The Employment Law Pod

UK immigration rule changes 2025: What employers must know

• Boyes Turner

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In this episode of The Employment Law Pod, Chris Harber Partner, Employment & Immigration at Boyes Turner breaks down the sweeping changes to the UK immigration system introduced in July 2025. These updates are part of the government’s ongoing strategy to "restore control" and represent one of the most significant overhauls to the Skilled Worker route in recent years. 

If your organisation holds a sponsor licence or relies on migrant labour, this is a must-listen. 

Key takeaways for employers:

  • Over 180 roles have been removed from the Skilled Occupation List.
  • Employers can no longer sponsor chefs, hotel managers, or other roles now classed below Level 6.
  • Sponsorship strategies must adapt to ensure compliance and avoid costly missteps.
  • The government is linking immigration policy with industrial strategy for the first time in years.

Boyes Turner’s Employment & Immigration team can help assess how these changes impact your recruitment plans. 

Episode Links

Chris Harber: 0:03 

Hello, I'm Chris Harber. I'm a Partner here in the Employment and Immigration team at Boyes Turner, and welcome to the August edition of the Employment Law Pod. 2025 is proving to be quite the year for immigration here in the UK. In May, the government published their white paper called Restoring Control Over the Immigration System. On the 1st of July, the government published their latest statement of changes to the immigration rules. These changes represent a fundamental shift in the UK's approach to immigration and bring about major changes to work visa categories. 

Chris Harber: 0:35 

Today, we're going to focus on the key areas that are going to affect sponsor licence holders in the UK, predominantly affecting the skilled worker immigration category. These changes came into effect on the 22nd of July. The key areas that we're going to look at today are the increase in the skills threshold, the increase in the salary threshold, the phasing out of the immigration salary list and also the closure of the care worker visa. So let's go into this in a bit more detail, starting with the increase in the skills threshold. So, to qualify for a skilled worker visa, roles will now need to meet the new, higher skills requirements. Now the changes are taking effect, the skills threshold will increase from what's known as RQF Level 3 to what's known as RQF Level 6. To provide some context to what these levels translate to in real life, level 3 is the equivalent of an A-level type role and Level 6 is the equivalent of a bachelor's degree type role. These changes have resulted in the removal of roughly 180 eligible codes from the skilled occupations list in the immigration rules, which represents a huge number of roles compared to those that are remaining. Transitional arrangements will be in place allowing those already in the UK who are sponsored under the skilled worker route to renew their visas or indeed switch to another sponsor. So if you're already sponsoring migrant workers in roles that do not meet the new skills threshold, you will be able to continue doing so. These transitionary arrangements will be kept under review and will be removed at a later date. Based on previous changes to the immigration rules, we would expect the transitional arrangements to allow this cohort to meet the required period for indefinite leave to remain. However, there have been rumours that the government are planning on retrospectively applying the new proposed 10-year rule to the skilled worker routes. My opinion is that this is unlikely, considering that this will be significantly changing the goalposts for anyone who's already in the UK. Nevertheless, watch this space and watch out for changes as and when they're announced. 

Chris Harber: 2:49 

Next we're going to look at the increase in the salary thresholds Now. This is where there's a little bit more complexity coming into the system. So the salary requirements across the skilled worker, global business mobility and scale-up routes are being increased and these are being brought in line with the 2024 annual survey of hours and earnings data. This is known as the ASH data. Minimum salary thresholds and going rates for individual occupations will both be increasing as well. For applicants who have been in the skilled worker route since pre-April 2024, the minimum salary threshold at extension stage will be increasing from £29,000 per annum to £31,300 per annum. For applicants who entered the skilled worker route post-April 2024, the minimum salary threshold will be increasing from £38,700 to £41,700. As part of this, you also have the discounted rates as well. The main route for this is the new entry rates so if you're under 26 or if you have a degree that was issued in the UK and the discounted salary threshold for new to increase from £30,960 to £33,400 per year. These changes apply to all certificates of sponsorship that were assigned since the 22nd of July. Applications with certificates assigned before this date will be considered in line with the immigration rules before 22nd of July. So if your certificate of sponsorship was assigned before Tuesday, the 22nd of July so if your certificate of sponsorship was assigned before Tuesday, the 22nd of July, then you're still okay, you will still be considered under the old rules. It's also worth highlighting as well that all of these salary thresholds are based on a 37 and a half hour working week. So if you have different contracted hours to that, or if you have variable working hours per week, then you need to consider this and you need to pro rata the salary accordingly. 

Chris Harber: 4:50 

As part of their strategy, the government are also planning to phase out the immigration salary list and introduce a new temporary shortage list. The immigration salary list has come under a great deal of criticism since it was introduced under the previous government. Its usefulness is limited, the roles on the list are very, very specific and don't have much practical application, and there aren't really that many benefits to being on the immigration salary list. At the moment. The exact details of the temporary shortage list are yet to be announced. However, we will watch out for these when these are published in the near future. 

Chris Harber: 5:24 

In the interim, there will be two lists that will run simultaneously. First of all, there will be an expanded immigration salary list, which will include a number of occupations in levels three to five that the Migration Advisory Committee has identified as being in a shortage, and secondly, the new temporary shortage list will be introduced, which would include occupations, also from level three to five, which the Department for Business and Trade and the Treasury have identified as being important for the UK's modern industrial strategy. This second point is particularly important because it links the immigration system inextricably to the UK's industrial strategy. This is the first time that the immigration system has been linked to an industrial strategy since the introduction of the points-based system. It also introduces more of a political element to the immigration system as well. The roles which will appear on this are going to be put forward by trade bodies, trade organisations across the economy. So there is a much more developed, much more detailed ability to put roles into this temporary shortage list. 

