The closure of the Immigration Salary List (ISL) on 31 December 2026 could have significant consequences for some sponsored workers in RQF Level 3-5 occupations.
Recent clarification reported by NHS Employers but not yet confirmed by the Home Office suggests that the impact of the ISL closure will depend not only on an employee’s occupation, but also on when they were first sponsored under the Skilled Worker route. In particular, workers first sponsored in certain RQF Level 3-5 occupations on or after 22 July 2025 may not benefit from the transitional protections available to individuals who were already in the route before that date.
As a result, two employees performing the same role for the same employer could ultimately face different immigration outcomes despite holding the same occupation code.
Changes introduced on 22 July 2025 increased the Skilled Worker skill threshold from RQF Level 3 to RQF Level 6. However, sponsorship remained available for certain sub-degree level occupations through transitional arrangements, the Immigration Salary List (ISL) and the Temporary Shortage List (TSL). The ISL is currently scheduled to close on 31 December 2026.
According to clarification reported by NHS Employers, the key date is when an individual’s first Certificate of Sponsorship (CoS) was assigned. Workers first sponsored in affected RQF Level 3-5 occupations before 22 July 2025 remain covered by transitional arrangements and can continue to apply for extensions, changes of employment and settlement under the current framework.
However, workers first sponsored in affected RQF Level 3-5 occupations on or after 22 July 2025 are in a different position. NHS Employers reports that these workers will no longer be able to extend their permission or change employment in those occupations once the ISL closes, unless another basis for sponsorship exists.
To illustrate:
Although both employees perform the same role, Employee A may continue to benefit from transitional protections, whereas Employee B may not. If the occupation is not retained under future immigration arrangements, Employee B could ultimately face restrictions on extending permission in that occupation after the ISL closes.
There may also be a planning opportunity before the ISL closes. NHS Employers notes that visa applications can still be submitted after 31 December 2026 where they rely on a valid CoS assigned before the closure date.
Many employers will naturally focus on whether a role appears on the future Temporary Shortage List. However, the more immediate issue may be identifying which sponsored workers rely on ISL eligibility today and whether they entered the Skilled Worker route before or after 22 July 2025.
For some employers, the affected population may not become apparent until an extension is required several years from now. For example, an employee first sponsored after 22 July 2025 may hold a three-year visa valid from August 2025 until August 2028. If their occupation ceases to be eligible when the ISL closes, waiting until August 2028 could mean that no further Skilled Worker extension is available in that role. The employer may therefore need to consider, before the end of 2026, whether to sponsor the employee for a further four or five years while the occupation remains eligible. This could protect the employee’s ability to accrue the qualifying residence period for settlement, subject to the rules in force at the relevant time.
Employers should therefore consider reviewing:
This is likely to be particularly relevant for employees first sponsored between 22 July 2025 and 31 December 2026 in occupations that currently rely on the ISL.
This is a nuanced transitional rule issue that may easily be overlooked because the risk is not based solely on occupation code or visa expiry date.
The Government has not yet implemented the final long-term arrangements that will replace the ISL, and employers should avoid making assumptions about which occupations will remain eligible under the future TSL. The ultimate impact will depend on the Government’s final policy decisions and any accompanying transitional provisions.
Nevertheless, sponsors should not wait until December 2026 to assess their position. Organisations with workers in RQF Level 3-5 occupations should identify potentially affected employees now, map their current visa expiry dates and consider whether a longer period of sponsorship should be secured before the ISL closes. Any strategy will need to take account of the final replacement arrangements for the ISL and potential changes under Earned Settlement.
Vialto Partners is monitoring developments closely and can assist employers with population reviews, sponsorship planning and individual immigration strategy assessments ahead of the closure of the Immigration Salary List.
For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:
Lyudmyla Davies
Partner
Sarah Ingles
Partner
Adam Sinfield
Director
Andrea Als
Director
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