The immigration White Paper: a short guide

16 December 2025

The long-awaited White Paper was published on 12 May 2025. The policies are intended to reduce net migration to the UK and encourage recruitment from the domestic workforce.

Here is a summary of the main things you need to know.

Timing

• Staggered start. The White Paper itself does not change the law. Some new Skilled Worker rules started where a certificate of sponsorship (CoS) was assigned on or after 22 July 2025. Other implementation dates will be staggered. Further details are included below.

• Consultations. Some of the changes, including to settlement and citizenship are subject to consultations. The earned settlement consultation was released in November 2025 and closes on 12 February 2026. New settlement rules could start as early as April 2026 with a phased implementation. For full details of the earned settlement proposals, see our FAQs.

 

Skilled worker

• Higher skill level. Since 22 July 2025 the skill level rose for new applicants from RQF level 3 to 6 – a return to the pre-Brexit Tier 2 level.
   
• Roles below level 6. Since 22 July 2025 for new applicants filling roles at level 3-5, only jobs on the Immigration Salary List or Temporary Shortage List can be sponsored. The Immigration Salary List will be abolished on 31 December 2026. The Temporary Shortage List is for roles recognised as a long-term shortage. Dependants are not permitted for new applicants on either list. No salary or visa fee discounts apply to Temporary Shortage List roles. For the Temporary Shortage List, by July 2026 the Migration Advisory Committee (MAC) will advise on workforce strategies which will require sponsors to train and engage with the domestic workforce - potentially not until 31 December 2026. 
   
• Higher salary thresholds. Since 22 July 2025, there have been increases to the general salary thresholds and going rates.
   
• Care workers. Since 22 July 2025, it is not possible to sponsor new care worker applicants.
   
• English language test level. From 8 January 2026, where a test is needed, the required level will go from B1 to B2 (it will stay at level B1 for Skilled Workers who already have permission before that date).
   
• Settlement and citizenship. As below, there is a proposal to increase the qualifying period for settlement (indefinite leave to remain) from 5 to 10 years for some applicants. There is a suggestion that people sponsored in roles below RQF level 6 will be subject to a 15-year baseline qualifying period to settlement. There is also uncertainty around whether this will apply to people already in the UK, including Skilled Workers.

The Senior or Specialist Worker (ICT) category is largely unaffected as a level 6 skill level is already required, it does not lead to settlement and there is no English language requirement. Since 22 July 2025 the Senior or Specialist Worker general salary threshold increased from £48,500 to £52,500.

 

Sponsors

• Skill level. Some sponsors may no longer be able to sponsor roles below level 6.
   
• Fees. Since 16 December 2025, the Immigration Skills Charge  increased for non-small sponsors from £1,000 per year of the sponsored visa to £1,320. The increase in time to settlement is likely to mean incurring further fees.
   
• Compliance. New compliance requirements can be expected, especially for any sponsors using the Temporary Shortage List and complying with a workforce strategy - once that is a requirement.
   
• Right to work checks. In parallel to the White Paper, new legislation is on its way in relation to employers needing to check the right to work of non-employees, especially in the gig economy.

 

English Language

• Adult dependent family members. By the end of 2025, it is expected that adult dependants (including of Skilled Workers) will need to satisfy English language requirements. If they need to take an English test they will need to achieve level A1 in the initial application, A2 at extension and B2 at settlement stage.

 

Settlement

• 5 to 10 years. The earned settlement consultation includes a proposal to increase the qualifying period for settlement (indefinite leave to remain) from 5 to 10 years for most people. 
   
• Faster for some, slower for others. New ‘earned’ settlement points-based criteria will mean some people can apply sooner than 10 years (for example based on taxable income, and English language ability). Some will need to wait longer than 10 years (for example if they have previously overstayed a UK visa for more than 6 months, or have claimed public funds). Mandatory criteria will need to be met including having a clean criminal record and earning at least £12,570 in the last 3-5 years. There are proposals that dependent family members should also have to meet the earned settlement criteria on an independent basis and so may qualify for settlement later than the main applicant.

• Transitional arrangements. The earned settlement consultation proposals include that the new rules may apply to people already in the UK with visas. It is unclear whether there will be transitional arrangements which mean that people already here will be subject to more lenient rules.

• Consultation. All the earned settlement proposals are subject to the consultation which closes on 12 February 2026. We encourage all employers and individuals to respond to the survey questions and write to their MP to share their views on the proposals.

 

Citizenship

• ‘Earned’ citizenship. Similar to the planned changes on settlement, the idea is that before someone can qualify for British citizenship they will need to meet certain points-based criteria. The government has said it will only start on the earned citizenship proposals once the earned settlement consultation has finished.
   
• Time to citizenship. Most people apply to naturalise after holding settlement for at least 12 months making the total journey time 6 years. A longer route to settlement will increase that. Applications could be slowed down further if for example the minimum time to hold settlement increases. The details are unknown at this point.

 

Other business route changes

• Graduate route. Overseas students who complete a degree in the UK can apply to the Graduate route. From 1 January 2027 visas will be reduced from 24 months to 18 months (PhD graduates will still get 3 years).
   
• Global Talent. In 2026 Global Talent visas will be made “simpler and easier for top scientific and design talent”.
   
• High Potential Individual. From 4 November 2025 the list of qualifying global universities will be doubled. A new cap/quota of 8,000 applications per year (beginning 1 November) will apply to this route.
   
• Innovator Founder. This infrequently used category for those starting an innovative business will be reviewed.
   
• UK Expansion Worker. The number of workers an overseas business seeking to expand into the UK can sponsor is expected to double from 5 to 10.

 

Family visas

• Overarching policy. By the end of this year, the White Paper envisages a common approach to family members in the UK, including dependants of those on work and other types of visas.
   
• New requirements. Requirements around English language (as above), genuine relationships and financial security can be expected. The new settlement and citizenship criteria will apply.
   
• Partners of British citizens. The earned settlement consultation confirms that partners of British citizens will still have a 5-year track to settlement. That may not be the case for partners of settled people who may instead need to wait 10 years. Partners may also need to have earnings of at least £12,570 over the 3-5 years before they apply for settlement.

 

What can be done to prepare?

• Apply now. If any sponsor or individual can apply now under the current rules we strongly suggest you apply as soon as possible, especially for Skilled Worker. A salary threshold review is expected from the MAC in December 2025.
   
• Settlement. Where anyone is eligible for settlement (or British citizenship) now they should apply without delay.
   
• Budget. Sponsors should plan ahead for increased costs in relation to visa fees.

 

What’s next

• Updates. We will continue to keep you updated with alerts, blogs and webinars when we receive further information.
   
• Other changes. As ever immigration law is fast moving. As well as changes in the White Paper the UK is potentially edging closer to an agreement with the EU for a new youth mobility scheme. 

 

If you have any queries in relation to the White Paper or any other immigration matter, please contact us.

Please note this short guide is for general information only and must not be used as a substitute for legal advice. You should always take legal advice which is tailored to your specific circumstances. 

Contact a member of the immigration team for more information.