• Insights

United Kingdom: Government Paper Sets Out Indefinite Leave to Remain Reforms and Launches Consultation

November 20, 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 government has published a paper setting out its proposals for Indefinite Leave to Remain (ILR) reforms and launching an associated consultation. The consultation will be open for submissions until February 12, 2026.    
  • The statement confirms plans to replace the current five-year qualifying period for ILR with a new, conditional “earned settlement” model that doubles that period to 10 years for most categories.
  • Applicants may be able to shorten the qualifying period if they meet earnings or integration benchmarks.
  • Those found non-compliant will face longer waits or refusal of ILR.
  • All applicants for ILR will, in any case, need to satisfy four mandatory eligibility pillars to qualify: Character, Integration, Contribution (including annual earnings of at least GBP 12,570 for at least three to five years), and Residence. The mandatory pillars are not part of the consultation, except for the duration of the earnings.

The situation

The UK government has published a paper setting out its proposals for Indefinite Leave to Remain (ILR) reforms and launching an associated consultation. The consultation will be open for submissions until February 12, 2026.

A closer look

  • ILR timeline doubled for most immigrants. Most individuals will be subject to a new standard 10-year qualifying period, which is double the current five years.
  • Other ILR timelines. The paper sets out other ILR qualifying periods for the following categories:
    • Lower-skilled roles. Those with skills below Qualifications Framework Level (RQF) Level 6 will qualify after 15 years.
    • Refugees. Refugees under core protection routes will qualify after 20 years.
    • Accelerated routes. Global Talent, Innovator Founder and foreign nationals under comparable accelerated routes will still be able to qualify after three years.
    • BN(O) category and Partners and Children of British Citizens. Those in the United Kingdom under the British Nationals (Overseas) category or as partners or children of British citizens will still be able to qualify after five years.
  • Potential changes in qualifying periods. Applicants may, however, be able to shorten (or be subject to longer) ILR qualifying periods if they meet, (or fail to meet), earnings or integration benchmarks. For example:
    • High earners. Those with taxable incomes (not just salaries) over GBP 50,270 will qualify after five years; those with income over GBP 125,140 will qualify after three years.
    • Public Service Employees.   Those who have worked a minimum five years in specified public-service roles (e.g. health, education, emergency services) will qualify after five years.
    • Civic volunteers. will enable applicants to apply for ILR after between five to seven years.
    • Advanced degree level English (C1) proficiency. Those able to speak high level English could apply for ILR after nine years.
    • Increased qualifying period. In contrast, those who claim public benefits for more than 12 months could have a further 10 years added to their qualifying period; and those who breach immigration laws could have anywhere between five to 10 years added to their qualifying period.
  • New mandatory conditions to qualify for ILR. The paper sets out four new mandatory eligibility requirements (that are not subject to consultation) that all applicants over 18 will need to satisfy to qualify for ILR based on: Character, Integration, Contribution and Residence. The contribution requirement includes annual earnings of at least GBP 12,570 for a minimum of three to five years.

Background

These reforms reflect the government’s ambition to make contribution a condition for settlement; and elevate the status to one that must be earned, rather than one accorded automatically. The rule changes’ proposed aim is to reward those who are considered high contributors while penalising those who are not. The declared reason is to assist and encourage integration, manifest control and limit access to public funds to those cohorts who have put more into the system than taken out.  

Impact

  • Consider consultation response. Employers with foreign employees should review the proposals and consider whether their organisation wishes to respond to the consultation, especially in areas such as earnings thresholds, dependants and the treatment of lower-skilled workers.
  • Review workforce and budget planning. Employers should identify employees who may benefit from accelerated routes (e.g. those earning GBP 50,270+) and should assess cost implications where longer sponsorship or residence may be required (e.g. RFQ 4–5 roles, and health & care workers).
  • Revisit sponsorship policies. Employers should consider projecting likely earnings three years ahead to maximise eligibility for high-earner reductions and early ILR.
  • Evaluate dependant policies. Since dependants would be assessed individually for ILR, employers should note that household composition and income may affect overall settlement outcomes. This could be one of the most critical areas for workforce planning, especially for those with children who will turn 18 during the lifecycle of a visa. Under the new rules, this could mean a main applicant qualifying at five years but a partner qualifying later if no qualifying period discounts apply (or not at all if the mandatory pillars are not met). Children would follow the second parent, meaning that if they turn 18, they may be required to meet the mandatory pillars, which include an earnings requirement. It is critical that government hear from employers and business about the impact to families (and therefore knock-on impact to businesses)

Looking ahead

Businesses should submit responses during the consultation period if they want to present any concerns or highlight potential impacts of the proposals to their employees and businesses. The reforms can be implemented through Statements of Changes, and therefore quickly after the consultation period ends. Once implemented, they will be difficult to reverse. Either way, the proposals represent a watershed change of the United Kingdom’s immigration architecture.

