After weeks of speculation, the much-anticipated Immigration White Paper was published by the U.K. government on 12 May.1  

The intention behind the Immigration White Paper is to outline the government’s strategy for immigration, including measures to reduce net migration and address perceived abuses within the system, whilst allowing the U.K. to remain open to international talent that will continue to enhance economic growth.  The intent to link the immigration system to skills and training requirements in the U.K. is reflected in several significant changes which have been announced.2   

At the Immigration White Paper press conference, Prime Minister Keir Starmer reiterated “So, as this White Paper sets out, every area of the immigration system, work, family and study, will be tightened up so we have more control,” whilst emphasising that “…We will create a migration system that is controlled, selective, and fair.”  On this premise, the proposed reforms are underpinned by core principles including: reduce net migration; link to U.K. skills needs; fair and clear rules; enforce the rules; and promotion of integration and social cohesion.3  Key reforms impacting various immigration routes and the immigration system itself are detailed below.  


WHY THIS MATTERS

The proposals are designed to reduce net migration; their impact is, however, not limited to U.K. employers and their talent recruitment or HR and global mobility teams.  The proposals will also impact educational institutions and their international recruitment strategies, whilst individuals seeking to remain in or enter the U.K. under the family routes may also need to review their personal circumstances and immigration position.

Although the proposals are subject to parliamentary approval and there are no implementation dates nor transitional arrangements announced as yet, consideration should be given to carrying out an impact analysis that incorporates progressive forward planning. 

For example:

  •  Businesses relying on migrant labour should consider assessing their mobility and talent recruitment policies, whilst evaluating how they align both to the U.K.’s skills and growth strategy.
  •  It is possible that the proposals may influence the decision-making process for key hires if their dependants are to be subject to English-language requirements and/or the route to settlement is prolonged.

In addition, for employers that provide financial and administrative support for immigration applications, further immigration fee increases may impact budgeting decisions and existing financial support policies.  Increased immigration costs, higher skills levels required to qualify for sponsorship, and higher standard of/new rules around English-language requirements may also impact on talent recruitment and mobility programmes, whilst potentially restricting continued access to global talent.


Context

On 28 November 2024, Prime Minister Starmer announced (amongst other things), measures that would be introduced to reduce immigration including the publication of an Immigration White Paper.4  This was in response to the release of revised estimates from the Office of National Statistics which indicated that nearly one million people entered Britain in the year ending June 2023, which was a four-fold increase from 2019 levels.

The new measures unveiled in the Immigration White Paper look to reshaping the immigration system towards those who contribute the most to economic growth, with higher skills standards for graduates and workers.  In addition, the new requirements to be placed on employers to boost domestic training are intended to end reliance on international recruitment.5   

In the live press conference on 12 May, the prime minister promised to “tighten up every area of the immigration system” and referenced the following proposals in the Immigration White Paper6:  

  • Skilled Worker threshold will be raised back to Regulated Qualifications Framework (RQF) 6 (Graduate Level) and above, and there will be tighter restrictions on recruitment for jobs with skills shortages.
  • Residency requirements to qualify for Indefinite Leave to Remain (ILR) will increase from the current five years to ten years.  “High contributing” individuals could be fast-tracked through the system.
  • Language requirements will be increased to help ensure a higher level of English.
  • English-language requirements will also apply to adult dependants, whereby they will have to demonstrate a basic understanding of the language.

Key Reforms 

Details on the reforms under the overarching categories/principles of work, study, family migration, enforcement, and fostering integration and cohesion include the below:

