Update to Minister of Religion and Religious Worker categories

On 3 September 2026, the Home Office published a statement of changes which included updates to the visa routes for Ministers of Religion and Religious Worker categories. Due to come into effect on 29 October 2026, we have summarised the key changes, followed by a brief overview of next steps for employers who are currently sponsoring or looking to sponsor migrants under these routes.

Minister of Religion visa

Removal of 6-year limit – currently a migrant under the Minister of Religion category can be granted permission for a maximum of three years and one month at a time and is subject to a maximum six-year cap on sponsorship. Under the new rules, permission can be granted for up to three years at a time and the cap of six years will be removed.

Expansion of duties for members of religious orders: the Immigration Rules have been amended to allow members of religious orders to undertake roles involving mainly non pastoral duties, such as school teaching, media production, domestic work or administrative and clerical work.

Religious Workers visa

Change to Resident Labour Market Test (RLMT) requirement

Under the current rules where the applicant is applying for permission to stay and remaining with the same sponsor, the sponsor does not need to meet the resident labour requirement by carrying out a national recruitment search. Conversely, if the applicant is applying for entry clearance or applying for permission to stay and changing sponsor, then the sponsor must carry out a national recruitment search.

Under the new rules, the national recruitment search requirement will be replaced with a minimum six-month affiliation requirement.

Proof of the role being supernumerary or involving membership of a religious order remain alternative options to meet this requirement. The affiliation requirement is intended to ensure an established connection to the sponsoring faith-based organisation is demonstrated, although these requirements are alternatives.

Clarification of duties

The Immigration rules have been clarified to confirm that the religious worker role must mainly involve performing non-pastoral religious duties. This reinforces the requirement that the role does not include work which falls under a role of a Minister of Religion.

Changes impacting both categories

New requirement for sponsors to confirm they will maintain and accommodate workers not entitled to NMW

Applicants who are not entitled to the NMW must meet the financial requirement by the sponsor confirming on the Certificate of Sponsorship (CoS) that they will maintain and accommodate the applicant for the duration of the period of permission in the UK. This applies both to applicants applying for permission to stay in the UK who have been living in the UK with permission for 12 months or more, as well as and applicants applying for entry clearance or applying for permission to stay after living in the UK for less than 12 months on the date of application. This reflects where applicants are not receiving a salary while they are in the UK.

Applicants entitled to the NMW and who are applying for entry clearance or applying for permission to stay after living in the UK for less than 12 months on the date of application must still satisfy the financial requirement by showing funds of £1,270.

New requirement for sponsors to confirm they will maintain and accommodate the dependents of workers not entitled to NMW.

Where the main applicant is not entitled to the NMW, and they have lived in the UK for 12 months, then they do not need to show evidence of the funds below. Instead, the sponsor must certify maintenance and accommodation for the partner or child on the CoS.

For a dependent partner or child of a Minister of Religion, where the main applicant is entitled to the NMW and has been in the UK for less than 12 months, the following funds are required to satisfy the financial requirement when the applicant is in the UK or is applying for entry clearance:

• £285 for a dependent partner;
• £315 for the first dependent child; and
• £200 for each additional dependent child.

What do these changes mean?

These changes represent a significant shift in the sponsorship framework for Ministers of Religion and Religious Workers. The removal of the previous six-year maximum stay provides faith-based sponsors with greater flexibility when engaging individuals in senior religious roles and members of religious orders. This is likely to be welcomed by organisations that require long-term continuity in leadership and pastoral positions.

However, sponsors should not assume that the reforms result in a lighter compliance burden. The amendments introduce additional evidential requirements linked to NMW exemptions, and sponsors will need to ensure they maintain appropriate records demonstrating that any exemption continues to apply. Regular internal compliance reviews will therefore become increasingly important.

Some aspects of the new arrangements may be more restrictive. In particular, where a role is neither supernumerary nor undertaken as a member of a religious order, and the individual has not worked for the same organisation overseas for at least six months, sponsors can no longer satisfy the eligibility requirements through advertising the role. While this limitation may present challenges in certain recruitment scenarios, organisations may be able to address it by engaging individuals overseas for a qualifying six-month period before making a UK sponsorship application. Nevertheless, the removal of the often burdensome advertising requirement is, on balance, a positive development.

The reforms also reinforce the importance of sponsor compliance. As UKVI will place greater reliance on information contained within the Certificate of Sponsorship, sponsors should expect increased scrutiny of the information they provide and be prepared for periodic compliance checks where concerns arise.

Looking ahead, the establishment of the Fair Work Agency as the body responsible for enforcing NMW compliance may introduce an additional regulatory consideration for faith-based sponsors. Organisations benefiting from NMW exemptions should be mindful that compliance may be assessed not only through the immigration system but also through wider employment law enforcement mechanisms. This could result in increased scrutiny of sponsorship arrangements and working practices within the sector.

How can employers prepare?

Employers should take this opportunity to forward plan as follows:

• Review their CoS process.
• Review current processes for assigning CoS.
• Advise applicants of the financial maintenance requirement, as failure to provide this information could result in the application being refused.
• Consider how the new six-month affiliation requirement can be evidenced, if applicable.
• Assess whether workers are entitled to receive the NMW and whether they are in a position to maintain and accommodate the worker in addition to any dependents.

With these changes, due to come into effect shortly, you may find that you need support reviewing your existing processes. Our team can support with retrospectively reviewing existing visa applications or advising on new ones under the Ministers of Religion and Religious Worker categories. They are also able to complete audit checks to ensure you are keeping appropriate records to evidence application processes, helping you to avoid fines under the new regulations. If you need support on these, please do get in touch with Aisha Choudhry.

The material in this article is provided for guidance and general information only and is not intended to constitute legal or other professional advice on 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 contact the Bates Wells team if you require further information.