The White Paper and Immigration Reforms

On 12 May 2025, the UK government released a White Paper titled ‘Restoring control over the immigration system’ outlining significant proposals to reform the current immigration system. The document sets out a wide range of changes to key visa routes and general immigration requirements. Below is a summary of the most important proposed reforms:

Skilled Worker visa updates

The proposed changes to the Skilled Worker route focus on raising thresholds and tightening eligibility criteria.

• Increase in the Immigration Skills Charge (ISC):
  The government proposes a 32% increase in the ISC, raising it from £1,000 to approximately £1,320 per year of sponsorship. Introduced in 2017, the ISC is a mandatory fee paid by UK employers when sponsoring skilled migrant workers. The funds are allocated to the Department for Education to support local workforce training, further education, and apprenticeships. In 2022/23, ISC revenue reached £553 million according to the Migration Advisory Committee Annual Report 2024.
• Raising the Skills Threshold:
  The proposed shift to allow sponsorship of roles at RQF Level 6 (degree-level roles only) would make a significant number of jobs, estimated at over 170 occupations, ineligible for sponsorship. These roles could in theory be added to a new Temporary Shortage Occupation List, with the existing Immigration Salary List abolished, but the government claims the new list will be under constant review.
• Increase in Salary Thresholds:
  Although not confirmed, there is speculation that the base salary requirement could rise to approximately £50,000, following the exclusion of lower-skilled jobs form sponsorship.
• Closure of visa sponsorship for care workers:
  This route will close to new overseas senior care workers, though in-country extensions will be allowed until 2028. The change shifts pressure onto adult social care providers to rely on the domestic workforce, amid already stretched local authority budgets.

Extended settlement (Indefinite Leave to Remain)
The UKVI proposes an extension of the qualifying period for settlement from 5 to 10 years for all work visa routes. A move has raised alarm among migrants already on the pathway to ILR, because the UKVI has not confirmed that it will not include existing visa holders. At the same time, the government indicated that faster settlement routes may be available for individuals who make significant economic or societal contributions. There will be consultations over this proposal during 2025, so we expect the new legislation to be in place by spring 2026.

Graduate visa update
The Graduate Visa duration is planned to be reduced from 24 months to 18 months. The government argues that graduates should transition more quickly into higher-skilled roles, because in practice many currently take up lower-skilled jobs.

Student Visa compliance for sponsors
Proposed changes include:

• Introduction of a levy on higher education provider income from international students, to be reinvested into the UK’s higher education sector.
• Stricter compliance requirements for universities, including enhanced monitoring of student attendance and course completion rates.

Other economic routes
To support innovation and economic growth, the White Paper proposes enhancements to various business immigration routes:

• Expansion of research internship schemes, particularly in Artificial Intelligence (AI).
• Extension of the Global Talent Visa to include more scientific and design professionals.
• Extend Innovator Founder visa options to support university-based entrepreneurs.
• Doubling of the Expansion Worker licence sponsorship quota for companies establishing a UK presence.
• Broadening eligibility for the High Potential Individual (HPI) route to include graduates from more global institutions.

General Immigration Requirements
Several overarching changes are also proposed:

• Higher English language requirements:
  • Main applicants for certain work visas may need to meet a B2 CEFR level of English, which is currently set at B1.
  • New English language requirement to be introduced for dependents starting at A1 CEFR level.
• Stricter compliance rules for employers and educational sponsors, who should expect to face tighter scrutiny and enforcement.
• Digital transformation of border control. The UK will continue implementing its Digital Border initiative, including the rollout of contactless eGates, ending issuing vignettes and passport collection at Visa Application Centres (VACs) for key visa routes. Indeed, UKVI latest eVisa guidance update on 9 June 2025 confirmed that UK visa vignettes will no longer be issued by UKVI (UK Visas and Immigration) after June 11, 2025. Instead, UKVI will require a UKVI account and digital immigration status (eVisas) for travel to the UK. This change applies to all visa categories, including student, work, and other visas.

