The UK Government announced on 14 October 2025 that they are implementing the second phase of their May 2025 White Paper, and we explain below what employers need to know.
Quick Guide
The key changes are as follows, click on the links for a full analysis of each change:
- From 8 January 2026¸ the English language requirement for main applicants in the Skilled Worker, Scale-up, and High Potential Individual routes will increase to B2 (from current B1);
- From 1 January 2027, the grant of permission under the Graduate Route will be reduced to 18 months for non-PhD graduates (down from the current 24 months);
- From 4 November 2025, the list of eligible universities under the High Potential Individual route will double; and
- Nationals of Botswana will now need to obtain a visa to travel as a visitor to the UK.
The Immigration Skills Charge (ISC) is set to increase by 32% to £1,320 for large sponsors and £480 for small sponsors. There are reports that this will take place in mid-December 2025.
In Depth
Higher English Language Level for main applicants in Skilled Worker, Scale-Up and High Potential Individual routes
From 8 January 2026, the required English language level for the Skilled Worker, Scale-Up and High Potential Individual (HPI) routes will be raised to B2 or upper intermediate level of the Common European Framework of Reference for Languages, which is similar to A-level standard. Examples of the standard a person at this level will need to meet are to:
- understand the main ideas of complex texts on concrete or abstract topics, including some technical discussions
- express themselves fluently and spontaneously enough to comfortably communicate with other English speakers
- produce clear, detailed text on many subjects and explain a complex viewpoint on a topic, including expressing advantages and disadvantages.
There is a transitional provision: If a worker already has permission in the Skilled Worker route granted at B1 level, they only need to meet B1 for their future applications.
It seems that the Government are redrafting the rules on how the English language requirement can be met but there is no indication that any changes will be substantive.
Please see the following summary table of the new requirements.
| Route | New English Level | Effective Date | Transitional Provision |
| New Skilled Workers/Scale-Up | B2 | 8 Jan 2026 | B1 if last grant at B1 |
| Skilled Workers/Scale-Up who already have a visa or have applied for a visa as at 7 Jan 2026 | B1 | 8 Jan 2026 | B1 if last grant at B1 |
| High Potential Individual | B2 | 8 Jan 2026 | B1 if last grant at B1 |
Graduate visa permission cut to 18 months for non-PhD graduates
Graduate visas will only last 18 months instead of 2 years if the person applies on or after 1 January 2027 (except for PhD Graduates who will continue to be granted 3 years or 36 months). The continuation of 3 years for PhD Graduates is intended to maintain the UK’s attractiveness for high level research talent.
| Route | Duration of Leave | Application date |
| PhD Graduate | 3 years | Any |
| Other Graduates | 2 years | Before 1 Jan 2027 |
| Other Graduates | 18 months | On/after 1 Jan 2027 |
High Potential Individual route expanded, subject to a cap
The list of eligible universities for the High Potential Individual (HPI) route will double from 4 November 2025, to include universities listed in the top 100 worldwide.
There will be a cap on HPI applications of 8,000 applications per year.
New Prestigious Prizes added to Global Talent
Those who have been awarded a prestigious prize, who will by implication be at the highest level of their field, can apply to the Global Talent route without an endorsement. Around 22 new prestigious prizes will be added to the Global Talent visa from 11 November 2025 in the fields of digital technology and in science, engineering, humanities, social science and medicine.
Students applying as Innovator Founders can be self-employed
Those on Student visas can be self-employed from 25 November 2025 if they have completed their course and have submitted an application for the Innovator Founder route.
Refusal grounds redrafted
The section of the Immigration Rules which covers the reasons applications can be refused has been redrafted into a ‘Part Suitability’ section which comprises of the current Part 9 and Paragraph 39E and will come into effect from 11 November 2025. This section will also apply to Family and Private Life routes.
Citizens of Botswana will require a visa to travel to the UK
From 15:00 on 14 October 2025, citizens of Botswana have been added to the visa national list, which means that they will need to apply for a visa to visit the UK and cannot simply apply for an Electronic Travel Authorisation (ETA). Those who already had a confirmed travel booking and an ETA can still arrive in the UK without a visa before 15:00 on 25 November 2025.
Palestinian nationals will be added to the visa national list from 11 November 2025, as a result of the UK formally recognising the state of Palestine.
Which changes are still upcoming?
We await the increase of the Immigration Skills Charge (ISC) by 32% to £1,320 for large sponsors and £480 for small sponsors. There are reports that this will take place in mid-December 2025.
The Government are expected to put out proposals for ‘earned settlement’ imminently. They have announced that they will be extending the qualifying period for Indefinite Leave to Remain (ILR) and Citizenship from 5 to 10 years. The ‘earned settlement’ proposals will set out the ways in which applicants can reduce their qualifying period by making certain contributions to the UK. We expect that there will be a short consultation period (some guesses are 4 weeks). After the end of the consultation period, the Government may implement the extension of the minimum qualifying period. This could be later this year, or early in 2026.
For both of these reasons, you may wish to consider bringing forward applications for Skilled Worker and for ILR and applicants may wish to consider bringing forward their Citizenship applications.
Employer Survival Guide: Top Five Tips
Our top tips for employers are as follows:
- If you plan to sponsor in the Skilled Worker route, consider assigning the CoS before mid-December 2025 to avoid the higher ISC fee.
- Check your Undefined CoS allocation and consider applying as soon as possible for any increased allocation needed, making sure to specify the number needed and to provide a detailed justification and business reasons with the request. There is likely to be a spike in applications prior to mid-December and again prior to 1 January by sponsors wishing to avoid the rule changes. Priority slots for CoS allocation requests are likely to get booked up far in advance which could mean that you are not granted an allocation until after the rule change.
- If you plan to sponsor a Skilled Worker who may struggle to meet the B2 English language requirement, consider submitting the visa application before 8 January 2025. If that is not possible, consider whether it would be appropriate to offer them support with intensive English language tuition and/or to factor in additional timing in the recruitment process for them to pass the test. Consider this early on in the recruitment process and provide training for recruitment teams where needed.
- Consider issuing regular communications to sponsored workers to update them on the latest changes and to let them know who to contact with any concerns.
- Consider sponsoring Students directly in the Skilled Worker route rather than using the Graduate route. This will mean that you are exempt from the ISC for the duration of their Skilled Worker sponsorship. If they do proceed in the Graduate route, consider if they can apply prior to 1 January 2027 to ensure that they are granted a period of 2 years’ permission to remain.