What Does The Immigration White Paper Mean For UK Businesses And Sponsor Licence Holders?

Posted onMay 14, 2025

Reducing net migration into the UK affects more than individual visa applicants and their families. It also affects British businesses, which in turn affects the UK economy and projected growth.

In this article, our Immigration Solicitors in London focus on how the May 2025 white paper will affect businesses with sponsor licences or companies planning on applying for a sponsor licence in 2025 or 2026.

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For specialist immigration and sponsorship legal advice, call Legal 500 featured OTS Solicitors on 0203 959 9123 or contact us online.

Planned changes to the Skilled Worker Visa

There are four planned changes to the Skilled Worker Visa route:

Increasing the skills eligibility criteria for a Skilled Worker Visa.
Increasing the minimum salary threshold for the Skilled Worker Visa and the immigration skills charge.
The creation of a temporary shortage list for some jobs.
Ending applications for Health and Care Worker Visas by care workers and senior care workers.

The full changes to all routes can be found in the white paper.

Increasing the skills eligibility criteria for the Skilled Worker Visa

A sponsoring employer can currently sponsor a skilled worker to fill a skilled job at an A-level standard or RQF level 3. The job does not require the successful applicant to have the equivalent of A-levels, but the applicant must have the skills or experience to do the skilled job.

Under the new proposals, a Skilled Worker Visa applicant will need to meet RQF Level 6 skills, equivalent to a degree. Looking at the list of jobs currently eligible for sponsorship for a Skilled Worker Visa, it is immediately apparent that many occupations will not qualify. For example, many lower-level but highly skilled construction, healthcare and hospitality jobs will not do so.

Increasing the minimum salary threshold for the Skilled Worker Visa

The government intends to abolish the immigration salary list (previously referred to as the shortage occupation list). The list allows some minimum salary thresholds for Skilled Worker Visas to be discounted.

Combined with the abolition of the immigration salary list discounts and the increase in the minimum salary threshold to the higher of:

£38,700 gross per year or
The going rate for the job as recommended by the Migration Advisory Committee (MAC) and approved by the government.

Many occupations will be excluded from Skilled Worker Visa recruitment, even if the job meets the enhanced skills criteria.

The MAC is to review the new salary requirements further. This review will consider salary issues such as:

NHS or public sector exemptions.
Regional salaries.
New entrant salaries.

However, the MAC review is specifically tasked with ensuring that the Skilled Worker Visa minimum salary threshold does not encourage UK employers to use sponsorship of overseas workers as a cheaper alternative to recruiting and training British and settled workers.

Transitional rules and existing Skilled Worker Visa holders

The changes to the Skilled Worker Visa rules will be applied to new overseas job applicants. Existing Skilled Worker Visa holders will be able to switch employers or apply to extend their Skilled Worker Visa. However, other visa holders will only be able to switch from their visa to a Skilled Worker Visa if they meet the RQF Level 6 criteria. For example, someone in the UK on a Spouse Visa whose relationship has ended and who wants to stay in the UK but who will need to secure a Skilled Worker Visa to do so.

The creation of a temporary shortage list

The temporary shortage list is intended to be a transitional arrangement enabling UK employers to adjust to the change in immigration rules and invest in UK-based recruitment and training.

The temporary shortage list will be able to include jobs in RQF Levels 3 to 5 that would no longer qualify for a Skilled Worker Visa under the new immigration rules. For example, the Migration Advisory Committee may recommend including skilled trades on the list to meet the government‘s house-building commitment.

The Migration Advisory Committee will review the jobs on the list on an ongoing basis. The MAC will also be able to recommend job quotas, caps, or visa restrictions on jobs to be included in the temporary shortage list.

Importantly, from the perspective of sponsor licence holders being able to recruit applicants with families, the Migration Advisory Committee will be able to recommend restrictions on Dependant Visas for Skilled Worker Visa applicants who qualify for the Work Visa because their job is on the temporary shortage list. The potential restrictions include:

Preventing some Skilled Worker Visa holders on the temporary shortage list from being able to bring dependents, such as those with lower-skilled jobs.
The minimum salary threshold for some jobs on the temporary shortage list will be increased if a family member accompanies the Skilled Worker Visa holder on a Dependant Visa.
Higher English language requirement threshold for some Skilled Worker Visa applicants and their dependents.

