Restoring Control over the Immigration System — UK Government White Paper
White Paper Sets Out a Multiyear Roadmap for Reform
At a Glance
- The combination of higher salary levels, longer qualifying periods for settlement and a 32% increase in the Immigration Skills Charge is expected to more than double the cost of long-term sponsorship for many employers, including adult care providers, start-ups and regional employers. The higher education sector is also likely to feel the financial strain.
- The reforms benefit high-skilled and strategic industries, particularly those aligned with the UK’s industrial strategy (such as AI, advanced manufacturing and life sciences). These sectors will see widened access under the Global Talent and High Potential Individual routes.
- The White Paper sets out a multiyear roadmap for reform. Employers should anticipate further constraints across sponsorship, settlement and compliance, with additional legislative changes to asylum and border controls expected later in 2025.
On 12 May 2025, the UK Government published the Restoring Control over the Immigration System White Paper, a major policy document outlining the Government’s plan to reduce legal migration by increasing employer compliance obligations, introducing stricter rules, and reshaping the immigration system around domestic skills and integration.
The proposals signal a shift away from using immigration to meet workforce demand, particularly in lower-paid sectors, and mark a continuation of efforts to reduce net migration to “sustainable levels”. We summarise the key proposed measures below.
Skilled Worker Route: Reversion to Graduate-Level Occupations and Higher Costs
The minimum skill level for the Skilled Worker visa route will be raised from RQF Level 3 (A-level equivalent) back to RQF Level 6 (graduate level), reversing the 2020 expansion that allowed lower-skilled roles to qualify. This change is expected to reduce the number of eligible occupations by around 180 roles and applies to new applicants both from overseas and those switching from other UK visa routes. Existing Skilled Workers in RQF 3-5 roles will be permitted to extend their visas and change employers under transitional arrangements.
The White Paper suggests that it is “generally quicker and easier to train people to undertake” sub-RQF level 6 occupations. Employers would be expected to use the existing talent pool already in the UK to fill these roles.
Alongside this, salary thresholds for Skilled Workers have already risen in April 2024 to £38,700 (general threshold), a significant increase from the prior level of £25,600.
Additionally, the Immigration Salary List (which allowed for discounted salary rates) will be abolished, and the Migration Advisory Committee (MAC) will conduct a full review of salary requirements.
The combination of higher minimum qualification level, higher salary levels, longer qualifying periods for settlement and a 32% increase in the Immigration Skills Charge is expected to more than double the cost of long-term sponsorship for many employers.
Introduction of a Temporary Shortage List for Sub-RQF 6 Occupations
A new Temporary Shortage List will provide time-limited access to the immigration system for sub-RQF 6 roles — but only where the MAC has endorsed inclusion and the sector has an approved workforce plan. Conditions may include visa caps and bans on accompanying dependent family members. Employers must demonstrate active engagement in training and recruiting UK workers.
The new Temporary Shortage List will replace the current Immigration Salary List, which currently allows employers to sponsor migrant workers with a salary 20% less than the standard rate for the occupation code. The new list will not have this reduced salary provision.
The Government’s objective is to reduce reliance on these roles over time, with future immigration access tied directly to domestic reform and labour market needs.
Longer Wait for Settlement
Currently, eligible visa holders can apply for Indefinite Leave to Remain once they have completed five years of continuous residence in the UK. The White Paper proposes extending the qualifying period from five years to 10 years.
The five-year qualifying period will continue to apply to non-UK dependents of British citizens.
Under the proposed rules, individuals will have the opportunity to access a shorter pathway to settlement based on Points-Based contributions to the UK economy and society, but there are no further details about how this will work in practice.
Family Migration: Alignment With Skilled Worker Thresholds
The Minimum Income Requirement (MIR) for sponsoring a partner increased from £29,000 in 2024, with further staged increases planned to align it with the Skilled Worker salary threshold. This creates significant new barriers for lower-paid migrants wishing to reunite with family in the UK. These changes reflect a broader strategy of aligning family migration with work-based criteria, increasing selectivity and reducing long-term settlement through family routes.
To increase selectivity, the Government proposes introducing an English language proficiency requirement for adult dependents, to strengthen the public interest test to find the balance between the rights of the individual and public interest, and to clarify the rules regarding “exceptional circumstances”.
