Further changes to the UK immigration system were announced on 14 October by the Home Office. These were clarifications on reforms outlined in the Immigration White Paper released by the UK government earlier this year and they aim to reduce net migration, boost productivity and strengthen the UK economy by attracting highly skilled talent. We expect further updates to be released in the coming months.
Part Suitability Framework Introduced, replacing the previously scattered “grounds for refusal”
Previously, UK immigration rules were scattered across numerous appendices, exceptions, and subclauses. The old system relied on “Grounds for Refusal,” which was a confusing mix of rules varying from one visa route to another. As a result, caseworkers could interpret eligibility differently based on the specific category under which applicants applied, leading to confusion, inconsistency, and frequent appeals.
Under the new rules, every visa route will be subject to the same universal test: Suitability. It means that if an applicant has a history of deception, criminal activity, immigration violations, or even unpaid NHS debts, they will face the same standard across all categories. There will be no loopholes or category-specific exceptions.
This change will restore public confidence in the consistency, firmness, and fairness of immigration decisions and will simplify casework, reducing human error and speeding up the decision-making process by UK officials.
Increased Immigration Skills Charge for Employers
Effective 16 December, the Immigration Skills Charge (the amount sponsors must pay per year to sponsor individuals under work routes, including Skilled Workers) will increase yet again.
Large sponsors will be required to pay £1,320 per year, an increase from the current £1,000 per year, while small or charitable sponsors will be required to pay £480 per year, an increase from the current £364 per year.
This increase will impact most employers and sponsored work visa applications. However, here is a short list of scenarios on when employers are not required to pay the Immigration Skills Charge:
- If sponsoring someone for a visa from outside the UK to work in the UK for less than 6 months
- If sponsoring someone to switch from a Student visa route
- If sponsoring certain occupations (e.g. scientists and researchers)
- If sponsoring someone under the Global Business Mobility Senior or Specialist Worker route for less than three years, and they are a national of an EU country (or normally work in the EU for your EU business but are being temporarily transferred to work in the UK)
Higher Financial Requirements for Students
From 11 November 2025, to secure a visa, international students will need to demonstrate higher levels of financial solvency. They will be required to show that they can support a monthly budget of:
- £1,171 per month outside London
- £1,529 per month in London
This may pose a barrier for lower-income applicants from developing economies.
Reduced Graduate Visa Lengths
As of 1 January 2027, the length of post graduate employment authorization will be reduced from two years for non-PhD graduates to 18 months. The length of post graduate work authorization for PhD graduates will remain unchanged at three years.
This change will likely result in employers having less flexibility to onboard and retain global graduates unless they move quickly to sponsor them under the skilled worker or another route.
Expansion of High Potential Individual Route
The High Potential Individual route allows recent graduates from eligible overseas universities to be granted permission to live and work in the UK for two years. On 4 November 2025, the number of eligible universities will double to the top 100 international universities, however an annual cap of 8,000 applications will be introduced. The number of individuals applying through the HPI route is expected to double in 2026 from 2,000 to 4,000 applicants.
New Entrepreneurship Pathway for Recent Graduates
Starting 25 November 2025, talented entrepreneurs studying in the UK will be able to seamlessly establish innovative business ventures in the UK after concluding their studies by transitioning from a student visa to the Innovator Founder route.
Increased English Language Requirements
Additionally, starting 8 January 2026, main applicants applying under the Skilled Worker, Scale-Up and High Potential Individual routes will be required to evidence English language proficiency at Level B2 on the Common European Framework of Reference for Languages, an increase from the current Level B1. This change will only apply to first time applicants, allowing those already holding permission under these routes to extend without evidence of higher proficiency.
E-Visa Transition
The UK will continue its transition to a digital immigration system with the next phase involving the removal of 90-day passport endorsements (transition to e-visas) for most main applicants on non-work or study routes, as well as dependents of those on work and study routes which transitioned in July.
Botswana and Palestine Added to Visa National List
Effective 14 October, Botswana has been added to the Visa National List, meaning that nationals of Botswana are no longer visa exempt and must secure a valid visa before entering the UK (no longer eligible for entry with an ETA).
Following the UK recognition of the State of Palestine, nationals will now require a visit visa. Palestine nationals will continue to require a Direct Airside Transit Visa unless exempt.
The Clark Hill EMEA Immigration team will be monitoring these changes and the impact on employers and UK visa holders. For more information or an assessment please reach out to EMEA@clarkhill.com.
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