UK Government publishes first statement of changes in 2025

In a series of wider acts to implement the Plan for Change, the government published its most recent procedural amendments in the first statement of changes to the Immigration Rules in 2025, published on 12 March.

These efforts are one of the key milestones in the mission-led government manifesto Plan for Change, which strives to strike a balance between the bargaining position of migrant workers and sponsoring employers.

From the guidance changes introduced at the start of 2025, clamping down on the use of the ‘clawback’ provisions and clarifying what costs can be recouped by an employer and what cannot, these changes to the Immigration Rules have sought to go further and address the issue of international workers facing destitution, exploitation and modern slavery, which has been on a steady rise. 

The health and social care sector is one of the biggest industries in the UK that relies on international workers to ensure the proper functioning of the sector. However, despite this increased reliance, compliance and regulation on the conduct of sponsoring employees has failed to keep up. As a result, since 2022, more than 470 sponsor licences have been revoked in the adult care sector, with nearly 40,000 migrant care workers finding themselves without sponsorship.

In response to this, the government has set out to implement a new priority recruitment strategy, mandating sponsoring employers to recruit from the existing pool of migrant workers who have been displaced and are seeking new sponsorship. According to the statement of changes, from 9 April 2025 new procedures must be implemented in internal and overseas recruitment, with greater scrutiny on record keeping under the new duty to prove that the sponsoring employer attempted to recruit an existing migrant based in the UK before assigning sponsorship to an overseas migrant. 
With a new duty to demonstrate efforts to employ UK-based migrants, employers will need to begin working with regional partnerships to effectively demonstrate their efforts. The statement of changes confirmed that this duty is only on employers hiring from the existing pool of migrant care workers in England and will not apply in the other UK nations yet.

This new duty will give displaced workers a priority position in the queue for sponsorship, with this hiring strategy aimed at also implementing ethical recruitment and prioritising their visa application submissions. 
Moreover, in line with these changes that focus mainly on workers in the care sector, the statement of changes outlined broader changes that affect skilled workers as a whole.

Firstly, the minimum salary for skilled workers is being updated to remain aligned with the latest Annual Survey of Hours and Earnings (ASHE) data from the Office for National Statistics (ONS). With salaries increasing from £23,200 per year (or £11.90 per hour) to £25,000 per year (or £12.82 per hour), earnings for international workers and UK-based workers will steadily rise together, ensuring fair remuneration for migrant workers.

Secondly, coinciding with their efforts to remove employers from recouping prohibited costs, the statement of changes details restrictions to the type of deductions that can be made from an applicant’s salary. By preventing any sponsorship costs from being passed onto applicants, certificates of sponsorship post 9 April 2025 must detail salaries above the threshold, after the subtraction of any miscellaneous payments from the migrant to the sponsoring employer. After such deductions have been met, the salary must still be above the threshold.

Additionally, the sought-after self-sponsorship of business owners under this route is under threat, with changes to effectively closing this loophole by preventing applicants from being able to contribute towards their salary through investment. This measure is being implemented as a means of preventing overseas workers from paying towards their salaries and ensuring the remuneration they receive is legitimate and fair. This loophole was intended for business owners, however, it has been mismanaged and abused, resulting in vulnerable migrants paying towards their salaries.  
Previously, applicants qualifying for a salary reduction as a ‘new entrant’ had to demonstrate that they were training towards a recognised professional qualification. This requirement has been narrowed, with the inclusion of the professional qualification needing to be a UK qualification. This restricts the number of applicants who will qualify under the new entrant criteria whilst simultaneously encouraging applicants to undertake UK-based qualifications.

With the 9 April 2025 being an important date in the immigration year calendar, its significance is heighted by the Home Office immigration and nationality application fees increasing on this date as well. More details on the particulars of the increases can be found here.

Therefore, should sponsoring employers hesitate to act, they risk getting caught up in the recent overhaul of the immigration system and falling foul of their sponsor duties. It is not yet clear how the amendments outlined in the statement of changes will be implemented in practice, with more information to be disclosed in the upcoming immigration white paper. However, for sponsoring employers planning to recruit overseas workers, it is imperative they remain vigilant and keep abreast with the recent changes should they want to retain their licence.

At Burness Paull we have years of experience dealing with the sponsorship system. We can guide you through these new changes and ensure compliance with the immigration rules. Get in touch with our immigration team.

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