The Government’s May 2025 White Paper, “Restoring Control Over the Immigration System”, proposes significant reform across multiple areas of UK immigration policy. Framed as a reset of the legal framework governing migration, the proposals will affect work routes, settlement pathways, family migration, student sponsorship, and compliance requirements.
While the Government has positioned these reforms as necessary to reduce net migration and ease pressure on public services, they will also require immediate consideration by employers and sponsors reliant on overseas talent, as well as by individuals with plans to remain in the UK long-term.
Below is our overview of the principal changes.
Indefinite Leave to Remain
The most significant change to the settlement framework is the proposed increase to the qualifying period for indefinite leave to remain (ILR), from five years to ten years. This would apply to most immigration categories, though there are exceptions:
- dependants of British citizens will remain eligible to apply for ILR after five years provided they ‘remain compliant’.
- existing fast-track settlement categories, including Global Talent, will continue to offer ILR after three years in qualifying cases.
- the European Settlement Scheme remains unaffected and the Government doesn’t appear to intend to rework the Withdrawal Agreement.
- the White Paper also signals a future points-based model for “earned settlement,” allowing some migrants to qualify before ten years based on economic or social contributions, though the criteria are yet to be defined.
The Government will also raise the English language threshold for ILR from CEFR Level B1 to B2 (Independent User). This elevation in standards is consistent across most immigration categories.
Additionally, the system will now require all migrants extending their stay to demonstrate language progression—reaching A2 for visa extensions and ultimately B2 for settlement.
Employers and migrants may wish to review current immigration strategies in light of these changes, particularly where shorter routes to settlement are an important consideration.
Skilled Worker Route
One of the key proposals is an increase in the minimum skill level for the Skilled Worker visa, from RQF Level 3 (A-level equivalent) to RQF Level 6 (graduate level). This effectively reverses the 2020 expansion of the route to include mid-skilled occupations in the wake of Brexit.
It is worth noting that while the job must be classified at RQF Level 6, there is no requirement that the individual hold a degree, provided they have the requisite skills and experience to perform the role.
In practice, this change will reduce the number of eligible roles by approximately 180 occupations. Salary thresholds will also rise in line with the new skill level, although it is not yet clear by how much. Existing Skilled Worker visa holders in roles below RQF Level 6 will continue to be eligible for visa extensions and employer changes under transitional provisions.
For Skilled Workers and all other roles where language requirements already apply, the minimum standard will rise from B1 to B2. For adult dependants of students and workers (many of whom were previously exempt) there will now be a mandatory English language requirement at A1 on entry. The Government has indicated that this will be reviewed over time, with a view to increasing the minimum language threshold.
End of the Immigration Salary List
The White Paper proposes that the Immigration Salary List (ISL), which replaced the Shortage Occupation List earlier in 2024, be withdrawn. Under the ISL, certain roles are permitted lower salary thresholds for visa eligibility, subject to MAC (Migration Advisory Committee) review and recommendation. These concessions will no longer apply.
Instead, the Government says it intends to introduce a new Temporary Shortage List (TSL), with a more restrictive structure and limited access.
This change would reflect a significant policy shift. Rather than offering structural salary exemptions for hard-to-fill roles, the Government intends to compel employers to reduce reliance on migration through investment in local workforce development.
Employers currently relying on the ISL for cost-effective sponsorship will need to reassess their recruitment strategies and budget for higher salary thresholds across the board.
Temporary Shortage List
The new Temporary Shortage List (TSL) would apply to occupations at below degree level (i.e. RQF Levels 3–5) that are currently deemed by the MAC to be in shortage and that would otherwise no longer be eligible for sponsorship once the ISL is phased out.
This route will only be available if the following conditions apply:
- where the Migration Advisory Committee (MAC) advises it is justified;
- a proper workforce strategy is in place to reduce dependency on migrant labour;
- employers have made demonstrable efforts to recruit and train from the domestic workforce; and
- the sector is aligned with national priorities – e.g. contributing to the UK’s Industrial Strategy or delivering critical infrastructure.
