UK Immigration: 2025 Summary

At a Glance

• The minimum skill level for the Skilled Worker visa route was raised from Regulated Qualifications Framework (RQF) Level 3 (A-level equivalent) to RQF Level 6 (graduate level).
• The UK’s Electronic Travel Authorisation scheme reached full implementation in 2025.
• The EU Entry/Exit System was introduced in 2025, requiring biometric checks for UK (and other non-EU) travellers entering the Schengen area.
• The Home Office has significantly intensified enforcement in 2025. This is a reminder that sponsor licence compliance is an ongoing compliance commitment, failure of which could result in serious consequences.
• With further regulatory reform and continued compliance action from the Home Office anticipated into 2026, sponsors must ensure their internal processes and record-keeping systems remain robust and compliant.

The year 2025 has been one of significant reform for the UK immigration system. Changes affect employers, sponsored workers, students and visitors, reflecting the government’s broader strategy of reducing net migration, and promoting integration and greater economic contribution.

This end-of-year review summarises the key developments affecting organisations and individuals.

We also look at the reporting, timekeeping and compliance duties imposed by the Home Office on organisations holding a sponsor licence, as a reminder of how sponsors can maintain compliance with their obligations and avoid the consequences of breach.

Key Changes in 2025

Work Sponsored Routes

• The minimum skill level for the Skilled Worker visa route was raised from Regulated Qualifications Framework (RQF) Level 3 (A-level equivalent) to RQF Level 6 (graduate level). This change removed approximately 180 occupations from eligibility, including roles in health and social care, hospitality, logistics, and construction, and broadly brings us back to a pre-Brexit skill level (when the skill levels were reduced to accommodate EU nationals who had not previously had to apply for UK work visas).
  • Transitional arrangements were implemented to allow those who had pending visa applications or were already in the route prior to that date to extend their leave or change employers even if their role no longer met the updated skill threshold.
• The Temporary Shortage List came into effect, allowing sponsors to hire individuals in RQF Level 3–5 roles and the government to address labour shortages through the immigration system.
• Restrictions were introduced for lower-skilled roles. Skilled Workers sponsored in RQF Level 3–5 occupations listed on the Immigration Salary List or Temporary Shortage List will be subject to restricted rights to bring dependant family members to the UK.
• General salary thresholds and “going rates” were updated based on the latest Annual Survey of Hours and Earnings data. For example, at the time of writing, the minimum salary threshold is now £41,700 for Skilled Worker visas and £52,500 for Senior or Specialist Worker routes.
• The government announced the Health and Care Worker visa route was closed to new overseas applicants, although extension of existing permissions under this route will continue to be possible until July 2028, subject to conditions.
• The Immigration Skills Charge increased by 32%, significantly raising sponsorship costs for employers, from £1,000 to £1,320 per year for large companies and from £364 to £480 per year for small companies.

Electronic Travel Authorisation

• The UK’s Electronic Travel Authorisation (ETA) scheme reached full implementation in 2025.
• ETA became mandatory for all non-visa nationals travelling to the UK for short-term visits, subject to certain exemptions. Following a period of flexible implementation of the requirement, the government later announced all non-visa national visitors will be legally required to have an ETA to travel to the UK from 25 February 2026.
• Individuals who are refused an ETA should apply for a Standard Visitor visa, which allows them to provide additional context and supporting evidence. If approved, they will be permitted to travel to the UK using the new visa instead of the ETA.
• An ETA refusal is not a travel ban, but applicants should plan accordingly.

Indefinite Leave to Remain (Settlement)

• The government established in its white paper and consultation “A Fairer Pathway to Settlement” that settlement and citizenship should be “earned privileges”, and applicants will need to demonstrate contributions to the UK economy and society.
• It has proposed a new framework increasing the qualifying period for Indefinite Leave to Remain from five years to 10 years for most work-based routes, subject to specific criteria which can reduce or increase the period and transitional arrangements for some applicants.
• The consultation period will end in February 2026, and the new rules are due to be implemented from April 2026.

Raised English Language Requirements

• The government announced the increase of the requisite English language level from B1 Level to B2 Level on the Common European Framework of Reference for Languages (CEFR) scale for applications under the Skilled Worker, High Potential Individual and Scale-up Routes. This change is effective from 8 January 2026.

Gibraltar

• From April 2025, residents of Gibraltar who previously enjoyed unencumbered travel to the UK are now required to obtain an ETA for short visits. This change aligns Gibraltar with other British Overseas Territories and forms part of the UK’s broader border security strategy.

Ukraine Schemes

• The Ukraine Permission Extension Scheme was launched on 4 February 2025, enabling Ukrainians and eligible family members already in the UK to extend their stay. Updates to the Homes for Ukraine scheme clarified eligibility definitions and ended the variation of permission process for biometric deferral cases.

Fee Changes

• The Home Office implemented increases to immigration and nationality fees, including for the ETA, work-sponsored routes and passport applications. The fees for several Sponsor Licence related processes were increased, including the pre-licence and post-licence priority services.

