The UK immigration system underwent one of its most significant overhauls in decades when the Home Office published Statement of Changes HC 997 on 1 July 2025. These changes, which took effect on 22 July 2025, fundamentally reshaped who can come to work in the UK and under what conditions. If you’re an employer sponsoring workers, currently hold a Skilled Worker visa, or plan to apply for one, understanding these changes is essential.
The reforms stem from the government’s Immigration White Paper titled “Restoring Control over the Immigration System,” published in May 2025. The government wants to reduce net migration and tackle exploitation in certain sectors. The system is being refocused on higher-skilled workers. What does this actually mean for you?
What Changed on 22 July 2025?
The HC 997 statement of changes introduced sweeping reforms across work visa routes. The most fundamental shift raised the minimum skill level for Skilled Worker visas from RQF level 3 (roughly A-level equivalent) back to RQF level 6, which corresponds to bachelor’s degree level. This single change removed between 100 and 180 occupations from the list of roles eligible for overseas sponsorship.
Alongside the skill threshold increase, salary requirements rose across the board. The government updated pay thresholds using the latest Annual Survey of Hours and Earnings data. Most sponsored workers now need higher salaries than before. No transitional relief exists for these salary increases. If you’re applying on or after 22 July 2025, you must meet the new figures regardless of when your Certificate of Sponsorship was issued.
The care sector faced particularly dramatic changes. Overseas recruitment for care workers (SOC code 6135) and senior care workers (SOC code 6136) stopped entirely on 22 July 2025. While in-country switching remains possible until 2028, this represents a fundamental policy shift away from international recruitment in adult social care.
The Skilled Worker Skill Level Increase
Before 22 July 2025, employers could sponsor workers for roles that were at an RQF level 3 or above. The government had lowered this threshold from level 6 back in 2020 to help businesses adjust after Brexit and the end of free movement with the EU. That temporary measure has now ended.
What does RQF level 6 actually mean? It’s the standard for undergraduate degrees. Think engineering, IT professional roles, business analysts, teachers, and similar graduate-level positions. Jobs like warehouse supervisors, hospitality managers, care workers, and many construction trades that previously qualified at level 3 to 5 no longer qualify unless they appear on specific shortage lists.
The Home Office restructured Appendix Skilled Occupations to reflect this change. Tables 1, 2, and 3 now list only occupations at RQF level 6 and above that remain fully eligible for sponsorship. New Tables 1A, 2AA, and 3A contain the level 3 to 5 roles that can still be sponsored under exceptional circumstances. These exceptions apply either because the roles appear on the Immigration Salary List or the new Temporary Shortage List, or because the worker was already sponsored in that role before the changes.
Transitional arrangements protect existing Skilled Worker visa holders. If you held a Skilled Worker visa in a below-degree-level occupation before 22 July 2025, you can continue to extend your visa, change employers, and take supplementary employment in similar roles. The Explanatory Memorandum makes clear these transitional provisions won’t last forever and will be reviewed in due course, but for now they provide a safety net for people already established in the UK.
New Salary Thresholds Across Work Routes
Salary requirements increased substantially across all sponsored work routes. For Skilled Worker visas, the general threshold rose from £38,700 to £41,700 for most roles. This figure applies to jobs at RQF level 6 and above unless a higher occupation-specific going rate applies.
The going rates themselves (the minimum salaries set for each occupation code) reflect the 2024 Annual Survey of Hours and Earnings data. Most occupations saw their minimum pay requirements increase by several thousand pounds. Roles in healthcare, engineering, and IT all now require higher going rates to reflect current UK pay levels.
There’s an important technical change that affects how employers calculate salary. Only the first 48 hours worked per week now count towards meeting the salary threshold. This closes a loophole where employers could meet requirements through excessive overtime rather than base pay. If you’re working 60 hours a week at £15 per hour, your salary for immigration purposes now equals £37,440 (48 hours × £15 × 52 weeks), not the £46,800 you’d earn from all 60 hours.
