You may have seen that yesterday, Prime Minister Keir Starmer announced a dramatic plan to tighten control of the UK’s borders, bring down net migration levels and avoid the UK becoming an “island of strangers”. Shortly afterwards, the Government published a white paper titled ‘Restoring Control Over the Immigration System’, setting out its long-term vision for legal migration reform in the UK. The full paper is available here.

Quite apart from the (some would say) controversial language used in the announcement, this is very significant news for UK employers and specifically those operating in the creative, technology and sports sectors which have regular and understandable immigration needs (be it a household name US actor, a prolific European software developer or the latest talented footballer from South America etc…) Whilst the proposals remain at policy stage and are not yet in force, they are wide ranging and the document provides a strong signal of the direction of travel in this area.

If the white paper proposals are advanced, they will re-shape the immigration landscape in the months and years ahead and will influence any UK-based business involved in international recruitment and visa sponsorship.

We have summarised the key proposals and what they could mean for UK employers below.

The white paper outlines more than two dozen reforms to the UK immigration system but in our view, the most significant proposed changes are these:

• Raising the skills threshold for Skilled Worker visas from the current minimum of Regulated Qualifications Framework (RQF) Level 3 (A-level equivalent) back to RQF Level 6 (graduate level). This is a material change, effectively narrowing Skilled Worker sponsorship to much more qualified individuals (i.e. university graduates).
• Introducing more enhanced compliance monitoring for employers. For example, key sectors where there are high levels of recruitment from abroad will need to produce, or update, a workforce strategy which relevant employers will be expected to comply with. This will detail steps to be taken on skills, training, and broader conditions, as well as engagement of the economically inactive domestic labour force.
• Salary thresholds will be further increased, building on the rises announced in Spring 2024. The percentage increases are yet to be announced.
• A new Temporary Shortage List will be introduced to replace the Immigration Salary List, but only occupations assessed by a newly established Labour Market Evidence Group and the pre-existing Migration Advisory Committee will be eligible. Employers will be expected to show commitment to domestic training as part of this process.
• The Immigration Skills Charge will rise by 32%. For medium and large sponsors, the cost of this for a single five-year visa is already £5,000. It will therefore increase to £6,600.
• English language requirements will be increased. Skilled Workers will need to meet the B2 level (up from B1), and a new A1 requirement will be introduced for the first time for adult dependants of workers and students. For those applying for settlement, the language requirement is expected to increase from B1 to B2.
• Graduate visas will be reduced from two years to 18 months, with further changes under consideration. The current proposal is not to scrap the route, but to shorten its duration and potentially reduce eligibility further. This will give graduates less time to survey the market before seeking sponsorship, most likely under Skilled Worker visas.
• The qualifying period for permanent settlement will double from 5 to 10 years across most routes. This clearly could cause a significant social impact to those with long-term settlement plans, whilst extending the immigration considerations employers will face with longer-term migrant staff.
• The social care visa route will be closed to new applications from overseas. Instead, sponsors will be required to recruit from the migrant workforce already based in the UK.

The white paper sets out the Government’s policy intentions, but no rule changes have yet taken effect. There is no confirmed implementation timeline, and many measures will require further consultation, secondary legislation, and updated guidance.

That said, the tone of the white paper is clear. The Government is moving toward a more restrictive and selective immigration system, with a particular focus on reducing net migration, limiting lower-skilled migration, and encouraging employers to invest more heavily in the domestic workforce.

In practical terms, employers should not panic, but it may be sensible to take stock of current and future needs. For example, if you are planning to sponsor a migrant worker in a role that currently qualifies but sits below RQF Level 6, it may be a good idea to move quickly. There is a real possibility that eligibility for such roles could be removed once the new skills threshold comes into force.

Even where roles are clearly above RQF Level 6, planning ahead is still important. Salary thresholds and sponsor obligations will change. Where visa applications are already in progress, it could be beneficial to submit promptly.

Employers should also be mindful of upcoming changes to English language and settlement requirements, which may affect future employee expectations and long-term recruitment planning.

Thankfully, the white paper suggests that those already in the UK on valid visas will not be immediately affected by these changes. Specifically:

• Workers already sponsored in RQF 3–5 occupations will likely continue to be eligible to extend their visas, change employer, or take supplementary employment in those same roles, even after the proposed RQF6 threshold comes into force.
• The proposed reduction in the Graduate visa route to 18 months is expected to apply only to new applicants. Those who already hold a two-year Graduate visa are expected to retain their current grant of leave.
• Existing sponsored workers are also unlikely to be subject to the new salary thresholds. As with the April 2024 changes, it is expected that new thresholds will apply only to new Skilled Worker applicants and to those extending their permission or switching role.

While the white paper gives a strong indication of where the system is heading, it has not yet been made law. The proposals are subject to change and the detail (particularly around exemptions and transitional measures) is not yet available.

Our key recommendations at this stage are as follows:

• Review current and future sponsorship plans, particularly for roles below RQF Level 6, and assess whether applications can or should be brought forward ahead of any rule changes, especially in light of potential increases to salary thresholds and the Immigration Skills Charge.
• Monitor developments around increased English language requirements, including for dependants and those approaching settlement, and ensure affected individuals have time to meet new test levels or apply under existing rules where possible.
• Prepare for enhanced compliance obligations, as there will likely be increased scrutiny on sponsors’ HR systems, right to work processes, and workforce development strategies. Employers should ensure systems are robust and up to date.
• Plan for longer-term recruitment needs, including reviewing internship and early career pathways, as employers who continue to rely on overseas recruitment may be expected to demonstrate parallel investment in domestic talent. Those involved in the financial side of recruitment, will need to adjust budgets and discuss the additional strain with relevant stakeholders.
• Consider how best to protect investments in people. For example, if you haven’t already, it may be worth considering the introduction of immigration costs agreements so that migrants are required to repay certain eligible sums should they leave employment and sponsorship early.

We will continue to track developments closely and will issue further updates as implementation plans are announced. In the meantime, please do get in touch if you have any questions.