Recommended Immediate Actions for Sponsors
The landscape of UK immigration rules is evolving rapidly, especially with the looming changes set to take effect by 22 July 2025. For sponsors looking to maintain their current benefits and manage their workforce effectively, prompt actions are essential. Here’s a detailed guide on what steps sponsors should consider taking now.
1. Timely Assignment of Certificates of Sponsorship (CoS)
Sponsors should prioritize assigning Certificates of Sponsorship (CoS) to workers who may be affected by upcoming changes on or before 21 July 2025. This will ensure that these workers are covered under existing rules, avoiding potential pitfalls in the transition.
2. Well-Documented Requests
It’s crucial for sponsors to submit requests for defined CoS as promptly as possible. Given the anticipated increase in demand, processing times may slow down. Preparing well-documented requests can streamline this process and enhance the likelihood of timely approvals.
3. Use of Priority Services
For in-country CoS allocations, sponsors should make use of priority services if available. Yet, even with priority, be prepared for possible delays due to increased demand or compliance queries, such as those arising from changes in corporate structure.
4. Early Assignments and System Suspensions
Assigning CoS as early as possible is advisable. As the changes approach, certain functionalities in the Sponsor Management System may be suspended temporarily to facilitate updates. Early action can help avoid disruptions in the onboarding of new employees.
5. Maximizing CoS Duration
Sponsors may want to issue CoS for the maximum possible duration. This strategy can mitigate the impact of impending salary threshold increases at the extension stage, as well as reduce the costs associated with the Immigration Skills Charge (ISC), where applicable.
6. Strategic Route Switching
Another consideration is whether to enable switches from the Student route to the Skilled Worker route, rather than from the Graduate route. This route will allow for ISC exemptions, a benefit that does not extend to graduates switching from the Graduate route.
7. Proactive Planning for Salary Thresholds
Sponsors should familiarize themselves with the new salary thresholds applicable at the extension or settlement stages for workers who receive CoS on or after 22 July 2025. Staying informed is essential to avoid future compliance issues.
What is Changing Now?
Updated Salary Thresholds
As of July 2025, general salary thresholds for various immigration routes will be updated based on the latest (2024) data, notably increasing for the Skilled Worker, Global Business Mobility, and Scale-up routes. Here’s a look at the new thresholds:
| General Threshold Type | Current Threshold (GBP) | New Threshold (GBP) |
| Skilled Worker – new applicants not eligible for salary discounts | 38,700 | 41,700 |
| Skilled Worker (PhD) | 34,830 | 37,500 |
| Skilled Worker (PhD STEM, etc.) | 30,960 | 33,400 |
| Skilled Worker not eligible for salary discounts | 29,000 | 31,300 |
| Global Business Mobility | 48,500 | 52,500 |
| Scale-up | 36,300 | 39,100 |
Salary Thresholds and Their Implications
The changes mean that individuals applying under the new Skilled Worker interim Temporary Shortage List (TSL) must meet these new salary requirements. Current high earner thresholds remain unchanged, while additional special provisions apply to health and education roles.
Raising the Skills Threshold
The minimum skills threshold is set to rise from RQF Level 3 to RQF Level 6, effectively removing around 180 medium-skilled occupations from eligibility unless already included in specific lists. Existing workers under the current rules can extend their sponsorship, but the transitional arrangements won’t last forever, prompting a need for proactive planning.
Immediate Changes to the Immigration Salary List
With the abolition of the Immigration Salary List (ISL) on the horizon, the Government is implementing an interim Temporary Shortage List (TSL) that will include medium-skilled occupations vital for the UK’s Modern Industrial Strategy. Certain conditions will determine occupation eligibility, indicating a more stringent approach moving forward.
Restrictions on Care Workers
New sponsorship restrictions will be placed on care worker positions unless a defined CoS is assigned before the deadline. This shift aims to simplify the recruitment process and maintain workforce integrity. Existing sponsors in this category should remain vigilant and plan for future changes.
What is Changing Later?
While there is much to digest now, some significant changes proposed in the Government White Paper will see delayed implementation. Key actions that will unfold include:
- Discontinuation of the Immigration Salary List.
- A comprehensive review of work route salary thresholds and discounts, expected by early January 2026.
- Increased English language requirements for main applicants; a shift scheduled by the end of 2025.
- A proposed increase of the Immigration Skills Charge by 32% for medium and large sponsors.
- Implementation discussions around ‘earned settlement’ or citizenship, to be commenced later this year.
- New requirements for work route dependants to be detailed by the end of 2025.
Need More Help?
For sponsors navigating these changes, expert guidance is invaluable. If you’re preparing for an upcoming Skilled Worker application or need assistance with compliance, please reach out to your usual Lewis Silkin contact for tailored advice and support.
