Immigration Round-up: November 2025

In this edition, you can find:

• UK Immigration Updates
• Alerts, Webinars & Resources
• Upcoming Public Courses
• Round-up Live

We hope you find these updates useful.

Section 1: UK Immigration Updates

1) October 2025 Statement of Changes

The UK Government’s October 2025 Statement of Changes to the Immigration Rules introduces a wide-ranging set of amendments that reflect evolving priorities – balancing border control, international cooperation, and humanitarian considerations.

These changes, announced on 14 October 2025 via a Home Office Statement and a written ministerial statement laid before Parliament, are already shaping the immigration landscape. While most White Paper proposals are now in force, one significant update – changes to the ten-year Indefinite Leave to Remain route – are still pending.

Below, we outline some of the key updates and changes to be aware of, helping you stay informed and prepared.

Immigration Skills Charge Increase

From 16 December 2025, the Immigration Skills Charge (ISC) will rise significantly, affecting businesses sponsoring migrants under the Skilled Worker and Senior or Specialist Worker routes (previously ICT category). The charge will increase by 32%, meaning large sponsors will pay £1,320 per year of the visa (up from £1,000), while small sponsors will pay £480 per year (up from £364).

Current exemptions remain in place for Certificates of Sponsorship (CoS) assigned for six months or less and for applicants moving directly from a Student visa to a Skilled Worker visa. However, there will be no transitional arrangements after 16 December 2025 – all Skilled Worker extensions and change of employment applications will be subject to the new ISC rate.

Sponsors should plan ahead to avoid higher fees. CoS’s must be assigned before 16 December 2025 to benefit from the lower rate and, once assigned, they must be used within three months. Visa applications can be submitted up to three months before the intended start date, so early action is key.

For UK-based applications, it would be sensible to ensure CoS’s are available in your Sponsor Management System (SMS). Standard requests can take up to 18 weeks, so consider using the priority service (as of 11 November 2025, this is now £350) for faster turnaround. For overseas applications, defined CoS requests are usually processed within one to two working days, but delays can occur if further information is requested, so we recommend submitting requests as early as possible.

Finally, note that the Home Office often closes the SMS the evening before changes take effect – sometimes earlier – so we suggest not leaving assignments until the last minute.

Increase in English Language Requirement

Meeting an English language requirement has long been a standard feature of most UK visa applications. Applicants who are not from a majority English-speaking country and do not hold a degree taught in English must take an approved English language test.

From 8 January 2026, the required English language level for the Skilled Worker, High Potential Individual (HPI), and Scale-up routes will increase from B1 to B2 (equivalent to A-level standard English) in all four skills (reading, writing, listening, speaking). This change applies only to first-time applicants to these routes from that date. Those already in one of these routes before 8 January 2026 can continue to meet the B1 requirement for future applications.

Key points to note:

• Effective 8 January 2026: Skilled Worker, HPI, and Scale-up visa applicants must meet B2 (CEFR level)
• Dependants: Currently, Skilled Worker dependants are not required to meet an English language threshold, but changes are expected soon introducing a lower level requirement for adult dependants
• Transitional arrangements: Applicants already in the UK under the Skilled Worker route can continue to rely on the B1 threshold
• Exemptions: Nationals of designated English-speaking countries and those applying under Senior/Specialist routes remain exempt
• Timing advantage: Initiating applications before 8 January 2026 may allow new joiners to benefit from the lower B1 threshold and avoid upcoming requirements for adult dependants

Graduate Route: Reduced Duration for Non-PhD Graduates

The Graduate route currently allows UK university graduates to stay in the UK for two years (or three years for PhD graduates) without requiring employer sponsorship. This route is a key entry-level option, enabling graduates to gain work experience and meet the salary thresholds for Skilled Worker visas.

From 1 January 2027, the visa duration for non-PhD graduates will be reduced from two years to 18 months. PhD graduates will continue to receive a three-year visa. Applications submitted before this date will still benefit from the full two-year period.

The Graduate route is widely used by UK students transitioning from study to work without sponsorship. Reducing the duration to 18 months will create pressure on businesses to accelerate structured graduate schemes and apprenticeships, which often run for two years. Employers should review their programmes now to ensure they can accommodate the shorter timeframe for the 2027 intake. Those students planning to use the Graduate route should apply before 31 December 2026 to secure the full two-year stay.

