United Kingdom: Immigration White Paper Proposes Restrictive Immigration Overhaul

The immigration white paper proposes the following reforms, among others:

• Skilled worker sponsorship. Limiting skilled worker sponsorship to graduate-level roles Regulated Qualifications Framework (RQF) 6+), up from the current high-school level (RQF3 – A levels). Any roles below RQF6+ would need to be on a Temporary Shortage Occupation List – which would be subject to sectoral review.
• Care workers. Closing the Care Worker Visa pathway to new overseas applicants. During a transition period until 2028, visa extensions and in-country switching would be available for affected foreign nationals already present in the United Kingdom.
• Students. Reducing the validity period of the ‘Graduate Route’ to 18 months (down from the current 24 months). This route, which allows graduates to remain in the United Kingdom after their studies, would also be linked to future job criteria, as opposed to the current situation, where there is no job level condition.
• Long-term residence and citizenship. Increasing the necessary period of residence to be eligible for long-term residence to 10 years, up from the current five years. The government is also considering establishing a fast-track route under a social and economic contribution-based model, but details are not yet confirmed. Citizenship reforms would also mirror these changes, with necessary residence periods increasing to 10 years – up from the current five years.
• Language requirement changes. Increasing threshold requirements for main applicants already subject to the language requirement, who would need to achieve a B2 level of English under the Common European Framework of Reference (CEFR) system. The language requirement would also be applied to adult dependants (who would need to reach at least A1). It remains to be confirmed if this would apply across all routes.
• Highly skilled routes. Doubling the number of eligible institutions from which applicants for the High Potential Individual (HPI) route could graduate to qualify; and streamlining and scaling the Global Talent and Innovator Founder visas. The paper also proposes adding a 6% tuition levy to overseas tuition fees and stricter sponsor metrics (with a ‘Red-Amber-Green’ compliance system); narrowing certain family-based immigration routes; and expanding visa revocation powers to cover non-custodial convictions.

As is their intention, these reforms would make the UK immigration landscape considerably more restrictive. Foreign workers seeking to be employed in roles below RQF Level 6 in particular would be the most impacted by these proposals.

Although there will be increased challenges attracting foreign talent, we expect that existing employees should benefit from transitional provisions.

These proposed reforms are part of the UK government’s general attempts to reduce net migration (in favour of the domestic labour market), and continue a general trend of restrictive immigration policy observed in UK politics over the last 18-24 months.

• Effective date. To go into effect, these proposals will either require rule changes or entirely new legislation. Accordingly, the date of implementation of these reforms remains unknown.
• Minimum salary levels. The GBP 38,700 minimum salary threshold for the Skilled Worker Visa remains in place, but these thresholds will rise and may change further, subject to review by the Migration Advisory Committee. We are continuing to monitor the situation.
• Compliance and monitoring. As part of these reforms, and in line with Fragomen observations over the last 12 months, increased compliance monitoring and auditing are expected from UK authorities.