For roles on the Immigration Salary List at RQF levels 3 to 5, the minimum equals £23,200 plus the full going rate for that occupation. The system automatically satisfies the hourly test of £17.13 for these roles, though again only 48 hours per week count.
Immigration Salary List and Temporary Shortage List
The government introduced two interim shortage occupation lists to provide limited access to below-degree-level roles. Neither list represents a long-term solution. Both are explicitly temporary arrangements that will be reviewed and potentially withdrawn.
The Immigration Salary List expanded to include all RQF level 3 to 5 occupations that the Migration Advisory Committee previously judged to be in shortage. This list will remain in place until 31 December 2026, though ministers can withdraw it earlier. Occupations on this list can be sponsored at reduced salary thresholds, but workers sponsored for these roles cannot bring dependants to the UK.
The new Temporary Shortage List covers roles the Treasury and Department for Business and Trade view as critical to the government’s Modern Industrial Strategy. Like the Immigration Salary List, these occupations are time-limited until the end of 2026 and carry the same restriction on bringing family members. The government expects sectors relying on these lists to develop domestic workforce strategies to reduce their dependence on overseas recruitment.
Care workers and senior care workers remain on the Immigration Salary List until 22 July 2028, acknowledging the acute shortages in this sector. However, as discussed below, the route is closing to new overseas applications, making this a transitional arrangement rather than a long-term solution.
Care Worker Route Closure
The most dramatic change for the healthcare sector was the immediate closure of overseas recruitment for care workers and senior care workers. From 22 July 2025, sponsors cannot issue Certificates of Sponsorship for new entry clearance applications in these occupation codes.
The government cited several concerns that drove this decision. Numbers under the care worker route had grown rapidly, reaching unexpectedly high levels. Authorities documented exploitation of overseas workers, licence compliance failures among care providers, and overstated demand projections. Multiple care sector sponsors lost their licences due to non-compliance. Workers reported poor conditions and unfair treatment.
In-country switching remains possible until 22 July 2028, but with strict conditions. The worker must already be in the UK on another visa route and must have worked for the sponsoring care provider for at least three months before the sponsor issues the Certificate of Sponsorship. This requirement aims to ensure workers have demonstrated suitability and that sponsors comply with employment law before sponsorship begins.
The policy signals a clear shift in government thinking. Sectors that rely heavily on overseas recruitment are expected to develop and implement workforce strategies focusing on UK-based recruitment, training, and retention. The Explanatory Memorandum warns that failure to do so may result in losing access to the immigration system entirely.
Dependant Restrictions for Below-Degree Roles
Another significant change affects family rights. Workers sponsored for roles at RQF levels 3 to 5 on either the Immigration Salary List or Temporary Shortage List cannot bring dependants to the UK. This mirrors the existing policy for care workers, which banned dependants from March 2024.
The restriction applies only to new applicants whom sponsors bring in after 22 July 2025. If you were already on the Skilled Worker route with dependants before this date, your family members can continue their stay. You can extend their permission when you extend your own visa. The ban doesn’t apply to roles at RQF level 6 or above. Only the below-degree positions on the shortage lists face this restriction.
This creates difficult choices for workers considering these roles. The inability to bring spouses and children fundamentally changes the attractiveness of coming to the UK, particularly for longer-term assignments. It’s a deliberate policy lever designed to discourage reliance on below-degree immigration while the shortage lists remain in place.
Global Business Mobility Route Changes
The reforms weren’t limited to the Skilled Worker route. Global Business Mobility routes saw salary threshold increases as well. For Senior or Specialist Workers, the minimum salary jumped from £48,500 to £52,500. The 48-hour weekly cap on countable hours now applies to these routes too, matching the Skilled Worker rules.
