2025 saw significant immigration upheaval through two Statements of Changes. More changes to settlement are expected this year. We outline the impact on sponsor licence holders.

Published: 21 January 2026
Author: Alice Balgarnie

As an employer, it might feel like you only have to blink, and the Immigration Rules are entirely unrecognisable. Here we set out some of the changes you might have heard about in the news recently. We’d urge employers to proceed with caution. These changes are a minefield and there are immigration and employment consequences of getting on the wrong side of them. Whilst immigration remains front and centre of UK news, these changes have not always been reported entirely accurately.

We recommend employers review their current sponsored workers, tracking their start date to determine which particular immigration rules on salary and skills level will apply to them. We also recommend considering upcoming plans for recruitment.

What has changed already?

The July 2025 Statement of Changes significantly impacted which roles can be sponsored. For employers holding a sponsor licence, or employers considering obtaining a sponsor licence in future, these changes will be particularly important to note.

Skills level

In order to sponsor an individual under a Skilled Worker visa, the job details provided in their Certificate of Sponsorship must meet certain requirements. One of these is that the Standard Occupational Classification (SOC) the job has been matched to is suitably skilled. Previously, this meant that the job had to be ‘medium skilled’- RQF3 or above. That’s A-Level equivalent.

However, as of 22 July 2025, the skills level for a job to be eligible has risen significantly. The job must now be ‘higher skilled’- RQF6 or above. These jobs are considered to be at least degree level.

That means many jobs are no longer eligible for sponsorship. Around 180 jobs are affected.

However, there are transitional arrangements available. Employers can still sponsor roles at RQF3 or above, where the SOC is listed on the Temporary Shortage List or Immigration Salary List. These are two lists for jobs identified as being in shortage. In addition, it is also possible to sponsor at the lower skills level, where the person has been sponsored since before July 2025. That means that there is still flexibility around Extension and Change of Employer applications.

Salary

Another requirement of sponsorship is that the role being sponsored is paid sufficiently. The Immigration Rules set out a general threshold and occupation specific thresholds. The salary must be higher than both, and the government has increased all relevant rates as part of the changes.

For most workers whose sponsorship began after 4 April 2024, they must now be paid the higher of £41,700 or the going rate for their job. This is an increase from £38,700.

It’s important to note that salaries do not need to be increased for the duration of a Certificate of Sponsorship. Meeting the new salary thresholds becomes critical when a new Certificate is assigned.

Consider:

• if I was to extend an employee’s visa tomorrow, would their job meet the new salary requirements?
• if not, is there a business case to increase the salary above the required threshold and going rate? Is this in line with anticipated salary review and/or promotion?
• if not, have we considered the implications of ending sponsorship of the individual? Unless they are able to switch to a different visa type, this will also mean ending employment. In which case, it may be appropriate to take employment advice.

Separately, we are aware of the increasing use of AI by migrants and employers alike. AI has commonly misunderstood this area of law so we would advise relying on official government sources and legal advice only. AI chatbots have not yet been able to pick up on the complex transitional arrangements protecting migrants already here.

Immigration skills charge

The Immigration Skills Charge, paid by employers when assigning a Certificate of Sponsorship, increased by 32% as of 16 December 2025. The cost increased from £364 to £480 per year for small/charitable sponsors, and from £1,000 to £1,320 per year for medium/large sponsors.

English language

From 8 January 2026, the English Language requirement increased from B1 to B2 level. B2 is known as ‘Upper immediate’ and requires learners to understand complex texts, or abstract topics; express themselves fluently and spontaneously; and produce clear, detailed text (British Council B2 Upper intermediate | LearnEnglish). This will affect initial applications to the Skilled Worker route, but it will not impact individuals who are already sponsored in the UK. Whilst many migrants already have a very high standard of English comprehension, the change is likely to impact certain sectors, such as the consumer and retail sectors, and certain nationalities, disproportionately.

Separately, the government intends to introduce English Language requirements for dependants for the first time. However, a date for this change has not yet been confirmed.

What further changes have been confirmed?

Other changes announced are yet to come into force. However, we do have some information on the upcoming changes.

The Graduate visa will be reduced from two years to 18 months for most graduates from 1 January 2027. PhD graduates will continue to be granted three years of leave. The government’s concern has been that most international students aren’t moving to degree level skilled work after graduation. Now, they will need to do so to find sponsorship: and in a shorter timeframe, too!

This will impact your workforce if you operate standard graduate schemes or hire lots of graduates, most of which operate for longer than two years. In particular, the technology, mobility and financial services sectors will likely be affected by this. You may now need to consider at the outset of a graduate scheme whether there is the budget, potential, and possibility to sponsor the individual. This will involve a detailed assessment of the skills level and salary level, in line with the recent increases. In any case, there will be difficult conversations and decisions to be made, some also potentially with employment law considerations.

Settlement

Separately, on 20 November 2025 the government announced their much-anticipated consultation on increasing the minimum residence requirement for Indefinite Leave to Remain. For the Skilled Worker route, this is currently five years. The consultation proposes to double this to 10 years, and to triple the requirement to 15 years for lower paid Health and Care workers.

Much of the controversy comes from the fact that the consultation proposes that the changes will extend to all migrants, not just migrants who enter the UK after the rules change. This means that a migrant close to settlement when the changes come in, with 4.5 years leave as a Skilled Worker, would then need another 5.5 years residence in the UK before they are able to apply to settle.

However, there is pushback, and it’s important to note that the proposals aren’t fixed until the end of the consultation. Once the consultation ends, changes are expected to be implemented in the Spring statement of changes. In the meantime, it is still possible to settle in the UK with five years residence.

The consultation is open until 12 February 2026. You can respond here: Earned settlement - GOV.UK

Conclusion

Last year was particularly significant for changes to sponsored working routes in the UK, and 2026 looks set to continue the trend. We recommend you staying informed of these changes, update any internal policies, and conduct a review of both current sponsored workers and potential hires. In many industries, sponsored workers remain essential to fill skills shortages, even as the UK Government continues with this stated aim of driving down net migration.

As a final note, and as previously mentioned, the rise in the UK of AI has led to a lot of misinformation. Unfortunately, AI generated search results are not grasping much of the nuance of the immigration rules, leading migrants to sometimes believe that they need to immediately change job roles or that a different set of salary thresholds apply to them. Please be aware and refer to official sources around the changes.

For tailored advice, we have a team of dedicated immigration experts available to assist.

We are working with the CIPD in sponsoring a series of thought-leading articles that focus on navigating the key agendas faced by HR directors and their teams including business immigration and staying future-focused. Look out for more on this series later this month.