17 Jun 2025
by Mohammad Chaudhry, Forbes Solicitors

Employers in particular sectors – like health care, social care and construction - have been dependent on overseas talent to fill persistent workforce gaps. Now they face new guidelines. As immigration rules tighten, the Skilled Worker route now demands foresight, adaptability, and a proactive approach to maintain access to skilled migrant workers where needed.

Adjustment to the Immigration Skills Charge

Employers should note that the Government has announced a 32% increase to the Immigration Skills Charge (ISC), raising the current fee of £1,000 per sponsored worker per year.

The ISC is a core component of the Skilled Worker visa route and applies to most employers who sponsor migrant workers. With the rise – at a date yet to be confirmed - the financial cost of recruiting internationally will be significant, especially for sectors like health, social care, and construction, where overseas hiring is often essential to address skills shortages.

Employers should consider workforce planning and recruitment budgets and prepare by adjusting budget forecasts to account for the higher costs of sponsorship.

Changes affecting adult social care

Due to serious concerns about the misuse and exploitation associated with the Adult Social Care Visa, the Government is closing this route to new overseas applications. This change affects occupational codes 6135 and 6136 (previously 6145 and 6146), which were added to the list of eligible roles under the Skilled Worker route in February 2022.

Now, employers will no longer be permitted to recruit new care workers from overseas using this visa route. A transitional period will run until 2028, allowing individuals already in the UK with valid working rights to extend their visas or switch into other eligible roles. However, this period will be subject to ongoing review, and employers are advised not to treat it as a long-term recruitment strategy.

From 9 April 2025, care providers wanting to recruit a new worker from overseas must first prove they have attempted to recruit a worker from within England.

Rising skill and salary thresholds

As part of a wider reform of the UK’s immigration system, the Government is introducing significant changes to the Skilled Worker route, raising both the minimum skill level and the salary threshold for sponsored roles. These measures are designed to reduce reliance on lower-skilled migrants.

Under the new rules, the minimum skill requirement for Skilled Worker Visas will increase from RQF Level 3 (roughly equivalent to A-levels) to RQF Level 6, which corresponds to degree-level roles. This shift represents a major tightening of eligibility criteria and is expected to disqualify a wide range of occupations that previously qualified for sponsorship.

According to Home Office analysis, approximately 180 roles currently eligible at RQF Levels 3 to 5 will no longer meet the new threshold. Roles likely to be excluded include care workers and senior care assistants; and lower-level construction trades.

These changes mark a significant narrowing of the Skilled Worker route and will directly impact employers in sectors that have traditionally relied on sponsoring mid-level or non-graduate roles. For health and social care providers, this means most frontline care roles will no longer qualify for new visa sponsorship. In construction, many skilled trades will be affected.

Mandatory workforce strategies: a new expectation for employers

Based on evidence from the Labour Market Enforcement (LME) Group, the Government is mandating that sectors heavily reliant on migrant labour develop or revise their workforce strategies. These strategies will not be optional: relevant employers will be expected to comply as part of their ongoing eligibility to use the Skilled Worker route.

To stay ahead, employers should:

  • Begin aligning their recruitment and training policies with emerging workforce strategies
  • Prepare for increased regulatory expectations tied to the Skilled Worker route.
The Temporary Shortage List replaces the Immigration Salary List

The government will introduce a new Temporary Shortage Occupation List (TSL) to allow time-limited access to the points-based immigration system. The TSL will establish a more defined, conditional, and temporary route for sponsoring migrant workers in roles classified at RQF Levels 3 to 5.

Sectors hoping to gain access to the TSL will be subject to a stringent set of evidential and policy-based requirements. To qualify, industries must present a robust, government-endorsed workforce strategy that sets out clear, long-term objectives for boosting domestic recruitment, and outlines how they will gradually reduce dependence on overseas labour.

In addition, sectors must demonstrate meaningful investment in UK-based training and skills development. Strong safeguards around fair working conditions will be essential. There will be particular scrutiny on sectors with a history of migrant worker exploitation, like the care sector.

Some occupations in the care sector (which fall under Standard Occupational Codes SOC 6135 and 6136) and some construction sector jobs (which fall under the Immigration Salary List) will be affected by the new temporary shortage list.

By taking action now, employers can plan and position themselves to maintain access to skilled migrant workers.