Important Updates
Important Updates
February 13, 2026 | United States, EthiopiaUnited States: Termination of Ethiopia TPS Stayed for Now
February 13, 2026 | South AfricaSouth Africa: Electronic Travel Authorization Requirement Updates
February 13, 2026 | ThailandThailand: New Rules Forthcoming for Board of Investment-Promoted Companies
February 13, 2026 | United StatesTimes of India: The 2027 H-1B Season: Revised Strategies for Sponsoring Employers and Implications for Aspirants
February 13, 2026 | United StatesUnited States: Temporary Funding for DHS Could Lapse After Midnight, Though Immigration Benefits Processing Would Continue
February 13, 2026 | United States, EthiopiaUnited States: Termination of Ethiopia TPS Stayed for Now
February 13, 2026 | South AfricaSouth Africa: Electronic Travel Authorization Requirement Updates
February 13, 2026 | ThailandThailand: New Rules Forthcoming for Board of Investment-Promoted Companies
February 13, 2026 | United StatesTimes of India: The 2027 H-1B Season: Revised Strategies for Sponsoring Employers and Implications for Aspirants
February 13, 2026 | United StatesUnited States: Temporary Funding for DHS Could Lapse After Midnight, Though Immigration Benefits Processing Would Continue
February 13, 2026 | United States, EthiopiaUnited States: Termination of Ethiopia TPS Stayed for Now
Subscribe
Fragomen.com home
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
Search Fragomen.com
  • Our Services
    For EmployersFor IndividualsBy IndustryCase Studies
  • Our Tech & Innovation
  • Our People
  • Our Insights
    Worldwide Immigration Trends ReportsMagellan SeriesImmigration AlertsEventsMedia MentionsFragomen NewsBlogsPodcasts & Videos
  • Spotlights
    Navigating Immigration Under the Second Trump AdministrationFragomen Consulting EuropeImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsVietnamese ImmigrationView More
  • About Us
    About FragomenOfficesResponsible Business PracticesFirm GovernanceRecognition

Our Services

  • For Employers
  • For Individuals
  • By Industry
  • Case Studies

Our Tech & Innovation

  • Our Approach

Our People

  • Overview / Directory

Our Insights

  • Worldwide Immigration Trends Reports
  • Magellan Series
  • Immigration Alerts
  • Events
  • Media Mentions
  • Fragomen News
  • Blogs
  • Podcasts & Videos

Spotlights

  • Navigating Immigration Under the Second Trump Administration
  • Fragomen Consulting Europe
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • Vietnamese Immigration
  • View More

About Us

  • About Fragomen
  • Offices
  • Responsible Business Practices
  • Firm Governance
  • Recognition
Select Language
  • English
  • French
  • French - Canadian
  • German

Select Language

  • English
  • French
  • French - Canadian
  • German
ContactCareersMediaClient Portal
  • Insights

United Kingdom: Clarification on Costs That Can be Recouped from Sponsored Workers

September 4, 2025

insight-news-default

Country / Territory

  • United KingdomUnited Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

At a Glance

  • The UK Home Office has recently provided clarity on costs that can and cannot be recouped from sponsored workers.
  • It has also clarified the meaning of rules introduced in April 2025 on costs that can be claimed back but that will reduce the salary of Skilled Workers for the purposes of the minimum salary calculation.
  • Sponsors of foreign workers in the United Kingdom should ensure that they comply with policies on recoupment of fees, as failing to comply with these requirements could lead to refused or curtailed visa applications, and/or adverse action being taken against a sponsor’s licence.

The situation

The UK Home Office has recently provided clarity on costs that can and cannot be recouped from sponsored workers. Due to increasing sponsorship costs, it is important that sponsors understand what they can lawfully recoup from workers and what costs need to be covered by sponsors in order to remain compliant with the law.

A closer look

  • Examples of costs that can never be reclaimed from any sponsored worker:
      • Licence fees (and associated legal costs for applying for or maintaining the licence);
      • Certificate of Sponsorship (CoS) fees;
      • Immigration Skills Charges; and
      • Legal fees that relate to assigning a CoS.
  • Skilled Worker costs that can be reclaimed. The following are examples of costs that can be reclaimed from Skilled Workers, but are deemed ‘business costs, immigration costs or investment’ and therefore reduce the salary for the purposes of minimum salary level (MSL) calculation include:
      • Visa fees;
      • Immigration Health Surcharge (IHS);
      • Priority fees (only where the worker had a genuine choice);
      • Legal fees relating to a visa application (only where the worker had a genuine choice); and
      • Dependant fees.

