Statement of Changes to the Immigration Rules: what do employers need to know?

read time: 9 mins
16.07.25

On 1 July 2025, the Home Office published a Statement of Changes to the Immigration Rules, implementing the first measures trailed in May’s Immigration White Paper.  A number of significant changes have been introduced, which will have major implications for UK employers sponsoring migrant workers. In this article we highlight these changes, outline the further changes in the pipeline, and provide immediate steps that employers need to take.

Changes to Immigration Rules Appendix Skilled Worker (‘Appendix Skilled Worker’) and other work routes

The Skilled Worker visa route is  the main work visa route available in the UK, enabling employers to sponsor eligible workers in specific roles. There are a number of criteria for this route, including an eligible occupation code, required skill level, and a minimum salary requirement. A number of changes to the Skilled Worker route are being implemented:

Skill level 

Possibly the most significant change that has been introduced is the skill level for the Skilled Worker route being increased from RQF Level 3 (A Level equivalent) to RQF Level 6 (degree level equivalent). This is effectively reverting back to the situation prior to the 2020 immigration reforms, when the skill level was lowered, and this change means that around 180 roles that have previously been eligible for the Skilled Worker route will no longer be eligible from 22 July 2025, other than transitional provisions.

This announcement has understandably created significant concern amongst employers who currently sponsor workers within these codes. It will, however, be of some reassurance that existing sponsored workers, and anyone sponsored before 22 July 2025, can continue to be sponsored in these codes and can therefore continue to extend their visas or make a change of employment application within the same occupation code but with a different employer. 

These ‘transitional arrangements’, for people already sponsored in these codes, are welcome but do create some confusion. Anyone who has read through the Statement of Changes will see that there are now a number of different tables setting out various salary options for different codes in different circumstances. This is not going to be straightforward to navigate for sponsors.  The Home Office have also said that these ‘transitional measures’ will not be in place indefinitely, so unfortunately there is no long-term certainty for individuals sponsored in these roles.

Salary increases – multiple work routes

Another key change, which will be felt by all employers sponsoring workers, is the increase to the minimum salary requirements. The Home Office has expressed that these changes are to ensure salary requirements continue to reflect the latest pay situation for UK workers. 

The key headline is that the general Skilled Worker minimum salary requirement is increasing from £38,700 to £41,700 per year. In all cases, the salary for a role will still need to equal or exceed the going rate for that role. Going rates have also increased, and the updated rates are set out in the Statement of Changes. 

Transitional provisions won’t apply for the minimum salary requirements, so this means that even if someone is currently already sponsored in the Skilled Worker route in line with the existing minimum salary requirements, if they make an extension or change of employment application, the new salary requirements will apply. 

There are also salary increases in other routes such as the Senior or Specialist Workers, UK Expansion Worker and Scale-up Worker routes. 

The Immigration Salary List and a new Temporary Shortage List – Skilled Workers

The Home Office has established a new Temporary Shortage List, which provides restricted and time-limited eligibility for certain occupations below RQF Level 6, where there is considered to be is a shortage of workers in those roles in the UK. 

The Temporary Shortage List is currently sitting alongside the Immigration Salary List, which contains occupations that have been identified as having labour shortages and are therefore eligible for Skilled Worker visas with a discounted salary. However, long-term the Home Office’s intention is to phase out the Immigration Salary List and replace it with the Temporary Shortage List. 

At the moment, both lists will expire on 31 December 2026, however the Home Office have indicated that this date could be moved forward. 

Changes in relation to adult social care

For anyone working in the care sector, a major change from the Statement of Changes is the closure of entry clearance applications for roles in occupation codes 6135 and 6136, ‘care workers’ and ‘senior care workers’. This means that overseas recruitment into these roles under the Skilled Worker route has ceased. Further, from 22 July, these codes are also no longer generally eligible for the Skilled Worker route, as the Home Office has determined that they do not meet the RQF Level 6 threshold. 

