Recommended immediate actions for sponsors 

To continue to benefit from the current Immigration Rules and transitional arrangements, sponsors should aim to assign CoS to potentially affected workers on or before 21 July 2025. They should also consider:

• Submitting well-documented requests for any required defined CoS as soon as possible (noting that processing is likely to slow down due to increased demand);
• Submitting well-documented requests for any in-country CoS allocations, using the priority service if available (noting that these may be slow to process due to increased demand and/or if any sponsor compliance queries arise, e.g. due to corporate structure changes);
• Assigning CoS as early as possible, noting that functions of the Sponsor Management System may be suspended in the days leading up to the change, to allow for updates in line with the Rule changes;
• Whether to issue the CoS for the maximum length possible, to avoid the impact of future salary threshold rises at extension stage, and to minimise the cost of the Immigration Skills Charge (ISC), if relevant;
• Whether to facilitate switches from the Student route to Skilled Worker rather than from the Graduate route, to benefit from an ISC exemption (noting that the exemption does not apply to Graduate route switchers); and
• What salary thresholds will need to be met at extension or settlement stage for workers who are due to extend with a CoS assigned from 22 July 2025, or to make an application for settlement on or after 22 July 2025.  

What is changing now?

Increasing the general salary thresholds for the Skilled Worker, Global Business Mobility and Scale-up routes

General salary thresholds are updated in line with the latest (2024) salary data from the Annual Survey of Hours and Earnings (ASHE) as follows:

Note the following:

• Individuals applying under the new Skilled Worker interim Temporary Shortage List (TSL) (see further details below) will need to meet the new undiscounted general salary threshold of GBP 41,700, or GBP 31,300 if the pre-4 April 2024 transitional arrangements apply to them;
• The ‘high earner’ threshold of GBP 73,900 that applies to the Senior or Specialist Worker route and UK Expansion Worker route has not been changed; and
• The lowest Skilled Worker general salary thresholds applicable to those in listed health and education occupation codes, and to those under pre-4 April 2024 transitional arrangements for STEM PhD, Immigration Salary List and new entrants were all increased to £25,000 from 9 April 2024. These remain as they are currently.

The new general salary thresholds represent routine market-based adjustments and will therefore apply, without any transitional arrangements, to individuals applying with a CoS issued on or after 22 July 2025. 

Increasing the occupation-based going rate salary thresholds for the Skilled Worker, Global Business Mobility and Scale-up routes

Occupation-based going rate salary thresholds are adjusted in line with 2024 ASHE figures. These will be applied to all individuals applying with a CoS assigned on or after 22 July 2025. Full details of the new rates are set out in the Statement of Changes, under the heading ‘Changes to Appendix Skilled Occupations’. 

Raising the Skilled Worker route minimum skills threshold

The minimum skills threshold is being raised from RQF Level 3 (A-level) to RQF Level 6 (bachelor degree level) – this removes approximately 180 medium-skilled occupations from eligibility unless they are already included on the Immigration Salary list or are included on the new interim Temporary Shortage List (discussed below).

Individuals already sponsored under the Skilled Worker route in RQF level 3 to 5 occupations when the changes are implemented (including those who successfully apply under the Rules in effect until 21 July 2025) may continue to be sponsored under transitional arrangements, including extending their permission and changing employment. The explanatory memorandum to the Statement of Changes notes that these arrangements ‘will not be in place indefinitely and will be reviewed in due course’. The presence of an intended ‘sunset’ provision is likely to cause anxiety amongst affected Skilled Workers, especially those who wish to settle in the UK. Affected individuals and their sponsors should monitor for further updates, and, in the meantime, work towards achieving settlement (if that is the goal) as soon as they become eligible.

The explanatory memorandum is silent on whether there will be transitional arrangements for settlement for affected Skilled Workers, presumably because the policy on this is yet to be determined in light of the White Paper’s ‘earned settlement’ proposal.

All existing Skilled Workers (including those who apply successfully apply under the Rules in effect until 21 July 2025) may also continue to take supplementary employment in Skilled Worker RQF 3+ occupations. This provision will however also be reviewed in due course.

