- with Senior Company Executives and HR
Keeping up with the many changes to immigration policy is always a challenge but this year is promising to be one of the most transformative years in recent memory. Changes to entry requirements, language thresholds, sponsor compliance and long-term settlement pathways will have significant implications for employers of all sizes, from multinational corporations and recruitment firms to SMEs sponsoring for the first time.
With key measures coming into effect or under consultation through the first half of the year, employers must act now to protect existing workforce plans and ensure future viability. A thorough review of policies, processes and talent pipelines will be essential in Q1–Q2 2026.
Mandatory Electronic Travel Authorisation (ETAs)
From 25 February 2026, nationals of countries that previously did not require a visa, including the United States, Canada and EU member states, will need a digital permission known as an Electronic Travel Authorisation (ETA) before travelling to the UK. This change affects short-term business travel, interviews, site visits and corporate engagements.
Employers should update travel policies, educate affected staff and incorporate ETA checks into pre-trip processes. Carriers will deny boarding to travellers without the necessary ETA, increasing the risk of business disruption if overlooked.
Higher English Language Requirements
As of 8 January 2026, applicants under the Skilled Worker, Scale-up and High Potential Individual (HPI) routes must meet an English language level of B2, up from the current B1 standard. For employers reliant on international talent, particularly in care, engineering, tech and healthcare sectors, this presents immediate recruitment challenges.
HR and mobility teams should review job specifications, assess current and prospective hires against the new threshold and consider employer-sponsored language support where appropriate.
Stricter Sponsor Compliance
Home Office compliance expectations continue to tighten. Employers can expect more rigorous checks on legal right to work procedures, accurate reporting, retention of records and duty to prevent illegal working. Sponsor licences may be subject to increased scrutiny, audits and sanctions for non-compliance.
An early audit of current compliance frameworks is advisable. Employers should verify that Responsible Officers and Key Personnel are trained and that internal processes align with evolving Home Office guidance.
Planning for "Earned Settlement"
Consultations around proposed reforms to settlement pathways, which includes extending the qualifying period for Indefinite Leave to Remain (ILR) from five years to potentially ten for many work routes — signal a shift towards "earned settlement". While these changes will likely place from mid-2026 or beyond, employers should factor them into long-term retention planning and talent strategy.
Actions for Q1–Q2 2026
To prepare effectively:
- Audit your workforce and sponsorship status — identify who is affected by ETA and language changes.
- Update travel and global mobility policies — embed ETA requirements and pre-travel checks.
- Review job descriptions and sponsorship criteria — align with new English language thresholds.
- Strengthen compliance frameworks — conduct internal audits and train key personnel.
- Engage early with employees — communicate changes and provide support for transitions.
The landscape of UK immigration in 2026 is evolving rapidly. Employers who anticipate shifts, educate their teams and adapt policies early will mitigate risk, protect business continuity and maintain competitiveness in a global talent market.
Vicash Ramkissoon is a Legal Director in the Business Immigration team at Duncan Lewis Solicitors, with more than 25 years' post-qualification experience. He advises corporate sponsors, SMEs and high-net-worth individuals on all aspects of UK business and private immigration law.
Vicash has particular expertise in complex Skilled Worker applications and Sponsor Licence matters across sectors including technology, care, hospitality and professional services. He regularly advises on strategic immigration planning, sponsor compliance and risk management, and represents clients in immigration-related judicial review proceedings where necessary. His client base includes multinational employers as well as high-net-worth individuals from Asia and the Middle East seeking tailored immigration solutions.
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.