Several occupation codes that were previously ineligible for Global Business Mobility routes have been updated in the new tables. The restructuring of Appendix Skilled Occupations means sponsors need to carefully check which roles remain eligible and what salary thresholds apply.
Afghan Relocations and Assistance Policy Closure
Separate from the work route changes, HC 997 closed the Afghan Relocations and Assistance Policy (ARAP) to new principal applications. From 15:00 BST on 1 July 2025, the Ministry of Defence stopped accepting new applications under this scheme.
The government stated that ARAP had fulfilled its purpose after relocating over 21,000 people. Authorities cited the large backlog of pending cases and high rates of ineligibility as reasons for closure. Family applications for people who applied before the deadline can still proceed, but new principal applicants can no longer access this route.
The decision proved controversial, with thousands of cases still pending and many applicants remaining in Afghanistan or other countries. Some MPs tabled a motion to disapprove HC 997 specifically because of the ARAP closure, though the government faced no obligation to allow a vote on the motion.
What Happened to Applications Submitted Before 22 July?
The statement of changes includes important transitional provisions. If you applied using a Certificate of Sponsorship that the sponsor issued before 22 July 2025, the Home Office will decide your application under the rules that were in force on 21 July 2025. This rule holds even if the decision doesn’t come until months later.
Similarly, applications that don’t require a Certificate of Sponsorship but came in before 22 July 2025 follow the old rules. This created a window where employers could assign Certificates of Sponsorship under the previous, more lenient requirements, provided they did so before the deadline.
No transitional arrangements exist for the salary increases. The updated going rates and general thresholds apply to all applications made on or after 22 July 2025, regardless of when the employer offered the job or recruited the worker. This caught some employers off guard, particularly those with recruitment processes already underway when the Home Office published HC 997.
Impact on Current Skilled Worker Visa Holders
If you currently hold a Skilled Worker visa in a role that’s no longer eligible at RQF level 3 to 5, the transitional provisions protect your position. You can continue to extend your visa in the same occupation, change to another employer for a similar below-degree role, and take supplementary employment in these occupations.
However, there’s an important caveat. These transitional arrangements are explicitly temporary. The Explanatory Memorandum states they “will not be in place indefinitely and will be reviewed in due course.” The government hasn’t specified when this review will happen or what it might conclude. This creates uncertainty for people building long-term lives and careers in the UK in these roles.
If you’re planning to switch employers or change roles, you still need to meet the salary requirements for your occupation. The skill level exemption only covers the new RQF level 6 requirement. You don’t get relief from the updated going rates and general salary thresholds.
Employer Compliance Obligations
Sponsors face heightened compliance expectations under the new regime. The Home Office has made clear that non-compliance and exploitation will not be tolerated, particularly in sectors that retain access to below-degree sponsorship.
Care sector sponsors face additional restrictions. From 22 July 2025, they must retain evidence that any worker they sponsor for in-country switching to care worker or senior care worker roles has been on the payroll for at least three months before they issue the Certificate of Sponsorship. This documentation requirement aims to prevent circumvention of the overseas recruitment ban.
The requirement for sponsors to recruit first from Skilled Workers seeking new sponsorship before issuing Certificates of Sponsorship for care roles no longer exists. This simplifies the process for the transitional period but doesn’t change the fundamental restriction that new overseas applications have closed.
Sponsors should review their processes for assigning Certificates of Sponsorship, ensuring they’re checking occupation codes against the correct tables in Appendix Skilled Occupations. The restructured tables mean some codes appear in multiple places, and it’s crucial to identify which applies to your specific circumstances.
Future Changes Already Announced
HC 997 was just the first wave of reforms. The government has already announced further changes coming in 2026 and beyond.
The Immigration Skills Charge increased on 16 December 2025, rising by 32% from £1,000 to £1,320 per person per year for most workers. This adds substantially to sponsorship costs for employers.
