New UK immigration work route restrictions from 22 July 2025

The government released a Statement of Changes in Immigration Rules, confirming that many of the work route restrictions outlined in the May 2025 White Paper will come into effect on 22 July 2025.  These include largely restoring the Skilled Worker minimum skill level to degree level, increasing minimum salaries, and restricting the care worker route to applications made from within the UK.

Five key action points you as an employer should take now

We appreciate that these changes are approaching quickly. Here are five key action points you as an employer should take now:

1. To benefit from the current Immigration rules and any transitional arrangements, consider assigning any Skilled Worker Certificate of Sponsorship (“CoS”) on or before 21 July 2025.  When doing so, please bear in mind the following:

• Processing is likely to slow down in the coming weeks due to an increase in demand. There has also been an increase in the Home Office requesting further information following a defined CoS or in-country CoS allocation request.  Requests for defined CoS or in-country CoS should be:
  • Submitted as soon as possible;
  • Be well-documented and include any necessary information or justification;

• The Home Office are increasingly raising sponsor compliance or right to work queries in response to a CoS request, e.g. raising corporate structure changes or requesting copies of right to work documents. If you need a CoS urgently, consider ensuring that you have up to date records on compliance;

• Use the priority service for in-country CoS allocation requests where possible, although it is likely to be harder to get a priority slot;

• The Sponsor Management System (SMS) will likely be suspended in the days leading up to 22 July 2025.  You should assign the CoS as soon as possible before this;

• It is permitted to assign a CoS up to 3 months in advance of the intended work start date.  If there are any intended hires over the coming 3 months, it is advisable to bring assigning the CoS forward where possible.

2. For staff who are currently sponsored in the Skilled Worker route, particularly in below degree level roles, consider issuing communications to staff to let them know who in your team they can contact if they have concerns about these changes.  We would be happy to assist with providing draft communications.

3. Conduct a review of whether your future hiring plans will be compromised in light of these changes. We can check for you if the role will still be eligible and if not, if any alternative routes may apply or if costs can be reduced. For example, sponsoring a Student in the Skilled Worker route means that you would benefit from an ISC exemption which can reduce costs.

4. Consider your budgets for future salary increases for Skilled Workers which will need to be made at the extension and settlement stages. Please note that going rates will increase in most occupations, including for those who entered the Skilled Worker route before 4 April 2024, who will have to meet the increased going rates at any extension or ILR application.

5. Monitor further updates.  When the Migration Advisory Committee (‘MAC’) and earned settlement consultations come out, consider contributing to these to have your voice heard on how your business and staff may be impacted.

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.

Increase in general salary thresholds for the Skilled Worker and Global Business Mobility routes

As indicated in the White Paper, the minimum salary will increase for most Skilled Workers. The Explanatory Memorandum describes these as ‘routine’ and in line with the 2024 salary data from the Annual Survey of Hours and Earnings (ASHE). The table of increases is below.

When and to whom will this apply?

Sponsors will need to meet these requirements from 22 July 2025. This means that sponsors can avoid the minimum salary increases if they assign a CoS before 22 July 2025. Sponsors assigning a CoS on or after 22 July 2025 will need to meet the minimum salary increases, including for extension applications.

The ‘going rate’ salary threshold for the occupation codes have been adjusted in line with 2024 ASHE figures.  The new going rates will apply where a CoS has been assigned on or after 22 July 2025. There seems to have been an increase in most occupation codes. This includes an increase in going rates for those who entered the Skilled Worker route before 4 April 2024, who will have to meet the higher going rates in any future application. Details of the new rates can be found in the Statement of Changes under the heading ‘Changes to Appendix Skilled Occupations’.

For those already sponsoring Skilled Workers, the changes may not have an immediate impact, but they will have to review and budget to meet the stated minimum salary increases in any future Skilled Worker extension application and at the time of a person applying for Indefinite Leave to Remain (ILR) (please see the fourth column in the table below for the new general minimum ILR salary requirements).  

The Government has commissioned the MAC to carry out a further review of salary requirements by early January 2026 and it is likely that further increases to the general minimum salary requirements and the going rates will take place following this.

As explained previously, the Government will consult later in the year on an ‘earned settlement’ proposal, which will determine whether some categories of workers will need to remain in the UK for up to 10 years before they can settle.  It is possible that those who meet the salary thresholds could be considered to have sufficiently contributed to reduce their settlement period to 5 years but this is pure speculation at present.*

The hourly rate is also increasing to £17.13 per hour, up from 15.88 per hour. If £17.13 per hour is higher than the discounted going rate, the £17.13 per hour must still be met.

*Please note that as well as meeting the general salary threshold for ILR, the person must meet the relevant ‘going rate’ for the occupation code. Please note that discounts to the going rate do not apply at the ILR stage and the full going rate must be met.  The relevant going rate is set out in the Table within Appendix Skilled Occupations which corresponds to the points option the person is sponsored in.  

Further points to note

Please note as follows:

• Those applying under the Skilled Worker interim Temporary Shortage List (TSL – see below) will not be eligible for salary discounts and will need to meet the general salary threshold of £41,700 or £31,300 for those with a grant before 4 April 2024;
• There has been no change to the minimum salary for those in health and education occupation codes or those with a grant before 4 April 2024 with a STEM PhD or on the Immigration Salary list, for whom the £25,000 minimum is not affected;
• The ‘high earner’ threshold for the Global Business Mobility – Senior or Specialist Worker route of £73,900 has not changed.

Removal of below degree level roles from the Skilled Worker route

As indicated in the White Paper, the skill level required for the Skilled Worker route will increase from Regulated Qualifications Framework (‘RQF’) level 3 (A-level) to RQF level 6 (degree level), which will remove around 180 below degree level roles from the route, unless they are included on the Immigration Salary List (ISL) or the new interim Temporary Shortage List (TSL) (see further below).

