On 1 July 2025, the Home Office published a significant Statement of Changes to the Immigration Rules (HC 997), building on proposals set out in the Government’s Immigration White Paper. These changes mark a key stage in what the Government has termed a “complete immigration reset”, aimed at reducing net migration, tightening work visa criteria, and strengthening compliance.
At Clarkslegal LLP, we outline the key updates, how they affect employers and visa holders—particularly those on the Skilled Worker and Global Business Mobility (GBM) routes—and how our team can assist you in staying compliant and ahead of policy changes.
Summary of Key Changes (Effective 22 July 2025)
Skilled Worker Route – Higher Skill and Salary Thresholds
From 22 July 2025:
New applicants under the Skilled Worker route must be sponsored in occupations at RQF Level 6 (graduate level) or above, reversing the 2020 post-Brexit move to RQF Level 3.
This disqualifies approximately 180 occupations from the route, unless they are listed on the Immigration Salary List or the new Temporary Shortage List, or the applicant is already within the route.
The general salary threshold has increased from £37,800 to £41,700, with occupation-specific rates updated in line with the 2024 Annual Survey of Hours and Earnings (ASHE).
The Global Business Mobility (GBM) Senior or Specialist Worker salary threshold has risen to £52,500 (from £48,500).
Transitional provisions will allow current visa holders and those with pending applications to continue working in now ineligible roles. However, these arrangements are subject to future review, and there are no transitional exemptions for the updated salary levels.
Restructured Appendix Skilled Occupations
The occupation appendix has been reorganised to clearly distinguish eligible roles by skill level. For the health sector, corrections have been made to reflect Agenda for Change pay bands in Scotland, ensuring proper alignment.
Phasing Out of the Immigration Salary List and New Temporary Shortage List
From 22 July 2025:
Occupations at RQF levels 3–5 will continue to qualify under the Skilled Worker route only if listed on either:
- The expanded Immigration Salary List (ISL), or
- The new Temporary Shortage List (TSL).
The ISL and TSL will operate as interim tools to support roles deemed critical under the UK’s Modern Industrial Strategy, with both lists scheduled for review and phased out by the end of 2026—with limited exceptions for adult social care roles.
Important: RQF Level 3–5 workers sponsored under these lists will not be permitted to bring dependants, unless:
They were already on the Skilled Worker route before 22 July 2025;
The dependant is a UK-born child or the worker has sole parental responsibility.
Significant Changes for Adult Social Care Workers
From 22 July 2025, the Skilled Worker route will close to new entry clearance applications for care worker and senior care worker roles.
However, in-country switching will be permitted until 22 July 2028, provided:
- The worker has been employed by their sponsor for at least three months, and
- The Certificate of Sponsorship is issued accordingly.
This reflects concerns around non-compliance, exploitation, and the over-reliance on the overseas care workforce. The current policy that prioritises recruitment from within the Skilled Worker route will be removed.
Closure of the ARAP Scheme
Effective 1 July 2025 at 15:00 BST, the Afghan Relocations and Assistance Policy (ARAP) scheme has closed to new principal applicants. Family applications remain open, and cases submitted prior to closure will still be considered.
The Afghan Citizens Resettlement Scheme (ACRS) will also close to new referrals, although existing cases will be processed.
The Global Business Mobility (GBM) Senior or Specialist Worker salary threshold has risen to £52,500 (from £48,500).
Neonatal Care Leave and Sponsorship Absences
From April 2025, neonatal care leave became a statutory entitlement. It is now a valid reason for sponsored workers to be absent from work without affecting their visa compliance.
EU Settlement Scheme: Change in Continuous Residence Test (HC 836)
From 16 July 2025:
Pre-settled status holders will qualify for settled status if they have been resident in the UK for 30 months in the past 60 months, regardless of gaps in residence.
This removes the prior requirement that no absence could exceed six months in any 12-month period.
Applicants previously refused on residence grounds may now be eligible to reapply or will be automatically reconsidered under these new criteria.
How Clarkslegal LLP Can Help
These changes are significant and will affect workforce planning, recruitment strategy, and immigration compliance across sectors. At Clarkslegal LLP, our specialist Business Immigration team provides clear, strategic advice to:
Employers
- Audit current workforce for roles affected by new thresholds or restrictions
- Plan ahead for TSL/ISL expirations and visa renewals before transitional periods end
- Support licence compliance and offer training to HR teams
- Reallocate workers impacted by role removals or salary changes
Visa Applicants and Workers
- Advise on switching options, ILR eligibility, and dependent family applications
- Help care workers plan ahead for transition before the 2028 deadline
- Assess new salary and skill level eligibility under GBM and Skilled Worker routes
Public and Third Sector
Offer insight into how these rules affect healthcare, care, construction, and logistics sectors
Provide representation and legal strategy in challenging sponsor decisions
Get in Touch
To discuss how the new immigration rules may affect you or your organisation, contact the Clarkslegal immigration team.