The intention is that the list will be strictly controlled with set sector eligibility criteria for a job to be placed on the list:

A government-approved workforce strategy specifying how employers plan to reduce reliance on sponsored workers.
An investment in UK-based training, including collaboration with Skills England.
Demonstrating fair working conditions together with assessing and reducing exploitation risks to overseas workers.
A plan for the employer and sector to reduce reliance on sponsorship of overseas workers and a timeframe.

Companies with sponsor licences will be expected to work with:

Regulatory bodies in their sector, and
Government bodies such as the Education Department, the Department for Work and Pensions, and the Home Office.

If a sponsor licence holder cannot show how they meet the criteria relevant to their sector, the white paper says that the sponsoring employer may be subject to restrictions or the revocation of their sponsor licence.

Stopping applications for Health and Care Worker Visas by care workers and senior care workers

The government plans to stop employers from being able to sponsor overseas carers and senior carers on Health and Care Worker Visas. Transitional rules will apply to all carers and senior carers in the UK on Health and Care Worker Visas. These provisions will allow for visa extensions and visa switches until 2028.

Crucially, the new immigration rules will say that carer and senior carer jobs cannot be included on the temporary shortage list.

Care homes, nursing homes and care sector providers need urgent immigration legal advice on how these arrangements will affect:

Their immediate carer and senior carer recruitment plans.
The retention of overseas staff and non-sponsored staff.
The impact of transitional arrangements on compliance and retention.
Sector-related compliance and increased Home Office enforcement.

Immigration and sponsorship after the white paper

The May 2025 white paper plans to take UK employers back to the days before Brexit, when the Skilled Worker Visa was limited to the highly skilled.

However, before Brexit, many EU nationals were available to work in the UK through the principle of free movement. In those halcyon days, there were no immigration controls or visa requirements placed on EU nationals, and if a UK company could not recruit and fill a degree-level job from within the UK or from the pool of EU talent, the company could tap global talent by sponsoring a non-EU worker on a Skilled Worker Visa.

At the heart of the white paper proposals is a return to the pre-Brexit Skilled Worker Visa eligibility criteria, but without the EU workers to pick up the recruitment slack. In the years since Brexit, Immigration Solicitors don’t think any political party is saying that the British education system produces the raw talent needed to quickly train recruits into the specific skilled workers required by UK businesses.

Redesigning the Skilled Worker Visa route

Many businesses applied for a sponsor licence to recruit job applicants from overseas on Skilled Worker Visas. For most companies, the application was a ‘’no-brainer’’. There was simply no choice; if the company wanted to continue to trade or expand, it needed to recruit the right skilled staff from overseas.

Keeping it British as a recruitment policy was not an option, as British people did not have the skill set or experience to fill vacancies, and apprenticeships were either unfilled or did not provide the apprentices with the skills they needed for the company to compete in national or international markets. However, the white paper argues that the historical expansion of the Skilled Worker Visa eligibility criteria enabled UK employers to underinvest in apprenticeships and career paths for domestic workers.

The government‘s white paper details how it plans to redesign the Skilled Worker Visa, but it is light on how schools, colleges, and higher educational institutions will do their part to churn out school and college leavers and graduates with the skill sets and experience that UK employers need. Unsurprisingly, many businesses reliant on overseas labour already say that the priority is wrong. The focus should be on education, and when that is producing the talent needed, UK companies will naturally want to recruit British and settled workers. After all, businesses don’t want to increase their overheads unnecessarily by paying for:

Sponsor licence application fees.
Key personnel to manage the sponsor licence.
Professional Sponsor Licence Management Services.
Certificate of sponsorship fees.
The immigration skills charge.
Voluntarily paying the Skilled Worker Visa fees and immigration health surcharge fees of overseas recruits who are in short supply.
The extra administration, compliance, and HR costs of hiring overseas workers.
The Immigration Lawyer’s fees for immigration legal advice if a sponsor licence is at risk of Home Office audit, suspension or revocation.

Despite UK business owners insisting that education should be the government’s first priority, sponsoring employers must prepare their companies for the massive sea changes proposed in the white paper.

Contact OTS Solicitors for immigration and sponsorship legal advice

The white paper poses many challenges for sponsoring employers and applicants for sponsor licences. OTS Solicitors specialise in business immigration and can answer all your questions on how the white paper proposals may impact your business and how to prepare for the change in immigration rules.

Contact Legal 500 featured OTS Solicitors on 0203 959 9123 or contact us online.

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