Fragomen can assist employers with submitting responses to the consultation. This alert is for informational purposes only. If you have any questions, please contact the global immigration professional with whom you work at Fragomen.

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

Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Director Isobel Neilson and Manager Sophie Jo Wasson examine how Malta’s Citizenship by Merit framework considers exceptional achievement and contribution alongside the country’s long-term priorities under Vision 2050, and what applicants should consider when developing a credible case.

Learn more

Media mentions

People Management: UK Right to Work Check Changes: What Businesses Need to Know

Partner Naomi Goldshtein discusses how new UK right to work requirements extend beyond direct employees and the steps businesses should take to understand and manage workforce compliance.

Learn more

Blog post

The Dutch-American Friendship Treaty at 70: How “Friendly” is it in Practice?

Partners Aviva Meerschwam and Christine Sullivan, Senior Associate Tuğba Özyakup and Junior Immigration Consultant Gabriela Gonzalez examine how the Dutch-American Friendship Treaty operates in the Netherlands and the US, and what the differences mean for entrepreneurs, investors and businesses pursuing transatlantic growth.

Learn more

Awards

Fragomen Named a Top 10 Finalist for the 2026 Cartus Masters Cup

Fragomen is a Top 10 finalist for the 2026 Cartus Masters Cup, Cartus’ highest supplier honor recognizing exceptional service, collaboration, innovation and commitment to clients and relocating employees.

Learn more

Media mentions

SHRM: Proposed $103,265 H-1B Is Changing Talent Acquisition Strategy

Partner Bo Cooper discusses the proposed $103,265 H-1B fee, potential legal challenges and its broader implications for employers and high-skilled immigration.

Learn more

Media mentions

Business Insider: The Hidden Sacrifices of Chasing an H-1B Career in America

Partner Aaron Blumberg discusses how proposed changes to the H-1B program could affect workers facing layoffs and families navigating dependent visa status.

Learn more

Blog post

Permanent Residence in Germany: Why Eligible Foreign Nationals Should Consider Applying Early

Senior Associate Arta Djahanschiri outlines the principal pathways to permanent residence in Germany, the flexibility and security the status can provide and why eligible foreign nationals should consider applying early.

Learn more

Blog post

Proposed Changes to Naturalisation by Residency in Ireland: What Does it Mean for Employers and Global Mobility Programmes?

Immigration Manager Jo Crawford examines proposed changes to Ireland’s naturalisation requirements and what they could mean for employers and global mobility programmes, including talent retention, workforce planning and business mobility. 

Learn more

Fragomen news

Comment on DHS Proposed $103,265 Fee on Cap-Subject H-1B Petitions.Learn more

Awards

Fragomen Receives Three 2026 Cartus Awards

Fragomen received three recognitions at the 2026 Cartus Global Network Conference for excellence in service, sustainability leadership and global citizenship.

Learn more

Blog post

Net Migration Policy: An Explainer Comparing Australia, Canada and the UK

Partner Jack (Eui Chul) Kim, Senior Counsel Dr. Anna Boucher, UK Government Affairs Strategy Director Shuyeb Muquit and Articling Student David Mucz examine how Australia, Canada and the UK measure net migration. They compare efforts to reduce migration with the need to maintain access to international talent, and explain the potential effects on employers, labor markets and economic growth.

Learn more

Media mentions

Bloomberg Law: White House H-1B Order Puts Employer Layoffs Under Microscope

Partner K. Edward Raleigh discusses how US employers should consider displacement and conduct a risk analysis when assessing H-1B filings in light of recent policy changes.

Learn more

Blog post

Malta Citizenship by Merit and Vision 2050: Who May Qualify and What Contributions Matter?

Director Isobel Neilson and Manager Sophie Jo Wasson examine how Malta’s Citizenship by Merit framework considers exceptional achievement and contribution alongside the country’s long-term priorities under Vision 2050, and what applicants should consider when developing a credible case.

Learn more

Media mentions

People Management: UK Right to Work Check Changes: What Businesses Need to Know

Partner Naomi Goldshtein discusses how new UK right to work requirements extend beyond direct employees and the steps businesses should take to understand and manage workforce compliance.

Learn more

Blog post

The Dutch-American Friendship Treaty at 70: How “Friendly” is it in Practice?

Partners Aviva Meerschwam and Christine Sullivan, Senior Associate Tuğba Özyakup and Junior Immigration Consultant Gabriela Gonzalez examine how the Dutch-American Friendship Treaty operates in the Netherlands and the US, and what the differences mean for entrepreneurs, investors and businesses pursuing transatlantic growth.