These proposals signal a decisive shift in UK immigration policy toward higher-skilled migration and stricter controls, while also aiming to invest more in domestic talent development. The government is expected to open a consultation period before finalising any legislative changes later in 2025.

Tech Nation to remain the Endorsing Body for Global Talent visa in technology

Following over 2 years of uncertainty, Tech Nation confirmed they are to remain the Government approved authority for Digital Technology endorsements for Global Talent visa applicants for further 3 years. They are expected to continue endorsing Global Talent applicants in the digital technology sector, and it remains to be seen whether the process will change as a result of new contract with the UKVI.

Youth Mobility Scheme can include EU nationals

The UK Government is exploring possibility of expanding Youth Mobility Scheme to EU countries as part of the recent EU-UK trade deal.
The scheme allows young people to spend up to 2 (or 3) years in countries participating in the program. The UK has currently reciprocal Youth Mobility agreements with Australia, New Zealand, Canada, South Korea, Andorra, Iceland, Japan, Monaco, San Marino and Urugay. A similar scheme is in place with India that is limited by ballot and higher healthcare charge.
The European Union and the UK has agreed in principle to further co-operate on the Scheme which would allow young British and EU citizens to freely travel and work in the respective countries for a time-limited period.

Biometric UK visa appointments in Russia

Visa applicants applying from Russia keep experiencing a shortage of biometric appointment slots. Applicants are unable to secure appointments in any VFS locations in Russia which significantly delays visa processing times. Those applying from Russia can expect a long wait to secure the appointment and where possible, consider applying from another location.

BRP and eVisa deadline on 1 June 2025

The grace period for using BRP card for travelling overseas ends on 1 June 2025. From this date, individuals traveling to the UK can no longer rely on expired BRP cards for international travel and must produce an eVisa to prove their right to enter the UK. The UKVI still advises to keep your expired BRP card as it may help with future applications to stay in the UK, and it can also still be used for generating share codes within the UK as a proof of rent or right to work.

As of April 2025 data, over 4 million people had successfully created a UKVI account to access their eVisa. This still leaves an estimated 550,000 immigration status holders who need to create a UKVI account. We therefore advise all those who have a UK visa to register for eVisa account with their passport as soon as possible.

Ecctis & overseas qualifications assessment

The UKVI has announced new updated services provided by Ecctis Ltd under a new contract effective from 1 May 2025. Eccits is a UKVI appointed body to conduct assessments of overseas qualifications for visa and nationality applications. The process now includes identity check for applicants and direct contact with educational institutions.

The assessment time has increased to 20 working days and expedited priority services are no longer available. The enhanced services include closer examination of overseas qualifications with as direct qualification verification. There will also be an automatic closure of application if awarding institution does not respond to Ecctis. Applicants are strongly advised to contact their awarding institution before applying. If the institution fails to verify an applicant’s qualification to Ecctis within 20 working days, the application will be closed automatically.

Applicants looking to file a visa application with a language or qualification requirement must allow sufficient time for assessment or seek alternative ways to meet the criteria, such as passing an English test instead of relying on the degree.

UK immigration department at Sherrards supports and educates their clients on the UK right to work and other UK immigration compliance regulations. If you have questions about your UK immigration compliance, please reach out to your usual Sherrards contact, or reach out to Nelli Shevchenko directly.

Immigration fees rise – What you need to know

The UK Home Office announced that most UK visa, sponsorship, and nationality fees will increase on April 9, 2025, impacting various categories, including work, visit, and settlement visas, as well as sponsorship and electronic travel authorization (ETA) fees.

Summary of main changes are below:

UK Visitor visa fee:

• Up to 6 months entry – from £115 to £125
• Up to 2 year entry – from £432 to £475
• Up to 5 year entry – from £771to 848
• Up to 10 year entry – from 963 to £1,059
• ETA – from £10 to £16

Skilled Worker & Global Business Mobility visa fee:
Applying outside the UK:

• Up to 3 years – from £719 to £769
• Up to 5 years – from £1,420 to £1,519

Applying inside the UK:

• Up to 3 years – from £827 to £885
• Up to 5 years – from £1,636 to £1,751

Sponsor licence application fee:

• Small company – from £536 to £574
• Medium or large company – from £1,476 to £1,579

Notably, a definition of ‘small’ company has changed on 6 April 2025 and the thresholds on turnover was increased from £10.0 million to £15 million or less, and balance sheet is increased from 5.1 million to 7.5 million or less. This means that more companies can now fall under the lower fee.