From 8 January 2026, English language requirements increase from B1 to B2 level on the Common European Framework of Reference for Languages scale. This applies to Skilled Worker, High Potential Individual, and Scale-up visa applicants. The higher standard means stronger English skills are required before someone can be sponsored.
Graduate visas will be shortened from 1 January 2027. Students who complete their degrees will receive only 18 months of post-study work permission instead of the current two years. PhD graduates still get three years, but the reduction for undergraduates and taught postgraduates is significant.
The most substantial changes take effect in April 2026, when new permanent residence rules come into force. The qualifying period for Indefinite Leave to Remain will increase from five years to ten years for most routes. This represents a fundamental shift in the pathway to settlement, doubling the time workers must spend on temporary visas before they can apply for permanent residence.
What This Means for Different Stakeholders
For employers, these changes require immediate action. Any recruitment processes underway need review to ensure salaries meet new thresholds and roles qualify under the updated occupation lists. If your workforce includes sponsored workers in roles that are no longer eligible, you need contingency plans for when transitional provisions end.
Sectors that previously relied on RQF level 3 to 5 roles must develop domestic recruitment strategies. The government has signaled clearly that access to overseas workers for these positions is temporary and conditional on demonstrable efforts to train and recruit UK-based staff.
Current Skilled Worker visa holders in below-degree roles face uncertainty. While transitional provisions currently protect your position, the lack of a clear endpoint creates challenges for long-term planning. You can extend your visa and change employers for now, but you should monitor announcements about when and how these transitional arrangements might change.
People planning to apply from overseas for roles at RQF levels 3 to 5 have limited options. You can only be sponsored if the occupation appears on the Immigration Salary List or Temporary Shortage List, and even then, you cannot bring dependants. The route is explicitly temporary, with both lists scheduled to end in December 2026 unless renewed.
Planning for Compliance
The complexity of HC 997 means sponsors need proper compliance systems. Every Certificate of Sponsorship assigned from 22 July 2025 onwards must be checked against the new rules. You need to verify the correct tables, the updated going rates, and the enhanced skill requirements.
Internal processes should reflect the new structure. Recruitment teams, HR departments, and those managing the Sponsor Management System all need training on the changes. The margin for error has narrowed. Getting it wrong brings consequences: refused applications, possible sponsor licence action, and significant financial costs from reapplying at higher salary levels.
Right to Work checks remain important. Sponsors must now also track the changing landscape for existing workers. Someone who was legitimately sponsored three months ago might not qualify for the same role today as a new overseas applicant. Understanding transitional provisions is crucial for compliance.
Looking Ahead
HC 997 represents a fundamental recalibration of UK immigration policy toward work migration. The focus has shifted decisively toward higher-skilled, higher-paid workers, with temporary and conditional access for sectors with genuine labour shortages that can demonstrate efforts to address those shortages domestically.
The government has commissioned the Migration Advisory Committee to conduct a thorough review of salary requirements, including all the discounts and exceptions that currently apply. That review will likely lead to further changes in 2026 or 2027. The MAC’s recommendations could introduce additional salary increases, remove more discounts, or restructure how going rates are calculated.
Further consultations are expected on workforce strategies for sectors that retain access to the Temporary Shortage List. These strategies will need to show concrete plans for reducing reliance on overseas recruitment through investment in training, improved retention, and better working conditions.
The broader policy direction is clear: the UK immigration system is moving toward fewer numbers, higher skills, and longer qualifying periods for settlement. For those already in the system or planning to use it, you need to understand these changes and prepare for further reforms. HC 997 was a significant step in an ongoing transformation.
This article provides general information about the Statement of Changes HC 997. Immigration law is complex and changes frequently. For advice on your specific circumstances, please consult a qualified immigration solicitor or adviser.
Related Topics:
- Statement of Changes HC 997 official document
- Skilled Worker visa requirements
- Immigration Salary List 2025
- Temporary Shortage List occupations
- Certificate of Sponsorship guidance