English Language and Integration
The White Paper places greater emphasis on integration, with increased English language requirements introduced at multiple stages. Skilled Worker visa applicants must now meet B2 level proficiency (up from B1), while dependents of workers and students must meet A1 level initially and progress to A2 level for visa renewal and B2 level for settlement.
Language and contribution will also become key requirements under proposed reforms to settlement and citizenship pathways, replacing automatic transitions with an “earned” model.
Student and Graduate Routes: Increased Restrictions and Financial Pressures
International students will face tighter rules on dependents, switching into work routes, and compliance thresholds for sponsoring institutions. The Graduate route is currently under review by the MAC, with the Government indicating support for a shortened post-study period and stricter employer engagement. Currently, Graduate visa holders can remain in the UK for up to two years (or three years if they earned a PhD); however, the proposed rules aim to shorten this to an 18-month period.
In addition, a new student sponsor income levy may be introduced, adding financial pressure on UK universities already facing reduced international enrolment.
Sponsoring institutions are currently subject to the Basic Compliance Assessment (BCA), which requires the institutions to maintain compliance by meeting the three following thresholds: (1) a visa refusal rate of less than 10%, (2) a course enrolment rate of at least 90% and (3) a course completion rate of at least 85%. Failure to meet any one of these thresholds can cause the sponsorship licence to be revoked or suspended for up to two years. The White Paper proposes increasing the enrolment and completion rates by 5% respectively. The new rules will also require sponsoring institutions to consider the local impacts of international recruitment.
Lastly, the Government has observed an increase in the instances of individuals making an asylum claim before their Student visa expires. The Government is seeking to introduce measures to prevent abuse of the system.
Refugee Employment Reform
A limited number of United Nations High Commissioner for Refugees (UNHCR)–recognised refugees living overseas may soon be eligible to apply under existing sponsored work routes, mirroring the Displaced Talent mobility model. This would open legal pathways to employment for displaced persons with in-demand skills.
Compliance and Sponsorship Reforms
The White Paper outlines a tougher compliance framework. Sponsors will be held accountable for domestic workforce engagement and may face restrictions if they fail to meet training and recruitment obligations. The Immigration Skills Charge — now increased to reflect inflation — will be reinvested into UK skills development.
The proposed Labour Market Evidence Group — involving the MAC, Skills England and the Department for Work and Pensions (DWP) — will monitor sectoral needs and influence which occupations retain visa eligibility.
Closure of Overseas Recruitment for Care Workers
The Adult Social Care visa route will close to new overseas applicants. Following evidence of widespread worker exploitation, the Home Office will instead focus on improving pay and conditions via the new Fair Pay Agreements. A transitional period will run until 2028, allowing in-country extensions and switches.
This marks a major reversal in access to international recruitment for a sector that has come to rely on overseas labour to fill vacancies.
Labour Market Evidence Group (LME Group)
The Government wishes to introduce the Labour Market Evidence Group (LME Group), which will cooperate with the Industrial Strategy Advisory Council, Department for Work and Pensions, Skills England and equivalents in the Devolved Governments, and the Migration Advisory Committee (MAC) to gather and share evidence about the state of the workforce, training levels, and participation by the domestic labour market, including at Devolved Government and regional levels.
Winners and Losers
The reforms benefit high-skilled and strategic industries, particularly those aligned with the UK’s industrial strategy (such as AI, advanced manufacturing and life sciences). These sectors will see widened access under the Global Talent and High Potential Individual routes.
Conversely, care providers, start-ups, regional employers and family migrants face steeper costs, reduced eligibility and greater administrative hurdles. The higher education sector — facing reduced student numbers and new levies — is also likely to feel the financial strain.
Looking Ahead
The White Paper sets out a multiyear roadmap for reform. Employers should anticipate further constraints across sponsorship, settlement and compliance, with additional legislative changes to asylum and border controls expected later in 2025.
Now is the time for sponsors and affected stakeholders to review their immigration strategies, workforce planning and integration processes in light of the UK’s ongoing shift toward a more restrictive and domestically focused system.
The material contained in this communication is informational, general in nature and does not constitute legal advice. The material contained in this communication should not be relied upon or used without consulting a lawyer to consider your specific circumstances. This communication was published on the date specified and may not include any changes in the topics, laws, rules or regulations covered. Receipt of this communication does not establish an attorney-client relationship. In some jurisdictions, this communication may be considered attorney advertising.