachelor degree level), reverting to the position pre the 2020 changes.
  • Around 180 occupation codes will therefore become ineligible for sponsorship (unless they are already on the Immigration Salary List or are included on the new Temporary Shortage List). Workers will continue to be able to be sponsored in these occupations only if they are already in the route or have been sponsored for an application which is later successful following the changes.

Immigration salary and temporary shortage lists

  • A Temporary Shortage List (TSL) will be introduced and will exist alongside the current Immigration Salary List (ISL) for a limited time.
  • Occupation codes below RQF level 6 will remain eligible for sponsorship only if they appear on either the TSL or ISL.
  • Both the ISL and TSL are transitional measures. All occupation codes on these lists will be removed and become ineligible for sponsorship by 31 December 2026, with the exception of adult social care occupation codes (6135 and 6136), which will remain eligible until 22 July 2028.
  • Workers sponsored in occupations on the ISL or TSL at RQF levels 3-5 will no longer be permitted to bring their dependants unless they were already permitted before these changes come into effect.

These changes will also come into effect on 22 July 2025.

Settlement/ ILR

  • No additional information has been provided regarding the proposed extension of the settlement period from 5 to 10 years, or the proposed tightening of the English language requirement applicable to the Skilled Worker route.

Practical steps for Sponsors

The above changes will significantly restrict the ability of sponsors to sponsor migrant workers from 22 July 2025. In the short time available before the changes take effect, we recommend the following steps are undertaken as a matter of urgency:

  • The existing undefined CoS allocation should be reviewed so that if any extension or switching applications are likely to be required before 22 July, CoS requests can be submitted in good time (bearing in mind the Home Office is likely to be inundated with priority service requests in the next couple of weeks!).
  • An audit of existing sponsored workers should be undertaken to ensure the new salary requirements will be met for extension applications. Where this won’t be the case, a new certificate of sponsorship should be assigned immediately (potentially for the full period required for eligibility for indefinite leave to remain to try to avoid the impact of future salary increases) so that an extension application can be made prior to 22 July.
  • An audit of employees working under temporary visas (such as student or graduate visas) should be undertaken. Where the intention was to switch them into the Skilled Worker route on expiry of those visas, a review of the skill and salary level should be undertaken immediately to check whether the post 22 July requirements will be met, or whether urgent switching applications are required before then.
  • Workforce planning measures should be implemented where the business currently relies on sponsorship for lower skilled / paid roles which won’t be eligible going forwards.
  • Steps should be taken to ensure staff responsible for sponsorship are kept updated with the changes so that they understand the implications for workers and the business and can reflect these in internal policy documents and decisions.

Our Business Immigration Team is currently working with sponsors to understand the impact of these changes on their existing and future recruitment needs. Please feel free to contact Shabana Muneer (Partner, Head of Business Immigration) or Ruth Jowett (Senior Associate, Business Immigration) to discuss the steps your business would benefit from taking.

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Shabana
Muneer

Partner

Employment & Immigration

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Ruth
Jowett

Senior Associate

Employment & Immigration

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