Restrictions, Digitisation, and Wage Levels: Proposed Changes to the UK Immigration System Begin

The UK Government has announced a series of changes to the UK immigration system, both from a legal and process standpoint. These updates mark the start of the implementation of the proposals set out in the UK Government's immigration White Paper, as well as the continuation of its digitisation of the system and streamlining of the application process. The changes, which are coming into effect in July 2025, include:

1. Raising the minimum skill level for the Skilled Worker category from Regulated Qualifications Framework ("RQF") level 3 to RQF level 6.
2. Raising the minimum salary levels for the Skilled Worker and Senior or Specialist Worker categories to £41,700 and £52,500 respectively.
3. A temporary expansion of the Immigration Salary List and the introduction of the Temporary Shortage List.
4. No longer issuing entry clearance vignettes (also known as visa labels) for work and study immigration routes.
5. In the United States, Application Support Centres ("ASCs") being replaced by UK Visa Application Centres ("VACs") and, in New Zealand, new VACs replacing the current centres.

The first three of these changes are being implemented on 22 July, the fourth came into effect on 15 July, and the transition from ASCs and VACs in the United States came into effect on 15 July with the transition to VACs in New Zealand taking place on 16 July.

Further details of these changes are set out below.

Raising the minimum skill level for the Skilled Worker category

From 22 July 2025, UK employers will only be able to sponsor individuals under the Skilled Worker route to undertake roles at RQF level 6 (UK Bachelor's degree level) or above. Currently, UK employers may sponsor individuals to undertake roles at RQF level 3 (UK A level) or above.

Those who are already in the United Kingdom under the Skilled Worker category undertaking roles at RQF level 3 to 5 will be able to renew their immigration permission, change employment, take supplementary employment and apply for indefinite leave to remain ("ILR")—also known as permanent residence or settlement—on the basis of the occupations that meet the current RQF level 3 and above criteria. However, it is important to note that the UK Government has stated that these arrangements will not remain in place indefinitely.

Raising the minimum salary level for the Skilled Worker to Senior or Specialist Worker category

The minimum salary level for the Skilled Worker category is being raised from £38,700 to £41,700 and for the Senior or Specialist Worker category from £48,500 and £52,500. This will again come into effect from 22 July 2025.

The UK Government has confirmed that these changes are routine updates to the salary requirements for these routes to ensure they remain in line with the latest (2024) Annual Survey of Hours and Earnings (ASHE) data, published by the Office for National Statistics, rather than a substantive increase to the minimum salary requirements for the Points Based System.

This distinction is important as it means that, while those who hold Skilled Worker immigration permission under the pre-4 April 2024 transitional arrangements will continue to benefit from a lower minimum salary threshold for the Skilled Worker category of £31,000, anyone else who is already in the United Kingdom under the Skilled Worker category undertaking roles at RQF level 3 to 5 will need to meet the new £41,700 minimum salary threshold if they apply to extend their stay in the United Kingdom.

The salary rates for individual occupations are also being updated in line with the latest ASHE data.

Temporary expansion of the Immigration Salary list and introduction of the Temporary Shortage List

The Immigration Salary List currently contains occupations eligible for sponsorship under the Skilled Worker category which require skills which have been identified as requiring skills which are in short supply in the local labour market and which it has therefore been deemed to appropriate to offer a discounted salary. The UK Government plans to replace this with a Temporary Shortage List which will contain RQF level 3-5 occupations which will still be capable of sponsorship under the Skilled Worker route.

While this Temporary Shortage list is being finalised, from 22 July 2025, the UK Government is introducing an expanded Immigration Salary List, containing the existing entries plus occupations at RQF levels 3-5 which have previously been identified as requiring skills which are in short supply in the UK labour market. An interim Temporary Shortage List is also being introduced containing occupations at RQF levels 3-5 which are seen as key to the UK Government's industrial strategy.

The intent is for the Immigration Salary List eventually to be phased out, and for any occupations appearing on the Temporary Shortage List—which will have conditions attached to them—to be removed after a certain period. Currently the removal date for occupations on both lists is set at the end of 2026, although the UK Government has said it may bring this forward if it identifies any immigration compliance issues with any of the occupations on these lists. Future occupations, which will also have conditions attached to them, will only be included on the Temporary Shortage List where it is deemed to be justified, where there is a workforce strategy in place, and where employers seeking to recruit from abroad are committed to playing their part in increasing recruitment from the domestic workforce.

Importantly, individuals sponsored in occupations on either list at RQF levels 3-5 after the changes come into effect will not be permitted to bring family members with them to the UK as their dependants.

No longer issuing entry clearance vignettes for work and study immigration routes

Normally, when an individual applies for UK immigration permission from overseas and their application is approved, their passport will be endorsed with an entry clearance vignette (or visa label) valid for 90 days or, if they are applying for immigration permission for less than six months, the duration of their immigration permission. The individual must then travel to the UK during the validity of the vignette.

From 15 July 2025, those applying for immigration permission under the work or study categories may not receive a vignette in their passport and will only be issued with digital immigration permission, also known as an eVisa. It is important to note that any family members applying for immigration permission as dependants will continue to receive a vignette.

Introduction of new VACs in the United States and New Zealand

In the United States, ASCs, which are operated by the US Department of Homeland Security, are being replaced by 38 new UK VACs operated by VFS Global. Under this new model, applicants will be required to book an appointment at their nearest VAC, attend in person at the scheduled date and time, and complete biometric enrolment and passport submission during the same visit. There will no longer be a requirement to courier passports to New York with a return shipping label.

Effective 16 July 2025, three new VACs are being introduced across New Zealand, replacing the centres operated by Immigration New Zealand and a Premium Application Centre in Auckland. Customers will book an appointment at their nearest VAC, attend in person at the scheduled date and time to complete biometric enrolment, and submit their passport during the same visit.

What this means for employers

The changes to the skill level for the Skilled Worker category and the salary levels for both the Skilled Worker and Senior or Specialist Worker routes will inevitably make it more challenging and more expensive for UK employers to sponsor migrant workers. UK employers will need to consider the positions for which they sponsor workers under the Skilled Worker category and, if any of them are at RQF level 3-5:

• For those who are already sponsored, employers must ensure that their salaries meet the revised minimum requirements when it comes to their extensions and consider advising them to apply for ILR, if that is their goal, at the earliest opportunity;
• If they wish to sponsor any workers in the future to fill these occupations, employers will need to check if those occupations feature on the Immigration Salary List or the Temporary Shortage List and be aware of any conditions attached to sponsoring individuals in those occupations. They may also wish to review the positions to see whether any of them can correctly be re-classified as RQF level 6 positions.

UK employers should also be aware of the changes to the UK immigration process. Where an individual is submitting their UK immigration application in the United States, the number of locations where they will be able to enrol their biometrics has been significantly reduced from over 130 ASCs to 38 VACs, which may increase the travel time and reduce appointment availability for applicants looking to attend a biometric appointment. In New Zealand, the number and locations of the VACs have effectively remained the same.

The removal of entry clearance vignettes for work and study immigration categories will make it even more important that, once an individual's application has been approved, they immediately register for a UK Visas and Immigration account, in order to verify that their eVisa has been correctly issued and is linked to their current passport before they travel to the United Kingdom.