As a further progression from this summer’s White Paper, the government has announced significant changes to the Immigration Rules affecting numerous UK immigration categories as well as changes to statutory instruments relating to various UK immigration costs. These changes will affect how businesses manage their overseas national workforce going forward.
Statement of Changes
The main changes and associated dates detailed in the most recent Statement of Changes are:
- Changes to English language requirement for economic migration routes – From 8 January 2026, new Skilled Worker, High Potential Individual and Scale Up migrants will be required to evidence their English language capability at the higher level of B2 (upper immediate). Individuals who are already in the UK can continue to rely on B1 for extensions on the same route.
- High Potential Individual institutions – With effect from 4 November 2025, the number of eligible institutions under this category will double however a cap of 8,000 applications a year is also being introduced.
- Change to reduce the duration of stay under the Graduate route – For applications submitted on/after 1 January 2027, individuals will be granted permission to remain in the UK for 18 months rather than 24 months. The period granted to PhD graduates will remain unchanged at 3 years. This reduction was introduced to encourage transition to Graduate level jobs and proper contribution to economy.
- Change to allow students to transition to the Innovator Founder route – With effect from 11 November 2025, there will be specific change to a Student’s conditions relating to work in the UK which will allow Students to establish a business in the UK and be self-employed where they have completed their course and are switching to the Innovator Founder route.
- Replacement of Part 9: Grounds for Refusal, with Part Suitability – With effect from 11 November 2025, Part Suitability will become the central reference point for all suitability-related refusal and cancellation grounds of permission.
Fee increases
This week and with immediate effect, the government announced the following fee increases from 21 October 2025:
- Priority processing of sponsor licence applications – £500
- Premium service fee for sponsor change of circumstances – From £200 to £350
- Premium service fee – From £500 to £750
The full list of updated Home Office fees can be found here.
Increase to Immigration Skills Charge
It has now been confirmed that from 16 December 2025, the Immigration Skills Charge will go up by 32% from the current £1,000 per year of sponsorship to £1,320 per year for large sponsors. For small companies the increase will be from £364 to £480 per year.
UK business will want to review the hiring plans and existing sponsored worker cohort to consider whether it would be suitable to assign certificates of sponsorship prior to 16 December 2025 and avoid the increase cost.
What’s on the horizon 2025/2026?
| Proposal | Timeframe |
| Expansion of eligible institutions under the High Potential Individual category | 4 November 2025 |
| Home Affairs Committee – Call for evidence on Earned Settlement | Deadline – 2 December 2025 |
| 32% increase in Immigration Skills Charge | 16 December 2025 |
| Changes to financial requirement for family routes | Before end of 2025 |
| English language requirement increasing to Level B2 (Skilled Worker, High Potential Individual, Scale Up) | 8 January 2026 |
| Earned settlement and British citizenship changes | Spring 2026 (TBC) |
| MAC review of Temporary Shortage List | Stage 1 – 9 Oct 2025 Stage 2 – July 2026 |
| MAC review of Skilled Worker salary requirements | Within 6 months from 3 July 2025 |
| Introduction of work strategy requirements for key sectors relying on high levels of international recruitment | TBC |
| ETIAS system rollout | Last quarter 2026 |
| Reduction of period of permission granted for Graduates | 1 January 2027 |
Recommendations for UK businesses
Given the changes afoot, we recommend that sponsors take the time to review a number of its’ processes in relation to the recruitment and retention of sponsored workers including:
- Review and assess future sponsorship needs for the business.
- Review and discuss the budget for sponsorship.
- Review and assess whether there is a need or scope to assign COS before 16 December 2025, ahead of the Immigration Skills Charge increase.
- Consider how long the business is looking to sponsor workers ahead of future changes.
- Consider your current Graduate cohort and whether the business has UK roles which could be filled by international students after sponsorship (therefore benefiting from an exemption from the Immigration Skills Charge).