MAC Review of the Temporary Shortage List (TSL)

The Migration Advisory Committee (MAC) has published its Stage 1 report as part of a two-stage review of the Temporary Shortage List (TSL). Introduced in July 2025, the TSL allows time-limited visa sponsorship for “medium-skilled” roles that do not meet the usual Skilled Worker threshold.
In its initial review, the MAC identified 82 occupations as potentially critical to sectors such as Advanced Manufacturing, Clean Energy, Creative Industries, Defence, Digital and Technology, Financial Services, Life Sciences, and Professional and Business Services, as well as the delivery of critical infrastructure.

The MAC will now begin Stage 2, which includes a Call for Evidence running until 2 February 2026. Employers and sector bodies are encouraged to submit evidence on which occupations should be included. Submissions are limited to occupations approved in Stage 1 (see Annex A of the report) and can be made here Temporary Shortage List review: stage 2 - GOV.UK.

The TSL could become a vital tool for addressing skills gaps in priority sectors. Employers should engage with their representative bodies to ensure their views are reflected in the MAC’s final recommendations.

2) Priority Service Fee Increases and Limited Availability

The Home Office has increased fees for both pre-licence and post-licence priority services for eligible work route sponsors. In addition, the Premium Customer Service for sponsors has been discontinued. The following changes were implemented with effect from 11 November 2025.

1. Pre-licence priority service
   This service allows certain sponsor licence applicants to reduce processing times from eight weeks to ten working days for straightforward applications. The fee has risen by 50%, from £500 to £750
2. Post-licence priority service
   Existing sponsors can request faster processing of certain changes, such as additional Certificate of Sponsorship (CoS) allocations, reducing turnaround from up to 18 weeks to five working days. The fee has increased by 75%, from £200 to £350. Availability remains capped at 100 slots per day, offered on weekdays between 07:00 and 17:00
3. Premium Customer Service discontinued
   The bespoke account management service, previously priced at £25,000 per year for medium/large organisations and £8,000 for small or charitable organisations, has now been withdrawn

Operational update and future changes

The Home Office reports that current service standards for entry clearance, leave to remain applications, and CoS requests are being met, with CoS allocations processed in around eight weeks. However, with upcoming changes such as the Immigration Skills Charge increase and English language requirement adjustments, application volumes may rise, potentially affecting turnaround times.

To address demand, the Home Office plans to add 250 extra priority slots per week in the new year, subject to review. Sponsors should act early to secure priority slots and avoid delays.

3) Increased Enforcement Activity from Home Office: What Employers Need to Know

The UK Home Office has reported a 63% increase in arrests for illegal working, marking a significant escalation in enforcement under Operation Sterling. Since October 2024, there have been over 11,000 raids resulting in more than 8,000 arrests. This crackdown sends a clear message: the government is adopting a zero-tolerance approach, and employers must ensure robust compliance with right to work requirements.

Failure to comply can result in severe penalties:

• Fines of up to £60,000 per illegal worker
• Potential imprisonment for up to five years
• Risk of business closure

With the Home Secretary emphasising a hard-line stance, employers cannot afford complacency. Compliance is not only a legal obligation but also an ethical responsibility that safeguards workforce integrity and protects businesses from reputational and financial harm.

Employers should act now to review and strengthen right to work processes across all employment types. Preparing for future changes, including the introduction of digital IDs, and ensuring HR teams are trained and policies updated will be critical. The recent surge in enforcement is a wake-up call: the government is serious about a crackdown on compliance.

4) Proposal to Extend RTW to Non-Direct Employees

On 29 October 2025, the Home Office launched a six-week public consultation on proposals to extend Right to Work (RTW) checks beyond traditional employment arrangements. The consultation, which closes on 10 December 2025, seeks views on applying RTW obligations to a wider range of working models, including gig economy roles, contractors, and zero-hour engagements.

Currently, civil and criminal liability applies only to sponsored employees, although best practice recommends verifying the RTW status of all non-sponsored contractors. Under the proposed changes, these checks could become a legal requirement for businesses benefiting from an individual’s services, regardless of employment status. This would include personnel supplied through IT, cleaning, catering, and other subcontracted arrangements.

The government’s direction of focus suggests more prescriptive verification processes, stronger audit trails, and integration with digital identity solutions to prevent identity misuse and account sharing. For many organisations, this will mean mapping labour models, reviewing supplier contracts, and ensuring systems can support expanded compliance duties.

Many employers have robust RTW processes for employees but less consistent controls for contractors and third-party engagements. Any extension of statutory duties will require significant operational adjustments. Businesses should act early and start by identifying the number and type of contractors currently engaged to understand the impact of the potential changes.

