The government released its White Paper on legal migration entitled ‘Restoring Control over the Immigration system’ on 12 May with a wide range of proposed reforms. These include restoring the Skilled Worker minimum skill level to degree level and increasing minimum salaries, restricting permission on the Graduate route to 18 months, raising the Immigration Skills Charge by 32%, and doubling the qualifying period for settlement to ten years.

We look at the key policies and how they may impact businesses.

When will the proposals be implemented?

In their announcement of the White Paper, the government says that some changes will be introduced in the coming weeks, with other measures consulted on later this year. We are waiting on timeframes and details of how the changes will be implemented. 

In the meantime, sponsors and individuals may wish to consider bringing forward applications for Skilled Worker or Senior or Specialist Worker ahead of any skill or salary increases and the Immigration Skills Charge increase.

With the lower Graduate route permission length and higher barriers to the Skilled Worker route, it is likely that there will be a fall in the numbers of international students applying to come to the UK, which would lead to a smaller pool of graduates to recruit from.

Skilled Worker restrictions

The Skilled Worker route is the most used route for work in the UK and leads to settlement.

The White Paper says that some changes will be ‘immediate’ and says that the first stage of reforms will include changes to the Skilled Worker visa.

The proposed reforms include:

  • Restore eligibility from RQF level 3 (A‐Level equivalent) roles to RQF (graduate) level 6 roles and above (as it was prior to 1 December 2020).Those already in the Skilled Worker route in roles below RQF 6 can extend, change employment or take on supplementary employment.
  • Abolish the Immigration Salary List (previously called the Shortage Occupation List), which allows listed occupations to pay 80% of the usual minimum salary.
  • Increasing the salary thresholds. It is not clear whether the general salary threshold, occupation-based going rates or both will be affected. The general salary threshold is currently £38,700 per year, with reductions for example for those at the start of their career; We expect those already in the Skilled Worker route can continue to meet current salary thresholds at the extension or settlement stages.
  • A Temporary Shortage List will be created to allow sponsorship of workers in roles below RQF6 (degree) standard.
    • Initially, the Temporary Shortage List will contain occupations that the Migration Advisory Committee (MAC) has recently considered to be in shortage, or which are crucial to the delivery of the UK’s Industrial Strategy.
    • After then, occupations will be chosen based in evidence by the MAC that are key to industrial strategy or delivering critical infrastructure, where there is a workforce strategy in place, and where employers are taking action to increase recruitment from the UK.
    • It does not seem likely that there will be any deductions in the minimum salary requirements for these occupations;
    • The MAC will make recommendations on time limits and caps on the number of visas. It seems likely that this route will not lead to settlement.
    • It seems likely that those coming to take up a role on this list will not be permitted to bring dependent family members.
  • Skilled Worker visas will be closed to social carers for new applications from abroad. Existing visa holders, including those in any visa category which allows them to carry out social care work, can continue to renew or switch into the Skilled Worker route in-country until 2028, but this will be kept under review.
  • A new Labour Market Evidence Group (LMEG) will analyse data on workforce needs, training levels, and domestic employment participation. This will inform the creation of a workforce strategy for key sectors with high levels of recruitment from abroad. Employers in these sectors will be required to comply with the workforce strategy to show investment in training and recruiting domestic talent.
  • Considering allowing a limited number UNHCR recognised refugees and displaced people abroad to apply under the Skilled Worker route where they have the skills.
  • Increasing the English language requirements and introducing these for adult dependants (see further details below).

We expect the changes in the salary and skills thresholds and the prohibition of new entry visas for care workers not already in the UK to come in imminently, in the coming weeks.

Immigration Skills Charge

The Immigration Skills Charge applies to the Skilled Worker and the Global Business Mobility – Senior or Specialist Worker routes. There is to be a 32% increase in the Immigration Skills Charge, raising it from £1,000 to £1,320 per year for medium or large sponsors, or from £364 to £480 per year for small or charity sponsors.

It’s important to note that the sponsor is not permitted to pass on the cost of the Immigration Skills Charge to a sponsored worker. There are other government and legal fees which sponsors are also not permitted to pass on. Please let us know if you require any further guidance on this.

The government will use this money to upskill the domestic workforce.

We anticipate this could be linked to the implementation of the other Skilled Worker measures which will come in the next few weeks.

Graduate route

The government will reduce the length of permission on the Graduate route from 2 years to 18 months. Currently PhD students are granted 3 years’ permission, but it doesn’t seem that there will be any differentiation for them.

This proposal seems likely to be part of the first stage of reforms. There is no timeframe for implementation in the White Paper, but it seems likely that it could come in within weeks.

Sponsorship reforms

The government will consider making it easier for sponsored workers to move between licensed sponsors for the duration of their visa, giving them more control over who they work for and reducing the risk of exploitation.

