The UK Home Office enacted important changes in April. An Immigration White Paper is expected to spell out further future measures to reduce immigration after the local elections, with employers lobbying for the government to prioritise business, while the government insists curbing migration need not hit growth. After a series of recent measures have made Britain’s immigration systems one of the most expensive in the world, that may not be what employers want to hear.
For now, there are a few developments that HR teams may now have to negotiate. It is crucial that employers keep on top of these changes as Home Office compliance visits have shot up 40% year-on-year, and civil penalties are rising too, with over £20 million issued in the last recorded quarter.
Sponsoring investors as Skilled Workers
Up to now it has been possible for businesses to sponsor their owners and investors if they fulfil the Skilled Worker requirements. The Home Office has sought to curb what it calls “self-sponsorship” and close the “loophole whereby applicants could effectively pay towards their own salary through investing in their sponsor’s business.”
They have used a rather blunt tool which will now affect any organisation sponsoring someone who has invested capital in it. Any salary paid to someone sponsored as a Skilled Worker after 9 April 2025 will now have to be high enough to meet minimum salary requirements for a Skilled Worker after accounting for the investment. Any amount invested in an organisation by a Skilled Worker (averaged over the length of their visa) will be deducted from their effective gross salary when calculating if they meet the minimum salary requirement to be sponsored.
Recouping immigration costs from sponsored workers
As well as invested capital, any deductions from a worker’s salary or repayments of loans that relate to business or immigration costs will now be deducted from gross salary to calculate if a sponsor has met minimum salary requirements. Deductions will be averaged out over the period that the worker is sponsored. Money won’t be subtracted if the deduction is related to a voluntary benefit where the worker has a genuine choice to take it up, such as a salary sacrifice arrangement for nursery fees.
Up to the start of this year, the only cost an employer must pay and not claim back from a sponsored migrant was the Immigration Skills Charge payable to sponsor them. A Skilled Worker sponsor now risks losing their licence if they recoup or attempt to recoup the costs of a Skilled Worker sponsor licence fee or any “associated administrative costs” on or after 31 December 2024, or a Skilled Worker’s Certificate of Sponsorship fee assigned on or after 31 December 2024 and any administrative costs associated with that.
Since 9 April 2025, Sponsors must not attempt to recoup the cost of a sponsor licence or associated administrative costs for any other sponsored work immigration route, nor the fee or associated administrative costs for a Certificate of Sponsorship for any migrant workers sponsored on a Global Business Mobility, Scale-up, Seasonal Worker, International Sportsperson or Minister of Religion route.
A sponsor may still expect a prospective worker to pay for their work visa. However, if the sponsor wants to have the option of passing on the costs of professional immigration advice for the visa, they cannot dictate that the worker must use immigration advice or which immigration adviser to use – though they may suggest one.
Skilled Workers sponsored on the most discounted minimums
The minimum salary threshold for Skilled Workers sponsored on the most discounted rates (those applying for Health and Care visas or visa extensions under rules for New Entrants, STEM PhDs or on the Immigrant Salary List or roles on national pay scales, such as many NHS or education roles) has been updated from £23,200pa (£11.90 per hour) to £25,000 (£12.82 per hour). This is to ensure pay remains above the National Living Wage, which is also increasing in April 2025. The government has also raised its going rates minimums for healthcare and education occupations sponsored on the national pay scales to reflect the latest pay scales.
Sponsoring carers and creative workers
Employers seeking to sponsor new care workers, home carers or senior care workers in England must first try employing candidates identified by their regional partnership as migrant care workers who have been left without a sponsor or at risk of exploitation after a recent Home Office crackdown on unscrupulous sponsors in the sector.
The new care worker recruitment requirement applies to any Certificate of Sponsorship assigned on or after 9 April 2025. It won’t apply if a prospective carer would not be working in England or if they are already sponsored in these occupations or switching from other immigration routes and they have been working for their sponsor already for at least three months.
Companies sponsoring creatives on Temporary Work – Creative Worker visas must not use that immigration route to fill a permanent position, “including on a temporary basis.”
Thresholds for small companies
The turnover and balance thresholds that define small companies changed on 6 April 2025. Small companies must now not have an annual turnover of over £15 million (up from £10.2 million) and no more than £7.5 million balance sheet total (up from £5.1 million). Sponsors have a duty to report within 20 working days where a sponsor changes from falling within the small sponsor regime to not falling within it (or vice versa). This change may be good news as small companies pay less for Skilled Worker and Senior or Specialist Worker sponsor licence applications and the Immigration Skills Charge paid for workers on these routes.
Immigration fees
The majority of visa application and nationality fees increased between 5 and 10% on 9 April 2025. However, sponsors will note the cost of a Certificate of Sponsorship to sponsor most migrant workers has risen from £239 to £525. You can find the full visa and immigration fee increases here.
Global Talent visa endorsement
Global Talent visa applicants must demonstrate that they are leaders, or show ‘promise’ in becoming a leader in digital technology, the arts, academia or scientific research, either through endorsement by an endorsing body or with qualifying awards. There were minor amendments this April to how evidence is presented to endorsing bodies such as the Royal Institute of British Architects or British Fashion Council, as well as amendments to lists of qualifying prizes and contributions.
Gig economy and zero hours workers will require right to work checks
Right to work checks on employees will be extended to cover gig economy and zero-hours workers. Currently, companies using such flexible arrangements are not required to check the status of on demand workers as the requirement is limited to employees only.
This change is likely to require legislation, so is unlikely to be any time soon. But with severe penalties for those caught out, including losing a licence to sponsor migrant workers, employers affected should be preparing for this change.
