The changing landscape for international talent

The backdrop

Against an ever-changing immigration and legal landscape, recruiting talent from overseas has become essential. Since 2020 Britain’s non-EU foreign workforce has grown to 3.2m people, more that double its pre-pandemic size.

The UK government’s industrial strategy aims to position the UK as a global leader in advanced sectors like artificial intelligence, green energy and biotechnology. These ambitions require a workforce with highly specialised skills that the UK labour market cannot fully supply. At the same time, the UK government is pursuing policies aimed at lowering net migration which is increasing the cost and administrative implications associated with sponsoring workers. This creates a challenge for the UK government, UK business and international companies looking to set up in the UK with some businesses now questioning whether they should restrict applications from international workers who need to be sponsored.

Key immigration changes in 2025

The Skilled Worker visa is the main route to working in the UK. Following changes in spring last year designed to lower net migration, the number of Skilled Worker visas issued reduced by 50%, with 252,700 fewer visas issued in 2024 compared with 2023.

Throughout 2025, the UK government has introduced significant amendments to the Skilled Worker visa route and other important policy changes. Below is a summary of some of the key changes:

Raising the threshold for Skilled Worker visas

Since 22 July 2025, the Skilled Worker route is primarily reserved for roles requiring RQF Level 6 qualifications (equivalent to a UK bachelor’s degree) which has removed at least 111 eligible occupations from the Appendix Skilled Occupations list.

This change does not affect people already on the Skilled Worker route as at 22 July 2025, in roles below RQF level 6, but the government has stated that the “transitional arrangements currently in place will not be so indefinitely and will be reviewed.

Increased visa fees

The cost of sponsoring workers under UK visa routes is higher than ever before.

In April the cost of a visa to work in the UK went up across the board, including for the Skilled Worker visa.

The increased standard costs (if applying from outside the UK) are now as follows:

• Skilled Worker (3 years or less): £719 to £769
• Skilled Worker (over 3 years): £1,420 to £1,519

New sponsorship costs for skilled workers

The government has introduced a significant policy shift regarding sponsorship costs. Sponsors are now prohibited from passing on the following sponsorship costs to skilled workers:

• Sponsor Licence Fee
• Certificate of Sponsorship Fee.

Increase to minimum salary requirement

The general salary threshold for skilled workers has risen from £38,700 to £41,700 and the new entrant rate (workers who meet certain criteria e.g. under 26, a recent graduate or in professional training) has risen from £30,960 to £33,400.

The increase means companies will need to ensure they are offering competitive salaries to attract and retain skilled workers from both the UK and international labour markets. If a business fails to meet the increased salary requirements, it could result in visa refusals or significant sponsorship licence penalties.

The Health and Care Worker visa route

The Health and Care Worker visa route for care workers and senior workers is now closed to new overseas applicants.

Requirement for a workforce strategy

A key government policy shift is that sectors must have in place a workforce strategy aimed at training and retaining UK-based workers. A failure to do so may result in losing access to the immigration system entirely.

New temporary shortage list

There is a new temporary shortage list for roles below RQF Level 6. This list is time-limited until the end of 2026 and will only apply to roles deemed critical to the UK’s industrial strategy or infrastructure delivery. Importantly:

• No salary or visa fee discounts will apply to roles on the temporary shortage list
• Dependants will not be permitted under this route
• The Migration Advisory Committee (MAC) will review the list and advise on its continuation beyond 2026.

Electronic Travel Authorisation scheme (“ETA”)

The ETA scheme grants permission to travel to the UK, in a similar way to the US’s Electronic System for Travel Authorization (ESTA). The ETA is not a visa and does not grant the right to live or work in the UK.

Since April 2025, the ETA has applied to all UK visitors who do not need a visa or permission to live, work or study in the UK. It also applies to those coming to the UK for up to three months on a Creative Worker visa (e.g. an actor, dancer, musician or film crew member), and to those coming for a permitted paid engagement.

Citizens from countries previously exempt from visa requirements must now apply for an ETA. This includes short-term business visitors.

Companies should review their travel needs to ensure that affected overseas employees have the necessary ETAs. Any failing to obtain an ETA could lead to delays or refusal of entry to the UK.

Future changes

It is anticipated that by the end of 2025 there will also be:

• An increase in the Immigration Skills Charge
• Higher English language requirements across many visa categories
• A new ‘family policy framework’ introduced.

What this means for business

The evolving immigration landscape, coupled with rising costs and increased administrative burdens, means businesses must take a proactive approach to workforce planning.

Reviewing internal training strategies and aligning them with new skills thresholds is essential to avoid operational disruption, particularly for roles now excluded from the immigration system.

Businesses should also audit existing visa sponsorships and closely monitor updates from the Home Office and the Migration Advisory Committee to ensure ongoing compliance. Failure to do so could result in sponsor licence revocation, reputational damage, financial loss, and disruption to both current and future sponsored workers. Importantly, employers must exercise caution in their recruitment processes to avoid inadvertently discriminating against international applicants.

The Employment Appeal Tribunal’s decision in Osborne Clarke v Purohit remains a binding precedent, highlighting that policies excluding non-EEA nationals can amount to indirect race discrimination. As such, businesses must ensure their hiring practices are fair, transparent, and legally compliant.