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At a Glance
- The High Potential Individual route is being expanded to include graduates from the top 100 international universities with a cap of 8,000 applications per year. This is expected to double the number of people using this route from 2,000 to 4,000 with the aim of encouraging promising graduates to base their careers in the UK.
- Part 9 of the Immigration Rules, which set out grounds for refusal across immigration routes, is being replaced by a new “Part Suitability”, effective from 11 November 2025. This accords with terminology used in simplified immigration routes whereby applicants are assessed against “suitability requirements”, not “grounds for refusal”.
- Further legislative changes are expected later in 2025, and the government’s direction is clear: a more restrictive, compliance-driven immigration system focused on domestic skills and integration.
On 14 October 2025, the UK government published a Statement of Changes in Immigration Rules, introducing various reforms in the wake of its Restoring Control over the Immigration System white paper published on 12 May 2025. These changes mark the first of many the government intends to make to reduce net migration and reshape the immigration system around domestic skills and integration.
Summary of the Full Changes
- Introduction of a visit visa requirement for nationals of Botswana
- Recognition of Palestine: Changes to the visa national list
- German school groups travel: Easing travel requirements for German school groups visiting the United Kingdom
- Change to the validity requirements in “Appendix Temporary Permission to Stay for Victims of Human Trafficking or Slavery”
- Introduction of dependants for stateless people (amendments to “Appendix Statelessness”)
- Changes to English language requirements for economic migration routes
- High Potential Individual visa — targeted and capped expansion of eligibility
- Change to reduce the duration of stay under the Graduate route to 18 months
- Change to allow students to transition to the Innovator Founder route
- Change to replace “Part 9: Grounds for Refusal”, with “Part Suitability”
- Change to align the Family and the Private Life rules with the common suitability rules for refusal (amendments to “Appendix FM: family members”, “Appendix Private Life”, “Appendix Adult Dependant Relative” and “Appendix Settlement Family Life”)
- Changes to “Appendix Temporary Work — Seasonal Worker” concerning the number of months a seasonal worker must be outside the UK before being permitted to apply for a new seasonal work visa
- Changes to the Ukraine Permission Extension scheme to maintain safeguarding measures
The rest of this article looks at the key changes in more detail.
Visa Requirement for Botswana Nationals — 14 October 2025
Nationals of Botswana now need to apply for and obtain a visa prior to visiting the UK, and Botswana has been removed from the list of countries eligible for an Electronic Travel Authorisation (ETA). Additionally, nationals of Botswana will be required to obtain a Direct Airside Transit Visa if they plan to transit through the UK while traveling to another country.
The idea behind this change is to ensure that those travelling to the UK are assessed against the Immigration Rules in advance of their arrival, reducing the number of asylum claims made at the port which increase operational pressures and divert staff.
Nationals of Botswana with confirmed UK travel bookings made before the visa rule takes effect may travel without a visa during a six-week transition period ending at 15:00 GMT on 25 November 2025, provided they hold an ETA.
Recognition of Palestine — 14 October 2025
Following the UK’s recognition of Palestine as a state, Palestine has been added to the visa national list, to ensure that Palestinian nationals must obtain a visa to visit the UK or to conduct airside transit travel.
Previously, Palestinian nationals could obtain visas either as citizens of the Occupied Palestinian Territories or as stateless individuals. This is therefore not a new requirement but rather an update to align the Immigration Rules with the UK government’s formal recognition of the State of Palestine.
Raising English Language Requirements — 11 November 2025
As promised in the white paper and as part of the government’s aim to promote integration, the English language requirement for the Skilled Worker, High Potential Individual and Scale-Up routes is being increased from B1 Level proficiency to B2 Level proficiency under the Common European Framework of Reference for Languages (CERF). From 8 January 2026, this will apply to those seeking an initial grant of leave in a relevant route. For those with existing permission which required a B1 Level, further extensions will continue to be subject to B1 Level.
In the white paper, the government also proposed introducing a language requirement for adult dependents of economic migrants, students and those seeking entry on family routes. However, this was not introduced in this round of changes to the Immigration Rules.
This change may limit the number of global institutions and qualifications that may meet the language requirement through Ecctis verification of the English proficiency and qualification comparison of overseas qualifications. This change is likely to encourage more visa applicants to sit language tests, instead of applying for an Ecctis certificate.
Duration of Stay under the Graduate Route Reduced — 1 January 2027
The duration of stay for Graduate visa holders — those completing a bachelor’s degree, master’s degree or other relevant qualification — post-study is being reduced from two years to 18 months. The government has introduced this change to address the number of graduates who remain beyond the completion of their studies, but do not progress into graduate-level roles and “properly contribute” to the economy. However, this does not affect the period of three years for those completing a PhD.
Expansion of the High Potential Individual (HPI) Route — 4 November 2025
The HPI route is being expanded to include graduates from the top 100 international universities with a cap of 8,000 applications per year. This is expected to double the number of people using this route from 2,000 to 4,000 with the aim of encouraging promising graduates to base their careers in the UK.
Previously, the route was only open to graduates from the top 50 international universities.
Student Visa Holders Converting to the Innovator Founder Route — 11 November 2025
Student visa holders are able to transition to the Innovator Founder route and establish a business after concluding their studies, to encourage innovative business ventures.
“Part 9: Grounds for Refusal” Replaced by “Part Suitability” — 11 November 2025
Part 9 of the Immigration Rules, which set out grounds for refusal across immigration routes, is being replaced by a new “Part Suitability”, effective from 11 November 2025. This forms part of a simplification initiative recommended by the Law Commission in January 2019, and accords with terminology used in simplified immigration routes whereby applicants are assessed against “suitability requirements”, not “grounds for refusal”.
Family and Private Life Routes — 11 November 2025
Applications under Family and Private Life routes will be subject to Part Suitability.
Previously, applicants under the Family and Private Life routes were subject to a separate set of suitability requirements, which were relatively less strict than those in Part 9 of the Immigration Rules. However, common suitability provisions will now apply to applications under these routes, ensuring a higher standard of requirements and greater consistency in the decisions across the different immigration categories.
Seasonal Worker Adjustments — 11 November 2025
Seasonal workers can no longer spend more than six months in the UK during any 10-month rolling period, a decrease from the 12-month rolling period. Workers will be permitted to apply for a new seasonal work visa, spending no more than six months in the UK during any 10-month rolling period.
Travel Measures for German School Groups — 14 October 2025
This change allows people aged 19 years and under studying at a German school or institution to visit the UK without a visa or ETA when travelling as part of a school party of five or more. EU, EEA and Swiss nationals who meet the same criteria can travel on a national identity card rather than a passport.
Immigration Skills Charge
The UK Immigration Skills Charge is set to increase by 32% from 16 December 2025. Currently, small or charitable sponsors pay £364 per year, while medium or large sponsors pay £1,000 per year. After the increase, small or charitable sponsors will pay £480 per year, and medium or large sponsors will pay £1,320 per year.
Looking Ahead
Further legislative changes are expected later in 2025, and the government’s direction is clear: a more restrictive, compliance-driven immigration system focused on domestic skills and integration.
Stakeholders will also need to await the introduction of the rules concerning the extension of the qualifying period for settlement, introduction of the requirements for “earned” settlement and citizenship, and clarification of whether this will apply retrospectively. These landmark changes are expected in either Q4 of 2025 or Q1 of 2026.
For More Information
For further information, you may contact the authors.