Youth Mobility Scheme

• Annual quotas for the Youth Mobility Scheme were updated in January 2025. Notable increases include Australia (42,000 places), Japan (6,000 places) and the Republic of Korea (5,000 places). These changes reflect the UK’s commitment to cultural exchange and provide opportunities for short-term employment.

UK–EU Mobility and Schengen Travel

• The EU Entry/Exit System (EES) was introduced in 2025, requiring biometric checks for UK (and other non-EU) travellers entering the Schengen area. Employers should anticipate longer processing times for business travel and advise staff to plan accordingly.
• On 7 November 2025, the European Commission announced stricter rules for Russian nationals to obtain multiple-entry Schengen visas. Most Russian nationals will now generally need to apply for a single-entry visa each time they plan to travel to the Schengen area.

Other Route Changes

• Part 9: “Grounds for Refusal” of the Immigration Rules was replaced by a new “Part Suitability” as part of the government’s simplification initiative, and in line with the suitability requirements, instead of grounds for refusal.
• These new suitability provisions now apply to applications under Family and Private Life Routes to raise standards and create consistency in decision-making.
• The High Potential Individual (HPI) Route was expanded to include graduates from the top 100 international universities, with a cap of 8,000 applications per year.
• Student visa holders are now able to transition to the Innovator Founder Route and establish a business after concluding their studies.
• Duration of stay under the Graduate Route will be reduced from two years to 18 months, for those applying on or after 1 January 2027. This will not impact those completing a PhD, who will continue to be issued visas valid for three years. The government also raised thresholds for sponsoring institutions under the Basic Compliance Assessment (BCA): visa refusal rates must remain below 10%, enrolment rates must reach at least 95%, and completion rates must be at least 90%.
• Seasonal workers can no longer spend more than six months in the UK during any 10-month rolling period, a decrease from the prior 12-month rolling period.
• The Global Talent Route was refined, with updates to evidential requirements and the Prestigious Prizes list. Applicants holding a qualifying prize can now bypass endorsement if specific criteria are met.
• A new pathway for UNHCR-recognised refugees to access sponsored work routes is under consideration, reflecting the government’s commitment to legal migration channels for displaced talent.

Sponsor Licence Compliance in 2025

The Home Office has significantly intensified enforcement in 2025: between July 2024 and June 2025, a record 1,948 sponsor licences were revoked, compared to 937 revoked in the prior year and 247 in the prior year to June 2023. This reflects a clear shift towards strict regulation of compliance obligations. This is a reminder that the obligations of a licence holder do not cease once their employee has been granted UK immigration status, but rather that sponsor licence compliance is an ongoing compliance commitment, failure of which could result in serious consequences.

Ongoing Responsibilities and Commitments

Compliance duties apply for the full duration of the licence. Authorising Officers and Level 1 Users remain accountable for sponsored workers until their permission expires or employment ceases. Failures in monitoring workers, maintaining documentation or reporting changes promptly are now among the most frequent triggers for enforcement action.

Reporting and Recording Duties

Home Office audits in 2025 have centred on timeliness and accuracy of reporting. Changes relating to sponsored workers must typically be reported within 10 days, while organisational changes generally require notification within 20 days.

Record-keeping remains a central area of inspection. Sponsors must maintain complete and accurate records spanning right-to-work checks, immigration expiry monitoring, employment contracts, payslips and recruitment documentation. Incomplete or inconsistent records are increasingly viewed as indicators of wider compliance failings.

Compliance Visits and Sanctions

The Home Office may conduct announced or unannounced compliance visits to verify adherence to these duties, and may review records, interview sponsored employees, and request documentation to confirm information provided in visa applications.

Where breaches are identified, sanctions may include reductions in Certificate of Sponsorship (CoS) allocation, downgrading to a B-rating, suspension of the licence holder’s ability to issue a CoS, suspension or revocation of the licence, and, in serious cases, referral to law enforcement.

Sponsors must also comply with wider UK law, including for example employment laws, and ensure the organisation does not engage in criminal activity or conduct deemed contrary to the public good.

Recent enforcement activity has highlighted several common risk areas:

• Right-to-work check failures
• Record-keeping and reporting omissions
• Unreported changes to key personnel
• Unreported changes of ownership
• Changes to the sponsored role
• Sponsored workers operating at an unlicensed work site
• Non-compliance with salary thresholds, including:
  • deductions reducing salary below permitted levels
  • miscalculation of salary for rota-based roles 
• Unlawful or excessive sponsor clawbacks

The Home Office has also identified the following common grounds for revocation:

• Sponsored workers not performing the role stated on the CoS
• Sponsored workers not being paid the required salary
• Sponsoring individuals for roles that were never genuinely available, leaving them without income or recourse
• Exploitation of sponsored staff, including coercive practices, poor working conditions, and threats of dismissal or “deportation” to deter complaints

The Home Office perceives these issues as evidence of systemic governance failings of the organisation to adhere to the compliance rules, leading to compliance actions such as downgrading the rating of the licence or revoking the licence completely.

Conclusion

With further regulatory reform and continued compliance action from the Home Office anticipated into 2026, sponsors must ensure their internal processes and record-keeping systems remain robust and compliant. One tool to further this aim could include, for example, periodic audits of those processes and systems.