Immigration update – Summer 2025

Immigration white paper and statement of changes to the immigration rules – July 2025

The major development this spring was the long-awaited release of the Government’s immigration white paper, titled 'Restoring control over the immigration system', which outlined key reforms to the immigration system.

Proposals include:

• Raising the skills threshold for the Skilled Worker visa
• Raising the salary thresholds and English language requirement for the Skilled Worker visa
• Introducing a possible 10-year route to settlement

Further details can be found in our article which can be accessed here.

In early July, a statement of changes to the immigration rules was released setting out the legal framework for the rise in the skill level and some modest salary increases. These will be in force from 22 July 2025. We have discussed this further in our article which can be accessed here.

The more substantial changes to the skilled worker visa route and the proposal to increase the route to settlement to 10 years are expected to be delivered in a longer time frame. The Migration Advisory Committee is going to conduct a thorough review into the salary thresholds for the Skilled Worker route and the new immigration shortage list which will be completed in Spring 2026.

Action point for employers

Following the release of the statement of changes, there is a short window to sponsor employees or potential recruits under the current, more flexible skilled worker visa criteria (including roles below RQF Level 5). Employers should:

• Assess which roles and individuals may be impacted by the skill level change
• Request an increase in their certificate of sponsorship (CoS) allocation (if needed) to cover potential applications
• Assign CoS before the deadline of 22 July 2025 if the applicant needs to benefit from the current skilled worker regime. 

We will be hosting a webinar on 17 July 2025 to discuss these changes in more depth. If you would like to join us please sign up here.

Statement of changes to the immigration rules – June 2025

A statement of changes to the immigration rules was published on 24 June 2025. The most significant news is the change to the continuous residence requirement for the EU Settlement Scheme (EUSS), so that applicants with pre-settled status will no longer need to have been continuously resident in the UK since the end of the transition period to remain eligible for settled status, if they have been resident in the UK for 30 months in the past 60 months.

Statement of changes to the immigration rules - April 2025

April saw a number of important changes to the Skilled Worker route, including a rise in the base level salary threshold for the skilled worker route and also new rules governing the recruitment of care workers. We explored this in our recent article.

One key update relates to new guidance on when employers can recover, pass on or clawback visa costs from employees. We discussed these changes in greater detail in our dedicated article. HR teams should familiarise themselves with these developments to ensure continued compliance.

Action point for employers

Employers should review the new rules, particularly with regards to the payment of immigration costs. If they have any arrangements in place with employees to recover costs via a loan or claw back clause it is worthwhile reviewing the provisions to check they are in line with the new requirements.

eVisa update

The rollout of the eVisa system continues to progress.

From 2 June 2025, expired biometric residence permits (BRPs) can no longer be used for travel to the UK or to generate share codes to prove right to work. Employers should ensure that any remaining employees who have not yet transitioned to an eVisa do so promptly—unless they are exempt (e.g. holders of ‘wet ink’ indefinite leave to remain stamps in passports, for whom it is optional).

The next phase of the rollout begins on 15 July 2025, targeting overseas applicants. From this date, some individuals applying for Skilled Worker visas from outside the UK will no longer receive a vignette in their passport. Instead, they will be expected to set up their eVisa in their UKVI account before they travel to the UK to facilitate entry and also demonstrate right to work.

Some Skilled Worker and dependent applicants will continue to receive vignettes valid for 90 days. They should still be encouraged to create a UKVI account as soon as possible. An employer can still carry out a right to work check on the basis of the vignette but this will only be valid for 90 days, during which time they will need to set up their account and generate a share code for an online right to work check to be carried out.

Action point for employers

Employers will need to be aware that Skilled Worker visa holders who have arrived from overseas may no longer be able to present a stamped vignette showing their entry into the UK. A sponsor is required to verify that a sponsored worker has entered the UK during the duration of their visa, so it is likely that employers will need to check a visa holder's date of entry via a boarding pass or ticket rather than checking the stamp in a passport. We anticipate further sponsor guidance being released in July to address this.

Right to work checks: Self-employed and gig economy workers

In March, the government announced plans to expand right to work checks to cover gig economy workers and certain self-employed individuals.

This change is progressing via amendments to the Border Security, Asylum and Immigration Bill, which will amend the Immigration, Asylum and Nationality Act 2006.

The new Section 45 provision will broaden the definition of a "person employing another" to include:

• Businesses engaging individuals under a contract for services
• Businesses engaging sub-contractors directly
• Individuals hired via online platforms or matching services

The bill is not yet law and we will need to see the secondary legislation and guidance to understand the full ramifications of the provisions.

Action point for employers

Once in force, these measures will extend the risk of a civil penalty for illegal working—up to £60,000 per individual—to a wider range of work engagements. This includes forms of self-employment and some non-traditional working arrangements previously considered to be outside the scope of right to work checks.

Employers should start preparing by:

• Reviewing worker categories and engagement models that they have within their business or organisation
• Assessing whether additional right to work checks will be required when the measures are in force
• Ensuring their right to work checking systems are robust enough to ensure compliance with the new measures

Youth Mobility Scheme: UK–EU developments

A positive development emerged from the UK-EU Summit in May 2025, where the UK government indicated a willingness to move forward with a Youth Mobility Scheme (YMS) for EU nationals.

This visa route allows young people to work and travel in the UK for up to two (and in some cases three) years, supporting cultural exchange and workforce flexibility.

There is much to be negotiated before a new visa route is launched and there are key questions to be resolved:

• Duration: Will EU nationals receive two- or three-year visas?
• Age range: Will the scheme apply to those aged up to 30 or up to 35?
• Quotas: Will there be a cap, and if so, how many places will be available?
• Immigration health surcharge (IHS): Will EU nationals be subject to the IHS? EU negotiators have called for an exemption.

However, this is a positive sign. A YMS visa with the EU may help to ease recruitment pressures caused by the tightening of the Skilled Worker visa criteria.

Need advice or help?

The immigration landscape is once again undergoing a significant period of change which will have wide ramifications for all employers. Please don’t hesitate to contact us if you have any questions or require tailored advice on any of the topics covered above.