The government's central aim is clear: reduce the number of people coming to the UK for work. Sensibly the government has stopped short of setting a firm numerical target but instead focussed on the perceived impact of a set of wide ranging reforms of the work based immigration system. While the tone of the white paper is attention-grabbing, many of the proposed measures are likely to face delays in implementation—and some may prove less impactful than they initially appear. Nevertheless, the direction of travel is clear: tighter controls, higher thresholds, and a growing administrative burden for employers looking to hire from abroad.

Raising the skill level for Skilled Worker visa holders

One of the most significant proposals is a return to a more restrictive definition of “skilled work.” Since 2021, roles qualifying for the Skilled Worker visa have needed to meet a skill threshold equivalent to RQF Level 3—roughly the standard of A-levels. The government now intends to raise that requirement to RQF Level 6, or degree level. This was the previous skill level require before the rules were amended in 2021. The policy document suggests that there will be amendments to the salary thresholds for the visa route as well.

To be clear, this will not mean that all applicants must have a degree. Instead, the job being offered must be assessed as requiring that level of skill. This is done by selecting the appropriate Standard Occupational Classification (SOC) code, and under the proposed changes, the list of eligible codes will be reduced to just 180 roles. An employer will need to assess whether a role they want to sponsor comes within the shortened list of codes.

This shift will likely exclude a wide range of roles currently eligible under the Skilled Worker route—especially those in construction, logistics, and hospitality—which could present serious challenges for sectors already struggling with domestic labour shortages.

The white paper does make clear that those individuals already in the skilled worker visa route will be able to extend their visa, even if their SOC code falls off the list of eligible codes. These means that any employers with applications in the pipeline which could be affected by these changes would be wise to move these plans forward to ensure they come within the present system.

Temporary Shortage List: A new, narrower pathway

The Immigration Salary List, introduced only last year to replace the Shortage Occupation List, will be rebranded again as the Temporary Shortage List (TSL). This will cover roles that fall below the new RQF Level 6 threshold but are still deemed necessary to the economy and so allowed access to the skilled worker system.

To be included on the TSL, roles will need to align with national priorities such as critical infrastructure or key industrial strategy sectors. The Migration Advisory Committee review will decide which roles qualify. There is also a new body being established called the Labour Market Evidence Group which will feed into this decision making process.

The white paper also indicates that salary discounts currently applied to shortage roles may be removed, which could make it even harder for employers to sponsor workers into these positions. Restrictions on bringing dependents for workers in TSL-listed roles are also anticipated, although few details have been shared.

English language requirements: Tougher standards

Applicants for the Skilled Worker visa are currently required to demonstrate English language proficiency at level B1 under the Common European Framework which is considered around GCSE level English. The government proposes raising this requirement to level B2—equivalent to A-level English. This requirement can be met if someone is from a majority English speaking country, they have a degree taught in English or they sit and pass an approved English language test.

In addition, for the first time, partners of Skilled Worker visa holders will also need to meet language requirements. On arrival, they will need to demonstrate proficiency at level A1 (basic conversation), and to extend their stay, they will need to show improvement to level A2.

The government's own research shows that the vast majority of visa holders already speak English well before they arrive in the UK so it's debatable what impact this will have on the numbers of applicants. It will, though, require employers to consider carefully the language ability of a potential applicant to consider if they can pass a necessary English language test. They may possess the language skills to do their job but may still fall foul of these new standards.

Tighter controls on dependents

The ability to bring dependents is often a deciding factor for skilled workers when choosing where to relocate for work. The white paper suggests there will be new restrictions placed on bringing dependents, particularly for those in roles listed on the Temporary Shortage List. This follows recent changes already affecting care workers, who can no longer bring family members as dependents to the UK.

If these restrictions on dependents are extended more broadly, they could significantly reduce the attractiveness of UK job opportunities for international talent. When combined with the new English language requirements for partners of skilled workers, the message is clear: the UK is narrowing access not just for workers, but for their families too. This could be particularly problematic in sectors that rely heavily on overseas talent, where candidates may be discouraged from applying if their family members cannot meet the language criteria. Ultimately, this risks deterring skilled professionals who might otherwise have chosen to build long-term careers in the UK.

Further restrictions for the social care sector

The white paper confirms a significant shift for the social care sector: employers will no longer be permitted to recruit care workers and senior care workers from overseas through the Skilled Worker route. Sponsorship will still be allowed for individuals already in the UK on a Skilled Worker visa or another eligible route, though the government has indicated that such recruitment will be subject to increased scrutiny.

This move comes despite a noticeable decline in the number of Health and Care Worker visas already issued, raising questions about whether further restrictions are justified. For a sector already grappling with persistent staffing shortages, the added limitations are likely to intensify existing pressures.

The white paper also outlines plans to make it easier for skilled workers to change employers, a step aimed at empowering individuals and reducing the risk of exploitation. While this could provide some flexibility in recruitment, it may also contribute to higher staff turnover and greater instability within already stretched teams.

