Closure of the Immigration Salary List and a reduced Temporary Shortage List: what employers should do now to prepare

What are the Temporary Shortage List and Immigration Salary List?

Following changes introduced on 22 July 2025, jobs sponsored under the skilled worker route generally need to be skilled to RQF level 6 or above (considered to be 'degree level'). However, certain occupations below that level, at RQF levels 3 to 5 ('medium' skilled), remain eligible for sponsorship where they appear on the TSL or ISL.

The TSL was introduced to provide time-limited access to skilled worker sponsorship for selected medium-skilled occupations considered important to the Government's Industrial Strategy or critical infrastructure. The MAC was subsequently commissioned to consider which occupations should continue to benefit from access to the route.

The ISL is due to close on 31 December 2026. The current immigration rules expressly give the occupations on the list a removal date of 31 December 2026.

What changes are expected?

The MAC has recommended that 28 occupations should be included on the future TSL, each for an initial period of 18 months. No occupation was considered to have a sufficiently strong Jobs Plan to justify three-year access.

* New additions to the list.

This means that the following roles that are currently on the TSL will no longer be sponsorable from 1 January 2027:

This also means that the following list of SOC Codes from the ISL are likely not to be sponsorable from the end of 2026 onwards.

The MAC's recommendations have not yet been implemented. The final position will therefore depend on the Government's response and the immigration rules giving effect to the changes. Employers should not assume that the recommended list is final until those rules are published.

What does this mean for existing sponsored workers?

Workers with existing skilled worker permission will not simply lose their immigration permission because their occupation is subsequently removed from the TSL or ISL. Their existing permission remains valid until it expires.

Importantly, transitional arrangements introduced alongside the July 2025 reforms allow existing skilled qorkers in occupations below RQF level 6 to continue to extend their permission, change employment, and undertake supplementary employment, subject to the relevant requirements.

The position is potentially more difficult for individuals who moved into the Skilled Worker route in a medium-skilled occupation after the July 2025 changes. Where their occupation subsequently ceases to qualify, their ability to extend may depend on the transitional provisions contained in the forthcoming immigration rules.

Employers should therefore identify this cohort now and consider whether any steps should be taken before the changes take effect.

What does this mean for employees who may require sponsorship in future?

Employers should prepare for a significantly narrower TSL from 1 January 2027 if the MAC's recommendations are adopted.

1. Review your workforce

Identify employees currently working under other immigration routes, particularly those with graduate permission, who may require skilled worker sponsorship in the future.

Some individuals working in medium-skilled occupations are eligible for sponsorship now but may cease to be eligible from January 2027. Employers should identify those workers and consider whether there is a case for bringing forward sponsorship while the role remains eligible. We anticipate that as long as the CoS is assigned before the rules change from 1^st January 2027, an applicant can make a visa application at a point after this date and still benefit from the old rules.

Employers should also identify current sponsored workers in affected occupations (those sponsored after 22^nd July 2025 in roles no longer on the ISL or TSL) and establish when their existing permission expires. This will allow them to assess quickly what action may be necessary once the final transitional arrangements are known.

2. Check your CoS allocation

Sponsors should review their available undefined CoS allocation now and consider how many additional certificates may be required before the end of the year. A worker normally has three months from the date on which a CoS is assigned to use it to make their visa application.

For occupations on the ISL, the current rules expressly provide for inclusion where the application relies on a CoS issued before the occupation's removal date. The precise transitional provisions accompanying the new TSL will, however, need to be checked once the forthcoming immigration rules are published.

3. Request additional CoS early

Where a potential shortfall is identified, sponsors should consider requesting an increase to their undefined CoS allocation as early as possible. The Home Office states that an application for additional undefined CoS can ordinarily take up to 12 weeks, although a priority service is available for eligible sponsors and requests. Priority requests are normally considered within five working days, subject to availability, but the service does not guarantee that the underlying request will be approved.

Requests should explain clearly why the additional allocation is required and provide sufficient information to enable the Home Office to assess the request.

What does the closure of the ISL mean for higher-skilled occupations?

Occupations which independently meet the RQF 6 skill requirement will remain potentially sponsorable even when the ISL closes, provided the other skilled worker requirements are satisfied.

However, employers will need to consider the effect of losing the ISL concession of a 20% reduction on the general salary threshold. For example, SOC 2111 Chemical Scientists, insofar as the current ISL covers nuclear-industry roles in Scotland, and SOC 2112 Biological Scientists currently appear on the ISL with reduced salary thresholds.

Their removal from the ISL will not necessarily make the occupations ineligible for sponsorship, but it may affect whether an individual satisfies the applicable salary requirements. Employers should therefore review affected workers' salaries before future extensions or changes of employment.

What about care workers?

Care workers and senior care workers are subject to separate transitional arrangements following the closure of the route to new overseas recruitment in July 2025. Certain in-country applications remain possible until 22 July 2028, subject to the applicable requirements. Given the complexity of these transitional provisions, employers should assess affected care workers separately rather than assuming that the general TSL and ISL position applies to them in the same way.

What shouldemployers do now?

We expect the forthcoming immigration rules to provide the legal framework for the changes before the end of the year. Until those rules are published, the MAC's recommendations remain recommendations rather than the final legal position.

That does not mean employers should wait. Now is the time to identify affected employees, review visa expiry dates and future sponsorship needs, check CoS availability, and ensure budgets are in place for the relevant sponsorship and immigration costs.

Once the rules are published, employers who have already completed that exercise will be well placed to make decisions quickly during the period before the changes take effect.

We will be examining these changes, as well as the other key developments of 2026, at our webinar, UK immigration law: the year in review and what's on the horizon for 2027, on 9 December 2026. We hope that the immigration rules will have been released by this point so will be able to give advice on how the new regime will operate during the session. Please do click on the link to sign up.