A new statement of changes: updates to the Immigration Rules

Following the release of the government’s white paper in May, a new statement of changes (HC 1333) to the Immigration Rules was published on 14 October 2025. The statement made amendments to numerous visa categories to remain aligned with the government's policy objectives and the white paper’s mantra of restoring control over the immigration system.

Some of the most important changes came into force on 14 October 2025 with others expected to be introduced over the coming months:

Graduate visa duration changes

• The previous position allowed eligible graduates who had finished a UK bachelor’s degree, master’s degree, or other relevant qualification to stay in the UK for a further two years, working in a graduate role.
• As detailed in the white paper, the duration will change from two years to 18 months and will affect applications submitted on or after 1 January 2027.
• This does not affect PhD students who will still be able to live and work in the UK for three years in a graduate role.

Immigration skills charge

• This mandatory charge paid by most employers is to increase by 32% on 16 December 2025.
• For medium and large sponsors, it will rise from £1,000 to £1,320 per worker for the first 12 months, with the cost for each additional six-month period increasing from £500 to £660.
• For small or charitable sponsors, the rate will rise from £364 to £480 for the first 12 months, and from £182 to £240 for each further six-month period.

English language requirement changes to economic migration categories

• As detailed in the white paper, applicants to the Skilled Worker, High Potential Individual and Scale-up Routes must now take a B2 level English test (as defined under the Common European Framework for Reference for Languages (CEFR)).
• This departs from the previous requirement to take a B1 level test and the change will take effect from 8 January 2026.
• B1 is the equivalent of a A-Level English and is known as “upper intermediate”.
• If you are currently on any of the affected routes and are extending your stay, you will not be subject to this change.

Student visa work conditions changes

• From 25 November 2025, students are now permitted to create a business once they have finished their educational course and are transitioning into the Innovator Founder visa category.
• This change is aimed at supporting entrepreneurial talents in the UK.

High Potential Individual - targeted and capped expansion

• From 4 November 2025, the High Potential Individual visa will increase its eligible institutions by two-fold, increasing from 50 to 100.
• There will now be a yearly cap of 8,000 applications.

Visit visa requirements: new countries added

Palestine

• In response to the UK recognising the state of Palestine in September 2025, Palestine has been added to the Visa National List with effect from 11 November 2025.
• The addition of Palestine on the Visa National List does not change the requirements for individuals from Palestine, who previously applied for a visit visa as a citizen of the Occupied Palestinian Territory or as stateless individuals.
• Citizens of Palestine will also require a direct airside transit visa (DATV) when conducting airside transit travel, unless they fall within one of the exceptions, so as not to circumvent the visa requirements.

Botswana

• From 14 October 2025, Botswana was removed from the Electronic Travel Authorisation (ETA) national list and added to the Visa National List, meaning nationals of Botswana must now apply for a visa before coming to the UK.
• Nationals of Botswana who already held pre-purchased tickets will benefit from the flexibility of the transition period, which is a six-week buffer period they will not be subject to a visit visa; however, they must have purchased their ticket before 15:00 BST on 14 October 2025. The buffer period will close on 25 November 2025 at 15:00 BST, with individuals prevented from changing their booking to an earlier travel date to avoid the rules.
• Citizens of Botswana will also require a direct airside transit visa (DATV) when conducting airside transit travel, unless they fall within one of the exceptions, so as not to circumvent the visa requirements.

Relaxation of travel requirements for German school groups visiting the UK

• Following Brexit, EU member states were subject to the same passport controls as the rest of the world. This resulted in the end of the List of Travellers scheme, that had allowed students studying in an EU member state to travel within the EU on an organised educational visit without a passport or visa.
• From 11 November 2025, nationals of any country that are under the age of 19, studying at a German educational institution and seeking to enter the UK as part of a school party of five of more organised by that institution, can enter as a visitor without needing an ETA or visa.

Introduction of ‘Part Suitability’ to Appendix FM, Private Life, Adult Dependent Relative and Settlement Family Life

• The previous position was that most immigration routes would be assessed against Part 9 of the Immigration Rules, which were the general grounds of refusal. However, this change has seen the centre reference point for all suitability-related refusal and cancellation grounds replaced with the new ‘Part Suitability’.
• This change will differentiate where refusals are required by law and where UKVI can exercise its discretion.
• This change seeks to create uniformity across the visa categories, whilst also making them more accessible and easier to navigate and will come into force on 11 November 2025.

Conclusion

The introductions in the most recent statement of changes do not come as a shock to the immigration sector, with their first mentions in the white paper in May this year, with more expected to come over the coming months. It is evident that the government is making practical and concrete measures to restore control over the immigration system, whilst simultaneously executing policy objectives to provide opportunities for accomplished or entrepreneurial economic migrants. The immigration sector should be prepared for further changes to be announced, with a particular focus on the immigration skills charge and settlement requirements. If you would like help to navigate the process, please contact our immigration team for a discussion around your circumstances.

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