Learn more

Awards

Fragomen Named a Top 10 Finalist for the 2026 Cartus Masters Cup

Fragomen is a Top 10 finalist for the 2026 Cartus Masters Cup, Cartus’ highest supplier honor recognizing exceptional service, collaboration, innovation and commitment to clients and relocating employees.

Learn more

Media mentions

SHRM: Proposed $103,265 H-1B Is Changing Talent Acquisition Strategy

Partner Bo Cooper discusses the proposed $103,265 H-1B fee, potential legal challenges and its broader implications for employers and high-skilled immigration.

Learn more

Media mentions

Business Insider: The Hidden Sacrifices of Chasing an H-1B Career in America

Partner Aaron Blumberg discusses how proposed changes to the H-1B program could affect workers facing layoffs and families navigating dependent visa status.

Learn more

Blog post

Permanent Residence in Germany: Why Eligible Foreign Nationals Should Consider Applying Early

Senior Associate Arta Djahanschiri outlines the principal pathways to permanent residence in Germany, the flexibility and security the status can provide and why eligible foreign nationals should consider applying early.

Learn more

Blog post

Proposed Changes to Naturalisation by Residency in Ireland: What Does it Mean for Employers and Global Mobility Programmes?

Immigration Manager Jo Crawford examines proposed changes to Ireland’s naturalisation requirements and what they could mean for employers and global mobility programmes, including talent retention, workforce planning and business mobility. 

Learn more

Fragomen news

Comment on DHS Proposed $103,265 Fee on Cap-Subject H-1B Petitions.Learn more

Awards

Fragomen Receives Three 2026 Cartus Awards

Fragomen received three recognitions at the 2026 Cartus Global Network Conference for excellence in service, sustainability leadership and global citizenship.

Learn more

Blog post

Net Migration Policy: An Explainer Comparing Australia, Canada and the UK

Partner Jack (Eui Chul) Kim, Senior Counsel Dr. Anna Boucher, UK Government Affairs Strategy Director Shuyeb Muquit and Articling Student David Mucz examine how Australia, Canada and the UK measure net migration. They compare efforts to reduce migration with the need to maintain access to international talent, and explain the potential effects on employers, labor markets and economic growth.

Learn more

Media mentions

Bloomberg Law: White House H-1B Order Puts Employer Layoffs Under Microscope

Partner K. Edward Raleigh discusses how US employers should consider displacement and conduct a risk analysis when assessing H-1B filings in light of recent policy changes.

Learn more
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
    Travel and Mobility Considerations: Situation in the Middle EastNavigating Immigration Under the Second Trump AdministrationImmigration Matters: Your U.S. Compliance RoadmapCenter for Strategy and Applied InsightsView 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

  • Travel and Mobility Considerations: Situation in the Middle East
  • Navigating Immigration Under the Second Trump Administration
  • Immigration Matters: Your U.S. Compliance Roadmap
  • Center for Strategy and Applied Insights
  • 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
Important Updates
Important Updates
October 1, 2026 | JapanJapan: Stricter Permanent Residence Requirements
October 2, 2026 | United KingdomUnited Kingdom: Draft Code on Expanded Right to Work Scheme Clarifies Employer Obligations
October 2, 2026 | United KingdomUnited Kingdom: Expanded RTW Scheme in Effect; Further Employer Guidance Published
October 2, 2026 | United StatesUnited States: September 2026 DOL PERM and PWD Processing Times
October 2, 2026 | United StatesUnited States: U.S. Consular Services in Brazil Suspended
October 1, 2026 | JapanJapan: Stricter Permanent Residence Requirements
October 2, 2026 | United KingdomUnited Kingdom: Draft Code on Expanded Right to Work Scheme Clarifies Employer Obligations
October 2, 2026 | United KingdomUnited Kingdom: Expanded RTW Scheme in Effect; Further Employer Guidance Published
October 2, 2026 | United StatesUnited States: September 2026 DOL PERM and PWD Processing Times
October 2, 2026 | United StatesUnited States: U.S. Consular Services in Brazil Suspended
October 1, 2026 | JapanJapan: Stricter Permanent Residence Requirements
Subscribe

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
  • AI Transparency Statement
  • UK Regulatory Requirements

Our firm

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

Information

  • Attorney Advertising
  • Legal Notices
  • Privacy Policies
  • AI Transparency Statement
  • UK Regulatory Requirements

Have a question?

Contact Us
  • LinkedIn
  • Youtube
  • Instagram
  • Facebook
  • TikTok
  • 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.