This means that, moving forward, for individuals to be eligible to make an application under these codes, one of the following criteria must be met:

  • The first is that ‘(i) The applicant must have been legally working for the sponsor in one of these SOC 2020 occupation codes for at least the three months ending on the date the certificate of sponsorship was issued by the sponsor to the applicant; and (ii) the date of the application must be before 22 July 2028’. This reflects a transitional period for switching from other routes, until 22 July 2028, although the Home Office have indicated that these transitional provisions will be kept under review. 
  • The second is that ‘the applicant must have permission as a Skilled Worker, sponsored in either of these occupation codes’.  

Other than in one or other of those circumstances, an individual will not be eligible to make an application to enter the Skilled Worker visa route in one of these two codes. 

Given these changes, the current care recruitment requirements, which were introduced in April 2025 and require care sector employers to first try to recruit from the pool of displaced workers – existing Skilled Workers seeking new sponsorship – are being removed. 

It's also worth noting that the Home Office are pre-empting any employers that might think of using the still-eligible occupation code 6131, Nursing auxiliaries and assistants, as an alternative to the care worker codes, to circumvent the care worker codes no longer being available. They have clarified that this code will now  ‘only apply to roles in environments where registered nurse roles also exist.’

These changes sit alongside a number of other amendments in the Statement of Changes, and are likely to be the changes that make the biggest impact on businesses sponsoring workers in the UK. 

Further changes in the pipeline

There were a number of further changes mentioned in May’s White Paper, which have not been implemented yet, and so which are still subject to further consultation and discussion but may still be in the pipeline:

  • The White Paper indicated that the Graduate Visa route, which currently allows students to stay in the UK for two years (three years for PhD students) after graduation to work on an unsponsored basis, would be limited to a period of 18 months post-study. If implemented, this will restrict flexibility for graduates, giving them a more limited opportunity to find sponsored work following the conclusion of their studies in the UK. It will also mean that employers who have been employing individuals on a non-sponsored basis while they are on Graduate visas will need to consider sooner whether they are prepared to offer sponsorship to these individuals, and if so, to make arrangements to do so. 
  • The Home Office also indicated that new English language requirements will be introduced, for both main visa applicants and their dependants. The standard of English that workers, for example on the Skilled Worker route, are required to meet will increase from B1 to B2 on the Common European Framework for Reference for Languages (CEFR), and an English language requirement for all adult dependants will also be introduced, at Level A1 CEFR. Any visa extensions will need to demonstrate progression to Level A2, and settlement applications will need to meet Level B2. This will have a significant impact, particularly for dependants who may not have a strong grasp of the English language prior to relocating to the UK. It will also increase costs for applicants as they will, in most cases, need to take and pass a Home Office-approved English language test prior to making a visa application, and may need to take further tests when applying to extend their visa and/or settle in the UK. 
  • The White Paper also indicated that the standard qualifying period for settlement in the UK will be increased from five years to 10 years on an eligible visa route, although it also stated that there will continue to be a five-year pathway to settlement for certain individuals - for example, non-UK dependants of British citizens, or based on an individual’s contribution to the UK economy and society. The Home Office has not indicated how an individual will be able to qualify for the five-year route, but has stated they will consult on these changes later in 2025. This will have a significant impact on individuals seeking to make their home in the UK long-term; it remains to be seen how wide-ranging the five-year pathway will be, and whether anyone not eligible for that pathway will need to continue to make extension applications every two and a half years, as is currently required. This would significantly increase those individuals’ costs as well as increase uncertainty of their long-term future in the UK until they have accrued 10 years’ residence. 

What next?

Given the scope of these new changes, and how soon they are being implemented, employers will need to take immediate steps to consider the impact that they are going to have on their organisations. We advise employers to consider their current sponsored workforce, and to assess whether there are any roles that the business sponsors workers in that are no longer eligible for the Skilled Worker route, as well as confirming the increased minimum salaries for any sponsored roles. 

Employers will also need to look ahead at any individuals they were considering sponsoring in future, to determine whether their prospective roles are still eligible for sponsorship, and (if not) whether anyone can be prioritised and be sponsored prior to 22 July 2025, under the current rules?  

If you have any questions on the changes to the Immigration Rules or need any business immigration support, please contact a member of Ashfords’ immigration team.

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