The Home Office published a Statement of Changes in Immigration Rules on 1 July 2025 introducing the first of the proposals indicated in the UK Immigration White Paper of 12 May 2025.
The changes primarily affect eligibility for sponsorship of workers under the Skilled Worker and Global Business Mobility ('GBM') routes, and take effect for Certificates of Sponsorship ('CoS') assigned from 22 July 2025 onwards.
Key changes
- Skilled Workers can only be sponsored long term in roles skilled to RQF 6 (Bachelor's degree). This brings the minimum skill level for Skilled Worker sponsorship into line with the GBM: Senior or Specialist Worker ('GBM: SSW') route.
- In addition to the general sponsorship salary thresholds increasing, there are increases to occupation based 'going rates' – which are often higher than the minimum salary threshold, and need to be checked on a case-by-case basis.
- There will be increased focus on sponsor compliance and training/recruitment from the resident workforce.
- Changes to shortage occupation list – 111 for temporary sponsorship only and salary 'discounts' abolished, but many RQF Level 3 roles imported as an interim measure following the skill level changes above.
- Expected by the end of 2025, the minimum English language
proficiency will increase as follows:
- B1 to B2 CEFR for Skilled Worker applicants
- B2 for applicants for Skilled Worker migrants applying for settlement
- PBS Partner Dependants – initial application A1, extension A2 and B2 for settlement
It is not yet clear whether any transitional arrangements will be included for extensions and settlement applications once these changes are introduced.
Recent changes to English language testing applied by test providers and changes by Ecctis to the degree certification process mean that processes may take longer and may have additional formalities to complete as part of obtaining the required English language evidence.
We can also expect a greater focus than in the past on evidence of recruitment and rationale for hiring and sponsoring a migrant worker instead of a settled worker, for Skilled Workers sponsored moving forward.
An increase to the Immigration Skills Charge and changes to the English language requirement have been excluded from this raft of changes, but these will come into force later this year. The English language requirement changes will not impact GBM:SSW migrants or their dependants, but will impact Skilled Workers and their Partner Dependants.
The ISC is going to be increased by 32%, which will mean the new ISC costs will be as follows:
| Sponsor size | One year sponsorship | Three years sponsorship | Five years sponsorship |
| Small | £364 to £480 | £1,092 to £1,440 | £1,820 to £2,400 |
| Large | £1,000 to £1,320 | £3,000 to £3,960 | £5,000 to £6,600 |
The date for this increase is to be confirmed, but will likely be implemented in September 2025.
Impact for existing sponsored workers
Workers that are already sponsored can continue in their current roles at their current rate of pay, regardless of these proposed changes.
There are going to be transitional arrangements under the Skilled Worker route which will allow workers currently sponsored in roles that fall below RQF 6 to extend their permission. These transitional arrangements will not be in place indefinitely, but no specific time frame has been given yet. The last date for extensions will likely be aligned with changes on the qualifying period for settlement, which will be the subject of consultations and transitional arrangements, expected to be published in Q4 2025.
There will be no transitional arrangements for the salary increases under the Skilled Worker and GBM:SSW routes. This means that some workers that are currently paid below the new minimum thresholds will need to have their salaries increased in order to extend their permission (note they do not need to have their salaries increased in order to retain their current permission).
The only exception to this is transitional arrangements for Skilled Workers that were first sponsored under the Rules in place prior to 4 April 2024, although note that the minimum salaries payable to his cohort have also increased. Note these transitional thresholds are in place until 4 April 2030 only.
Action for employers
- Urgently review candidates and roles for sponsorship.
- Where the changes mean a role or individual may not be sponsored in future, accelerate processes to ensure the individual's CoS is assigned no later than Monday 21 July 2025. Note that the sponsor management system ('SMS') is often taken offline in the days before major changes are implemented, to allow for updates to be made to the system. We therefore recommend being prepare to assign CoS by 18 July wherever possible, in case the SMS is unavailable on Monday 21 July.
- Defined CoS requests for overseas applicants regularly take more than one week to be reviewed by the Home Office and should therefore be requested by 11 July if intending to assign prior to 18 July.
- Review Dependants' English language proficiency and encourage Dependant applications to be submitted as soon as possible where there are concerns about English language level.
- Where there are concerns that an individual's role may fall below RQF 6, we can assess whether it would be possible to sponsor the individual under a more senior role/occupation code.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
