Statement of changes to the immigration rules (July 2025): Implementation of white paper reforms

These changes come into force on 22 July 2025 and will apply to applications that rely on certificates of sponsorship (CoS) issued on or after this date. This provides a short window in which applications can still be made under the current, more flexible visa regime.

Rise in the skill level for the Skilled Worker visa

The skill level for the skilled worker visa is rising from RQF level 3 (A-level) to RQF level 6 (degree level). This returns the eligibility requirement to the level it was at pre-2021. This change in skill level relates to the skills required for the occupation and does not introduce a requirement for an applicant to hold any particular qualifications.

A large number of standard occupational codes will no longer be eligible for skilled worker sponsorship under the immigration rules. However, if a code is RQF level 5 or below and appears on the Immigration Salary List or the new Temporary Shortage List then it will still qualify for sponsorship, albeit with slightly less privileges than other Skilled Worker visa applications.

This change in the skill level will not affect those individuals who are already in the Skilled Worker visa route or who apply on the basis of a CoS assigned before 22 July 2025. This means that there are just three weeks left to make applications under the current visa rules. The transitional measures for current Skilled Worker visa holders will not be in place indefinitely and will be reviewed in due course.

Action points

• Employers should consider whether there are any individuals within their business or organisation that may require skilled worker sponsorship in the future and will not qualify under the new rules.
  • If so, a CoS may need to be assigned for these individuals in the three week window before implementation on 22 July 2025.
• Employers should also consider whether they have sufficient number of CoS for applications to be made. If you do not, please action your allocation increases. There is a likely to be a surge in demand and the Home Office are closely scrutinising these requests.

Immigration Salary List and Temporary Shortage List

For roles which no longer meet the skill threshold, the Immigration Salary List will be maintained, for a temporary period at least, meaning roles on this list will still qualify for sponsorship. This includes care workers and senior care workers.

 An interim Temporary Shortage List (TSL) is being launched alongside it, containing occupations that the Department for Business and Trade and the Treasury have identified as being important for achieving the Modern Industrial Strategy.

Roles which appear on the TSL will be able to make applications for Skilled Worker visas up until 31 December 2026. This will allow the Migration Advisory Committee to carry out a thorough review of what roles should appear on this list and to publish their recommendations.

Workers in roles on the TSL face a limited range of benefits compared with those roles at RQF level 6. They will not be able to secure visas for their dependents unless they are children born in the UK or where the Skilled Worker has sole parental responsibility for them.

The list of the roles on the Temporary Shortage List currently features the following;

• 1243 Managers in logistics
• 1258 Directors in consultancy services
• 3111 Laboratory technicians
• 3112 Electrical and electronics technicians
• 3113 Engineering technicians
• 3114 Building and civil engineering technicians
• 3115 Quality assurance technicians
• 3116 Planning, process and production technicians
• 3120 CAD, drawing and architectural technicians
• 3131 IT operations technicians
• 3132 IT user support technicians
• 3133 Database administrators and web content technicians
• 3412 Authors, writers and translators
• 3414 Dancers and choreographers
• 3417 Photographers, audio-visual and broadcasting equipment operators
• 3422 Clothing, fashion and accessories designers
• 3429 Design occupations not elsewhere classified – only the following job types:
  • Industrial and product designers
  • Packaging designers
  • Performance make-up artists
  • Set designers
  • Visual merchandising managers and designers

• 3512 Ship and hovercraft officers
• 3520 Legal associate professionals
• 3532 Insurance underwriters
• 3533 Financial and accounting technicians
• 3541 Estimators, valuers and assessors
• 3544 Data analysts
• 3549 Business associate professionals not elsewhere classified – only the following job types:
  • Business support officers
  • Business systems analysts
  • Contract administrators
  • Clinical coders
  • Clinical trials administrators
  • Research coordinators

• 3552 Business sales executives
• 3554 Advertising and marketing associate professionals
• 3571 Human resources and industrial relations officers
• 3573 Information technology trainers
• 4121 Credit controllers
• 4122 Book-keepers, payroll managers and wages clerks
• 4129 Financial administrative occupations not elsewhere classified – only the following job types:
  • Box office assistants
  • Grants officers
  • Mortgage administrators
  • Revenue assistants (excludes National and Local government revenue occupations)
  • Treasury assistants

• 4132 Pensions and insurance clerks and assistants
• 5213 Welding trades
• 5214 Pipe fitters
• 5223 Metal working production and maintenance fitters
• 5225 Air-conditioning and refrigeration installers and repairers
• 5231 Vehicle technicians, mechanics and electricians
• 5232 Vehicle body builders and repairers
• 5233 Vehicle paint technicians
• 5235 Boat and ship builders and repairers
• 5241 Electricians and electrical fitters
• 5242 Telecoms and related network installers and repairers
• 5244 Computer system and equipment installers and servicers
• 5245 Security system installers and repairers
• 5249 Electrical and electronic trades not elsewhere classified
• 5311 Steel erectors
• 5315 Plumbers and heating and ventilating installers and repairers
• 5319 Construction and building trades not elsewhere classified – only the following job types:
  • Builders
  • Divers
  • Fence erectors
  • Industrial climbers
  • Remotely Operated Vehicle (ROV) operators
  • Steel fixers and underpinners

• 5322 Floorers and wall tilers
• 5323 Painters and decorators
• 5330 Construction and building trades supervisors
• 8133 Energy plant operatives

The list is surprisingly broad. It will soften some of the impact of the rise in the skill level, as quite a lot of roles will still be eligible even though they are below RQF level 6. At least until the MAC completes its review, there will still be potential for some medium skilled roles to apply for Skilled Worker visas.

Salary level increases for the Skilled Worker visa

There will be increases to the general salary thresholds and going rates for the Skilled Worker route which will take effect from 22 July 2025. Unlike the changes to the skills threshold, these will apply to all Skilled Worker visa applications from 22 July onwards, meaning they will impact not only those applying for a Skilled Worker visa for the first time but also those people extending their visas.

From 22 April the following salary thresholds will apply:

Salary thresholds for applicants who entered the skilled worker visa route post 4 April 2024

Salary thresholds for legacy applicants who entered the skilled worker visa route pre 4 April 2024 and also those individuals applying in a Health and Care Worker role

Action points

• Employers should review the thresholds and consider if this could impact both upcoming recruitment but also current sponsored employees who may not be able to extend their visas
• Applications may need to be made in advance of the measures being implemented to ensure continuity of employment

Adult social care

As set out in the white paper, entry clearance applications from abroad for care workers and senior care workers (codes 6135 and 6136) will close from 22 July 2025. Transitional measures are in place until 22 July 2028 which will allow individuals to switch from other visa routes into the skilled worker visa route. In order to benefit from this provision, workers must have worked for their employer for at least 3 months before the date their CoS was issued to them.

The requirements for sponsors to first try to recruit from the pool of skilled workers seeking sponsorship is being removed from 22 July 2025 as well.

To prevent the apparent misuse of occupation code 6131 'Nursing auxiliaries and assistants' to circumvent the changes, a clarification is being added to confirm this occupation code only applies to roles in environments where registered nurse roles also exist.

Next steps

These changes mark the start of a pivotal shift in how UK employers approach international recruitment. There may be visa applications that need to be made before 22 July to ensure that critical talent can remain in their roles. It is therefore important that business and organisations understand the detail and prepare for the operational, compliance and workforce planning implication.

If you require advice on the impact of these changes please contact Joanna Hunt.

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.