UK to Tighten Immigration Rules: Highlights from the 2025 White Paper

By Paul Richmond - Managing Partner

13 May 2025

In This Article

1. A Clear Political Mandate for Change
2. Skilled Worker Route: Higher Thresholds, Fewer Eligible Roles
3. The Temporary Shortage List: A New, Time-Limited Pathway
4. Closing the Social Care Visa Route
5. Family Migration and Dependants: Tighter Controls, Clearer Rules
6. Earned Settlement and Citizenship: Contribution Over Time
7. Study Routes and Graduate Visas: Under Review
8. Final Thoughts: A System in Transition
9. Contact Our Immigration Barristers
10. Frequently Asked Questions
11. Glossary

The UK Government’s White Paper Restoring Control over the Immigration System, presented to Parliament in May 2025, outlines the most sweeping changes to the UK’s legal migration framework in over a decade. Framed as a response to record-high net migration and a perceived overreliance on international recruitment, the White Paper sets out a detailed and ambitious policy agenda aimed at reducing migration, tightening UK visa eligibility, and embedding migration policy within broader labour market, skills and integration strategies.

1. A Clear Political Mandate for Change

According to the Prime Minister’s speech accompanying the White Paper, net migration has risen from 224,000 in 2019 to 906,000 in 2023. This, he said, “happened by design, not accident.” The reforms of the past five years, including the expansion of the Skilled Worker route to sub-degree level occupations and liberalised policies for international students and care workers, are now presented as unsustainable. The new White Paper seeks to “turn the page” by reducing migration across all categories – work, study, family, and settlement – and replacing what the Government calls “a one-nation experiment in open borders” with a more controlled and contribution-based system.

2. Skilled Worker Route: Higher Thresholds, Fewer Eligible Roles

At the core of the White Paper’s legal migration reforms is a fundamental restructuring of the Skilled Worker visa route, designed to reverse what the Government describes as a dramatic and unsustainable broadening of eligibility in recent years. Under proposals set out in Restoring Control over the Immigration System, the minimum skill level for sponsored roles under the Skilled Worker route will be restored from RQF Level 3 (broadly A-level equivalent) to RQF Level 6, which corresponds to degree-level occupations.

This reform marks a clear departure from the liberalising changes introduced in 2020, when the UK’s post-Brexit Points-Based System was launched and the skill threshold was deliberately lowered to allow non-graduate roles to be sponsored – particularly in sectors such as health and care, hospitality, food production, logistics, and retail. While this approach succeeded in expanding the pool of eligible jobs and facilitating recruitment during and after the COVID-19 pandemic, the White Paper now argues that it resulted in over-recruitment from abroad and underinvestment in domestic training.

According to Home Office analysis, around 180 occupations that currently qualify for sponsorship at RQF Level 3–5 will become ineligible under the new threshold. Roles likely to be excluded from the Skilled Worker route going forward include a wide range of supervisory and technician-level positions, as well as almost all roles in care, catering, customer service, warehouse operations, and lower-level construction trades.

To complement the revised skills threshold, the Government has also implemented a new salary framework. From April 2024, the general salary threshold for most Skilled Worker roles was raised to £38,700 per year, up from £26,200 previously. This threshold will apply across the board unless a higher “going rate” is set for a specific occupation. The White Paper confirms the Government’s intention to abolish the Immigration Salary List (ISL) – formerly known as the Shortage Occupation List – which previously allowed for discounted salary thresholds in specific roles experiencing national shortages.

In place of the ISL, the Migration Advisory Committee (MAC) will undertake a comprehensive review of the new salary requirements, including any exemptions or reduced thresholds for newly qualified workers, public sector roles, or specific regions. The MAC will be asked to ensure that salary levels reflect fair market wages and do not create perverse incentives for employers to recruit internationally as a substitute for investing in pay and training for UK-based staff.