When and to whom will this apply?

The change will come in on 22 July 2025, which means there is still a window to sponsor Skilled Workers in a below degree level role by assigning the CoS before 22 July 2025.  However from that date, unless the role is on the ISL or the TSL, below degree level roles will no longer be eligible for the Skilled Worker route.

Skilled Workers who are already sponsored in a below degree level role where the CoS was assigned before 22 July 2025 can continue to be sponsored, including to renew, change employment and take supplementary employment. However the explanatory memorandum says that ‘the transitional arrangements will not be in place indefinitely and will be reviewed in due course’. The possibility that a cut-off point may be implemented to extend or apply for settlement will cause anxiety for some workers in medium skilled positions. Sponsors of those affected should keep an eye out for updates and workers should aim to apply for settlement as soon as they are eligible.

As noted above, there is a consultation later this year on the Government’s earned settlement proposals and the explanatory memorandum does not state whether there will be transitional arrangements for settlement for Skilled Workers in below degree level roles.

Those granted permission in the Skilled Worker route from 22 July 2025 will not be permitted to undertake supplementary employment in a below degree level role unless it is on the ISL.  It is unclear if those who are being sponsored in the TSL from 22 July 2025 can carry out supplementary employment.  Those employing workers who are carrying out supplementary employment for them should be cautious as to whether this is permitted if it is in a below degree level role not on the ISL.

In order to implement the change in skill level, Immigration Rules Appendix Skilled Occupations will be split into different tables, separating out occupations at RQF Level 6 and above (tables 1, 2 and 3) from occupations at RQF levels 3-5 (tables 1a, 2aa and 3a).

In order to meet the skill requirement, individuals will need to be sponsored for an occupation that comes within any of the following:

• the RQF level 6 occupation in tables 1, 2 and 3;
• the ISL or the new TSL;
• The tables for RQF levels 3-5, namely tables 1a, 2aa or 3a, if:
  • ‘the applicant was granted permission as a Skilled Worker under the rules in place before 22 July 2025, and they have had continuous permission as a Skilled Worker since then…
  • Is relying on salary points under options F to J and meets the requirements of SW 4.2(b)(ii)… they were granted permission as a Skilled Worker under the rules in place before 4 April 2024, and they have had continuous permission as a Skilled Worker since then…

Immigration Salary List (ISL) expanded temporarily

The MAC has been commissioned to carry out a thorough review of the ISL and the interim TSL by early July 2026. The Government plans to abolish the ISL and replace it with the TSL. In the meantime, the Government has expanded the ISL to include occupations below degree level where the MAC identified them as being in shortage in 2023 or 2024.

Those sponsored under the ISL will not be permitted to bring dependents if they are sponsored for the first time with a CoS assigned on or after 22 July 2025.  Skilled Workers eligible to be accompanied by dependants before 22 July 2025 on the ISL are covered by transitional arrangements.  Children born in the UK will be exempt from this restriction, as well as children where the worker has sole parental responsibility.

A new interim Temporary Shortage List (TSL)

The new TSL will allow Skilled Workers to be sponsored in below degree level occupations where these are seen as important for progressing the UK’s Modern Industrial Strategy.

To be sponsored on the TSL, a CoS must be assigned between 22 July 2025 and 31 December 2026, although occupations may be removed or added before the end of 2026. Please note that it is therefore important to check the TSL before assigning any CoS as the list is subject to change.

The MAC will advise on whether occupations should be added or removed from the TSL, depending on whether this is 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.

Those sponsored on the TSL will not be permitted to bring dependants, except where the child was born in the UK or where the worker has sole parental responsibility. There is no indication as to whether those sponsored on the TSL will be permitted to settle in the UK but this seems unlikely.

Care workers

From 22 July 2025, entry clearance applications for Skilled Workers in SOC 2020 occupation codes care workers 6135 or 6136 will no longer be permitted.

Those planning to sponsor care workers not already in the UK must assign a defined CoS before 22 July 2025.

It will still be possible to sponsor care workers applying from within the UK, but only if (1) the application is made before 22 July 2028 and (2) the person has been legally working for the sponsor for at least 3 months before the CoS is assigned. However the Home Office will keep this under review, so it could end earlier.

Those who are already sponsored as a care worker or senior care worker or who are eligible to apply before 22 July 2028 will be permitted to continue to make extension applications.

Are there updates on further White Paper changes to be implemented?

There are updated timeframes as follows:

• In its recent announcement the Government has indicated that the following changes will be implemented by the end of this year.  These could take place in September/October 2025, when Statements of Changes are often released, or at any time between now and at the end of the year:
  • Increasing the Immigration Skills Charge by 32% i.e. to £1,320 per year for medium or large sponsors, or £480 per year for small or charitable sponsors;
    • Increasing the English language requirement for main applicants from CEFR Level B1 (intermediate) to B2 (upper intermediate);
      • Introducing an English language requirement for adult dependants in speaking and listening, starting at CEFR Level A1(beginner), rising to CEFR Level 2 (elementary) at extension and to CEFR Level B2 (upper intermediate) at settlement;
        • Introducing new requirements for work route dependants e.g. finance requirements.
        • The earned settlement and earned citizenship consultation will still be consulted on later in 2025;
        • As stated above, the MAC will undertake a review of salary thresholds by early January 2026 and a review of the TSL and ISL by early July 2026.

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

The material in this article is provided for guidance and general information only and is not intended to constitute legal or other professional advice upon which you should rely. In particular, the information should not be used as a substitute for a full and proper consultation with a suitably qualified professional. Please do contact the Bates Wells team if you require further information.