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Unless you have been living under a rock, or boycotting news and social platforms in favour of the outside world and unseasonably warm weather (for which you cannot be blamed), you will likely be well informed by now on the landmark proposals set out in the government’s Immigration White Paper (the White Paper).
The White Paper, released on 12 May 2025, introduces significant reforms aimed at reshaping the nation’s immigration landscape. While the government’s stated objective is to fix the “distorted labour market” in order to address falling GDP and depressed productivity, the proposed measures have prompted a range of responses from the business community, with many expressing concern over the potential adverse effects on a variety of sectors.
In our previous article, we set out the main White Paper proposals in detail. This article will focus on those reforms likely to have the most significant impact on UK businesses, and we share our thoughts on the key considerations following the rollout of the White Paper.
Workforce strategy – introducing the Labour Market Evidence Group
The Labour Market Evidence Group is being created to gather data on the labour market. Its purpose is to identify the sectors which have high levels of overseas recruitment. These sectors will be required to provide a workforce strategy. This must stipulate what needs to be done in terms of skills, training and other conditions to engage the resident labour market, with the aim of decreasing reliance on overseas talent.
What is a ‘workforce strategy’? How will compliance with the same be enforced? Currently, these questions remain unanswered. On paper, this comes across as a demanding measure, requiring significant time, resource and engagement by UK businesses to assist the government with gathering the relevant data. Fundamentally, upskilling and training the UK workforce is a policy issue and, whilst UK businesses will undoubtedly be on hand to assist, it is hoped that the government will not lean too heavily on those sectors that have utilised their right to recruit from overseas, in line with immigration rules and legislation.
Skilled Worker applicants to have higher qualification and English language ability
In 2020, the Regulated Qualifications Framework (RQF) for Skilled Worker applicants was lowered from RQF 6 (bachelors degree or equivalent) to RQF 3 (A-level or equivalent), as a quid pro quo measure following Brexit and the loss of free movement. Under the White Paper, the government propose to reverse this change, reinstating the RQF 6 minimum qualification requirement for Skilled Worker migrants. An uplift to the minimum salary requirement is also proposed, although the level of increase remains unknown.
If the qualification increase is to come into force, it risks excluding those with significant industry experience and knowledge from sponsorship. Sectors such as catering, hospitality and entertainment will likely be hit the worst, given individuals working in these areas may not have attended further education institutions, but instead spent many years learning and perfecting their craft on the job.
A transitional arrangement will be available to those currently in the UK and working in an RQF 3 level position. They will be permitted to remain on the Skilled Worker visa route, renew their visa or apply to change their employment.
Similarly, the minimum English language requirement under the Skilled Worker route will be raised from B1 (intermediate) to B2 (upper intermediate) in accordance with the Common European Framework for Reference for Languages. This is unlikely to present a significant barrier for many sectors, where English proficiency is a requirement for the role. Of course, this will not always be the case, and there are likely many positions where there is a requirement to work from inside the UK, but with a conversational level of English proficiency. Further, adult dependents of Skilled Workers will also need to demonstrate English proficiency at level A1 (basic user), which may again present a barrier for certain demographics.
Immigration Skills Charge (ISC)
UK Sponsor Licence holders will know that this is a skills levy employers pay to the Home Office when they assign the Certificate of Sponsorship (CoS) to a migrant worker. Currently, the levy is set at £364 per year for small or charitable sponsors, and £1,000 per year for medium and large sponsors. Under the proposed reforms, the ISC fee will be increased by 32% for both sponsor categories. As a result, the cost is expected to increase from £364 to £480(ish) per year for small, and from £1,000 to £1,320 per year for medium and large sponsors.
An unsurprising reform given we have seen significant increases to numerous immigration associated fees over the past 24 months, such as the 66% increase to the Immigration Health Surcharge, and 120% increase to the CoS fee. It was only a matter of time until the ISC payment followed suit. The proposed rise in ISC payment, compounded by the increased length of time a migrant worker must live in the UK before achieving settlement (from five to ten years), will impose a significant financial burden on employers.
Abolition of the Social Care visa
Under the proposed reforms, the Social Care visa route will be closed. For those individuals already in the UK, they will have until 2028 to extend their visas, switch to a new employer or other in-country routes. The government confirmed its intention to monitor this arrangement, suggesting further changes could be put in place at any time between now and 2028.
Over recent years, the care sector has been a significant focus point for both the previous and current governments, due to the high level of overseas workers and higher risk of exploitative employment practices. The crackdown on rogue care institutions has seen around 470 providers have their Sponsor Licences either revoked or suspended, and around 40,000 migrant workers displaced since 2022. Of course, where immigration laws and policy are flouted, the Home Office is duty bound to act. But, why should the many be punished for the actions of a few?
Better pay and working conditions for those tasked with caring for the most vulnerable in our society is something we can all agree on. The White Paper suggests that “fair pay agreements” will solve all the problems. However, in the absence of any concrete detail to explain how the funding will operate and, importantly, where it will come from, this measure is unlikely to provide much comfort to those operating in the care sector or, indeed, for those with aging relatives.
The ‘new’ shortage occupation list
As we bid adios to Appendix Immigration Salary List, the second, or maybe third iteration (it is hard to keep count) of the official list to document UK labour shortages, we welcome the Temporary Shortage List (TSL). This will permit sponsorship of positions levelled at RQF 3 – 5 (below degree level) where long-term shortages exist.
At present, it is not clear which roles will be included in the TSL as this will be subject to another review by the Migration Advisory Committee. The government’s approach with the TSL is increasingly restrictive, requiring sponsors to prepare ‘workforce strategies’ (see above), and limitations on bringing across family dependents.
Where to go from here?
As set out in our previous article, it is important to bear in mind that, currently, these are proposals only. Any formal change will require further legislation or policy updates. However, it is clear from Kier Starmer’s highly emotive speech on Monday that Labour intends to tighten up the current immigration framework, to achieve its core aim of reducing the UK’s net migration figure. Therefore, it seems likely that a number of the proposals will be implemented, but to what extent remains to be seen.
For now, businesses are encouraged to:
- Review and consider sponsorship requirements over the next 12 months – will you be recruiting into a sponsored role? If yes, consider expediting the plans to take advantage of the current UK immigration rules and framework.
- Could there be longer-term implications on recruitment strategy? If so, what steps can be taken to remedy any potential issues?
- Meet with your sponsored workforce – it is likely in a time of such uncertainty, many could feel concerned about their future prospects in the UK and would greatly benefit from support and guidance.
- Consider whether anyone in the sponsored workforce is approaching settlement under the current five-year framework, and whether they intend to apply to remain in the UK indefinitely. Subject to meeting the eligibility requirements, it is advisable for them to apply for settlement as soon as possible.
We do anticipate transitional arrangements will be introduced, but if you are planning applications or reviewing workforce needs, we strongly recommend seeking advice as soon as possible.
Please get in touch if you would like to understand how these proposals could affect your business or long-term planning.
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