UK Immigration Round-up: May 2025

Welcome to our regular immigration round-up, providing a helpful summary of what's new and in the pipeline for UK immigration, along with links to a wealth of detailed resources and courses at your disposal.

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) White Paper

The UK Government's recently published Immigration White Paper (Restoring control over the immigration system white paper) proposes major changes to the UK Immigration system which the government aim to curb migration and boost domestic talent. The key changes proposed include:

• Proposed changes to the Skilled Worker Route
• Higher skills threshold: roles requiring a Skilled Worker Visa would return to a minimum skill level of RQF 6, which is equivalent to a UK bachelor's degree. The Government has indicated that there will be transitional provisions in place for Skilled Worker Visa holders who are currently sponsored below RQF level 6, which will allow them to extend their visas/switch to a different employer
• Salary threshold: increased to reflect the UK's median earnings
• Temporary Shortage List (TSL): a temporary and conditional TSL will be created for specific roles skilled to RQF levels 3 – 5
• Increased costs: a 32% hike in the Immigration Skills Charge will add costs for businesses hiring overseas

• Social Care Route Closure
  The UK Government will close the social care worker route for new overseas applicants, citing concerns over exploitation. It is proposed that current workers would be able to extend their visas until 2028, but no new sponsorships will be allowed for care workers from abroad. The route for healthcare professionals, such as doctors, nurses, and pharmacists, will remain open
• Graduate visa changes
  The Graduate Visa will be cut from 2-3 years to 18 months, with stricter employment requirements for graduates during this period.
• Stricter Rules for Universities
• Higher compliance standards for universities recruiting international students, including a traffic-light rating system
• A crackdown on aggressive overseas marketing and stricter rules for sponsorships

Family, Settlement and Citizenship Changes

• The Indefinite Leave to Remain (ILR) qualifying period will double from 5 to 10 years, with exceptions for Skilled Workers and those contributing significantly to the economy
• Changes to family migration and citizenship rules are expected, including higher income and English proficiency requirements for dependents
• New reforms will introduce an “earned track” for citizenship, where contributions to the UK’s economy and society (e.g., higher salaries, skills, community service) will shorten the time required for citizenship
• English Language Requirement Expansion: Stricter English language requirements are proposed across all immigration routes, applying to main applicants and dependants
• Enforcement and Border Management
  The introduction of a universal eVisa system, replacing physical biometric residence permits. This will allow employers, landlords, and others to access real-time immigration data for compliance checks.

Increased penalties for non-compliance and a bolstered enforcement team to handle irregular migration.

There are no confirmed dates for implementation yet. Some of these changes will likely be implemented in a statement of changes in coming months, others will be phased in over a longer period or consulted on first and therefore Employers and sponsors should continue to monitor developments.

Employers should prepare for higher recruitment costs and tighter regulations on sponsorship. Sponsors in particular should consider reviewing their current sponsored workforce and those in the pipeline timing of sponsorship given the increased ISC and also changes to Skilled Worker and potential settlement and how to communicate with the current population of sponsored employees. Employers should stay ahead of the curve with compliance training and timely applications before these reforms take full effect. 

2) Skilled Worker Salary Deductions

From 9 April 2025, the UK Home Office has implemented a significant change to the Immigration Rules for Skilled Workers, introducing a new provision (SW 14.2A). This rule governs how salary thresholds are assessed by the Home Office, with important implicants for sponsors.

Deductions from salary - including loan repayments, investments, or other payments to the sponsor or related parties - must be subtracted from the worker's gross pay unless they are genuinely optional benefits, such as salary sacrifice arrangements. If these deductions reduce the worker's effective salary before the required threshold, applications may be refused, or an existing worker's permission may be curtailed.

Employers should review proposed payments agreements with sponsored workers to ensure that they do not fall foul of the new rules in relation to deductions that applied from 9 April 2025 onwards. Employers should plan ahead to remain compliant under the stricter approach and seek legal advice where salary deductions, investments, or related-party payments may apply. 

3) Skilled Worker – Reclaiming Immigration Related Fees

Sponsors under the Skilled Worker route are now prohibited from recovering certain sponsorship-related costs from employees due to changes in Home Office guidance. 

