UK Immigration Round-up: July 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) Immigration Reform: Skilled Worker and Work Route Changes from 22 July 2025

On 12 May 2025, the UK Government published its White Paper: “Restoring Control over the Immigration System”, outlining a comprehensive overhaul of the UK’s immigration framework. The first major step in implementing these reforms came with the Statement of Changes to the Immigration Rules, published on 1 July 2025, with significant changes taking effect from 22 July 2025.

These reforms aim to reduce net migration, raise skill and salary thresholds, and end the UK’s reliance on lower-skilled overseas recruitment. A central feature is the closure of the social care worker visa route to new overseas applicants, in response to widespread concerns over abuse and exploitation in the sector. Transitional arrangements have been set out for those care workers already in the UK. The Social Care Worker visa route closed to new overseas applicants from 22 July 2025. Sponsors will no longer be able to recruit under SOC 6135 (Care Workers and Home Carers) or SOC 6136 (Senior Care Workers). In-country switching into these roles will remain possible until 22 July 2028, but only where the individual has worked for the sponsor for at least three months.

From 22 July 2025, the minimum salary threshold for Skilled Worker visas increased from £38,700 to £41,700, while the new entrant rate increased from £30,960 to £33,400. The Global Business Mobility (GBM) salary threshold also rose from £48,500 to £52,500. These changes reflect the updated going rates for SOC codes which are based on the 2024 Annual Survey of Hours and Earnings. Transitional arrangements will apply to Skilled Worker visa holders granted permission before 22 July 2025. However, these concessions are explicitly temporary and subject to review. For example, those with visas granted before 4 April 2024 will now need to meet a minimum salary of £31,300, up from £29,000.

In addition, the required skill level for Skilled Worker visas increased from RQF Level 3 (A-Level equivalent) to RQF Level 6 (graduate level), with over 100 occupations removed from the Skilled Worker visa eligibility list. Access to the immigration system will be limited to roles deemed critical to the UK’s industrial strategy or infrastructure development. To support this, the government introduced a Temporary Shortage List (TSL), which will be time-limited and conditional. Occupations on this list will only remain beyond December 2026 if recommended by the Migration Advisory Committee (MAC). A review from the MAC is awaited. 

Workers in these roles will no longer be permitted to bring dependants or benefit from salary and visa fee discounts. The government has also confirmed that it will abolish the previous Immigration Salary List (ISL) in due course. In the interim, it reserves the right to restrict immigration access further where there is evidence of abuse or exploitation.

Existing visa holders will still be able to extend their visas, bring dependants, change employment, and take supplementary work in roles below RQF Level 6. However, employers should be aware that these flexibilities will not remain in place indefinitely.

Home Secretary Yvette Cooper described the reforms as a “complete reset” of the immigration system, stating that the previous government allowed net migration to quadruple in four years. She emphasised that each sector must now have a workforce strategy in place to train UK workers or risk losing access to the immigration system altogether.

There are further changes expected by the end of 2025 which employers should be aware off. These reforms include: raising the Immigration Skills Charge (ISC fee) by 32%, increasing language requirements across visa route, and introducing a new family policy framework. These measures form part of a broader programme of immigration and border security reform, with additional announcements on asylum and border control anticipated later this year. The government’s stated aim is to build an immigration system that supports the UK economy, values skills, tackles exploitation, and ensures that those who come to the UK make a genuine contribution. Employers will need to look toward investing in domestic talent pipelines to reduce their reliance on overseas recruitment.

2) Immigration Reform: Key Impacts on the Hospitality Sector

The recent immigration reforms, which took effect from 22 July 2025, are set to have a significant impact on various sectors. None more so than the hospitality sector, which is heavily reliant on international labour and faces acute challenges as a result.

Higher Skills Threshold

From 22 July 2025, only degree-level (RQF Level 6) roles and above will be eligible for sponsorship for new hires under the Skilled Worker visa route. This change removes over 100 previously eligible roles many in the hospitality sector (including chefs).

Temporary Shortage List (TSL)

While the Government has proposed a Temporary Shortage List for sub-degree level roles, the role of chef is notably absent from the initial list. Future versions may offer relief, but access will be time-limited and conditional, with employers required to comply with sector-wide workforce plans. Importantly, sponsored workers under the TSL will not be permitted to bring dependants, potentially making these roles less attractive to international candidates.

Temporary Worker Visa Changes

Proposed changes to the Student Visa and Graduate Visa routes may reduce access to temporary labour. The planned reduction of the Graduate visa duration from two years to 18 months could hinder hospitality employers seeking to hire recent international graduates without sponsorship.

Indefinite Leave to Remain and Language Requirements

The qualifying period for Indefinite Leave to Remain is set to double from five to ten years, extending the time individuals must spend on time-limited visas. Additionally, stricter English language requirements are proposed across all immigration routes, including for dependants, which may further deter international talent.

With increased costs and reduced access to international labour, employers may experience staffing shortages and pressure on service standards. We strongly encourage hospitality employers to begin strategic planning now. For tailored advice or support navigating these reforms, please contact our immigration team.

3) Changes to Entry Clearance for Study and Work Routes

The Home Office updated its guidance on ‘Online immigration status (eVisa)’, introducing a significant change that took effect from 15 July 2025. Under the new guidance, applicants for entry clearance under study and work routes may no longer be issued with a vignette in their passport. Instead, they will be required to create a UKVI account and access it before travelling to the UK.

