Immigration White Paper 2025: What Employers Need to Know

ILR qualifying period extended from 5 to 10 years.

Graduate Route reduced to 18 months, down from 2 years.

Skilled Worker Visa eligibility restricted to RQF Level 6 and above.

Immigration Salary List abolished, replaced with Temporary Shortage List.

Social care visa sponsorship ended for new overseas applicants.

Increased Immigration Skills Charge (ISC) across all sponsorship tiers.

English language standards raised for main applicants and dependants.

Sponsor compliance tightened with digital monitoring and enforcement tools.

Labour Market Evidence Group (LMEG) created to direct visa policy.

The Skilled Worker Visa long considered a key route for foreign recruitment will face stricter conditions. Employers should note the following:

• The minimum skill threshold is raised to RQF Level 6, limiting eligibility to graduate-level occupations

• Roles previously on the Immigration Salary List will lose preferential treatment, with no more salary discounts or exemptions

• A new Temporary Shortage List will be introduced for roles below RQF Level 6, but only after rigorous justification and LMEG approval

• Employers must prepare for reduced flexibility in hiring for non-degree roles and anticipate more scrutiny in Certificate of Sponsorship (CoS) applications

Sectors like logistics, warehouse management, cleaning, hospitality, and basic construction roles may face immediate impacts. Employers in these industries should evaluate whether upskilling or automation could help close future labour gaps.

The Shortage Occupation List UK will be phased out. In its place, the Temporary Shortage List (TSL) will serve as a dynamic and evidence-driven register of occupations eligible for immigration flexibility. Key features include:

• Eligibility reviews conducted by the Migration Advisory Committee (MAC) and informed by LMEG data

• The requirement for sectors to have clear domestic workforce plans before international roles are added to the list

• Rolling updates to reflect labour market shifts and avoid long-term dependency on foreign labour

Employers are encouraged to work with sector councils and trade associations to provide accurate workforce data to MAC and LMEG.

A major blow to the care sector, the immigration white paper states that the Health and Care Worker visa will no longer apply to new overseas recruits for frontline care roles:

• This policy is immediate for new applicants post-implementation

• Transitional arrangements are in place until 2028 for those already on this route

• Care workers currently in the UK may still extend their visa or switch categories if eligible

The government believes this will force providers to invest in local workforce development. Employers in social care should explore partnerships with training colleges and review long-term recruitment models.

Salary Thresholds

The immigration white paper confirms that salary thresholds for all sponsored visas will increase, although exact figures are still pending. The goal is to align salaries with local market expectations and reduce exploitation. Employers will be expected to offer competitive wages that reflect the real cost of living and job value.

Immigration Skills Charge (ISC)

The Immigration Skills Charge (ISC), which must be paid by sponsoring employers, will rise by approximately 32% from the 2025–26 financial year. The government intends to reinvest this additional revenue into training and upskilling the UK’s domestic workforce in key priority sectors.

At present, small businesses and charities pay £364 per year, while medium and large sponsors pay £1,000 per year. These will increase to around £480 and £1,320 per year, respectively. For multi-year visa sponsorships, this adds a significant cost burden over time.

When considered alongside the proposed extension of the Skilled Worker route from five to ten years before eligibility for ILR, this reform represents a substantial financial commitment for employers, especially in high-volume sectors like healthcare, social care, and hospitality.

One of the most discussed reforms, the Graduate visa UK route will now allow only 18 months of unsponsored work, compared to the previous 2 years:

• The change is designed to prevent long-term stay without integration or sponsorship

• Universities and student groups have warned this may reduce the UK’s appeal to international students

• Employers who rely on graduate recruitment pipelines will need to act faster to sponsor suitable talent

It may also drive more students to pursue immediate sponsorship via the Skilled Worker route instead of relying on unsponsored work.

Family and private life routes will be restructured under a new, unified framework. Key elements include:

• Tighter eligibility criteria to ensure only genuine, lasting relationships are recognised
• Expanded English language and financial requirements for dependants
• Clarified rules for sponsors on work, student, protection, and other visas
• Specific exemptions for Armed Forces families, aligned with the Armed Forces Covenant

Applications for a dependent visa UK or family visa UK will be subject to more documentation and checks, especially around relationship legitimacy.

The UK is shifting toward a points-based model for both ILR and British citizenship:

• 10-year residency becomes the baseline requirement for most

• Applicants may earn accelerated settlement through a combination of:

  • Documented tax contributions

  • Service in public sector roles like the NHS or police

  • Demonstrated community engagement and civic participation

This approach aims to reward economic and social contribution, replacing the current blanket rule of ILR after 5 years.

Integration is a key theme throughout the immigration white paper. The government plans to:

• Raise the minimum standards of English for more visa routes
• Require both main applicants and dependants to prove language ability
• Introduce systems for tracking language progress over time

Employers hiring internationally should start building language capability screening into recruitment processes.

To address abuse and non-compliance, the immigration white paper introduces a digital-first enforcement regime:

• Sponsors with weak governance will be placed under mandatory improvement plans

• The Home Office will apply caps on CoS issuance during compliance reviews

• All visa holders will be subject to digital ID tracking to monitor location and employment

• Breaches will lead to financial sanctions, sponsor licence downgrades, or removal

Employers should conduct a full review of their sponsorship systems and reporting processes.

1. Conduct an audit of current visa holders and forecast renewal timelines
2. Engage trade bodies and provide data to influence MAC/LMEG assessments
3. Update job role criteria to meet RQF Level 6 and salary expectations
4. Budget for ISC increases and potential compliance costs
5. Improve onboarding with English language screening and documentation workflows
6. Train HR teams on upcoming reforms and new compliance obligations

• The 2025 Immigration White Paper represents a major pivot toward a more controlled and contributions-based immigration framework. While it restricts low-skilled entry, it also opens the door wider for international professionals in STEM, finance, healthcare, and innovation.

  For employers, early preparation will be essential. Those who act now by aligning HR processes, auditing visa systems, and adapting hiring strategies can ensure compliance while still benefiting from global talent flows.

X Law is here to help you understand how each reform affects your business, evaluate visa strategies, manage compliance risks, and streamline your sponsorship processes with confidence. Contact us Today!