On 23 July 2026, the Migration Advisory Committee (‘MAC’) published its Stage 2 report on the Temporary Shortage List (‘TSL’), recommending which occupations should remain on the TSL after the current interim list expires on 31 December 2026. The Immigration Salary List (ISL) will be replaced by the TSL on 31 December 2026.

The TSL is intended to give temporary access to the immigration system for critical RQF 3-5 occupations with long term shortages and incentivise employers to increase recruitment from the domestic workforce and manage exploitation. 

Stage 1 Review

In its Stage 1 review in October 2025 the MAC identified 82 occupations as potentially crucial to prioritised sectors including Advanced Manufacturing, Clean Energy Industries, Creative Industries and Professional and Business Services and the delivery of critical infrastructure.

The MAC recommended that occupations be included on the TSL for up to three years after which their ongoing inclusion should be reviewed against sector Jobs Plans.

They recommended that TSL visas should be issued for up to five years, but did not state whether time spent on the route should count towards indefinite leave to remain.

They also recommended that the ‘new entrant’ discount should not apply to those on the TSL.

Stage 2 Review

The MAC recommended that 28 occupations, including 3120: CAD, drawing and architectural technicians, remain on the TSL after 31 December 2026, down from the 52 occupations on the current list. It also recommended limiting TSL access to 18 months instead of three years, for all occupations because the Jobs Plans, which set out how sectors will increase training and make greater use of the domestic workforce, were insufficient.

In its summary for code 3120, the MAC found limited evidence of a historical occupation wide shortage, but identified area- and sector-specific recruitment difficulties. It considered future shortages plausible given the occupation’s importance to government priorities, including infrastructure delivery, and highlighted exploitation risks within the construction sector.

The MAC acknowledged that the occupation codes may not reflect how roles operate in practice and that some roles cut across multiple occupation codes.

What is the short-term impact?

The reduction from 82 to 28 occupations indicates that the government is taking a more restrictive approach to the TSL.

The current TSL expires on 31 December 2026. We expect the government to confirm in autumn 2026 whether it accepts the MAC’s recommendations, with any changes taking effect in early January 2027. If accepted, employers will continue to be able to sponsor international candidates under code 3120 from January 2027 until the end of June 2028, with any further changes expected in spring 2028.

If the government accepts the recommendation, sponsors of code 3120 roles will benefit because Architectural Assistants will not need to be qualified architects or satisfy the skill and salary requirements for code 2451 Architects.

The MAC confirms that workers in TSL roles can switch into higher-skilled RQF 6 roles and that, for now, TSL occupations can lead to settlement. However, we are still awaiting further proposals on earned settlement to confirm whether this will remain the position.

For 3120 to remain on the TSL beyond the initial 18-month period, the sector will need to submit a stronger Jobs Plan explaining how the sector is addressing shortage drivers, such as retention and pay, and how far any initiatives are expected to increase workforce supply and over what timeframe.

This benefit may be short lived if code 3120 is removed from the TSL by, or before, June 2028. If it is removed before a worker’s visa expires and they cannot switch into an RQF 6 role by then, they will need to cease work and may not be able to apply for settlement.

What is the longer-term impact?

The MAC will carry out a further full review when the 18-month access period expires, with greater emphasis on the quality of Jobs Plans and clear evidence of progress in reducing reliance on migration. The government’s aim is to reduce the number of occupations on the TSL unless there is a clear need that cannot be met through robust domestic workforce strategies.

How can employers prepare?

Employers should take this opportunity to forward plan as follows:

  • review employees currently sponsored under code 3120, or likely to be sponsored under that code soon, and bring forward applications where possible so they are submitted before 31 December 2026;
  • consider extending Certificates of Sponsorship for up to the five year maximum where possible, in case the role is later removed from the TSL;
  • where possible, prepare employees sponsored or recruited under code 3120 to qualify by the end of June 2028 review, so they can switch into code 2451;
  • identify any staff who may be eligible for settlement as soon as possible, whether under the Skilled Worker or Long Residence route;
  • monitor publication of the updated TSL by the Home Office.

If you would like to discuss anything outlined in this article, please 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 advice.