  • Clawback clauses which are conditional (where repayments only need to be made if the worker leaves their employment early) are not considered to be deductions from salary for the purpose of the rule. However, they must be reasonable and not in place to prevent sponsored employees from leaving their employment.
  • Loans. Genuine loan arrangements should not impact MSL calculations. However, where a sponsor is paying directly for items or costs (such as IHS) and then recouping from the applicant, this is not considered a loan and will impact the MSL.
  • Implementation. The rule on MSL calculations sets out how salaries will be considered at the application stage for Skilled Worker visas submitted on or after April 9, 2025. The Home Office is not reassessing salaries set out in past applications. However, the prohibition on passing on associated legal fees for Skilled Worker CoS issuance is applied from December 31, 2024, and not when the guidance was clarified in April.
  • Calculation. Deductions will be averaged over the duration of the visa for the purpose of salary confirmation, rather than calculated at the actual repayment rate.

Background

On April 9, 2025, a new salary deduction rule came into force for Skilled Workers, as reported in our alert, updated March 12, 2025. This rule affects how the Home Office calculates whether a worker’s salary meets the minimum threshold. This rule is designed to prevent salary thresholds from being met through certain payments made by employees themselves.

The changes in April also clarified a change in December 2024 that legal fees in relation to assigning a Skilled Worker CoS cannot be reclaimed and extended this to other sponsorship.

Impact

Employers should ensure that their policies on recoupment of fees comply with these rules and that permitted recoupments are factored into salary calculations.

Failure to comply with these requirements could lead to refused or curtailed visa applications, and/or adverse action being taken against a sponsor’s licence.

Looking ahead

The clarification demonstrates the UK Home Office’s intention to restrict the practice of recovering sponsorship costs from sponsored workers and to ensure that Skilled Workers receive the salary offered to them.

This alert is for informational purposes only. If you have any questions, please contact the global immigration professional with whom you work at Fragomen or send an email to [email protected].

Country / Territory

  • United KingdomUnited Kingdom

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Share

  • Twitter
  • Facebook
  • LinkedIn

Explore more at Fragomen

Blog post

Time to Act: Three Key Questions for Employers Ahead of March 1 Remuneration Increases for Employment Permits in Ireland

Immigration Director Deirdre Murray explores the impact of upcoming employment permit changes on employers and workforce planning in Ireland. 

Learn more

Video

Global Entry | #MobilityMinute

Director David Iannella discusses how Global Entry can help frequent business travelers navigate US entry more predictably and access TSA PreCheck.

Learn more

Video

London Fashion Week 2026

Manager Russell Hodges and Associate Gurpreet Phalora explain key UK immigration considerations for London Fashion Week 2026.

Learn more

Advisory services

The EU Blue Card Recast Through the Employer Lens

Senior Counsel Jo Antoons and Immigration Supervisor Elisabeth Kamm explore the EU Blue Card recast and its impact for employers, highlighting how hiring, retention and mobility decisions are affected. 

Learn more

Media mentions

Times of India: The 2027 H-1B Season: Revised Strategies for Sponsoring Employers and Implications for Aspirants

Partner James Pack on US H‑1B updates and what employers should know for the upcoming lottery.

Learn more

Immigration analysis

Applying for Swiss Citizenship: When Timing and Eligibility Matter

Manager Konstantin Schmid provides a practical overview of Swiss citizenship routes, eligibility rules and common reasons applications are delayed or refused. 

Learn more

Media mentions

CNN: These Americans Are Clinging to Hope for Italian Citizenship

Manager Pierangelo D’Errico discusses how recent changes to Italy’s citizenship rules are affecting applicants with Italian ancestry.

Learn more

Podcast

Space for Everyone: Women in Space - Breaking Barriers, Shaping the Future

Director Laxmi Limbani discusses how women are shaping the global space sector, the barriers they face and what is needed to support a more inclusive space workforce.

Learn more

Media mentions

Games Industry: Tightening Immigration Rules Will Impact the Games Industry in 2026

Senior Manager William Diaz outlines how immigration changes in the US and UK may affect workforce planning and mobility for the games industry in 2026.

