UK Immigration in 2025: reflecting on change and looking forward to 2026

2025: A year of change in UK immigration

2025 saw a year of major changes to UK immigration policy. The Labour government described their proposal to double the settlement qualifying period to 10 years as “the biggest shake-up of the legal migration system in nearly half a century”.  Other changes include increased sponsorship costs, reduced visa eligibility and the expansion of right to work checks.

We look here at the key developments of 2025 and what we can expect in 2026.

Key immigration changes of 2025

Extended qualifying period for settlement

The Government published their Immigration White Paper in May 2025, which proposed in particular to extend the qualifying period for settlement from 5 to 10 years in most routes. There is a consultation on this proposal which closes on 12 February 2026. The consultation provides that people can have their qualifying period reduced or extended depending on their contribution to society. For example, the criteria for a shorter qualifying period could include earnings at least £50,270; working in certain health and education roles; or carrying out community volunteering. Conversely, a breach of immigration laws or relying on benefits could result in a longer qualifying period.

Further, there may be a minimum income requirement of £12,570 for all applicants for settlement, including potentially for dependent partners and the partners of British or settled persons, as well as an upper intermediate (A-level) English language requirement.

The proposals would affect those already in the UK without settlement (apart from under the EU Settlement Scheme). Those who hold settlement will not be affected.

For employers, the cost of sponsorship may be dramatically higher as they have to sponsor workers earning under £50,270 for an additional 5 years or more. The proposals could make the UK less appealing to international talent than competing countries.

The changes will be implemented in phases beginning April 2026. Those who are eligible to settle before then should apply as soon as possible. All organisations and individuals affected are encouraged to respond to the consultation. You can join our response to the consultation here if you reply to us by 19 January 2026.

White Paper Implementation

Further White Paper changes which restrict eligibility to come and work and live in the UK have been implemented or are due to be implemented including:

• On 22 July 2025, eligibility for the Skilled Worker route was restricted to roles at degree level, with over 100 occupations no longer eligible for sponsorship. In particular, care workers could no longer be sponsored from outside the UK. The minimum salary level was raised to £41,700. The Temporary Shortage List was introduced, designed for temporary sponsorship in medium skilled categories at a minimum salary of £41,700.

• On 4 November 2025, the list of eligible universities on the High Potential route doubled.

• On 11 November 2025, the reasons for refusal of applications were redrafted into a ‘Part Suitability’ section. This now applies to the family and partner rules, and are much more restrictive for those applicants than before.

• On 16 December 2025, the Immigration Skills Charge increased from £1,000 to £1,320 for large sponsors and from £364 to £480 for small or charitable sponsors.

• The government expanded its prohibition on sponsors passing on sponsor licence or Certificate of Sponsorship (CoS) fees from the Skilled Worker to other routes including the Global Business Mobility and Minister of Religion from 9 April 2025. It clarified that the costs prohibited from being passed on included premium or priority services and legal advice fees where the person did not have a genuine choice in using them. Certain individual visa fees may be recouped through clawback policies if those are not considered debt bondage. Updated guidance is awaited.  

Home Office statistics published in November 2025 indicate a significant decrease in the issuance of work visas following the above immigration reforms. Skilled Worker visa grants were 46% fewer in the year to September 2025 compared with the previous year, and Health and Care visas were down 89%. Similarly there were 22% fewer family-related visas compared to the previous year, due to falls in Partner visas.

Transition to eVisas and Electronic Travel Authorisation

From April 2025 Biometric Residence Permits were no longer valid for travel, meaning that travellers needed to have set up their eVisa account to ensure smooth entry to the UK.

eVisas were rolled out to applications for permission to enter in most visa categories, replacing vignettes.

The UK’s Electronic Travel Authorisation (ETA) scheme was extended in April 2025 to all ‘non-visa nationals’.

EU Settlement Scheme

From 16 July 2025, pre-settled status holders can be granted settled status where they have been resident in the UK for at least 30 months in the most recent 60 month period. These absences can be taken at any time in the preceding 60 months. The changes will apply under both the automated process, and where people make applications for settled status.

What to expect in 2026: key developments

Looking ahead, several key immigration changes are set to take effect in 2026:

Further implementation of the White Paper has been announced as follows:

• 8 January 2026 – Skilled Worker, Scale-Up and High Potential Individual applicants will need to meet an upper intermediate English Language requirement (level B2, up from level B1).
• 2 February 2026 – closing date of the Migration Advisory Committee’s (MAC) call for evidence on which occupations should remain on or be added to the Temporary Shortage List (TSL). The MAC should report on this by 2 July 2026.
• April 2026 onwards – the earned settlement proposals and increase in the minimum qualifying period for settlement will be implemented in phases.

• 1 January 2027– Graduate route visas will be granted only for 18 months, or 36 months if the person has a PhD.
• Date unknown – upper intermediate level English language requirement to be rolled out to adult dependants of workers and students.

We provided some employer survival tips here.

Expansion of right to work checks

The Border Security, Asylum and Immigration Act 2025 received Royal Assent on 2 December 2025. Section 48 of the Act expands the illegal working regime to the gig economy, self-employed contractors and online job matching platforms (details here). After a government consultation that ended on 10 December 2025, these changes are expected in 2026 or 2027, following a business awareness campaign.  

Enforcement of the ETA scheme

Starting 25 February 2026, the government will strictly enforce the ETA scheme, so anyone who needs an ETA but does not have one will be refused boarding.

Ongoing tougher enforcement

In 2025, the government intensified efforts against illegal work on sponsor compliance, revoking 1,948 sponsor licences in the year to June 2025 – over twice as many as previous months – and increasing arrests by 51%. We wrote about compliance tips here. This crackdown is set to continue into 2026, with enforcements efforts likely targeting gig economy and self-employed contractors once the expansion of right to work checks comes in. 

MAC Salary review

The MAC published its report on salary requirements for work visas on 17 December 2025, and recommended keeping the general threshold at £41,700 and a single new entrant rate of £33,400. They recommended that for the temporary shortage list, the minimum salary should be around £30,900, but that sponsorship in those jobs should not lead to settlement. They also flagged the negative impacts of having an English language requirement which exceeds employers’ requirements. We expect the government to implement some of these proposals in the coming months.

MAC review of the TSL

When looking at which occupations should be included on the TSL, the MAC will work with the Labour Market Evidence Group (LMEG) to review developments of a workforce strategy, skills strategy and domestic labour strategy. It is likely that measures will be introduced in the coming years for employers considered reliant on a migrant workforce to show a commitment to upskilling the domestic workforce.

EU travel and new border systems

The roll out of the EU’s long-delayed Entry-Exit System (EES) began on 12 October 2025, with full implementation expected by 10 April 2026. The EES is a digital border system which will capture and store the facial image and fingerprints of travellers to the EU and flag if they have overstayed. The European Travel Information and Authorisation System (ETIAS) will be implemented in the last quarter of 2026 and will require pre-authorisation to travel to the EU.

Conclusion

2025 was a year of fundamental change for UK immigration, and 2026 promises greater shifts. As the increased focus on compliance continues, employers must stay on top of the latest developments. From the enforcement of the ETA scheme to the expansion of right to work checks, businesses must adapt to the evolving landscape. We will continue to track these developments and provide regular updates to help employers navigate the changing immigration environment.

For guidance on navigating any of the above changes, please reach out to our team for expert advice.

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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.