  •  Work route
    • The Skilled Worker threshold will return to RQF Level 6 (Graduate level) and above;
    • The English-language requirement will be raised from B1 to B2 (A-level standard) for main applicants;
    • A new Temporary Shortage List will be introduced;
    • The Immigration Skills Charge will see an increase of 32 percent in line with inflation;
    • A limited pool of recognised refugees and displaced people will contribute through employment, where they have the requisite skills;
    • The Global Talent route to be enhanced to enable the very highly skilled to have opportunities to come to the United Kingdom;
    • Overseas recruitment for social care visas will end – there will be a transition period until 2028 to permit visa extensions and in-country switching.
  • Student route
    • Compliance obligations will be enhanced with Basic Compliance Assessment metrics being raised by 5 percent;
    • The Graduate route will be reformed with the grant of leave to be reduced from 24 months to 18 months (excluding PhD students);
    • Impact assessments to be introduced requiring higher education institutions to demonstrate how they are considering local impacts when taking decisions on international recruitment.
  • Family migration routes
    • Framework for family migration to be revised with clearer parameters around when cases can be treated as “exceptional” under the family- and private-life immigration arrangements;
    • Tightening of suitability rules on the family routes;
    • Financial requirements for the family routes will be informed by the Migration Advisory Committee’s report on the Minimum Income Requirements expected to be published in June.
  • Settlement
    • Standard residency requirements to qualify for ILR will increase from the current five years to ten years;
    • Shorter pathway to settlement for non-U.K. dependants of British citizens to five years will be retained;
    • Expand the Points-Based System to both settlement and citizenship rules so they are based on contribution to the United Kingdom – details will be set out to Parliament later this year;
    • Existing safeguards to protect the vulnerable will be retained;
    • Creation of a new bereaved parent route.
  • Citizenship
    • Reforms to align to the settlement reforms;
    • Increase standard qualifying period and allow those with greater contributions to qualify sooner;
    • Refresh the “Life in the U.K.” test and how it operates.
  •  Enforcement
    •  Enhancement of border security and improve compliance with immigration laws, including for example, measures to tackle illegal working and strengthening of enforcement capabilities;
    • New intelligent technologies for contactless travel through eGates – use of facial comparison technology will be introduced;
    • Detailed reforms and stronger measures to help ensure laws are upheld including streamlining and speeding up the removals process;
    • Strengthening of enforcement activity against foreign national offenders in the United Kingdom.
  •  Fostering integration and cohesion
    • Focus will be on community cohesion and societal contribution;
    • Raising of English-language requirements for workers where a language requirement already applies from B1 to B2;
    • A new language requirement will be introduced for adult dependants of workers and students at level A1 (aligning with the spousal and partner routes);
    • Requirements to be introduced to demonstrate progression to A2 for any visa extension and B2 (independent user) for settlement.

KPMG (U.K.) INSIGHTS

Next Steps for Reforms

It is important to note that the proposed reforms will be subject to parliamentary approval and will require changes to the Immigration Rules which may influence the phasing of implementation.  Details on transitional arrangements and any grandfathering provisions that may be announced over the course of the coming weeks and months will need to be carefully reviewed for impact

Concluding Thoughts & Considerations

As an immediate action, U.K. businesses should consult with their immigration counsel to understand what the proposals could mean from the transactional, operational, and budgeting perspectives.  The proposals, whilst providing clarity on what is expected, could also have created some business uncertainty and worry for employees given timeframes for implementation and as details on transitional and/or grandfathering provisions have not been provided.  Managing employee “experience” within such an evolving immigration landscape, i.e., where significant changes are announced with no substantive detail on their operation and implementation, could well pose challenges for U.K. businesses.

Furthermore, the proposals are expected to impact on workforce planning, talent, and mobility recruitment and retention policies, long-term business planning, and budgeting considerations.  Engagement across stakeholder groups should be seen as a key priority so that downstream processes are agile and flexible enough to incorporate any final proposals.  This should be undertaken in conjunction with immigration counsel to help ensure that the appropriate impact analysis is completed within the requisite legal frameworks and parameters. 


FOOTNOTES:

1  Prime Minister's Office, 10 Downing Street and The Rt Hon Sir Keir Starmer KCB KC MP, "PM speech on migration: 28 November 2024" (28 November 2024).

2  Home Office and The Rt Hon Yvette Cooper MP, "Radical reforms to reduce migration" (11 May 2025).

3  Prime Minister's Office, 10 Downing Street and The Rt Hon Sir Keir Starmer KCB KC MP, "PM remarks at Immigration White Paper press conference: 12 May 2025" (12 May 2025).

4  HM Government, "Restoring Control over the Immigration System" (May 2025).

5  HM Government, "Restoring Control over the Immigration System" (May 2025).

6  Prime Minister's Office, 10 Downing Street and The Rt Hon Sir Keir Starmer KCB KC MP, "PM remarks at Immigration White Paper press conference: 12 May 2025" (12 May 2025).

Contacts

Kelly Whiter

Partner

KPMG in the UK

Nadia Idries

Director & Solicitor

KPMG in the UK

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* Please note the KPMG International member firm in the United States does not provide immigration or labour law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.

The information contained in this newsletter was submitted by the KPMG International member firm in the United Kingdom.

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