Expanding the Immigration Salary List (ISL) on a temporary basis before abolition

The Government confirmed in the White Paper that it plans to abolish the ISL, and to replace it with a Temporary Shortage List (TSL). However, an interim measure will be put in place ahead of the Migration Advisory Committee (MAC) comprehensively reviewing the TSL. On 3 July 2025 Home Secretary commissioned the MAC to complete this review by early July 2026. Under this measure, the ISL will be expanded to include occupations at RQF levels 3 to 5, if the MAC has identified them as being in shortage in their 2023 or 2024 reviews.

Individuals sponsored under the ISL will be ineligible to bring dependants if they are sponsored for the first time with a CoS assigned on or after 22 July 2025. Skilled Workers who were eligible to be accompanied by dependants under the Rules in place up to 21 July 2025 will be covered by transitional arrangements. Children born in the UK will be exempt from this restriction, as will children for whom the worker has sole parental responsibility.

Introducing an interim Temporary Shortage List (TSL) to the Skilled Worker route

A new interim Temporary Shortage List (TSL) will cater for medium-skilled (RQF level 3 to 5) occupations identified as being important for progressing the UK’s Modern Industrial Strategy. An applicant must apply with a Certificate of Sponsorship assigned between 22 July 2025 and 31 December 2026. The Home Office states that the Government reserves the right to remove occupations from the TSL earlier if compliance issues are identified.

Further, occupations will only be added or remain on the TSL beyond the end of 2026 where:

• The MAC has advised inclusion/retention is justified;
• There is a workforce strategy in place; and
• Sponsors demonstrate they are committed to increasing recruitment from the domestic labour force.

From 22 July 2025, the eligible occupations for the interim TSL will be  set out within Appendix Skilled Worker, in a new para SW 6.1A.. Approximately 50 occupations are included.

Gradually removing care workers and senior carer workers from Skilled Worker sponsorship 

Unless a defined CoS has been assigned before 22 July 2025, it will not be possible to sponsor a care worker or senior care worker for entry clearance under the Skilled Worker route. The recently introduced requirement for sponsors to seek to firstly recruit from the in-country pool of displaced care workers will become redundant because of this change. 

In-country switches into these occupations will still be allowed for applications made before 22 July 2028, provided the applicant has been legally working for the sponsor for at least 3 months before their Certificate of Sponsorship is assigned. The Home Office has however stated that this arrangement will be kept under review, so it’s possible it could end earlier than currently indicated. 

Individuals who are already sponsored as a care worker or senior carer, or who are sponsored following an application made before 22 July 2028 will be eligible to make extension applications.

Amending the requirements for sponsoring nursing auxiliaries and assistants

The Home Office wishes to avoid the possibility sponsors attempting to use this occupation code to fill roles that are in effect carer or senior carer roles. A clarification is therefore being made to confirm the nursing auxiliary and assistant occupation only applies in environments were registered nurse roles also are present. It is not yet clear how this will be assessed – this may be explained in updated Home Office guidance due to be released on 22 July 2025.  

What is changing later?

The following White Paper proposals have been deferred until a later date:

• Discontinuing the Immigration Salary List;
• Comprehensively reviewing work route salary thresholds, including discounts – the MAC has been commissioned to do this, with their report due by early January 2026;
• Increasing the English language requirement for main applicants from CEFR Level B1 (intermediate) to B2 (upper intermediate) – this is due by the end of 2025;
• Introducing a stepped English language requirement for adult dependants, starting at CEFR Level A1 (beginner) at the first application, rising to CEFR Level A2 (elementary) at extension and to CEFR Level B2 (upper intermediate) at settlement – this is due by the end of 2025;
• Increasing the Immigration Skills Charge by 32%, i.e. to £1,320 per year for medium or large sponsors, or £480 per year for small or charitable sponsors – this is due by the end of 2025;
• Implementing earned settlement (and earned citizenship) – these developments will be consulted on later in 2025; and
• Bringing forward new requirements for work route dependants as part of a new overarching family policy – this is will be set out by the end of 2025. 

Need more help?

If you require assistance with an upcoming Skilled Worker application, please get in touch with your usual Lewis Silkin contact.