They will be exploring financial measures, penalties or sanctions to incentivise sponsors to show greater responsibility in their sponsorship practices, as well as measures which will support compliance with visa conditions by migrants.

There is no timeframe for implementation, but it seems that this may take place later in the year.

Alternatives to the Skilled Worker route

The government is looking to increase immigration of the ‘very highly skilled’ to supercharge growth. Current proposals include:

  • review the Innovator Founder visa to ensure that it supports entrepreneurial talent currently studying at UK universities,
  • increase places for research interns, including those working in Artificial Intelligence,
  • make it ‘simpler and easier for top scientific and design talent to use the Global Talent visa’,
  • doubling the number of workers that an overseas business can send to the UK in the Expansion Worker route to establish a presence in the UK, and
  • explore a targeted and capped expansion of the High Potential Individual route, looking to double the number of qualifying institutions.

These proposals may be helpful to some applicants but apply to niche areas and we do not expect that they will have a significant impact.

It is indicated that this will be part of the first stage of reforms, and where specific measures have been identified, it is possible that these could come in within the next few weeks. Otherwise, for the Innovator Founder review or exploration of expansion of the HPI, there is no indicated timeframe for implementation in the White Paper.

English language

Currently Skilled Workers must meet a language requirement at CEFR level B1 in speaking, listening, reading and writing (Intermediate User). A dependant Partner of a Skilled Worker does not need to currently meet an English requirement until they come to apply for settlement, when they must meet a requirement at CEFR level B1 in speaking and listening, and the same applies for Citizenship. The government proposes to:

  • Increase the standard for Skilled Workers and other workers currently subject to the requirement from CEFR level B1 (Intermediate User) to B2 (Independent User). We expect that this will apply in reading, writing, speaking and listening.
  • Introduce a new English language requirement for all adult dependants of workers and students, setting a minimum threshold at CEFR level A1 (Basic User) at the initial application, level A2 (Basic User) when extending their visa and to level B2 (Independent User) for settlement purposes. Our understanding is that this requirement will be in speaking and listening only (not reading or writing).
  • Increase existing settlement language requirements across most immigration routes from level B1 to level B2 (Independent User).
  • Facilitate easier access to English language classes for those already in the UK, in collaboration with relevant government partners.

There is no mention of transitional arrangements. Normally new measures only apply to those entering the route for the first time but there have been exceptions to this in the past such as for dependant partners having to meet absence requirements.

There is no indicated timeframe for implementation.

Earned Settlement

The government plans to increase the standard qualifying period for settlement in most immigration routes from five years to ten years.

They will consult later this year on an ‘Earned Settlement’ model, where migrants will need to demonstrate long-term contributions to the UK economy and society before being granted settlement. The same model will be extended to citizenship applications.

The consultation will include the possibility of having the ‘opportunity to reduce the qualifying period based on Points-Based contributions to the economy and society.’

Those who are family members of British citizens (which includes those on spouse visas) will continue to be eligible for settlement after five years ‘provided they have remained compliant with their requirements’.

There will be a review of the current Life in the UK test.

There is no mention of transitional arrangements. Normally new measures only apply to those entering the route for the first time. It seems likely that whether transitional arrangements apply will be decided following the consultation later this year.

There is no clear timeframe for the consultation or implementation, and we await further details.

Right to Work checks

The White paper says that the right to work check regime will be extended to cover non-employees engaged under a ‘worker’s contract’ such as agency workers, sub-contractors, workers engaged via fee-charging online businesses and other forms of ‘gig-economy’ workers. The amendment will cover scenarios where there is no contractual relationship between the business and the worker, but the worker nevertheless provides work or services for the business, even if the business is unaware that the worker is doing so.

In the meantime, a draft clause regarding the right to work was published on 7 May 2025 as an amendment paper to the Border Security, Asylum and Immigration Bill. The clause may still be amended, but it gives an indication as to how the final regulations may look.

We will shortly provide a separate note on these proposals, on which the government has said they will consult before the provisions come into effect.

There is no clear timeframe for the consultation or implementation, and we await further details.

Three key action points you as an employer can take now

We appreciate that there are a lot of proposed changes which may feel daunting. Here are three key action points you as an employer can take now:

  1. Consider issuing communications to staff to let them know who in your team they can contact if they have any concerns about these proposals.  We would be happy to assist with providing draft communications and/or to provide one off immigration advice sessions to your organisation regarding the changes.
  2. Look at your recruitment pipeline, and what impact these changes may have. We would be happy to discuss your plans with you.
  3. Consider your budgets for immigration fees in light of these proposed increases. We can help you to plan accordingly.

We will be closely monitoring the government’s updates on the proposals and will share more as developments happen.  

We also are keen to influence policy and ensure our clients’ and contacts’ voices are heard. Once any government consultation opens, we will be looking to feed back contributions from industry and stakeholders, and we will get in touch to ask for your comments.

For now, if there’s anything covered in this article that you would like to discuss, please do get in touch.