Applicants applying as dependants or under visa categories other than study or work will still receive a vignette in their passport. The updated guidance states that applicants will be informed of the process when they apply, leaving some uncertainty about whether this change will apply to all study and work routes from the outset, or whether the application process itself will be revised.

The practical benefit of this change, as outlined in the Immigration White Paper, is that affected applicants will no longer need to return to a visa application centre to collect their passport or wait for it to be returned by courier once their visa has been granted. UKVI expects this change to streamline the process and reduce delays for those impacted.

4) Civil Penalties: Increased Fines and Enforcement Activity

In February 2024, the Home Office introduced a substantial increase in civil penalties for employers who hire or retain individuals without the legal right to work in the UK. First-time breaches now attract fines of up to £45,000 per illegal worker, while repeat offences can result in penalties of up to £60,000 per worker. This significant increase on previous levels signals the government’s strengthened approach to tackling illegal working.

Civil penalties are financial sanctions imposed on employers who fail to carry out proper right to work checks or who knowingly employ individuals without lawful immigration status. While these penalties are not criminal convictions, the consequences can be significant. According to Home Office data for the first quarter of 2025 (January to March), 748 civil penalty notices were issued, totalling £41.6 million in fines. This marks a sharp rise from the previous quarter (October to December 2024), which saw 489 notices and £29.2 million in penalties.

Since the Labour Government came into office in July 2024, enforcement activity has increasingly intensified. Over 9,000 enforcement visits have been carried out, resulting in 6,410 arrests and 1,921 civil penalties, more than a 40% increase compared to the previous year. In January 2025 alone, immigration enforcement teams visited 828 premises, a 48% increase on the same month in 2024. Recent operations have targeted sectors such as hospitality, construction, car washes, and care providers.

The implications for employers go beyond financial penalties. Businesses found in breach may face revocation of their sponsor licences, reputational damage, and, in cases of knowing employment, criminal prosecution with potential custodial sentences of up to five years. To mitigate risk, employers should take proactive steps to ensure compliance. This includes conducting right to work checks consistently in line with Home Office guidance and maintaining clear, dated records of all checks. Regular internal audits of employee files, particularly for subcontractors and temporary workers, are also advisable. Finally, employers should be aware that they have 28 days to respond to a Civil Penalty Notice. Options include paying the fine, submitting an objection, or lodging an appeal through the Home Office’s formal process.

5) Sponsorship and Student Visa Guidance: Key Updates from 29 May 2025

Effective from 29 May 2025, the Home Office introduced important updates to the Sponsorship Duties Guidance and the Student and Child Student Guidance. These changes focused on strengthening record-keeping obligations, safeguarding requirements for child students, and clarifying permitted living arrangements.

Sponsorship Duties and Record-Keeping

The revised guidance eliminated Appendix D and now directly lists all documentation sponsors must retain. These documents can be stored in either paper or electronic format, provided they are accessible upon request. For student sponsors, records must be retained throughout the sponsorship period and until the earlier of one year after sponsorship ends or the date a compliance officer confirms completion.

Specific documents that must be retained include copies of passports, eVisas, attendance and absence records, contact details, and Academic Technology Approval Scheme (ATAS) certificates. Child student sponsors must also retain all parental consent letters.

Sponsors are no longer required to retain original passports, which must be returned to students after copies are made. However, for students under 18, passports may be held for safekeeping with written parental or guardian consent and must remain accessible. Sponsors must also comply with data protection obligations under the Data Protection Act 2018.

Safeguarding and Child Student Responsibilities

The guidance introduces a dedicated section on safeguarding, outlining the national minimum standards for child care and accommodation. It also reflects the March 2025 Immigration Rules changes, including updated maintenance fund requirements based on living arrangements and school location.

Sponsors must now keep detailed records of Child Students’ travel and living arrangements, sponsors must now confirm the living arrangements of sponsors Child Students on the Confirmation of Acceptance for Studies (CAS). This includes documenting the child’s arrival, the individual collecting them, and where they will stay if not going directly to school.

Permitted Living Arrangements and Reporting Obligations

Child Students must reside in one of the permitted living arrangements listed in Appendix Child Student. Any changes to these arrangements must be supported by updated parental consent and a revised letter of undertaking. Sponsors are required to notify UKVI via the Sponsor Management System (SMS) within ten working days of any non-compliant arrangement and the steps taken to resolve it. Compliant changes do not require reporting.

Nominated Guardians and Letters of Undertaking

The Student and Child Student guidance now recognises nominated guardians as a permitted living arrangement. These individuals may care for children outside of term time for less than 28 consecutive days or act as the school’s emergency contact. Nominated guardians must be over 18, appointed by the child’s parent, legal guardian, or school, and cannot be private foster carers or the child’s parent.

An updated letter of undertaking is required for all intended carers or nominated guardians. Where a guardianship organisation is still allocating a guardian, sponsors must provide interim details, including the organisation’s contact information, establishment date, and confirmation that all guardians have undergone appropriate background checks.

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

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• For Immigration updates select: Preferences › Service lines › Employment & Labor Law › Immigration and Global Mobility.

Round-up Live

Our  Round-up Live will be held on Thursday 18 September 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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