Sponsors must not seek reimbursement from sponsored workers for a variety of fees, including sponsor license application fees, adding routes to a license, CoS, Immigration Skills Charge (ISC), premium and priority services, and "associated administrative costs".

Updated guidance from the Home Office has now confirmed that "associated administrative costs" include: premium or priority fees for sponsor license application or changes, fees for assigned or requesting CoS, and legal or immigration advice where the employee has no genuine choice in provider, or where service were imposed or provided by the sponsor. Employers should be aware of this broad definition that may capture indirect cost-recovery mechanisms, such as salary deductions or internal repayment clauses.

If a sponsor recoups, or attempts to recoup, prohibited costs, the Home Office can revoke the sponsor licence. Employers should audit current sponsorship practices and contracts for any unlawful cost recovery clauses, and eliminate deductions linked to sponsorship fees before assessing compliance with salary thresholds. Advice should be sought if it is not clear whether arrangements are caught under the new rules. Sponsors must act to ensure sponsorship arrangements remain compliant, updating HR policies and training relevant staff.

4) HOELT Tender

The Home Office is preparing to procure a new English language testing system for UK immigration applicants, with a contract expected to launch in August 2025.

The reformed Home Office English Language Test (HOELT) will assess speaking, listening, and, where required, reading and writing skills at CEFR levels A1 to C1. It will apply to various immigration routes and be delivered both in the UK and internationally. The Home Office’s aim is to streamline and standardise testing for UKVI purposes with one provider.

5) RTW on Non-employees

The UK government has announced plans to extend right to work (RTW) checks to non-traditional working arrangements, including self-employed individuals, gig economy workers, and those on zero-hour contracts. This marks a major shift in employer compliance duties and forms part of the draft Border Security, Asylum and Immigration Bill.

Currently, statutory RTW checks only apply to employees under standard contracts. while the Home Office previously encouraged voluntary checks for contractors, this will become mandatory when in force. Once in force, civil penalties of up to £60,000 per illegal worker, business closures, and even criminal liability (including up to five years' imprisonment) could apply for non-compliance, regardless of contract types.

The new rules will apply to business engaging individuals directly or via third-party platforms. While the implementation date is yet to be confirmed, the Home Office intends to consult with affected sectors before the rules take effect. Employers are urged to review onboarding procedures now, conduct internal audits, and train relevant staff to ensure compliance. Businesses should take advantage of the current lead time to prepare for incoming changes.

6) Youth Mobility Scheme Quotas

The Home Office have made changes to the 2025 Youth Mobility Scheme (YMS) introducing new participating countries and updated visa quotas. The scheme offers young people aged 18-30 (or 18-35 for some nationalities) the chance to live and work in the UK for up to two years (with a one-year extension for some nationalities).

New countries added to the YMS list include Uruguay, South Korea, The Philippines, Costa Rica and India (via an existing ballot system). For full details, refer to Appendix Youth Mobility Scheme of the Immigration Rules, with updates effective 9 April 2025.

7) Updated Visa Fees

From 9 April 2025, the Home Office introduced widespread increases to UK visa and immigration application fees. These changes affect most application routes, including visits, work, study, family, settlement, and citizenship. Employers and sponsors should take note of the new rats to plan effectively.

Among the most notable increases, short-term visit visas have risen to £127, while Skilled Worker visas now cost £769 for applications up to three years. Partner visa fees are up to £1,939, and Indefinite Leave to Remain applications now cost £3,029.

Employers sponsoring workers will also face steeper fees. The cost to assign a Certificate of Sponsorship has more than doubled, from £239 to £525, marking a 120% increase. Sponsor licence fees have risen too, with large sponsors now paying £1,579 and small sponsors £574.

8) Permitted Paid Engagement (PPE) for Visitors

Professionals visiting the UK for short-term, pre-arranged paid work can continue to rely on the Permitted Paid Engagement (PPE) route under the Standard Visitor visa. This route allows experts to undertake specific paid activities without sponsorship, provided the engagement is arranged in advance and completed within 30 days of arrival.