The new skills and salary criteria will be applied prospectively. Individuals who already hold a Skilled Worker visa for a sub-degree level role will not be required to leave the UK and may continue to extend their visa, change employers, or take supplementary employment, provided they remain in one of the currently eligible roles. However, new applicants from overseas – or those switching into the Skilled Worker route from other categories – will be assessed against the stricter RQF 6 and salary criteria.

In practice, this creates a two-tier Skilled Worker system, where migrants already in the UK benefit from transitional protections, while future applicants face a significantly narrower range of options. The Government has indicated that this approach is designed to minimise disruption for employers and visa holders already relying on the pre-reform framework, while firmly closing the door to future reliance on migration for roles that are no longer deemed sufficiently skilled.

The Home Office has also committed to monitoring the effect of these reforms on labour market outcomes, particularly in relation to recruitment and retention across affected sectors. Over time, it is expected that some roles previously eligible under the Skilled Worker route may be transferred to the Temporary Shortage List (TSL) instead – subject to a sector-wide workforce strategy and MAC approval – although such access will be explicitly temporary and conditional.

These reforms represent a decisive shift in the structure and purpose of the Skilled Worker visa, realigning it with the Government’s broader objective of encouraging long-term investment in domestic human capital. For employers, it signals the need for forward planning, internal workforce development, and reassessment of future sponsorship strategies. For applicants, it narrows the range of viable immigration routes and raises the bar for entry.

Richmond Chambers continues to advise both employers and prospective Skilled Worker applicants on how to adapt to these changes, ensure compliance with the evolving legal framework, and explore alternative UK immigration pathways where appropriate.

3. The Temporary Shortage List: A New, Time-Limited Pathway

As part of its strategy to reduce net migration while ensuring that labour market gaps can still be addressed in the short term, the Government proposes the creation of a new Temporary Shortage List (TSL). This list will replace the current Shortage Occupation List for sub-degree level roles and will introduce a more structured, conditional, and time-limited mechanism for sponsoring migrant workers in occupations at RQF Levels 3 to 5 – typically non-graduate roles such as skilled trades, technicians, or lower supervisory positions.

Under the new system, occupations below RQF Level 6 will only be eligible for sponsorship if they appear on the Temporary Shortage List. Inclusion on the list will not be automatic or permanent. Instead, the list will be tightly controlled, governed by a new framework that places significant emphasis on domestic labour market reform, training, and employer accountability.

To be included on the TSL, a sector will need to meet strict evidential and policy criteria, including:

• A credible, Government-approved workforce strategy that clearly identifies long-term domestic recruitment goals and outlines how employers intend to reduce reliance on overseas workers;
• Demonstrated investment in UK-based training, upskilling, and labour participation, including collaboration with Skills England and the Devolved Administrations;
• Evidence of fair working conditions and mitigation of exploitation risks, particularly where the occupation has been associated with past abuse of migrant workers;
• A clear trajectory for winding down overseas recruitment, supported by sector-wide action plans and timelines.

These workforce strategies must not only be industry-led but also be coordinated with Government departments including the Department for Work and Pensions, the Department for Education, and the Home Office. Employers in these sectors will be expected to demonstrate compliance with the workforce plan and may be subject to restrictions or loss of sponsorship rights if they fail to uphold agreed standards.

The Migration Advisory Committee (MAC) will play a central role in overseeing the Temporary Shortage List. It will assess proposed workforce strategies and advise the Home Secretary on:

• Whether an occupation qualifies for inclusion on the list;
• The duration of its inclusion;
• Any caps or quotas to be applied to visa numbers; and
• The terms and conditions under which visas for these occupations may be granted.

Importantly, visa conditions for occupations on the TSL will include additional restrictions on dependants. These may take the form of:

• A ban on bringing dependants for certain low-wage or high-turnover occupations;
• Higher salary thresholds for applicants wishing to be accompanied by family members; or
• Increased English language requirements for both primary applicants and dependants, consistent with the Government’s broader integration agenda.

While the full operational detail of the TSL has not yet been published, the White Paper makes clear that its purpose is not to facilitate long-term migration, but rather to act as a transitional tool – granting controlled access to the immigration system while sectors implement domestic reforms. Over time, access to the TSL is expected to become more limited, with the ultimate goal of phasing out international recruitment in roles that the Government believes should be filled by the UK workforce.

