United Kingdom: Mobility – 2025 Highlights and 2026 Outlook

The last year has seen the UK Government propose, and begin to implement, sweeping changes to the UK immigration system. These proposals were initially set out in the UK Government’s immigration white paper, Restoring Control over the Immigration System, with the first set of changes coming into effect in July. This article looks at the main changes which came into effect in 2025 and the changes confirmed and proposed for 2026, which businesses will need to take into consideration when looking to employ overseas nationals in the United Kingdom.

2025: Highlights

1. The minimum skill level for the Skilled Worker route, which enables UK employers to sponsor overseas nationals to undertake permanent vacancies in the United Kingdom, was raised from Regulated Qualifications Framework (“RQF”) level 3 (UK A level) to RQF level 6 (UK Bachelor’s degree level) or above.

Those who are already in the UK under the Skilled Worker category undertaking roles at RQF levels 3 to 5 may continue 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, the UK Government has stated that these arrangements will not remain in place indefinitely.

2. The minimum salary level for the Skilled Worker category was raised from £38,700 to £41,700, and for the Senior or Specialist Worker category from £48,500 and £52,500. The changes were made to take into account increases in average salary levels since the minimum salary levels were last reviewed.

Those who currently hold Skilled Worker immigration permission under the pre-4 April 2024 transitional arrangements will continue to benefit from a lower minimum salary threshold of £31,000. Everyone else who holds Skilled Worker immigration permission, and who are undertaking roles at RQF levels 3-5, must meet the new £41,700 minimum salary threshold if they apply to extend their stay in the United Kingdom.

The minimum salary rates for individual occupations were also raised in line with the latest wage data.

3. The UK Government has introduced an expanded Immigration Salary List (“ISL”) and an interim Temporary Shortage List (“TSL”), pending the introduction of the full TSL.

The ISL currently lists occupations eligible for sponsorship under the Skilled Worker category, which have been identified as requiring skills which are in short supply in the United Kingdom and should benefit from a lower minimum salary threshold.

While the full TSL is being finalised, the UK Government has introduced an expanded ISL, 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. An interim TSL has also been introduced containing occupations at RQF levels 3-5 which are seen as key to the UK Government’s industrial strategy.

The intention is for the ISL to be phased out, and for any occupations appearing on the interim TSL—which have conditions attached to them—to be removed by 31 December 2026, by which time the full TSL should be in place.

Importantly, individuals sponsored in occupations on either list are not permitted to bring family members with them to the United Kingdom as their dependants.

4. The number of institutions which qualify for the High Potential Individual (“HPI”) category, which is the route that enables those who have graduated with a Bachelor’s degree or above from certain overseas institutions to work or look for work in the United Kingdom, was doubled from around 50 to 100. An annual cap of 8,000 visas was also introduced which will run from 1 November to 31 October each year.

5. The Immigration Skills Charge (“ISC”), which employers are required to pay when sponsoring overseas nationals, was increased by 32%. For large businesses, the ISC was increased from £1,000 to £1,320 per year; for small businesses, it was increased from £364 to £480 per year.

6. One change which was to occur in 2025, but has been shelved, was the introduction of a new online portal to enable sponsor licence holders to manage their licences and issue Certificates of Sponsorship (essentially electronic work permits) to overseas nationals they wish to sponsor to work in the United Kingdom. Instead, the UK Government decided to restart its programme of enhancing the current Sponsorship Management System, which had been on hold.

2026: Outlook

1. From 8 January 2026, the English language requirement for the Skilled Worker, HPI and Scale-up routes will be increased from B1 Level to B2 Level (as defined under the Common European Framework for Reference for Languages) for those applying for their first grant of UK immigration permission under these routes.

Those who have already obtained immigration permission, which requires English language ability at B1 level, will continue to be subject to a B1 level requirement when applying to extend under the same route.

2. The UK Government is looking to increase the qualifying period for ILR for Points Based System migrants and their dependants.

Currently, individuals who are in the United Kingdom under certain Points Based System routes, including the Skilled Worker category, qualify for ILR after they have spent a continuous period of five years in the United Kingdom under that route. Their dependant family members, which normally include their partner and any minor children, would also qualify for ILR once they had spent five years in the United Kingdom with dependant immigration permission.

The UK Government is looking to increase the standard qualifying period for ILR for these individuals to 10 years.

However, the UK Government has also stated that migrants who can demonstrate that they are making a contribution to the UK economy and society will be able to qualify for a shorter route to settlement. It has indicated that factors that are likely to be considered will include the migrant being employed, making National Insurance contributions, and contributing to the local community, such as through volunteering.

Successful applicants would also need to demonstrate a higher level of English language ability than is currently required.

The UK Government has launched a consultation on the proposals, which is due to close on 2 December 2025, with changes likely to come into force during 2026.

3. Looking even further ahead, from 1 January 2027, immigration permission under the Graduate route, which enables graduates from UK institutions with a Bachelor’s degree or above to work or look for work, will only be issued for 18 months. Currently, immigration permission under the Graduate route is issued for two years.

The changes to the skill level for the Skilled Worker category, the salary levels for both the Skilled Worker and Senior or Specialist Worker routes, and the increase to the ISC have inevitably made it more challenging and more expensive for UK employers to sponsor migrant workers.

It has also meant that UK businesses now have to undertake more active work force planning. If they do wish to sponsor an individual under an occupation classed as being at RQF level 3-5, employers can now only do so if the individual they wish to sponsor already holds Skilled Worker immigration permission or if the occupation features on the ISL or the interim TSL. Even if the occupation does appear on one of those lists, the employer needs to check that they, and the migrant, can comply with any conditions attached to sponsoring an individual in that occupation.

Although the number of qualifying institutions has doubled under the HPI category, the annual cap means that this category may be of limited use to employers.

Looking ahead, it will be important for employers to ensure that those they wish to sponsor are able to meet the higher English language threshold.

However, the potential change which has garnered the most headlines has been the proposed increase to the qualifying period for ILR. The UK Government has yet to confirm whether the changes will apply to those who are already in the United Kingdom under the affected routes, or only to those entering the United Kingdom after implementation. There are also real concerns that these new rules will lead to a reduction in the number of highly skilled individuals coming to the United Kingdom due to the longer qualifying period for ILR, and the increased cost which will inevitably flow from both migrants and employers having to pay additional Government fees to cover the increased sponsorship period.