Immigration White Paper 2025 - restoring control over the immigration system

Posted: 15/05/2025

The government's white paper published on 12 May 2025 promises to radically reform the immigration system so that it is 'controlled, managed and fair'. While there has been a lot of talk in the press about the timing of the release of the paper, in reality the government has been working on a proposal to reform the immigration and skills system since it was elected.

The white paper is built on five core principles:

1. reducing net migration;
2. upskilling;
3. fair and effective system;
4. enforcement;
5. integration.

In this briefing we summarise some of the key proposals impacting businesses, education providers, individuals and their families.

The timeline for implementing the proposals remains uncertain, as several require prior consultation scheduled for later this year. Staying informed and preparing for potential changes will be key in ensuring a smooth transition. Below is a summary of the main proposed changes:

Work routes

• Skilled Worker

Minimum skill level and salary increases: Skill level for sponsorship to return to graduate level (RQF level 6), which will make approximately 180 occupations ineligible for sponsorship. This will not affect current skilled worker visa holders.

Earned settlement: The government would be consulting on increasing the qualifying period for settlement from 5 to 10 years, with the possibility that this could be reduced based on 'points-based' contributions to the UK economy and society.

Workforce strategies: A Labour Market Evidence Group (LME) will be established to advise on the state of the labour market and inform on policy making. Based on their evidence, key sectors with high levels of overseas recruitment will need to produce workforce strategies which sponsors will then need to adhere to, if they want to continue recruiting from overseas.

Immigration Skills Charge: This is set to increase by 32% from £364 to approximately £481 per year of sponsorship for small businesses (including charities) and from £1,000 to £1,320 for medium and large sponsors.

Shortage occupations: Create a new Temporary Shortage List and abolish the current Immigration Salary List (and the discount on salaries). It will include occupations with a skills requirement of RQF 3-5 (below degree level) with long term shortages. Initially, occupations already identified by the Migration Advisory Committee (MAC) as being in shortage will be listed. This category will be time limited, is unlikely to lead to settlement and will not allow family members to join applicants.

Social Care visa route: This route will be closed for new applications from abroad. A transitional period will allow sponsors to recruit candidates already in the UK until 2028, but this will be kept under review.

English language: The English language requirement will be increased from level B1 to B2.

Family members: Introduce salary thresholds for all skilled workers seeking to bring in dependants.

• Other work routes

Graduate route: The visa duration will be reduced from two years (for bachelor's and master's degree graduates) and three years for PhD holders to 18 months.

High Potential Individual (HPI): Currently open to overseas graduates of the top 50 non-UK universities, this route will be expanded to include graduates from twice as many institutions. Unlike the Graduate route, there is no proposal to reduce the duration of this visa to 18 months.

Global business mobility: The number of expansion workers an overseas business can send to the UK to support establishing a presence in the UK will be doubled.

Global Talent: The application process will be simplified and streamlined for top scientific and design talent.

Innovator Founder visa: This route will be reviewed to determine if it adequately supports entrepreneurial talent currently studying at UK universities to move into this immigration category.

The Future technology research and innovation GAE scheme: The number of places on the scheme will be increased, although this is not currently subject to a cap.

Enforcement activity

In the next few months, the government will roll out an advanced data management system which will provide enforcement officers with access to digital identity and immigration status information for overseas nationals and make the issuing of civil penalties more immediate.

What steps should businesses take now?

While there are no set dates for the changes to come in, HR teams can begin preparing by:

• reviewing planned recruitment that may be affected, including individuals who may need to switch routes and assessing budgetary requirements;
• establishing dedicated hotlines for international employees;
• conducting a compliance audit to ensure all systems and processes (including Right to Work checks) align with UKVI requirements.

The government will consult on many of these proposals. Employers hiring under work routes should try to get involved in the process to ensure their sector's voice is heard.

Education providers and students  

The white paper outlines several significant changes for education providers and international students which will impact sponsor obligations, recruitment practices, and post-study work opportunities:

Basic Compliance Assessment (BCA): The minimum pass requirement of each BCA metric will be raised by 5%: refusal rate to 5%; enrolment rate to 95% and course completion rate to 90%. Implement a new Red-Amber-Green banding system to rate BCA performance which will be publicly available

Compliance: New interventions will be introduced for sponsors who are close to failing their BCA metrics, including bespoke action plans and restrictions on CAS allocation

Agents: Sponsors using agents will be required to sign up to the Agent Qualify Framework

Recruitment: Sponsors requesting significant increases in their CAS allocation must demonstrate that local impact has been considered.

Short-Term Study route: The processes of accreditation bodies will be reviewed to ensure they are robust, given the currently high level of short-term study visa refusal rates.

Levy on Higher Education tuition: Further details on this levy will be set out in the Autumn Budget.

Graduate Route: The visa duration will be reduced from 2 years (for bachelor's and master's degree graduates) and 3 years for PhD holders to 18 months.

What steps should education providers take now?

While there are no set dates for the changes to come into place, institutions should:

• immediately review BCA performance across all metrics and seek advice if there are any concerns;
• reassess recruitment strategies and agent networks;
• conduct an independent compliance audit to ensure that any areas of concern are actioned straight away.

Individuals and family members 

The proposals also introduce new requirements for individuals and families navigating the immigration system:

Finances: A financial requirement will be introduced across the board to ensure the family unit has sufficient funds. 

English language: English language requirements will be expanded to include all adults dependants. The level required will be basic with a higher level to be achieved at extension.

Earned settlement: The government would be consulting on increasing the qualifying period for settlement from 5 to 10 years, with the possibility that this could be reduced based on 'points-based' contributions to the UK economy and society. This change will not apply to family members of British citizens and victims of domestic violence.

Earned citizenship: The requirements for earned citizenship will be aligned with those for earned settlement, extending the qualifying period, with the potential for those with greater contributions to qualify sooner.

What steps should individuals take now?

While there are no set dates for when these proposals are set to be implemented, individuals currently eligible for settlement or citizenship may want to consider making their applications under the current rules while things are more certain.

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