UK Immigration Round-up: September 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.

UK Immigration Updates

1) Debate on proposal to extend qualifying period for Indefinite Leave to Remain (ILR) from 5 to 10 years

On 8 September 2025, the House of Commons debated two e-petitions opposing the Government’s proposal to extend the qualifying period for ILR from five to ten years, highlighting concerns over fairness, trust, and the retrospective impact on Skilled Worker and British National (Overseas) visa holders. MPs criticised the anxiety caused to migrants who entered under existing rules, warning of disrupted lives, increased costs, and challenges for employers in key sectors. While the Government reiterated that settlement is a privilege, it acknowledged public concern and confirmed a formal consultation will be launched later in 2025 to gather feedback and consider sector-specific protections before finalising the policy.

EES, replacing manual passport stamping for non-EU nationals, including UK travellers to the Schengen Area. Travellers must register their biometric data - photo and fingerprints - on their first visit to the Schengen Area, with records valid for three years or until passport expiry. Children under 12 are exempt from fingerprinting. If the traveller is entering the Schengen Area through St Pancras International, the Eurotunnel at Folkestone or the Port of Dover, the EES check will be conducted pre-departure within the UK. The EES will implemented over a period of six months and is expected to be fully operational by 10 April 2026. No pre-travel action is required, but travellers should allow extra time at borders. The EES is being introduced as part of wider work the EU is undertaking to strengthen border security, culminating in the European Travel Information and Authorisation System (ETIAS) being launched on a date yet to be confirmed in 2026.

3) Home Office Publishes Quarterly Illegal Working Penalties

On 29 August 2025, the Home Office published its quarterly list of employers who had received civil penalties for hiring illegal workers, covering the period from 1 January to 31 March 2025. Fines totalled £18.6 million, with many businesses fined £45,000 for first-time offences. Sectors affected include hospitality, retail, construction, and care, with a particular focus on businesses such as car washes, takeaways, and salons. The report signals increased illegal working enforcement, with potential consequences other than civil penalties including criminal charges, sponsor licence revocation, and reputational damage. Employers are urged to review right to work procedures and conduct audits to ensure compliance.

4) Sponsor Licence Revocations Hit Record High

Between July 2024 and June 2025, the UK government revoked 1,948 sponsor licences - more than double the previous year’s figure - as part of a broader crackdown on immigration system abuse. Sectors which saw the highest levels of sponsor licence revocations include adult social care, hospitality, retail, and construction for a wide range of sponsor breaches, including underpayment of migrant workers, facilitating the entry of individuals to breach the immigration rules, or failing to deliver promised jobs. Based on current trends, sponsor revocations for this year are expected to exceed the record high once again. Sponsors are therefore urged to review their sponsor duties and undertake audits to ensure compliance.

5) UKVI Priority Change of Circumstances Service – High Demand, Limited Access

The priority change of circumstances service allows sponsors to prioritise certain requests (e.g. additional Certificate of Sponsorship (CoS) allocation, adding new level 1 user, replacing the Authorising Officer) each day, by submitting an application via email. The service offers faster processing than the standard 18-week route, typically completing requests in five working days. Despite extended operating hours and an increased daily cap of 100 requests, slots fill rapidly and have been very difficult to come by in recent weeks (even when submitting daily requests at 6:59 am). UKVI has also increased scrutiny of submissions and could lead to requests for information or rejections without refund. Due to high demand, the service should be used as a contingency, not a routine solution. Sponsors are advised to plan ahead, forecasting changes early.

6) Ukraine Extension Scheme Extended

On 1 September 2025, the UK Government announced that the Ukraine Permission Extension (UPE) scheme would be extended for a further 24 months. This extension allows eligible Ukrainian nationals and their family members—who are already in the UK under one of the Ukraine visa schemes—to apply for a further period of permission to remain in the UK following their initial UPE grant. Further details about the extended scheme are expected to be released in due course.

7) Reduction in Visas Granted Across Key Categories

New Home Office data reveals a steep decline in non-visit visas granted, with 852,324 issued in the year ending June 2025 – 11% down on the previous year – driven by sharp falls in the work and study routes. The number of Health and Care Worker visas granted fell by 77%, following policy changes restricting dependants and tightening employer checks. The number of Student visas granted were down by 18%, also due to restrictions on dependants. The number of Worker visas granted (which includes Skilled Worker visas) dropped by 38%, largely due to higher salary thresholds and the increased skill level to RQF6 for the Skilled Worker route. These changes have contributed to a growing recruitment crisis across several sectors, including the hospitality and care sectors.

8) Further Clarification on Salary Deductions for Immigration Costs

Where a sponsor covers immigration costs upfront, the sponsor can seek to enter a loan agreement with the sponsored worker to recover certain immigration costs (i.e. Immigration Health Surcharge and visa application fees for both the sponsored worker and any dependants) through deductions from the sponsored worker’s salary. Please note, sponsor licence fees, Certificate of Sponsorship (CoS) fees, legal fees relating to sponsor compliance/CoS assignment and the Immigration Skills Charge can never be passed on to the sponsored migrant. Priority service and legal fees for advising the sponsored worker can only be recovered if the sponsored worker has a voluntary and informed choice.

For Skilled Worker applications submitted on or after 9 April 2025, the individual’s salary has to account for any salary deductions relating to these immigration costs and therefore can impact on eligibility for sponsorship. Where the role remains eligible for sponsorship even when taking into account salary deductions relating to these immigration costs, the recoupment arrangements should be set out in a sponsor note following CoS assignment.

The Home Office has clarified that, where a dependant applies separately from the sponsored worker at a later stage, the sponsor covers the dependant’s immigration costs and recoups these through a loan agreement by deducting from the sponsored migrant’s salary, the impact on salary should be averaged over the total length of sponsorship and reported through the sponsor management system in the same way as other reductions in salaries.

Sponsors are urged to review and document all cost recovery arrangements carefully and ensure that salary deductions relating to immigration costs for both sponsored migrants and dependants are taken into account both when assigning the CoS and throughout the duration of sponsorship.

Alerts, Webinars & Resources

Global employment and labor law update - We have transformed our Global Employment and Labor Law Update into a new dynamic hub making it easier than ever to access the latest insights and developments across multiple jurisdictions. We have incorporated our EU Directives Tracker into our Managing a Global Workforce hub – helping you to stay ahead of the curve with easy access to summaries of key employment-related EU Directives and practical actions, and allowing you to monitor the status of the Directives as they move through the EU legislative process and into local implementation.

Read our latest update on legal employment and labor law developments.

Access our Managing a Global Workforce hub  

Upcoming public courses

• Immigration UK – Right to work in 2025 – 08/10/2025 & 09/10/2025
• Immigration UK Business – sponsor licencing course - 18/11/2025 & 19/11/2025

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Round-up Live

Our  Round-up Live will be held on Thursday 6 November 11am-12pm (UK time). This session gives you an opportunity to discuss the recent changes within the immigration landscape 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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