Hot on the heels of the government’s proposals outlined in their Immigration White Paper in May, the first raft of immigration rule changes has now been published and will come into force on 22 July 2025. The new rules will apply in respect of Skilled Worker applications where the Certificate of Sponsorship is issued on or after 22 July 2025. 

The sponsorship system is already a difficult and expensive process for most employers to navigate and these latest changes will only exacerbate those issues.

Sponsors should now check urgently whether quick action is needed before these changes are introduced. This may include issuing (and where necessary applying for) a Certificate of Sponsorship before 22 July 2025, for example to support an extension application for an existing Skilled Worker migrant who would not meet the new salary requirements or finalising sponsorship for new hires who may not meet the new minimum skill level and/or salary requirements. 

How will the sponsorship rules change?

Skilled Worker route - minimum skill level will increase to highly skilled

The minimum skill threshold for the Skilled Worker category of sponsorship will increase from medium to highly skilled. This means that any individuals who are entering the Skilled Worker category for the first time, and whose Certificate of Sponsorship is assigned on or after the changes are enacted, must in most cases be sponsored in a role that is classified as highly-skilled (RQF Level 6 or above – equivalent to a graduate level occupation). Currently all roles which are medium-skilled or above (RQF Level 3 or above) are eligible for sponsorship under the Skilled Worker route. 

Exceptions for medium skilled roles on interim shortage occupation lists 

Roles which are not highly skilled and so fall below RQF Level 6 will only be capable of sponsorship from 22 July 2025 where they are listed in one of the Home Office’s official shortage occupation lists. These lists will include roles where shortages have been identified, as well as roles within sectors that the government sees as crucial to the UK’s industrial strategy such as tech, clean energy and life sciences.

However, these shortage lists are designed to be an interim measure and the intention is that they will be phased out by 31 December 2026 at the latest. There are still many unknowns at this stage – for example, it isn’t clear whether an individual sponsored on this basis will subsequently be able to extend their leave if, at the time their Skilled Worker permission expires, their role is no longer on the shortage list or whether they will be able to count the time they have spent in the UK towards Indefinite Leave to Remain. 

Our understanding is that these individuals will not be able to bring dependants with them to the UK. This means that any spouse, unmarried partner or children of these individuals would have to find another immigration category in order to accompany or join them in the UK and in many cases this is unlikely to be possible.

Transitional rules for those whose Skilled Worker Certificate of Sponsorship is assigned before 22 July 2025

The new rules make it clear that those who have Skilled Worker permission on the basis of the current (pre 22 July 2025) rules (which includes anyone who applies for Skilled Worker leave from 22 July 2025 onwards on the basis of a Certificate of Sponsorship which was assigned prior to 22 July 2025) can continue to be sponsored for medium-skilled roles for the time being. Rather ominously though the new rules also state that these are transitional arrangements that “will not be in place indefinitely and will be reviewed in due course”. We will have to wait and see what approach is adopted longer-term for this cohort of existing Skilled Worker migrants

Salary increases for all sponsored routes

There will also be increases to the minimum salary thresholds across the board, both for the general salary thresholds and the “going rates” for each particular job code (SOC Code).

The general minimum salary thresholds will rise as follows:

• Skilled Worker – from £38,700 to £41,700 per year
• Global Business Mobility: Senior/Specialist Worker – from £48,500 to £52,500 per year
• Graduate Trainee – from £25,410 to £27,300 per year

However, a sponsor must pay the higher of either the general minimum salary threshold or the relevant ‘going rate’ for the particular role being sponsored. In addition to the increases to the general thresholds, these going rate salaries are also increasing. For example, someone sponsored in a programmer/software developer role (SOC Code 2134) must currently be paid at least £49,400 per year (assuming no salary discounts are applicable) and from 22 July 2025 this will increase to £54,700 per year (based on a 37.5 hour working week).

Importantly there will not be any transitional arrangements in relation to the salary increases. This means that where a business is sponsoring existing workers it’s important to check now whether they will be able to meet the new minimum salary thresholds for the sponsored worker’s future extension or Indefinite Leave to Remain application and take advice at the earliest opportunity where it appears they will not. 

Care workers

The care sector has been particularly targeted by the Home Office in previous immigration rule changes. The new rules effectively hammer in the last nail of the coffin for sponsorship of overseas nationals in care worker and senior care worker roles (SOC Codes 6135 and 6136 respectively) by closing the route altogether for new Skilled Worker entry clearance applications from 22 July 2025.

It will however still be possible for individuals to submit applications from within the UK for this type of role where they are switching from other routes (for example the Graduate route) and have been employed by the sponsor for at least three months before their Skilled Worker Certificate of Sponsorship is assigned. This transitional arrangement will be available only until 22 July 2028. Again, though, it is made clear that this is subject to review so the government retains the right to pull the concession earlier.

Action points for employers

Given that the rules will be implemented very shortly, it’s strongly advisable to consider the following at the earliest opportunity:

• Carry out an audit of your existing sponsored workers to check whether they would be able to meet the new minimum salary requirements for their particular role. Where there is an issue it may be a good strategy to assign a Certificate of Sponsorship before 22 July 2025 to support an earlier extension (or if relevant submit the Indefinite Leave to Remain application before 22 July 2025) so that they can obtain further or indefinite leave on the basis of their current salary under the existing rules.
• Check your pipeline for sponsored workers to identify if the particular role and salary will meet the new sponsorship rules. If the role is not classified as highly-skilled or their salary would be too low to meet the new salary thresholds, it may be possible to sponsor them under the current rules prior to 22 July 2025 depending on how quickly the Certificate of Sponsorship can be assigned. If the person is applying from overseas, time needs to be allowed to apply for a defined Skilled Worker Certificate of Sponsorship first. Sponsors will also need to check they have an available undefined Certificate of Sponsorship to assign to existing sponsored workers. We recommend taking advice if you have already made a job offer to someone who will now not be eligible for sponsorship under the new rules.
• Going forwards, if the role is not regarded as highly skilled, check whether the role is on one of the shortage occupation lists. If so, it should be possible to sponsor the individual after 22 July 2025 if the salary thresholds are met but you will need to make it clear early on to them that they cannot bring any dependants to the UK and in many cases this will be a deal breaker. Businesses will also need to explain to these individuals that it might not be possible to remain in the UK on a long term basis.
• With immigration fees to sponsor workers already running into thousands of pounds and the Immigration Skills Charge due to rise by 32% later this year, it’s important to ensure that this is included within financial planning discussions, as well as factoring in the extra costs of potentially needing to sponsor workers for up to 10 years (rather than 5 years) due to the proposals set out below in relation to the residency requirements for Indefinite Leave to Remain). Furthermore, increased salary thresholds for sponsored workers may also need to be built into budgets going forward.
• Employers may need to look at workforce planning, particularly where they have been using the sponsorship system to recruit for medium-skilled level roles as this won’t always be possible going forward.
• Ensure those responsible for sponsorship keep on top of the immigration changes. Consider sponsorship training for the relevant team or signing up to our email alerts for further updates here. 

Other future changes 

• There are further changes coming along the track – in particular, we anticipate that the proposals to increase the level of English language required for Skilled Workers and their dependants may come into effect later this year and there will also be a consultation in relation to extending the residency period required for certain immigration categories (including those with leave under the Skilled Worker route) for Indefinite Leave to Remain from its current five year to 10 years. Further details are outlined in our previous immigration alert which is available here. Employers should make sure that they keep sponsored workers updated on latest developments where possible. 

Employers should be alive to these important immigration changes on the horizon so that they can prepare as best they can and brace themselves for the immigration storm ahead.