The UK's immigration system has recently undergone a number of changes and is projected to continue evolving through the first quarter of 2026. Below are some of the most recent updates which affect employers and individuals, and which you should be considering now to assess any potential impact they may have on your business or personal life.
European Union's new entry/exit system
Effective from 12 October 2025, the European Union has implemented several modifications to existing protocols for British and other non-EU nationals travelling to the Schengen area (including Iceland, Liechtenstein, Norway and Switzerland but excluding Ireland and Cyprus).
The initial change involves the introduction of the new Entry/Exit System (EES), which will replace the traditional passport-stamping process for arrivals and departures with an electronic record system. The EES registers non-EU nationals travelling for a short stay (ie up to 90 days in a 180 day period), each time they cross the external borders of any of the European countries using the system. Under the EES, travellers’ details will be automatically recorded at entry and exit points through a kiosk that scans passports, captures fingerprints and takes photographs to create a digital profile. This profile will be retained for three years and may be utilised for future journeys. A comprehensive list of exemptions can be found on the European Union's official website.
Registration for the new EES has commenced at airports starting 12 October 2025, with the same date applicable to coach passengers travelling via Eurotunnel or ferries. By April 2026, it is expected that all border crossings will have transitioned to the new system.
Increase in immigration fees and skills charge
The immigration fees for the post-licence priority service and the sponsor licence priority service will increase from 11 November 2025. The post-licence priority service will increase from £200 to £350 (an increase of £150), whereas the sponsor licence application priority service will increase from £500 to £750 (an increase of £250).
In addition, the Immigration Skills Charge payable by sponsors when they assign a Certificate of Sponsorship (CoS) to non-exempt sponsored workers will increase by 32% from 16 December 2025.
What is the impact of these continued fee increases?
Employers should continue to plan ahead for recruitment, budget strategically and continue to collaborate with their HR and legal departments to establish comprehensive, forward-looking processes and strategies. The post-licence priority service is widely used by sponsors and often becomes essential when an additional undefined CoS is needed faster than the standard 18-week processing time. Sponsorship is already a significant expense, and recent fee increases highlight the importance of proactive planning. Businesses must anticipate future recruitment needs and allocate resources accordingly to avoid unexpected costs and delays.
Statement of changes to the immigration rules
The Home Office published a Statement of Changes to the Immigration Rules on 14 October 2025, which implements further key proposals that were outlined in the Government's Immigration White Paper.
The Statement of Changes includes the following:
- Effective from 8 January 2026, applicants for the Skilled Worker, Scale-Up and High Potential Individual work visas will have to meet B2 level English (A-Level standard), up from the previous B1. This will add further complexity to the preparation burden for applicants and could act as a barrier to entry for those who are unable to meet this higher English language level. Employers looking to sponsor individuals after 8 January 2026 should work with the individual to plan ahead for the application and assess whether they can meet this higher language threshold. If they can't they may need to consider taking an English language course to enable them to meet the required level (which will add another cost to the application process).
- The post-study work visa's (Graduate visa) period of grant for international graduates is set to be reduced from two years to 18 months from 1 January 2027. However, PhD graduates will be exempt from this change and will continue to be eligible for three years of permission. The two-year Graduate Visa previously gave employers valuable flexibility to evaluate graduates’ performance and cultural fit before committing to Skilled Worker sponsorship. Reducing this period significantly increases pressure on employers to make sponsorship decisions much earlier—often before graduates complete structured two-year training schemes. This creates operational challenges, as businesses may need to commit resources without having a full picture of the graduate’s capabilities. The shorter visa term could also make UK graduate programmes less attractive to international candidates, who may prefer markets offering greater stability and time to transition into skilled roles. For employers, this means potential difficulty in attracting top global talent and a shrinking pool of skilled workers.
- From 4 November 2025, the number of eligible universities for the High Potential Individual Visa will be expanded to include international institutions ranked in the top 100, with a cap of 8,000 applications per year.
- Botswanan nationals visiting the UK will now need to obtain a visitor visa in advance of travelling from 14 October 2025. There will, however, be a six week transition period for individuals who already held the previously accepted Electronic Travel Authorisation.
Temporary shortage list review: stage two
The Migration Advisory Committee (MAC) has released its report on stage 1 of the Temporary Shortage List review, available through this link. The stage 1 report provides recommendations for the structure of the Temporary Shortage List and lists 82 occupations proposed for further consideration at stage 2 due to their relevance to the Government's industrial strategy or critical infrastructure.
Recommendations include:
- A default duration of three years for occupations added to the Temporary Shortage List (TSL), with the possibility of shorter periods if Job Plans are not fully detailed but expected to improve.
- Visa durations may be set between three and five years, but the MAC advises that these should not exceed five years if the TSL is not intended as a route to settlement (which is yet to be confirmed).
- English language requirements should be set at a minimum of B1.
- The MAC suggests that the Home Office prioritises a simple and flexible approach in designing the TSL and continues to examine alternative sponsorship models. It also notes that there are differing views regarding the reintroduction of a Resident Labour Market Test and maintains the option of nation-specific additions to the list, although with strict criteria.
- The Immigration White Paper and subsequent rule changes have excluded dependants from TSL occupations; therefore, the MAC has not addressed this further.
The MAC is seeking evidence regarding workforce shortages and approaches to strengthen the domestic workforce. Employers should actively participate in ongoing consultations and evaluate their talent pipelines and sponsorship agreements to determine potential impacts from these forthcoming policy changes. The MAC's call for evidence is an opportunity for employers, trade bodies and stakeholders to influence and feed into the TSL by gathering and submitting evidence to the MAC related to specific labour shortages.
Stage 2 of the Temporary Shortage List review will close on 2 February 2026.
Further details about the stage 2 review are available here.
Right to work scheme consultation
The Home Office is consulting on extending right to work checks to the gig economy. It is currently proposing to expand the Right to Work scheme to cover those who engage individuals as casual or temporary workers under a worker's contract, individual sub-contractors, and through online matching services (that provide details of service providers to potential clients or customers for remuneration).
If this policy is extended, it will create a new legal obligation on employers who engage 'gig economy workers' to conduct a right to work check before engaging them for work. This will increase costs and administrative responsibilities for those employers, and will expose them to the risk of significant financial penalties if they fail to comply with the right to work checking regime. We anticipate that employers within the construction, hospitality, food delivery and courier industries will be hardest hit by these changes.
Further information can be found here.
This article is for general information only and reflects the position at the date of publication. It does not constitute legal advice.