Certificate of sponsorship (CoS) fee:

• Change from £239 to £525

Settlement & Naturalisation fee:

• Indefinite Leave to Remain – from £2,885 to £3,029
• Naturalisation as adult British citizen – from £1,500 to £1,605

Global Talent application fee:

• Stage 1 – from £524 to £561
• Stage 2 – from £192 to £205

Spouse & Family visa fee:

• Fee change from £1,846 to £1,938

The full list of the latest UKVI fees can be found on the Government website here.

Sponsored workers salary deductions and new entrant

Significant updates to the Immigration Rules took effect from 9 April 2025, impacting how salary thresholds for Skilled Worker visas are assessed. Under the new rules, certain payments made by the applicant to their employer (or a related entity) will be deducted from the applicant’s salary when determining whether the minimum salary requirement has been met. Specifically, the following types of payments must now be subtracted from the gross salary:

• Deductions from salary (e.g. regular payroll deductions for immigration-related expenses)
• Repayments of loans provided by the sponsor or a related party (e.g. repayment of loans given to cover visa fees or the Immigration Health Surcharge (IHS))
• Investments made by the applicant into the sponsor’s business (e.g. contributing capital in return for a higher declared salary)

These deductions will be averaged over the entire period of sponsorship. Importantly, even if these payments are made voluntarily or via informal agreements between the employer and employee, they will still reduce the salary figure used for compliance. Only payments that are genuinely optional benefits, such as salary sacrifice schemes (e.g. cycle-to-work or pension contributions), which the applicant is not compelled to take, will be exempt from deduction—provided they are not connected to immigration or business costs.

This clarification is part of the government’s broader effort to strengthen the sponsorship system and prevent the exploitation of sponsored workers through inflated or misleading salary declarations. Employers should take immediate steps to audit current practices, including any standard deductions for immigration costs, and adjust HR and recruitment processes accordingly.
Additionally, the new rules confirm that “new entrant” salary discounts based on training must now relate to a UK-recognised professional qualification only.

With a White Paper on immigration policy expected in May 2025 and the Migration Advisory Committee’s review of the IT and engineering sectors pending, further changes may be on the horizon. Sponsors must ensure continued vigilance to avoid non-compliance as enforcement action by UKVI continues to rise.

Electronic Travel Authorisation (ETA) is mandatory for all visitors

From 2 April 2025, all foreign nationals require an Electronic Travel Authorisation (ETA) prior to arriving to the UK as visitors for up to 6 months. Previously, non-visa nationals did not require a pre-arrival authorisation to come to the UK and were able to seek entry upon arrival. Since 2024, the UK government has started implementing in stages a requirement for ETA for visitors. ETA applies to all foreign non-visa nationals, unless they are British or Irish, or already have a UK immigration status (visitor visa, eVisa, or settlement).

The ETA is valid for 2 years or for the validity of the passport, whichever expires first. This is a multiple entry authorisation record and is only applicable to one passport. It currently costs £10 going up to £16 from 9 April 2025.

Current processing time is stated as 3 days but can take longer in certain complex circumstances. According to the UKVI statistics, 98% of all current applications is decided within 24 hours but they see an increased demand in ETA that can affect the processing times.

The UKVI is also going to enforce the requirement for visitors to have an ETA before they board the plane, train or ferry to the UK, making all carriers responsible for checking all passengers’ UK immigration documents. You can be refused boarding if you come to the UK without a necessary documentation.

If you are refused an ETA, you are required to apply for UK Visitor visa in advance of your trip and it can take up to a month to get a UK visa.

Therefore, it is important to apply for ETA in advance of your UK trip to avoid disappointment. Global mobility and HR teams should ensure that all business travellers have a valid ETA or visa before they travel to the UK.