Employer's responsibilities to train local workers

The Labour government has long signalled its intention to align immigration policy more closely with domestic skills development. The white paper reinforces this, making it clear that employers wishing to recruit from overseas will be expected to play a greater role in building local talent pipelines. New measures are expected to incentivise and increase investment in training, particularly in sectors that rely heavily on migrant labour. Employers in these sectors will be required to produce a “workplace strategy” outlining the steps they are taking to upskill the UK workforce.

However, the white paper offers little detail on how this requirement will operate in practice, or how it will interact with the current sponsorship system. We will need further clarity to assess its potential impact and implications for employers.

Higher costs for employers

Employers will also face an increased financial burden for using the sponsorship system. The Immigration Skills Charge—which must be paid by sponsors and cannot be passed on to applicants—is set to rise by 32%. The current charge is £364 for small businesses and £1000 for a medium to large sponsor per year of a visa. For a large business sponsoring a five-year visa, this means an increase of around £1,600 per worker for this fee alone.

This comes on top of previous hikes to visa application fees and the Immigration Health Surcharge. As a result, businesses that rely on international hiring will need to factor in significantly higher per-employee costs when planning budgets or negotiating salaries.

A longer route to settlement

One of the most controversial changes is the proposed increase in the qualifying period for settlement under the Skilled Worker route—from five years to ten. The white paper suggests there will be exceptions for individuals who make significant contributions to the UK economy or society, the criteria for this have not yet been defined.

This change has several implications. First, it extends the time during which skilled migrants must continue renewing visas, which adds cost and complexity. Second, it could make UK-based roles less attractive to international talent, particularly when other countries offer faster or more stable routes to permanent residence.

For employers, a longer settlement period may increase staff turnover if workers choose to move to jurisdictions with more favourable policies. It may also increase administrative burdens, as employees will require visa extensions over a longer period, involving the greater use of certificates of sponsorship and higher amounts of the Immigration Skills Charge.

The immediate question is whether these new reforms will apply to those already in the UK on a skilled worker visa. The Home Secretary has explicitly not ruled this out. We understand that the government will set out further details of these reforms later this year and will consult on them. It will be some time before this proposal fully takes shape.

Changes to the Graduate Route

The white paper confirms that the popular post-study Graduate visa will remain in place but the visa length will be shortened from two years to 18 months. Earlier leaks had suggested more dramatic restrictions, such as limiting eligibility to those with a qualifying job offer, but the government appears to have stepped back from this.

Even so, the shortened timeframe is clearly designed to push recent graduates into the Skilled Worker route more quickly. This could place pressure on both candidates and employers to initiate sponsorship processes sooner—potentially shifting costs and compliance burdens earlier in the employment relationship.

Limited news on citizenship

Unlike other areas of immigration policy, the citizenship process has remained largely unchanged for decades. The only significant announcement is a planned refresh of the Life in the UK test. However, there is a suggestion of bringing in some form of 'earned citizenship' but little detail is given.

Attracting the 'Very Highly Skilled'

While much of the white paper is focused on restriction, there are some initiatives designed to attract top talent. These include faster processing for out-of-country applicants via mobile apps, simplified routes for global talent applicants and research interns, and expanded quotas under the Global Business Mobility: Expansion Worker visa and High Potential Individual route.

For large organisations recruiting in sectors like science, design, and tech, these measures may create new opportunities. However, for most businesses, especially SMEs, the broader trend remains one of increased regulation and cost.

Implementation timeline

It’s worth remembering that a white paper is not a setting out a legal framework—it’s a policy roadmap which sets out proposals for future rules and legislation. Some of the changes, particularly those proposed to the Skilled Worker route, are likely to be implemented imminently via a Statement of Changes to the Immigration Rules. Others will require primary legislation through an Immigration Bill, which could take months or longer depending on the legislative timetable and political developments.

There is also a possibility that some proposals may be dropped, delayed, or modified in response to consultation or parliamentary scrutiny.

Final thoughts for employers

While the government’s rhetoric may suggest a radical overhaul, the practical impact of these proposals varies. Some changes—such as the increased skill level—may not make as big an impact as envisaged due to changes that have already been made to the skilled worker system via salary threshold increases. Others, like restrictions on dependents and a longer path to settlement, could have more lasting consequences for recruitment and retention.

What’s clear is that hiring internationally is becoming more complex, more expensive, and more tightly controlled. Employers should start preparing now by reviewing sponsored roles, updating compliance procedures, budgeting for higher fees, and advising internal stakeholders on how these changes could affect future hiring strategies.

We will continue to monitor developments as the proposals move toward implementation. In the meantime, now is a good time to audit your organisation’s use of the immigration system and ensure you’re ready for what lies ahead.

We will be discussing the impact of the White Paper at our webinar 'Navigating the latest Immigration Law Changes: Essential Updates for HR Professionals' taking place on Thursday 15^th May. Please sign up if you have not done so already here. If you would like to discuss this or the impact of the new changes please contact Joanna Hunt.