The Home Office white paper published on 12 May 2025 sets out the Government’s policy to reduce net migration.  The aim is set out as favouring training UK workers rather than recruiting from overseas.

However, many organisations may be concerned about the changes proposed by the white paper, particularly the health and care sector.

Some of the key changes proposed in the paper are as follows

1. Increase in the skill level required for a skilled worker
2. Abolition of the Immigration Salary List
3. Closing the social care visa route to overseas recruitment
4. Restrictions on dependants for lower-skilled workers on the temporary shortage list
5. Increasing salary thresholds for all visa holders seeking to bring in dependants
6. Increasing English language requirements for visa holders and dependants
7. Increase in the Immigration Skills Charge (ISC)
8. Graduate visa route to be for a maximum of 18 months (currently this is 2 or 3 years)
9. A potential introduction of further reforms to the sponsorship system.  This will include exploring making it easier for workers to move between licensed sponsors for the duration of their visa, giving them more control over who they work for and reducing the risk of exploitation.

We answer some of the questions employers may have around these changes:

Q: Will the changes in this paper definitely come into force?

This white paper sets out the Government’s proposals for future legislation, but this will be consulted on and possibly debated, and changes could be made before a bill is formally presented to parliament.

Q: How will the skill level change?

Currently, the skill level is A level (known as Regulated Qualifications Framework Level 3), but the plan is to increase this back to degree level (RQF 6).  It was previously at RQF 6 before Brexit.

This will result in a significant number of roles (the white paper suggests 180) no longer being eligible for the skilled worker visa. 

Q: Will salary thresholds rise?

Yes, the white paper specifically states that salary thresholds will rise.  It does not state by how much these will rise.

Q: What does the abolition of the Immigration Salary List mean?

The Immigration Salary List replaced the previous Shortage Occupation List in April 2024.  Now, the proposal is to have a narrow list of critical shortage occupations on a temporary shortage list (which could include roles below RQF 6). We do not know which occupations these will be at this time.

However, the white paper sets out that (longer term) sponsorship of such roles will only be permitted on a time limited basis where the Migration Advisory Committee (MAC) has advised it is justified, where there is a workforce strategy in place, and where employers seeking to recruit from abroad are committed to playing their part in increasing recruitment from the domestic workforce.

Q: When will these changes come into effect?

There is little by way of timescales in the white paper, but it has been indicated in the press that changes to the care worker visa will happen this year. 

As noted below, there is also an indication that a transition period in respect of care workers will end in 2028.

Q: If the social care visa route is closed, what happens to all the carers who are already in the UK?

Overseas recruitment has already been restricted on this route due to the provisions which came into force on 9 April 2025, which (in very brief terms) require employers to consider if they can employ a displaced care worker (from the in-country redeployment pool) before being able to recruit from overseas.

The proposal appears to be to close the route to those applying for entry clearance as a carer from overseas, rather than (immediately) closing it to those already in the UK.  However, the details relating to this are not yet clear, and it is envisaged that the route will also be closed to in-country applicants in the future.  The white paper sets out that for a transition period until 2028, they will permit visa extensions and in-country switching for other already in the country with working rights, but that this will be kept under review.

It is possible, therefore, that existing care workers will not be able to extend their visas after 2028.

Q: Can I still apply for a sponsor licence as a care provider?

Yes, these are only proposals in the white paper at the moment, and it is still possible to sponsor care workers until the changes come into effect (and likely for a period afterwards for those already sponsored).

Q: Are there any plans to tackle exploitation?

Yes, there are proposals to protect the vulnerable from exploitation.

For example, there is a plan to explore making it easier for workers to move between employers.  It has been widely recognised in the media that there has been exploitation of some sponsored care workers, and this proposal may improve this.  However, the white paper only sets out that this should be explored, and it may be the case that the care worker visa is closed before any such measures may be introduced.

Q: Is this likely to affect civil penalties for illegal working?

The white paper notes that 1,000 staff have been redeployed into enforcement and returns since the election.  There is a plan to “surge resource” into the key sectors where illegal working is taking place.  Therefore, employers will need to be more stringent than ever when conducting right-to-work checks.  We have already noticed an increase in information requests relating to suspected illegal workers from the Home Office in the last 6 months.

What can we do to plan for these changes?

Some organisations, particularly in the care sector, will need to change their long-term recruitment strategy, for example, where this involves recruiting migrant care workers. 

Often, organisations will have thought carefully about the strategy of recruiting from overseas before implementing it, particularly as the minimum salary for sponsored adult social care workers is £12.82 per hour, significantly higher than the National Living Wage. Therefore sponsored care workers are not a cheap alternative, and they are often only used when options for recruiting locally have been exhausted.

Providers in the care sector will need to carefully consider:

• What percentage of their workforce is likely to be affected by reviewing:
  •  existing sponsored staff (checking their visa expiry dates); and 
  • those carrying out supplementary work (who are sponsored by other providers).
• Whether they can offer incentives for recruiting from within the UK.  This is likely to be difficult in light of the funds some will have available to offer incentives.  The Homecare Association, for example, has flagged that 79% of homecare services are purchased by councils and the NHS, who fix prices which are too low to cover costs. 
• The additional cost of sponsoring employees – the proposed increase in the Immigration Skills Charge (together with the recently increased CoS assignment fee of £525 per employee) means costs have increased and will need to be factored in when determining whether to sponsor an individual.

While there is reference in the white paper to strengthening UK training and workforce strategies for higher-skilled occupations and to creating a Labour Market Evidence group, it is not clear how the care sector will be supported, particularly in the short term.  Fair Pay Agreements, referred to within the white paper as moving the UK away from a dependence on overseas workers to fulfil care needs, are not likely to come into effect for some time.

If you would like further advice on sponsorship, right to work checks or the planned government changes, please contact me.