In the interim, a preliminary version of the Temporary Shortage List will be adopted, including occupations that the MAC has recently deemed to be in shortage or which are considered strategically essential to the UK’s industrial or infrastructure priorities. However, this initial list will be subject to review and sectoral compliance with the new standards.

For sponsoring employers, the introduction of the TSL represents a significant compliance challenge. Sponsors will no longer be able to rely on the straightforward eligibility of lower-skilled roles under the current Points-Based System. Instead, they will need to participate actively in workforce planning, engage with government-backed training bodies, and meet higher sponsorship standards to retain access to overseas recruitment.

At Richmond Chambers, our team is assisting employers, sector bodies and applicants in preparing for these reforms, including advising on sponsorship obligations, workforce planning documentation, and the future viability of recruitment strategies under the Temporary Shortage List regime.

4. Closing the Social Care Visa Route

Among the most far-reaching – and contentious – reforms proposed in the May 2025 White Paper is the closure of the Health and Care Worker visa route to new overseas recruits in the adult social care sector. This reform represents a decisive policy shift away from the recent reliance on international labour to fill chronic staffing shortages in care homes and domiciliary care services across the UK.

Under the proposals, from 2025 onwards, no new applications for care workers and senior care workers under the Health and Care Worker visa route will be accepted from outside the UK. This includes the occupational codes 6145 and 6146, which were added to the list of eligible roles under the Skilled Worker route in February 2022 as a temporary measure to address acute labour shortages in social care. At the time, these roles were included on the Shortage Occupation List, enabling recruitment with lower salary thresholds and reduced visa fees. However, that policy is now being reversed.

While the route will close to new overseas entrants, transitional measures will permit in-country extensions and switching for those already working in the UK under the care route. These provisions will remain in place until 2028, after which the Government expects the sector to have shifted away from international recruitment in favour of a domestically sustained workforce.

The White Paper sets out a dual rationale for the closure of the care worker route. First, the Government argues that the sector has become structurally dependent on low-paid overseas labour. Between 2021 and 2023, over 50% of Health and Care Worker visas were issued to dependants rather than main applicants, and by 2024, 75% of all Health and Care visas were issued to dependants – an indication, according to the Government, of both the scale and the long-term settlement impact of the route.

Second, the Home Office contends that persistent shortages in the adult social care sector are not due to a lack of available labour, but rather to poor pay, conditions and career progression opportunities. The White Paper acknowledges that even some reputable employers have struggled to retain staff due to sector-wide issues, but points to widespread exploitation and abuse in the care recruitment process as justification for withdrawing the route entirely. This includes documented cases of care workers being underpaid, placed in substandard housing, or working in roles that did not meet the Home Office’s genuine vacancy test.

In response, the Government has pledged to shift responsibility for workforce reform away from the immigration system and towards domestic labour market solutions. A central feature of this new approach will be the establishment of Fair Pay Agreements – sector-wide collective bargaining mechanisms between employers, workers and Government, intended to set enforceable minimum standards on pay, working hours and job security across the care industry. These agreements are modelled on similar frameworks in countries such as France and New Zealand and are intended to improve conditions and reduce turnover in the social care workforce without recourse to international recruitment.

The MAC will no longer be asked to advise on the eligibility of care roles for sponsorship under the Points-Based System, and care work will not be eligible for inclusion on the forthcoming Temporary Shortage List. In effect, the care sector will be excluded entirely from the sponsored work migration framework.

These reforms represent a fundamental reconfiguration of the relationship between immigration and social care workforce planning. While intended to incentivise structural improvements in the sector, the removal of access to overseas recruitment poses a clear and immediate risk of labour shortages in the short to medium term. Care providers who have relied heavily on international recruitment – especially those operating in regions with low domestic workforce availability – will need to adapt quickly to the new regime and explore alternative recruitment and retention strategies.