Legal obligations for the UKVI eVisa account holders

Th UK visa system is being digitalised with introduction of eVisas and UKVI accounts for all UK immigration status holders linked directly to the identity documents. The UKVI account allows the visa holder to view and prove their immigration status electronically to employers, landlords, banks, airlines and other agencies. Everybody who has a UK immigration status, such as visa or settled status, must have a UKVI eVisa account. If you do not have an eVisa account already, you should register as soon as possible here.

UKVI eVisa account replaces previous physical documents, such as Biometric Residence Permits (BRPs) and Biometric Residence Cards (BRCs). Although the BRPs have expired on 31 December 2024, they continue to be accepted until 1 June 2025. The transitional period was extended twice already, so it is possible that it will be extended again.

On 27 March 2025, the Government introduced formal maintenance obligations for UKVI account holders. In an event of non-compliance, the UKVI can impose sanctions and penalties on the UKVI account holders. The sanctions include refusal of a visa application, suspension of ability to create a share code to prove immigration status, visa cancellation and in severe cases, and even civil penalties up to £1,000.

It is a legal requirement that a person with a UK immigration status must register and maintain a UKVI account with access to the eVisa. The account holder is under obligation to keep their personal information in the account accurate and up to date with details such as:

1. passport or identity document;
2. biographical details;
3. residential address;
4. contact details; and
5. facial image of their face.

If any of these details change, the account holder must report the changes to UKVI.

Right to work checks extending to ‘gig’ economy and contactor workers

On 30 March 2025, the UK Home Secretary Yvette Cooper announced that businesses operating in the ‘gig’ economy and those offering zero-hours contracts will be required to carry out the right to work checks on people working for them on a flexible basis. The checks are required to avoid civil penalties of up to £60,000 per worker found to be working illegally.

Currently, companies are required to carry out right to work checks on all employees where formal employment relationship existed. Contractors and informal workers are excluded from the illegal working penalties and the employers are normally only encouraged to ensure all workers have a right to work in the UK before engaging them.

The provisions to expand the existing right to work checks obligations is an amendment to the Employment Rights Bill which is currently in the House of Lords. If adopted, it is expected to become law in spring 2025. If passed, the requirement to complete a right to work check and enforcement provisions will apply to all, including those on-demand workers, particularly operating in construction, food delivery, beauty salons, courier services.

The change follows a recently published study, carried out by Verian on behalf of the Home Office on the overall employers awareness and compliance of the Right to work checks. It shows that whilst 89% employers have an understanding of basic right to work requirements, many are not familiar with detailed compliance obligations. Small employers in specific sectors are particularly at risk of non-compliance. Various transitional arrangements such as cessation of Biometric Residence Permits and switching to eVisas creates further challenges.

In summary, the research has shown that:

• Smaller employers, hiring agencies, zero-hours workers, and those in the construction industry are at a higher risk of failing right to work compliance.
• Most employers (80%) answered at least one compliance question incorrectly, meaning they were at risk of potentially non-compliant behaviour.
• Employers varied their use of key Right to Work mechanisms depending on their business size, sector and use of agency/zero-hours workers.
• Employers need further education on illegal working or right to work check enforcement, such civil penalties.

Right to work checks should not be complicated and once the process is established, the businesses would be protected against potential penalties. In addition, a compliant business protects itself from enforcement actions that can also bring reputation and operation damage.

UK immigration department at Sherrards supports and educates their clients on the UK right to work and other UK immigration compliance regulations. If you have questions about your UK immigration compliance, please reach out to your usual Sherrards contact, or reach out to Nelli Shevchenko directly.

The last increase to the civil penalty was in 2014. From January 2024 , this will be raised up to £45,000 per illegal worker for a first breach (from £15,000), and up to £60,000 for repeat breaches (from £20,000).

We have assisted numerous employers in ensuring compliance. Whether this is in terms of advice on issues surrounding illegal working generally,  or more specific concerns. 

If you have any concerns about your processes, please do not delay.  An audit or health-check could be the key to avoiding non-compliance. 

Please contact Emma peacock on the below details for more information, if required.