Immigration

United Kingdom | White Paper—UK government announces sweeping changes to immigration policy

Summary

The United Kingdom Government has published an immigration White Paper which sets the policy direction for United Kingdom immigration and contains some major changes to reduce net migration to the United Kingdom.

Overall, the impact of the changes will be to make United Kingdom immigration harder and more expensive for employers.

The detail

The government has announced:

• Increased Immigration Skills Charge — The ISC will increase from £1,000 per year to £1,320 per year with funds going to the Department of Education for employers to request to use for investment in training.
• Higher ILR residence requirement — Increasing the time it takes to qualify for Indefinite Leave to Remain in the United Kingdom from 5 years to 10 years for most routes with shorter qualification times available for those who pay tax, contribute to the United Kingdom community, are in a strategic and skilled job or are dependants of British citizens. A consultation on how this will look will be launched later in the year but employees may express alarm on what this means for them; we are seeking urgent clarification from the Home Office on who will be impacted and when.
• Higher naturalisation residence requirement — Increasing the standard time it takes to qualify for British citizenship with shorter qualification times available for those who pay tax, contribute to the community and are in a strategic and skilled job.
• Review Life in the United Kingdom test — Review the effectiveness of the test and how it operates.
• Higher skill level requirement — Raising the skills threshold for sponsored visas from RQF3 (School leaver) to RQF 6 (Degree level) unless there is strong evidence of skills shortage. Salary thresholds will rise accordingly. The Immigration Salary List which gives people discounts from salary thresholds will be abolished and the MAC will be commissioned to undertake a thorough review of salary requirements.
• New consulting body — Establishing the Labour Market Evidence Group (LMEG) to inform understanding of where sectors are overly reliant on overseas labour and reverse underinvestment in domestic skills.
• New Temporary Shortage List — A list of roles which may benefit from a lower skills threshold to provide time limited access to the immigration system, as decided by the LMEG.
• New United Kingdom investment requirement — Linking sponsorship of visas to investment and training in the United Kingdom via an industry sector based workforce plan where one is required as decided by the LMEG.
• Higher English language requirement — Increasing English language requirement for workers and settlement applications from B1 to B2 level (higher intermediate). NB Global Business Mobility visas will remain English language requirement free.
• New English language requirement for dependants — Introducing English language requirements for new adult dependant of workers applications starting at A1 level (basic) with progression to A2 for extension and B2 for Settlement.
• Shorter Graduate Visa Route — The period of grant for the Graduate Visa will be reduced from 24 months to 18 months.
• Family migration — A reform of the framework for family migration to tackle the overly complex family and private life immigration arrangements, including clear relationship requirements, appropriate level of English language requirements, and ensuring the family unit has sufficient funds without relying on the taxpayer. This will also include a clear framework on those seeking to enter or stay in the United Kingdom on the basis of exceptional circumstances.
• Global Talent Visa — A review to expand the visa route to encourage more applicants.
• Foreign national offenders — Establishing new procedures so that the Home Office can more easily take enforcement and removal action and revoke visas in a much wider range of crimes where noncustodial sentences have been given, not just cases which are sent to prison.
• Student route — Introduce a 6% Higher Education levy on tuition fees for international students payable by universities/HEI.
• Care workers — Health and Social Care visa route will be closed to new applicants from overseas and current visa holders will be phased out by 2028.

The individual measures will be introduced over a number of years through statements of changes, but there is no published time frame at present. We can expect some of the changes in Statements of Changes this year, but the Home Office would not commit to a schedule when pressed.

Many of the changes will be subject to transitional arrangements, meaning that existing visa holders should not be impacted, but this cannot be guaranteed for every change and further details on this will be announced in due course.

Analysis

Background

Net United Kingdom migration to the United Kingdom has increased significantly in the past 5 years since the end of the Covid-19 pandemic and the end of Freedom of Movement between the United Kingdom and the European Union from 1 January 2021.

In the 2010s, net migration was around 200-250,000 per year on average, but hit a record high of 906,000 in 2023 before falling to 728,000 in 2024.

This was due to a number of unusual factors such as the Ukraine settlement scheme, the Hong Kong BNO visa route, a post-pandemic surge, Brexit and a huge increase in visas being issued to care home workers.

The last Conservative government introduced measures in 2024 to lower net migration such as stricter requirements on dependents, increasing immigration fees and increasing salary thresholds for sponsored workers and family visas. Visa applications and approvals have already decreased significantly, but the new Labour government’s White Paper goes further.

Impact on Employers

Overall, the changes will make United Kingdom immigration harder and more expensive for employers.

For employers who use a sponsor licence to sponsor workers, there will be a higher skills threshold, increased fees, potentially a longer route to settlement (meaning that workers may have to be sponsored for longer) and higher English language requirements which could potentially reduce the pool of workers who are able to come to the United Kingdom with their families.

This reduces the pull factor to the United Kingdom as employers may be reluctant to sponsor for long periods of time due to increased costs and workers may not be willing to relocate without their adult dependents who do not meet the English language threshold.

For graduate employers, the reduction in length of the Graduate Visa from two years to 18 months will have a negative impact on two year graduate schemes and will require an earlier switch on to the Skilled Worker route. However, if the United Kingdom Government introduces a Youth Mobility scheme for EEA nationals, there may be some relief available.

Recommendations

The White Paper sets out the government’s intention but does not provide real detail so your only immediate job may be to brief your colleagues on the changes, in so far as they are known. Please get in touch if you would like help composing your message to the business.

In the short term, employers should consider undertaking impact analysis of:

• Immigration Skills Charge increase from £1,000 to £1,320 per year — Vialto can assist with this analysis projecting the increased costs and budget adjustments.
• The increased skills threshold from RQF3 to RQF6 — Vialto can review Certificates of Sponsorship issued in the last 5 years to analyse the percentage of workers who fall below the new threshold and what impact this could have.
• Shorter Graduate Visa route — Vialto can review your graduate schemes to analyse the number of graduates which rely on the Graduate Visa to complete programmes and the numbers which may need to switch into the Skilled Worker visa or rely on the proposed Youth Mobility scheme. In the alternative, an accelerated graduate scheme may be considered.
• The new English language requirement for dependants and the higher English language requirement for workers — Vialto can undertake detailed data analysis on which countries might be impacted by this requirement. For example, most Indian degree holders will meet the requirement already but other nationalities may struggle where higher level English language learning is weaker, for example Japan.
• The longer residence requirement for ILR may require more visa extensions and therefore increased costs in future so an impact assessment should be considered.
• Increased compliance enforcement should prompt a full review of employers’ current policies and processes and Vialto’s compliance team can assist, including mock audits.

Contact us

For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:

Lyudmyla Davies
Partner (Solicitor)

Ian Robinson
Partner

Andrea Als
Director (Solicitor)

Tom Marsom
Director (Solicitor)

Lucy Vaux
Senior Manager (Solicitor)

Awale Olad
Senior Manager

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