At Richmond Chambers, we are advising employers, care workers, and their families on the transitional provisions and longer-term planning options in light of these reforms. We encourage those affected to seek expert legal advice as soon as possible to understand the implications for visa renewals, switching options, and future eligibility under the evolving framework.

5. Family Migration and Dependants: Tighter Controls, Clearer Rules

The White Paper outlines a far-reaching reform of the family migration system, aimed at reducing net migration, increasing public confidence, and embedding clearer expectations around integration, contribution and self-sufficiency. While the core framework for family migration under Appendix FM of the Immigration Rules will remain in place, the eligibility criteria for joining family members in the UK – whether as a spouse, partner or dependant – will be significantly tightened.

One of the most impactful changes is the proposed increase to the minimum income requirement for sponsoring a partner under the five-year family route. As of April 2024, this threshold was raised to £29,000 (up from the previous level of £18,600). The White Paper confirms the Government’s intention to raise the threshold further in stages, with the figure set to reach £38,700 by early 2026. This amount is aligned with the average earnings of full-time workers in the UK and is designed to reflect the minimum level of financial self-sufficiency required to support a family without recourse to public funds. The revised threshold will apply both to British citizens and settled persons sponsoring a partner, and to skilled workers seeking to sponsor dependents.

In parallel, the White Paper sets out a graduated English language requirement for all adult dependents, including those accompanying workers, students, or family route sponsors. The current requirement of A1 level English at entry will be replaced with a more structured, staged approach:

• At the point of entry, all adult dependents will be required to demonstrate English language proficiency at CEFR Level A1, evidencing a basic ability to communicate in everyday situations.
• At the extension stage, applicants will need to meet A2 level, indicating an ability to understand frequently used expressions and engage in routine interactions.
• At the point of settlement (ILR), a new, higher standard of B2 level English will apply in most cases. B2 reflects an upper-intermediate level of fluency, enabling applicants to engage in more complex discussions and demonstrate genuine linguistic integration into UK life.

These measures represent a substantial increase in the linguistic expectations placed on migrant families and mirror broader reforms to settlement and citizenship, which will increasingly require evidence of sustained integration over time. The introduction of a B2 English language requirement for ILR marks a significant shift from the current B1 threshold, and will likely necessitate formal language training for many applicants.

The White Paper also signals a legal and procedural shift away from the broad, discretionary framework currently used to assess exceptional circumstances under Article 8 of the European Convention on Human Rights (ECHR). The Government’s stated aim is to reduce reliance on case-by-case human rights assessments and to replace them with a clear statutory framework that defines the circumstances under which leave outside the Rules may be granted. While no draft legislation has yet been published, the stated policy intention is to make decision-making more predictable, consistent, and rooted in clear legislative criteria, rather than discretionary balancing of private and family life rights.

Taken together, these proposals indicate a firm move towards a more rules-based and restrictive family migration system, with higher financial, linguistic and evidential thresholds. While exceptions will remain for vulnerable applicants – such as those caring for British citizen children or facing insurmountable obstacles to family life abroad – the direction of travel is towards narrowing the scope of discretion and formalising the process.

For individuals and families seeking to settle or reunite in the UK, these proposed reforms reinforce the importance of early legal advice, meticulous financial planning, and preparation for English language testing. Richmond Chambers will continue to advise on the evolving requirements and assist clients in navigating this more demanding legal framework.

6. Earned Settlement and Citizenship: Contribution Over Time

The White Paper introduces a transformative shift in the UK’s approach to long-term residence and naturalisation through the development of a new “Earned Settlement” model. This new framework is designed to recalibrate the conditions under which migrants can obtain Indefinite Leave to Remain (ILR) and, subsequently, British citizenship, by placing a far greater emphasis on long-term contribution, integration, and civic participation.

Under the current system, most migrants on work and family routes are eligible to apply for ILR after five years of continuous lawful residence, provided they meet certain salary, English language, and knowledge of life in the UK requirements. The White Paper now proposes a fundamental revision of this model: for the majority of migrants, the qualifying period for settlement will be increased to ten years.