Chris Harber: 6:33 

Given the increase in the skills threshold, occupations below level six must be listed on either the Immigration Scat Salary List or the Temporary Shortage List to be eligible for sponsorship. An important point to note on the Temporary Salary List is that it will be time limited and also conditional on a set number of rules. There will be removal dates for occupations that appear on this list, which will initially be set for the end of 2026. Roles on the list will be subject to regular reviews by the Migration Advisory Committee and occupations will only be included or retained on the list if the following requirements are all met Firstly, that the Migration Advisory Committee has advised that the role is still justified to be on the list. Second, where there is a workforce strategy in place for that given role and industry. And finally, where employers recruiting from abroad are committed to contributing to recruitment from the domestic workforce. 

Chris Harber: 7:31 

Applicants relying on the temporary shortage list where their roles are below the skills threshold, ie they're in levels three to five, will no longer be permitted to bring their dependents. This is a significant step away from the previous system, where all roles were eligible for dependents to apply alongside each other, and will actually introduce quite an important barrier and a reason why a number of people might not want to move to the UK. This restriction will not apply to applicants relying on the temporary shortage list where their role is at level 6 or above. So when you're considering sponsoring someone for a visa, it's very important to look at the skill level of that role, even if it is on the temporary shortage list, as it could have significant consequences for that individual's family members. Next we're going to look at the much vaunted and proposed closure of the care worker visa. 

Chris Harber: 8:28 

Since the introduction of care workers to the shortage occupation list a couple of years ago, the home office have encountered a number of challenges as to how this particular migration pattern has worked. There have been many instances of malpractice, many nefarious actors have obtained sponsor licences allowing them to sponsor care workers, and the Home Office has had to take action against a significant number of providers who have not been meeting their sponsor duties over the last couple of years. Following these concerns and many instances of exploitation of migrant workers, the Home Office has taken the decision to no longer allow care workers to be eligible for sponsorship under the Skilled Worker Route. This affects both care workers and senior care workers. Additionally, for in-country applicants, the government is removing the requirement for sponsors to first try to recruit from the existing pool of skilled workers seeking new sponsorship. Now this may seem counterintuitive. For a bit of background, earlier this year the Home Office introduced a facility for sponsor license holders in the care industry to access pools of displaced migrant workers. So where a care provider has lost their sponsor license, inevitably over the time those individuals will no longer be able to work for that sponsor. What this displaced workers list did is that it gave the ability to sponsor license holders in the care industry to go to this pool first of all and recruit from them, so trying to keep the people that were displaced from losing their sponsor licenses in the past and get them back into employment Now. This may seem counterintuitive and it may seem like it's a step back on an important compliance aspect. 

Chris Harber: 10:13 

The trouble that we've had since the introduction of this displaced workers list is that the administration of these lists varies significantly from region to region. There isn't really any common processes that are followed. The Home Office have very little oversight and control over how each of these individual lists are managed, and the documentation and the evidence that's required for applications from these individuals varies significantly depending on the caseworker that's assigned to an application. These individuals varies significantly depending on the caseworker that's assigned to an application. So I think this is more the home of trying to tidy up things and make the application system just a bit smoother for care workers who are already in the UK. For in-country applicants applying to switch from other visa categories, they must have been legally working for the sponsor for at least three months before the date their certificate of sponsorship was assigned. This is to allow sufficient time for both the sponsor and the migrant to demonstrate compliance with employment law and mitigate the risks relating to potential exploitation. It's important to point out as well that there is a transitionary period which will run until the 22nd of July 2028, and at which point these occupations will be removed from the immigration salary list and the temporary shortage list. So what can we take away from these changes? What things do we really need to be considering over the coming weeks and months? 

Chris Harber: 11:39 

For many employers relying on migrant workers, we believe that these changes will create significant challenges. The increase in the skills threshold and subsequent removal of approximately 180 roles from the eligible occupation list will remove, or at least drastically reduce, the ability for some sectors to rely on new overseas recruitment. A good example of this is the hospitality industry. So for the hospitality industry, under the old immigration rules there were a range of occupation codes that the industry could rely on to sponsor migrant workers. For example, hotel managers, bar managers, chefs, catering managers, events managers a whole range of occupation codes that were used. Quite significantly, the Home Office has moved all of these roles below level six, which means that it's no longer possible to sponsor anyone new into these roles. Quite importantly, this also means that if you're currently employing someone on a graduate visa, it will no longer be possible for them to switch into one of the previously eligible occupation codes, such as, for example, a hotel manager or a chef. 

Chris Harber: 12:51 

The case study of chefs is particularly relevant here, and we're actually now in a position where it is the hardest it's ever been to recruit chefs from outside of the UK. Now, before we left the European Union, the skill level was at level six before. So a big thing the Home Office have gone to great, great lengths to explain. As part of these changes is that the skill level is only returning to where it was before we left the European Union. For chefs in particular, that's actually not the case, because, whilst previously it was still possible to sponsor chefs under the old tier two general routes, there were specific requirements that had been applied for the nature of the business and the seniority of the role. In this instance, the Home Office have decided not to return to those previous conditions and have quite simply removed chefs from the entire occupation code. So this means that, regardless of your business, regardless of the quality of the restaurants, regardless of the skill or experience of the chef, it is no longer possible to sponsor chefs who are applying from outside of the UK. 

Chris Harber: 13:58 

If your recruitment strategy is going to be affected by these changes, then we can assist with planning and with strategy development and with identifying other recruitment resources for you. If you'd like to discuss how these changes will impact your business, please do get in touch with us. You can find out how in the episode notes. Thanks for listening to the Employment Law Pod. If you're interested in checking out more episodes in this series, please go to the Boyes Turner website. If you’re interested in checking out more episodes in this series? Please go to the Boyes Turner website. You can also follow wherever you get your podcasts. Goodbye.