Learn more

Media mentions

Global Mobility Lawyer: Talent Fault Line: How Modern Risks Are Reshaping Global Mobility

Partner Julia Onslow-Cole highlights how global mobility is becoming a strategic, board-level consideration requiring careful planning, compliance and workforce management.

Learn more

Video

Ireland Employment Permit Salaries: Hiring and Renewal Risks for Employers

Director Fatima Aydin outlines Ireland’s roadmap for increasing minimum annual remuneration salary thresholds and the implications for employer workforce planning and compliance.

Learn more

Video

Samba, Stamps and Seleção: Moving Football Across South America | #FragomenFC - Ep. 14

In this episode of the Fragomen FC, Partner Rick Lamanna, Senior Manager Jake Paul Minster, Manager Gustavo Kanashiro and Manager Sergio Flores discuss how immigration systems across the Americas shape football mobility, compliance and cross-border movement throughout South America.

Learn more

Blog post

Time to Act: Three Key Questions for Employers Ahead of March 1 Remuneration Increases for Employment Permits in Ireland

Immigration Director Deirdre Murray explores the impact of upcoming employment permit changes on employers and workforce planning in Ireland. 

Learn more

Video

Global Entry | #MobilityMinute

Director David Iannella discusses how Global Entry can help frequent business travelers navigate US entry more predictably and access TSA PreCheck.

Learn more

Video

London Fashion Week 2026

Manager Russell Hodges and Associate Gurpreet Phalora explain key UK immigration considerations for London Fashion Week 2026.

Learn more

Advisory services

The EU Blue Card Recast Through the Employer Lens

Senior Counsel Jo Antoons and Immigration Supervisor Elisabeth Kamm explore the EU Blue Card recast and its impact for employers, highlighting how hiring, retention and mobility decisions are affected. 

Learn more

Media mentions

Times of India: The 2027 H-1B Season: Revised Strategies for Sponsoring Employers and Implications for Aspirants

Partner James Pack on US H‑1B updates and what employers should know for the upcoming lottery.

Learn more

Immigration analysis

Applying for Swiss Citizenship: When Timing and Eligibility Matter

Manager Konstantin Schmid provides a practical overview of Swiss citizenship routes, eligibility rules and common reasons applications are delayed or refused. 

Learn more

Media mentions

CNN: These Americans Are Clinging to Hope for Italian Citizenship

Manager Pierangelo D’Errico discusses how recent changes to Italy’s citizenship rules are affecting applicants with Italian ancestry.

Learn more

Podcast

Space for Everyone: Women in Space - Breaking Barriers, Shaping the Future

Director Laxmi Limbani discusses how women are shaping the global space sector, the barriers they face and what is needed to support a more inclusive space workforce.

Learn more

Media mentions

Games Industry: Tightening Immigration Rules Will Impact the Games Industry in 2026

Senior Manager William Diaz outlines how immigration changes in the US and UK may affect workforce planning and mobility for the games industry in 2026.

Learn more

Media mentions

Global Mobility Lawyer: Talent Fault Line: How Modern Risks Are Reshaping Global Mobility

Partner Julia Onslow-Cole highlights how global mobility is becoming a strategic, board-level consideration requiring careful planning, compliance and workforce management.

Learn more

Video

Ireland Employment Permit Salaries: Hiring and Renewal Risks for Employers

Director Fatima Aydin outlines Ireland’s roadmap for increasing minimum annual remuneration salary thresholds and the implications for employer workforce planning and compliance.

Learn more

Video

Samba, Stamps and Seleção: Moving Football Across South America | #FragomenFC - Ep. 14

In this episode of the Fragomen FC, Partner Rick Lamanna, Senior Manager Jake Paul Minster, Manager Gustavo Kanashiro and Manager Sergio Flores discuss how immigration systems across the Americas shape football mobility, compliance and cross-border movement throughout South America.

Learn more

Stay in touch

Subscribe to receive our latest immigration alerts

Subscribe

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • UK Regulatory Requirements

Our firm

  • About
  • Careers
  • Firm Governance
  • Media Inquiries
  • Recognition

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • Twitter

© 2026 Fragomen, Del Rey, Bernsen & Loewy, LLP, Fragomen Global LLP and affiliates. All Rights Reserved.

Please note that the content made available on this site is not intended for visitors / customers located in the province of Quebec, and the information provided is not applicable to the Quebec market. To access relevant information that applies to the Quebec market, please click here.