Employers are strongly encouraged to respond to the consultation to help shape the final policy. Submissions can be made online before 10 December 2025 here Extending the Right to Work Scheme - GOV.UK.

5) Indefinite Leave to Remain (ILR) Consultation

The Home Office is currently consulting on significant reforms to Indefinite Leave to Remain (ILR) eligibility. At present, most routes require a five-year qualifying period, but proposals indicate this could increase to ten years for the majority of applicants. While details remain under review, transitional arrangements are expected for those already on routes with a five-year requirement, though these have not yet been defined.

The government has also signalled plans for an “Earned Settlement” pathway, allowing certain applicants to retain the five-year qualifying period if they meet strict criteria. These may include continuous employment, levels of National Insurance contributions, good character, minimal reliance on benefits, and evidence of community or charitable contributions. However, no formal eligibility rules have been published, and further details are unlikely before February 2026.

Importantly, the five-year qualifying period will continue for spouses of UK citizens and individuals with status under the EU Settlement Scheme, who will remain unaffected by these changes.

If implemented, these reforms will have a major impact on employers and sponsors, who may need to support skilled migrants for longer periods unless they qualify under the proposed points-based “Earned Settlement” route. The Home Affairs Committee has launched an inquiry into these proposals, examining their potential effect on immigration levels, the economy, and integration. Employers are encouraged to participate in the call for evidence, which is open until 2 December 2025, to highlight the financial and operational implications for businesses.  If you would like to contribute to the consultation you can do so online here: Home Office Consultation on Earned Settlement.

6) UKVI Sponsor Guidance Updates

On 11 November 2025, the Home Office made a series of updates to sponsor guidance across multiple routes. The main changes impacting sponsors are set out below:

• Advantageously, there is a new clarification on ‘branches’ of sponsors (including branch offices, subsidiaries and parent or sister companies), so that where a branch is currently unregistered on the licence, a sponsored worker working for the main sponsor or one of its registered branches can move to work for that branch before the addition of the branch has been approved by the Home Office. This will only be possible where the following apply:
  • The relationship between the sponsor and the branch meets the definition of ‘common ownership or control’ in the Global Business Mobility guidance
  • The sponsor has, and will continue to have, full responsibility for the worker’s duties, functions and outcomes or outputs
  • The sponsor has notified the Home Office of the worker’s change of work location within 10 working days of the change, and
  • The sponsor has made a request to add the relevant branch to its licence within 20 working days of the date the worker started working for that branch
• The trial of the Sponsor UK service that has been in place for certain sponsors in the Government Authorised Exchange (GAE) scheme has been closed and those sponsors will return to using the existing standard processes and Sponsor Management System. This follows the announcement by the Home Office in letters to stakeholders at the end of October 2025 that it had decided that it would no longer be proceeding with the development of a new sponsorship IT system (previously known as the Sponsorship Roadmap)
• The Premium customer service is being closed on 30 November 2025
• The Home Office has now confirmed its intention to phase out Level 2 Users over time, explaining that the distinction between Level 1 and Level 2 functions has become diminished in practical terms. Sponsors not yet affected need take no immediate action but are advised to plan for this change
• The Home Office provided clarification on which additional routes a person will no longer receive a vignette when successfully applying for entry clearance from 30 October 2025: Minister of Religion and Scale-up worker main applicants; and dependants in all sponsored routes
• Lastly, under Appendix D, sponsors must now follow updated procedures when verifying a worker’s date of entry where their passport does not contain an entry stamp. This may occur if the worker entered via e-Passport gates, travelled from another part of the Common Travel Area, holds an EU, EEA or Swiss biometric passport and applied via the ID Check app, or is an offshore worker arriving in UK waters without first entering the landmass. Sponsors must confirm the worker did not enter before the start date of their permission by checking their vignette or eVisa, request evidence of travel (such as boarding passes or tickets), and record the date of entry (though retaining evidence is not required). For offshore workers, sponsors must also report the date they arrived in UK waters in line with the Immigration (Offshore Worker Notification) Regulations

Section 2: Alerts, Webinars & Resources

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Section 3: Upcoming public courses

Cross border working – international remote working and international assignments – 20/01/2026

Section 4: Round-up Live

Our White Paper special Round-up Live will be held on Thursday 11 December 11am-12pm (UK time). This session gives you an opportunity to discuss the recent changes within the immigration landscape relating to the recent UKVI White Paper and to raise any questions about the issues that are currently affecting your business.

The login details to the Teams meeting room can be found below:

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