The Home Secretary has published its most recent Statement of Changes (HC 997), effective from 1 July 2025, which solidifies its extensive plans outlined in the eagerly anticipated Immigration White Paper. This move aims to reset the UK immigration system, “restoring proper control and order” through transformative proposals that seek to reduce net migration. This Statement of Changes comes only one week after the last Statement of Changes (HC 836), which made amendments to, among other things, the EU Settlement Scheme, the Private Life route, and Appendix Continuous Residence.

This fresh Statement of Changes mainly focuses on the reforms directed at the Skilled Worker route, with the new rules taking effect on 22 July 2025, a short three weeks from their announcement. Alongside these significant shifts are amendments to the Health and Care Worker route (for social care workers only), the introduction of interim shortage lists, and the removal of Appendix Afghanistan Relocations and Assistance Policy (ARAP).

Appendix Skilled Worker minimum skill level

Prior to the UK’s departure from the EU in 2020, the Appendix Skilled Worker route (previously Tier 2 (General) as it was then known) mandated the minimum skill level for sponsorship to be at Regulated Qualifications Framework (RQF) level 6 or above (degree level). To account for transitional teething problems from Brexit, the RQF level was reduced to level 3 and above (A-level). However, in recent years, there has been widespread identification of alleged abuse in RQF level 3-5 occupations, resulting in the return to the mandated minimum skill level to RQF 6. This change is drastic, resulting in around 180 eligible occupations being removed. This amendment will come into force on 22 July 2025 and will only apply to new applicants, with existing applicants being able to remain sponsored in occupations at level RQE 3–5 if they are already on the route, have an outstanding successful application, or their occupation is on the newly expanded Immigration Salary List or the brand-new Temporary Occupation List.

As a result, the Home Office is introducing new tables outlining the occupation levels for Appendix Skilled Worker, which is anticipated to bring greater challenges in navigating this route.

Increased salary thresholds

In line with the latest Annual Survey of Hours and Earnings (ASHE) data, there will be increases to the salary thresholds for the Skilled Worker, Global Business Mobility, Scale-up, and PhD routes. The Skilled Worker route will be rising from £38,700 per annum to £41,700 per annum, with the Global Business Mobility route rising from £45,800 to £52,500. These are routine changes to ensure international workers are adequately remunerated in line with the pay situation for UK workers.

It is anticipated that this increase in salary will result in ineligibility for a large volume of applicants, and employers should be encouraged to expedite applications to ensure they are submitted before 22 July 2025.

Moreover, employers and international workers must be cautious that there are no transitional provisions in place for salary increases and will be under a duty to meet the increased salary thresholds after 22 July 2025 if they wish to extend their visa or secure a new role with a new employer. However, some discounts on the minimum salary level remain in place.

Introduction of a Temporary Shortage List

In response to the removal of nearly 180 occupations, the Statement of Changes has recognised that there will be genuine labour shortages. To prevent such shortages, employers will still be able to recruit international workers who do not meet the mandated RQF level 6 skill; however, there will still be limitations.

This will be implemented by the introduction of the Temporary Shortage List (TSL), which will operate in the interim alongside the existing and newly expanded Immigration Salary List (ISL). The TSL will not be as far-reaching as the ISL, as it will only include occupations that are complementary to the UK’s industrial strategy or critical infrastructure. The ISL will remain in operation, which will be expanded for the time being, with a view to being phased out. The security of the occupations on the ISL and TSL will be at risk, with the government reserving the right to remove these occupations at their own discretion, on advice from the Migration Advisory Committee, on their assessment of whether the occupations can be justified. 

Removal of dependents for workers at RQF levels 3-5

Workers who are entering the UK to work in occupations at RQF level 3 – 5 will now be unable to bring their dependents. This change comes in line with the restriction on care workers and senior care workers bringing dependents; however, it will not apply to those already in the UK in these occupations, children born in the UK, or where the worker has sole parental responsibility. This restriction will come into force on 22 July 2025.

Adult social care

On 22 July 2025, international recruitment in the adult social care sector will cease, leaving employers unable to recruit from overseas. Employers will now only be able to hire from the pool of domestic UK workers or international workers already working in the UK. The impact of this closure will be far-reaching, with anticipated issues for the care sector as a whole. As a result, transitional provisions have been put in place until 22 July 2028 (although this will be kept under review), allowing for in-country transfers for existing care workers. It is hoped that this will prevent care workers from exploitation and secure their roles in the domestic workforce, without the risk of an influx of international workers taking positions. See our earlier blog article here

Action for employers

With such drastic changes looming in the coming weeks, employers should urgently review their international recruitment policies to account for the amendments being made to salary increases and occupations that are at risk of being ineligible. A practical tip which could mitigate the adverse impact of these changes is expediting the applications for international workers who would not meet the post-22 July 2025 requirements, as they will be assessed against the existing rules, despite their application being granted after the relevant date.

Moreover, a top priority for employers is to remain up to date with the ongoing changes to the ISL and TSL. With these occupation codes having fragile security, there is a high risk of removal over the next year for many positions.

Additionally, care sector employers will now be under intense scrutiny to ensure their record keeping duties are up to date, should existing care workers wish to transfer employers, as they will need to prove they were employed for a minimum of three months.

Therefore, with such significant changes coming into force in the coming weeks, it is imperative that employers act with urgency, or they risk getting caught up in the recent overhaul of the immigration system and falling foul of their sponsor duties.

For advice or support about the changes to immigration rules or assistance with submitting an immigration application, get in touch with our immigration team.

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