Navigating the new immigration rules – What has changed in 2025?

Over the past 18 months, we have seen a significant shift in the immigration landscape in the UK. Against the backdrop of the incoming Labour Government in July 2024 announcing its intention to reduce net migration levels with the long-term aim of investing in training and upskilling of the domestic labour market, employers will have felt the political changes - particularly those in sectors most reliant on overseas workers, such as health and social care, hospitality, construction and the creative industries.

In this article, we look at some of the key changes that have been rolled out this year and provide our top tips to assist businesses to navigate the new immigration rules.

Key changes – what has happened so far?

The start of 2025 brought with it increased compliance visits by UK Visas and Immigration (UKVI) resulting in fines for existing sponsor licence holders who had failed to comply with employment laws, and revocation of licences in serious cases. Shortly thereafter, the Immigration and Nationality (Fees) (Amendment) Order 2025 substantially increased certain Home Office fees, such as the certificate of sponsorship fee, which has been raised from £239 to £525. It is likely that UKVI will continue to increase its oversight by way of desk top reviews and spot checks.

Most notably, in May 2025, the Government released its highly anticipated Immigration White Paper, which set out “radical reforms to Britain’s immigration system” with the aim of “restoring control to our borders”. This was in direct response to policies under the former Conservative Government, which increased inward migration to mitigate labour shortages post-Brexit, which some have dubbed the “Boriswave”. The Immigration White Paper proposed changes to make it more difficult to move to and settle in the UK and also set out aims to tackle irregular migration and promote integration and community cohesion.

Key date: 22 July 2025

The first set of changes following the White Paper were introduced on 22 July 2025, in particular:

• skill level increase from RQF Level 3 (school leaver) to RQF Level 6 (graduate level) for Skilled Worker visa applicants
• reduction of roles that can be sponsored for new skilled workers with new occupation tables published
• increase in general salary thresholds and ‘going rate’ for all occupation codes
• closure of Care Worker and Senior Care Worker visa routes, with a transition period until 2028
• introduction of Temporary Shortage List (TSL), which includes medium-skill jobs eligible for sponsorship

The Home Office’s explanatory memorandum to the statement of changes advises that the increase to the skill level threshold is a return to pre-Brexit levels. It was reduced, in part, to help businesses adapt to the ending of free movement between the UK and EU. The motivation for the change now is due to concerns about high net migration figures. exploitation of overseas recruits and the future impact of low skilled migration on public funds. The impact is mitigated by the introduction of the Temporary Shortage List and a lengthy transition period regarding the closure of Care Worker and Senior Care Worker visa routes.

Key date: 14 October 2025

A further set of changes were announced on 14 October 2025, including:

• 32% increase to the Immigration Skills Charge (ISC)
• increase in the English language requirement for Skilled Worker and High Potential Individual (HPI) applicants from Level B1 to Level B2 (upper intermediate, A-level standard) from 8 January 2026
• expansion of the High Potential Individual (HPI) route for self-sponsors from top universities
• reduction of the Graduate visa route from two years to 18-months (although PhD graduates will still be granted three years), for applications submitted on or after 1 January 2027

The 32% increase to the Immigration Skills Charge will come into force on 16 December 2025. This is the fee paid by employers who wish to sponsor migrants. The current fees are £364 per year for small businesses or charities and £1000 per year for medium to large businesses. The charge has not been increased since 2017 but is now likely to rise with inflation year on year. This will likely be coupled with a requirement for employers to develop domestic training plans to boost British skills and recruitment levels before hiring from overseas.

The increase in the English language requirement is unlikely to affect many applicants on the Skilled Worker or HPI routes who already arrive with high levels of English or may be switching from the Graduate visa route having completed a degree level qualification in the UK. However, the Government has also expressed intentions to raise the expected levels of English for dependants, which will be effective from early 2026.

The intended list of eligible institutions for the HPI route has almost doubled and the Home Office will update its 'Global Universities List'. Whilst not the most commonly used route, the number of places will nevertheless be capped at 8,000 applications per year. Since it was launched, between May 2022 and June 2024 roughly 4,500 main applicant visas and around 620 dependant visas had been granted, with applicants predominantly originating from the USA, China and India, according to Home Office data.

The reduction of the Graduate visa route is fuelled by concerns that graduates are completing their studies in the UK but not moving into graduate level roles and “properly contributing to the economy”. The Government hopes that this change will encourage the move into the workforce but estimates a long-term reduction of student visa applications.

Reminder of other recent changes

At the end of 2024, the Home Office continued its digitalisation of the immigration system with the introduction of eVisas to replace Biometric Residence Permits (BRPs), which were formally phased out from 31 December 2024.

Another key change was the relaxing of the rules for Skilled Worker visa holders who are now permitted to take up supplementary employment outside of their normal working hours, up to a maximum of 20 hours per week, provided the additional role is one that could be sponsored under the skilled worker rules.

Looking to the future – what else is on the horizon?

There will be further reforms to the sponsorship system, including putting more responsibility and accountability on effective and reliable sponsors. This should also make it easier for Skilled Workers to move between licenced sponsors for the duration of their visa.

The Government has also proposed a doubling of the qualifying period for settlement from five years to ten years, which has undoubtedly caused concerns for both individuals already on the route to settlement, as well as employers who face lengthier periods of sponsorship; however, further details are yet to be confirmed.

Impact on businesses and top tips for sponsor licence holders

Changes are coming in thick and fast, and we would advise businesses to be mindful of the mooted changes over the coming months. 

• Apply early: sponsors of incoming staff or existing employees whose visas coming up for renewal are advised to apply early to benefit from the current fees. You can apply up to three months in advance of their start date. It is also worth requesting an increase in your CoS allocation as early as possible.
• Review sponsorship pipeline: now is the time to review your sponsorship budget and consider whether it may be prudent to sponsor staff for longer.
• Open communication: continue to ensure open communication with sponsored staff. The changes are likely to be felt widely for individuals and their dependants.
• Compliance is crucial: having robust systems in place will protect you and your business. We would recommend diarising visa expiry dates, ensuring employees satisfy requirements before sponsoring, and reporting any updates in employment to the Home Office, including promotions or role changes.
• Invest in training: for those reliant on care staff from overseas, the transition period is a key time to upskill the domestic workforce and revise training and recruitment policies accordingly.

This insight was authored by Principal Associate, Younes Ech-Chadli and 
and Trainee Solicitor, Hanna McRobbie.