Following the publication of the Immigration White Paper in May 2025, a number of the proposed changes came into effect in July 2025, especially in relation to the Skilled Worker category. These included significant changes to the skills and salary thresholds.

Whilst employers have been grappling with these significant changes, the Home Office published another Statement of changes on 14 October 2025. Some of these further changes have already been implemented whilst others are on the horizon:

Expansion of the High Potential Individual route 

This is a useful visa category for individuals who have graduated in the past five years from a top overseas university which is listed on the government's annual Global Universities List. It allows them a two-year period (or three years if they graduated with a PhD) to live and work in the UK for any employer or in self-employment (with some limited exceptions). From 4 November 2025, the number of universities on the list has now almost doubled, with more representation in particular for European and Australian institutions, although the majority of universities on the list are still American universities.

Sponsorship priority service fees increased from 21 October 2025

The priority service for a sponsor licence application (to have the application processed within 10 working days rather than the standard 8-week processing time) increased from £500 to £750. 

The post-licence priority service for sponsor requests, such as increasing the Certificate of Sponsorship allocation or changing the Key Personnel on the sponsor licence, also went up from £200 to £350 per request. Obtaining the priority service for these requests means they should be processed within 5 working days, rather than waiting up to 18 weeks on the standard service. It has however become increasingly difficult in recent months to obtain the priority slots as there are only a limited number available each day.

Increase to the Immigration Skills Charge from 16 December 2025

For Certificates of Sponsorship assigned on and after 16 December 2025, the Immigration Skills Charge (ISC) will rise by 32% (with some limited exceptions for particular roles such as sports coaches and clergy). 

For a small or charity sponsor the current ISC fee of £364 per year of the visa will rise to £480 per year. For medium or large sponsors, the fee will rise from the current £1,000 to £1,320 per year of the visa. 

These are significant increases given that the costs of sponsorship are already so high. Sponsors can try to minimise the impact by considering their recruitment and sponsorship pipeline and checking if it’s possible to assign a Certificate of Sponsorship before 16 December 2025 to avoid the ISC hike (bearing in mind that the Certificate of Sponsorship must be used to support an immigration application made within three months of issue). Long-term, sponsors will need to review their budgets for recruitment and sponsorship to take into account these increased costs.

Important English language changes – January 2026

For particular immigration categories, including the Skilled Worker and High Potential Individual routes, the level of English language required for new applicants is being increased from the current B1 level (intermediate) to B2 level (upper intermediate). This change will affect those applying in these immigration categories for the first time from 8 January 2026. There is no change to the English language requirements for individuals already in the UK under these immigration routes - for example, an individual with Skilled Worker leave will be able to extend their leave without having to pass an English language test at Level B2 or above.

The Immigration White Paper in May 2025 also indicated the government would bring in a new English language requirement for adult dependants of sponsored workers and students. This is not yet being introduced and appears to have been sidelined for the time being. 

From a practical perspective, employers should check their current sponsorship pipeline to check if any applications should be submitted under the current rules (by 7 January 2026 at the latest) to ensure individuals can still meet the English language requirement.

For applications submitted from 8 January 2026 onwards, employers will need to consider the likelihood of the individual meeting the new requirements and may need to build in additional time for individuals to complete and pass an approved English language test (if this is how they will meet the English language requirement).

Graduate route changes – 1 January 2027

The length of immigration permission granted for those applying under the Graduate route will be reduced from the current two-year period to 18 months. This will affect those who apply under the Graduate route on or after 1 January 2027. It does not however impact those who graduate from a UK university with a PhD, who will continue to be granted three-year Graduate leave (as is currently the case).

The Graduate route is a helpful bridge for recent UK graduates to get started in their careers before potentially switching into a different immigration route, such as Skilled Worker. The reduction of the length of Graduate leave to 18 months is likely to mean that less individuals will be in a position to meet the salary requirement for the Skilled Worker route (which increased in July 2025) as they will have less time to develop in their careers. It also means that those with immigration permission under the Graduate route may not have sufficient leave to enable them to complete graduate training programmes, which often last for two years.

What is still around the corner?

Huge changes to settlement

One of the more concerning proposals in the Immigration White Paper is the government’s proposal to double the residency period for settlement (also known as Indefinite Leave to Remain) in many immigration routes, including Skilled Worker, from the current five years to 10 years.

The White Paper also talked about introducing the concept of ‘earned’ settlement – this would appear to allow some individuals to obtain settlement in a shorter period of time if they meet certain criteria to demonstrate their contribution to UK society or the UK economy, with the details still to be determined. It’s worth noting that these proposals do not apply to those who hold immigration leave on the basis of being married to or the partner of a British citizen or someone settled in the UK.

It's currently unknown whether there would be transitional arrangements for individuals already in the UK or whether the changes would be retrospective. Overall, these changes will make the sponsorship system more expensive and cumbersome for employers and individuals since sponsored workers will generally need to be sponsored for much longer periods to obtain settlement.

There is currently a call for evidence in relation to these proposed reforms and the deadline for responding is 2 December and employers and individuals should consider contributing - Call for Evidence - Committees - UK Parliament

Sponsors demonstrating a commitment to upskilling the UK workforce

The White Paper also indicated that the government wants to tie the ability to use the sponsorship system to employers demonstrating that they have workforce strategies in place to develop the domestic UK workforce. The White Paper is very clear that employers failing to invest in domestic training will, under such proposals, face restrictions on sponsorship rights. At this stage we have no further guidance and will have to wait and see what developments there are going forward.

Conclusion

The impact of all of these immigration changes will be felt by employers who rely on overseas talent and by individuals coming to the UK. The costs of sponsorship have already risen significantly over recent years but these costs will double for sponsors if they need to sponsor a worker for 10 years to reach settlement in the UK. 

The last year or two has also seen a surge in compliance action. There was a doubling of sponsor licence revocations in the period from July 2024 to June 2025 compared to the previous year and the number of civil penalties for illegal working (of up to £60,000 per worker) has also increased significantly. All in all it is an unsettling time for those who employ or sponsor foreign nationals.

With the recent noise in the press about the Home Secretary, Shabana Mahmood, seeking inspiration from Denmark to shake up the UK immigration system further, this could just be the beginning. It’s important that employers are alive to what is happening so that they can prepare to try to minimise the impact on the business and the workforce as far as possible.