Visa conditions under the TSL will also be significantly tightened, such as shorter visa terms, the inability to bring dependants, and exclusion from settlement. This would be a notable shift from the current ISL arrangements.
Importantly, the White Paper recognises that the new framework will take time to implement. As an interim measure, the TSL route would initially reflect existing shortages identified by the MAC, including roles critical to industrial delivery. So, while some continuity may exist in the short term, employers should be preparing now for a future in which access to overseas labour in RQF 3–5 roles might become more limited and conditional.
Closure of the Health and Care Worker visa to social care workers
Under transitional arrangements until 2028, the Government will permit visa extensions and in-country switching for care workers already in the UK with Skilled Worker visas. However, future overseas recruitment into these roles under this route will cease.
According to the Government, this decision follows reports of widespread exploitation in the sector and is part of a wider move to establish domestic recruitment and Fair Pay Agreements for care workers.
Increased Sponsor Obligations
Several changes are proposed which will have financial and administrative implications for sponsors and their sponsored workers:
- the Immigration Skills Charge will rise by 32% from £1,000 to £1,320 per year for medium or large sponsors, or from £364 to £480 per year for small or charitable sponsors.
- English language testing will apply to adult dependants of workers and students for the first time, initially set at B1, with an intention to raise this to B2 in the future.
- Basic Compliance Assessment thresholds for education sponsors will increase. Sponsors will now be required to maintain at least a 95% course enrolment rate and a 90% course completion rate.
Sponsors are advised to review their compliance procedures in anticipation of more stringent audit thresholds and enforcement activity.
Graduate and Student Routes
The Graduate Visa route will be reduced from two years to 18 months. There appears to be no differentiation or exceptions for PhD or other doctoral graduates.
The Government also intends to explore the introduction of a 6% tax on income from international students, payable by education providers and earmarked for reinvestment in the domestic skills sector.
These changes form part of a broader review of the UK’s international education strategy and are likely to affect both student recruitment and institutional compliance arrangements. Sponsors should review their current recruitment approaches and make changes where necessary ahead of the changes.
Expansion of Highly-Skilled Categories
In contrast with the overall tightening of eligibility criteria, the Government has committed to expanding certain high-skilled immigration categories. These include:
- the Global Talent route, which may see wider eligibility and continued access to three-year settlement;
- a review of the Innovator Founder route;
- an expansion of the High Potential Individual (HPI) route, with a potential doubling of qualifying institutions; and
- changes to the UK Expansion Worker category to attract business investment.
These developments are likely to be welcomed by employers and individuals operating in knowledge-based or innovation-driven sectors.
Family and Private Life Routes
The Government intends to simplify and reform the family and private life immigration framework, including:
- increasing the English language requirement for settlement across most routes from B1 to B2;
- introducing an English language requirement for adult dependants of students and workers;
- and tightening the legal framework around Article 8 (right to family life) claims, by legislating to clarify that the right to remain is a matter for Parliament rather than the courts.
These proposals suggest a significant shift in the approach to long-standing legal arguments relied upon by individuals resisting removal or seeking to regularise their status
Border and Compliance Enforcement
The White Paper outlines a renewed emphasis on enforcement, including:
- increased powers to refuse entry at the border where visa conditions have been breached;
- wider use of digital e-Visas to track compliance and reduce illegal working;
- and further legislative changes intended to streamline the removals process.
These developments will support a broader policy of system enforcement and sponsor accountability.
Conclusion
The Government’s proposals represent a comprehensive reworking of the UK’s immigration framework, with significant legal and operational implications. The overall direction is clear: tighter eligibility criteria, increased compliance obligations, and a renewed emphasis on domestic workforce development.
Employers, education providers, and individuals currently in the UK or planning to apply should assess how these changes may affect them, particularly in relation to settlement timelines, sponsorship eligibility, and longer-term immigration planning.
For further advice or to discuss how these reforms may impact your organisation or immigration strategy, please contact our team.
