Legal development

Immigration rule changes announced

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    What you need to know

    • The Home Office are reducing the number of roles which are eligible for sponsorship in the UK and have also increased the salary thresholds. These changes will take effect from 22 July 2025.

    What you need to do

    • Review any current recruitment processes to ensure that they will meet the new thresholds.
    • Where possible bring forward any sponsorship where the change in rules will otherwise prevent the application proceeding.

    Following the Government's Immigration White Paper, published in May, more details have been provided in the latest Statement of Changes laid before Parliament on 1 July. This briefing outlines the principal immigration changes that will take effect on 22 July 2025. The reforms chiefly affect the Skilled Worker route through substantial increases to the skills and salary thresholds.

    What is changing?

    The skill level for new Skilled Worker certificates of sponsorship (CoS) will revert to Regulated Qualifications Framework (RQF) Level 6 (degree-level), effectively reversing the 2020 concession that allowed lower skilled (RQF 3-5) roles to be eligible for sponsorship.

    Over 100 roles that previously qualified (e.g., many administrative, technician and associate professional positions) will be removed from the main eligibility tables unless:

    (i) the migrant is already in the Skilled Worker route (or holds a pending application filed before 22 July 2025); or

    (ii) the role appears on one of two interim shortage lists (see below).

    For now, existing Skilled Workers may extend, change employer or take supplementary employment in RQF 3-5 roles, but the Home Office has stated that these transitional concessions “will not be in place indefinitely.”

    In addition, the Home Office has completed the delayed 2024 Annual Survey of Hours and Earnings (ASHE) uplift across every sponsored route and implemented increases for both the Skilled Worker and the Global Mobility routes.

    For Skilled Workers the new general threshold will increase from £38,700 to £41,700 (noting there are lower rates available still for new entrants and PhD applicants).

    The Global Mobility – Senior or Specialist Worker/Expansion worker routes will also increase, from £48,500 to £52,500.

    In addition, all individual occupation “going-rate” figures have risen in line with ASHE data.

    Importantly no transitional protection applies to the salary increases. Any extension, change of employment or new hire relying on a CoS issued on or after 22 July 2025 must meet the higher figure in force on the date the CoS is assigned.

    What are the Interim arrangements for lower skilled (RQF 3-5) roles?

    Until 31 December 2026, RQF 3-5 occupations can still be sponsored if listed on either:

    (i) an expanded Immigration Salary List (ISL) – incorporating roles identified by the MAC as in shortage; or

    (ii) a new Temporary Shortage List (TSL) – covering roles prioritised under the Government’s Modern Industrial Strategy.

    The ISL will eventually be phased out and an updated TSL issued. Importantly the Government has reserved the right to remove roles earlier than the 31 December 2026 longstop date.

    A key restriction to be aware of is that workers sponsored in RQF 3-5 ISL/TSL occupations may not bring dependants with them to the UK (subject to limited exceptions).

    What should our business do?

    In order to ensure that you are prepared for the impact of these changes, consider:

    • mapping all current and forecast sponsored roles against the new Appendix Skilled Occupations tables (now separated into Tables 1-3 for RQF 6+ and Tables 1a, 2aa, 3a for shortage-concession roles at RQF 3-5). Will they meet the requirements still;
    • accelerate any CoS allocations for affected positions by 22 July 2025 to secure protection;
    • identify any individuals currently employed whose salary will need to be increased to meet the new thresholds when they renew their current leave;
    • alternative recruitment strategies for roles losing sponsorship eligibility from 23 July 2025 onward.

    From 22 July 2025 the UK sponsorship regime becomes markedly more selective, only degree-level roles will qualify as Skilled Work unless granted a time-limited shortage concession, and all sponsored routes face higher pay floors. Organisations must react swiftly to secure grandfathering where possible, to avoid imminent salary hikes and to preserve critical talent pipelines.

    Want to know more?

    The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to.
    Readers should take legal advice before applying it to specific issues or transactions.