Immigration White Paper - Understanding the Direction of UK Immigration and Labour Market Reform: Key Insights for Employers

Tightening Eligibility to RQF Level 6+ and the Introduction of the Temporary Shortage List (TSL)

• What does RQF Level 6+ mean?
  It’s not a requirement for candidates to hold a degree—rather, the job must be classified at degree-level skill under the Standard Occupation Code (SOC). A list of eligible occupations should this take place can be found here.
  

• Impact:
  171 occupations will no longer qualify for Skilled Worker sponsorship unless included in the TSL. 

• Transitional Provisions:
  Current Skilled Workers in sub-RQF 6 roles will be protected. They can extend, switch employment, and take supplementary work under existing rules. However, new applicants must meet the new threshold once implemented.
  

• About the TSL:
  The TSL will enable certain RQF Level 3–5 occupations to remain eligible if they are critical to the economy or national priorities (e.g. infrastructure, key sectors). The Migration Advisory Committee (MAC), with input from a new Labour Market Evidence Group, will determine eligible roles.
  
  Employers are strongly encouraged to participate in consultations, particularly where changes will impact sector sustainability. Representations should include strategies for upskilling and recruiting locally.
  
  
• Timelines:
  These reforms are unlikely to take effect before October/November 2025. Businesses should:
  
  • Review the skill levels of both current and future employees
  • Consider submitting sponsorship applications sooner, particularly for roles likely to be excluded under new rules
  • Be aware that salary discounts for shortage roles may also be removed
  • Monitor for further details about the "temporary" nature of TSL roles and whether they will allow a route to settlement

Dependents and the TSL

• Policy Change:
  Skilled Workers in TSL roles will no longer be allowed to bring dependents. However, this will not apply retrospectively.
  

• Reassurance for Existing Employees:
  Those already on a Skilled Worker visa should be allowed to continue to sponsor dependents. This is consistent with the 2024 care worker changes, where transitional protections applied.
  
  
  

Increase to the Immigration Skills Charge (ISC)

• What’s Expected?
  This change is likely to be implemented quickly and may come into effect within weeks after a statutory order is laid in Parliament.

• Action for Employers:
  Plan ahead. Assign Certificates of Sponsorship (CoS) now if possible, before costs increase.

Graduate Route Reduction to 18 Months

• Likely but Not Imminent:
  The change is expected but likely won't affect this year's graduates. 

• Employer Considerations:
  • Sponsoring international graduates under the Skilled Worker route exempts employers from paying the ISC for four years and allows use of the lower new entrant salary thresholds.
  • Employers should consider transitioning current graduate visa holders to Skilled Worker visas to avoid the ISC increase and reduce long-term costs if a 10-year route to settlement becomes law (see 6 below).
    
    
    

Higher English Language Requirements and Introduction for Dependents

• Who Will It Affect?:
  Likely to apply at the point of settlement for existing skilled workers and their dependents, and at visa application for new dependent arrivals once introduced.

• Employer Considerations:
  • Existing Skilled Workers may wish to sponsor dependents now to avoid future language test requirements.
  • TSL job holders won't be able to sponsor dependents, further limiting talent appeal.
  • These changes could deter international applicants and should be considered in workforce planning.

Extension of the Qualifying Period for Settlement from 5 to 10 Years 

• Uncertainty Around Implementation:
  The Home Secretary's proposal has caused widespread concern. While not yet law, businesses should prepare for the possibility.
  

• Legal Precedent:
  In a 2009 High Court ruling regarding the Highly Skilled Migrant Programme, it was judged that retrospective changes to settlement eligibility were unlawful. Those already on a path to settlement should not be affected.

• Planning Implications:
  • Employers must consider the cost of supporting workers for 10 years instead of 5.
  • The UK's potential move to a 10-year path to citizenship would be the longest in the developed world, impacting international competitiveness.
  • Those already on a visa path to settlement have a legitimate expectation that they will continue to settlement under current rules.