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      On 1 July 2025, the U.K. government laid before Parliament a Statement of Changes to the Immigration Rules (HC 997).  The changes are the first to implement the immigration strategy outlined in its Immigration White Paper¹ and are aimed at “ending the U.K.’s reliance on overseas, lower skilled recruitment.”2

      The changes summarised here take effect on 22 July 2025.

      WHY THIS MATTERS

      The changes affect a wide range of immigration categories, including the Skilled Worker, Global Business Mobility, and Scale-up routes.

      These reforms represent a significant tightening of the U.K.’s immigration system and have wide-ranging implications for businesses sponsoring workers from overseas with potential challenges around recruiting/hiring foreign nationals into certain roles and bringing foreign nationals (including, especially, their trailing dependants) into the U.K. for work purposes.

      Increased salary thresholds and immigration-related fees may raise international assignment programme costs for many employers. 

      Key HighlightsHeader

      Skilled Worker Route

      • Skills Threshold Raised: The minimum skill level for sponsorship will be raised from RQF Level 3 to RQF Level 6, removing approximately 180 occupations from eligibility for sponsorship.
      • Salary Thresholds Updated: The general salary threshold and going rates will be updated in line with the 2024 Annual Survey of Hours and Earnings (ASHE)3.  From 22 July 2025, the general threshold for Skilled Workers will increase from £38,700 to £41,700 and the new entrant threshold will increase from £30,960 to £33,400.  There will be no transitional measures put in place for this, and salary changes will apply across the board, although lower salary thresholds will still apply for those on the Skilled Worker route before 4 April 2024.
      • Appendix Skilled Occupations Restructured: Occupations are now grouped by skill level (RQF 6+ vs. RQF 3-5) across new tables.
      • Transitional Arrangements: Existing Skilled Workers can continue to renew visas, change jobs and take supplementary employment in RQF 3-5 occupations (which will be reviewed later) but salary increases with extensions and settlement applications will apply.  A Migration Advisory Committee (“MAC”) review of the salary requirements (as well as discounts) is to follow.

      Immigration Salary List & Temporary Shortage List

      • Expanded Immigration Salary List: To include occupations on the current Immigration Salary List as well as those occupations that the MAC identified as facing shortages in its 2023 and 2024 reviews.
      • Temporary Shortage List Introduced: Containing occupations at RQF levels 3-5 identified as being important by the Department of Business and Trade for the U.K.’s Modern Industrial Strategy4, and subject to review by the MAC.
      • Dependants Restricted: New entrants on either list cannot bring dependants.
      • Sunset Clause: Occupations on these lists will be removed by 31 December 2026, except for adult social care roles, which have a transition period until 22 July 2028.

      Global Business Mobility and Scale-up Routes

      • General Salary Thresholds Increased: Global Business Mobility route threshold will increase from £48,500 to £52,500; Scale-up route threshold will increase from £36,300 to £39,100.

      Adult Social Care

      • Closure of Entry Clearance: New overseas applications for care workers and senior care workers will be closed.
      • In-Country Switching Allowed: Until 22 July 2028, in-country applicants can switch into these roles if they have worked for their sponsor for at least three months.
      • Transitional Provision: Allow those already sponsored in these roles to extend and settle without needing to meet the higher RQF 6 skill level.

      KPMG LLP (U.K.) INSIGHTS

      Taking Action

      In light of the upcoming changes, U.K. businesses should:

      • consult with their immigration counsel to understand what the changes mean for their affected
        populations;  
      • review current and future sponsorship plans considering the new salary and skill thresholds, and the
        end of discounts available in shortage occupations;
      • consider moving applications forward, where possible, before 22 July 2025, to take advantage of the benefits of the current Immigration Rules.  If in-year increases to CoS allocations are needed, these should be submitted on a priority basis and as soon as possible.

      Considerations

      The proposals are expected to impact on workforce planning, talent, and mobility recruitment and retention policies, long-term business planning, and budgeting considerations.

      The changes, whilst providing clarity on what is to come from 22 July 2025, could create some business uncertainty and worry for employees given the timeline for implementation.

      Transitional provisions will need to be communicated to those already being sponsored.  Managing employee “experience” will be important to tempering heightened anxiety and mitigating confusions caused by these changes.

      Engagement across stakeholder groups should be seen as a key priority so that processes are flexible enough to incorporate the changes.  This should be undertaken in conjunction with immigration counsel to help ensure that the appropriate impact analysis is completed.

      What’s Next

      The latest Statement of Changes begins the process of reform that the government laid out in its Immigration White Paper in May 2025.  In an announcement on 1 July 2025, introducing the Statement of Changes, the Home Secretary, Yvette Cooper, sign-posted the following changes from the Immigration White Paper that will be implemented later this year, including:

      • an increase to the Immigration Skills Charge (the Immigration White Paper proposed a rise of 32 percent);
      • raising the English-language requirements across immigration routes;
      • laying a new family migration policy before Parliament.  
      FOOTNOTES:

      1  U.K. Home Office, Immigration White Paper, “Restoring Control over the Immigration System,” published 12 March 2025, at: https://www.gov.uk/government/publications/restoring-control-over-the-immigration-system-white-paper.  (For related coverage see, GMS Flash Alert 2025-094, 13 May 2025.)

      2  U.K. Home Office, “Major immigration reforms delivered to restore order and control,” at: https://www.gov.uk/government/news/major-immigration-reforms-delivered-to-restore-order-and-control.

      3  U.K. Home Office, Statement of Changes in Immigration Rules (HC 997), laid before Parliament on 1 July 2025.  See: https://www.gov.uk/government/collections/immigration-rules-statement-of-changes.

      4  U.K. Government, Industrial Strategy. See: https://www.gov.uk/government/publications/industrial-strategy.

      Contacts

      Kelly Whiter
      Kelly Whiter

      Partner

      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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