From 9 April 2025, visitors using the PPE route can now use eGates (if eligible by nationality), removing the need to speak with a Border Force officer, unless questioned. They are no longer required to proactively declare the purpose of their visit, although they must carry a formal invitation from a UK-based organisation confirming the nature and timing of the engagement.

For employees and event organisers, it is essential to issue clear, detailed invitation letters confirming the visitor's expertise and role during their stay. While only nationals from countries on the UK's visa national list require a visa in advance, all PPE visitors must be able to demonstrate their plans and ties to their professional work abroad if asked at the border.

The update streamlines access for international talent, but employers must continue to ensure engagements fall within PPE rules and that visitors are not carrying out border work or employment.

9) Care Worker Recruitment Outside the UK

From 9 April 2025, UK employers sponsoring care and senior care workers face significant changes to immigration rules that will directly impact recruitment, salary practices, and compliance obligations.

Higher Salary Thresholds

The minimum salary for new Certificate of Sponsorship (CoS) has increased from £23,200 to £25,000 per year (12.82 per hour). This applies to all new hires, visa switches, and extensions issued from or on 9 April 2025. Current sponsored workers on existing CoS are not affected until renewal.

Tighter Rules on Salary Deductions

Sponsors must now exclude certain deductions, such as immigration loans, from the salary stated on the CoS. If these deductions push a worker's pay below the £25,000 threshold, the role will no longer qualify for sponsorship. Routine practice like salary deductions for visa fees or the Immigration Health Surcharge may put employers at risk of non-compliance.

Recruitment Within the UK First

Reminiscent of the former resident labour market test, sponsors must now demonstrate the have attempted to recruit displaced care workers already in the UK before hiring from abroad. This includes contacting regional partnerships to check for available workers who have lost sponsorship due to licence revocation. A letter confirming no suitable candidates are available will be required if proceeding with overseas recruitment.

Over 470 sponsor licences in the care sector have been revoked since 2022. With enforcement tightening, it is critical employers review their recruitment and payroll policies to ensure compliance. These changes, though intended to prevent exploitation, may further strain care providers already facing staffing shortages.

10) Changes to ECCTIS Services

On 1 May 2025, ECCTIS, the Home Office’s designated commercial partner for verifying overseas qualifications, formerly replaced its Visas and Nationality service in a new platform: the Qualifications and Language Service (QLS). This change introduces a revised framework for assessing the comparability of foreign academic qualifications and English language proficiency. One of the most significant procedural changes introduced is the requirement for live identity verification, applicants must complete a biometric check.

The new QLS provides two distinct services: English Proficiency and Qualification Comparison, and Qualification Comparison. Both services are subject to a revised fee of £210 plus VAT, representing a significant increase from the previous fee of £140 plus VAT for standard verification. The expected processing time is now up to 20 working days. Notably, ECCTIS has discontinued its expedited (48-hour) service, previously available for an additional fee. Organisations should familiarise themselves with the implication of this change as the QLS introduces new procedural requirements, higher costs, and the removal of the previously available fast-track options.

Alerts, Webinars & Resources 

Global employment and labor law update - We’ve recently updated our first edition of our quarterly Global Employment and Labor Law update for 2025.

Key developments features in this edition include: 

• China: new flexible retirement rules and changes in Shanghai's court practice on open-ended employment contracts following fixed-term contracts
• Ireland: upcoming expanded gender pay gap reporting requirements
• Spain: a landmark Supreme Court ruling on disciplinary dismissals and an anticipated new law reducing maximum working time
• UAE: new ADGM regulations covering a wide range of topics including visas and work permits, working hours, discrimination protections, termination, and record keeping
• UK: upcoming new offence under which large employers may be held criminally liable for employee fraud
• US: new pay transparency requirements in several States

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

Read here 

 

Upcoming public courses

• AI and UK HR: Innovation and Compliance – 23/09/2025
• Introduction to UK Employment Law – 14/10/2025 & 16/10/2025

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Round-up Live “White Paper” Special

Our White Paper Special Round-up Live will be held on Thursday 19 June 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.

You can find details on how to join this session by adding it to your calendar: 

Add session to calendar