This new ten-year standard will apply to most work-based migration routes, as well as other long-stay visa categories, and is intended to reflect a more demanding and merit-based approach. The Government’s rationale is that permanent residence should not follow as a near-automatic consequence of temporary migration, but rather should be earned over time by individuals who can demonstrate a sustained and measurable contribution to the UK – economically, socially, and civically.

While the ten-year threshold will become the default, the White Paper confirms that certain categories will retain accelerated pathways to settlement, including:

• Dependants of British citizens, particularly spouses and children, under the family route;
• Refugees and those granted humanitarian protection, where shorter routes to ILR are enshrined in domestic and international law;
• Vulnerable migrants, including victims of domestic abuse and trafficking, for whom longer residence requirements would be inappropriate or disproportionate.

In a notable departure from the current binary model, settlement and citizenship will now be formally incorporated into the Points-Based System. The Government intends to develop a points-based framework for ILR and naturalisation, whereby applicants will be able to earn points not only through lawful residence and continuous employment, but also through evidence of integration and public service.

Examples of contributions that may accelerate or enhance a person’s settlement application include:

• Employment in critical national infrastructure (e.g. education, health, defence);
• Exceptional talent or innovation, particularly in science, technology, and the arts;
• Community engagement or volunteering, especially where this supports vulnerable groups or strengthens social cohesion;
• Strong English language proficiency and proactive engagement with civic institutions.

Applicants who meet these enhanced contribution criteria may be eligible for accelerated settlement, potentially after five to seven years, although the Government has stated that detailed criteria and scoring mechanisms will be subject to consultation in late 2025. It is not yet clear whether accelerated pathways will be discretionary or codified in the Immigration Rules.

Alongside these structural reforms, the White Paper signals a review of the Life in the UK Test, which is currently a mandatory requirement for both ILR and naturalisation. While the Government continues to support the principle of testing knowledge of British values, institutions and history, there is widespread recognition that the current test is outdated, overly focused on obscure facts, and does not adequately assess civic understanding or integration.

The review will consider whether the test should be aligned more closely with the English for Speakers of Other Languages (ESOL) curriculum, include oral or practical elements, or be tailored to reflect the length and nature of the applicant’s residence in the UK.

Finally, the White Paper proposes reforms to make citizenship more accessible for long-resident young adults, particularly those who have grown up in the UK but face barriers to registration or naturalisation due to cost, evidential burdens, or their parents’ immigration status. The Government acknowledges that many of these young people are de facto British in every sense but lack a route to secure this status formally. Proposals under consideration include:

• Reducing or waiving naturalisation fees for applicants under 25 who have spent most of their lives in the UK;
• Streamlining the registration process for children born abroad but raised in the UK from an early age;
• Clarifying evidential requirements around continuous residence and lawful status during childhood.

Together, these reforms reflect a wider rebalancing of the UK immigration system: restrictive at the front end, but more demanding and merit-based at the point of settlement and citizenship. While this may close off faster routes to permanent status for many, it also offers a clearer, more structured pathway for those willing and able to demonstrate long-term integration and contribution.

At Richmond Chambers, we are assisting clients in assessing how these proposed changes may affect their future eligibility for settlement and citizenship, particularly those with complex immigration histories or transitional status. Early legal advice is strongly recommended for individuals planning long-term residence in the UK under the new regime.

7. Study Routes and Graduate Visas: Under Review

The White Paper introduces a series of reforms aimed at tightening oversight of the UK’s study visa system and curbing what the Government sees as the use of student and graduate routes as indirect pathways to long-term migration. While international students remain welcome, the focus is firmly on ensuring that their primary purpose is academic study, not long-term economic settlement.

One of the most significant changes is the restriction on dependents of international students. From 2025, only those undertaking PhDs or other advanced research programmes will be permitted to bring dependents to the UK. This builds on earlier reforms and reflects Government concerns over a sharp rise in dependent numbers – rising from fewer than 20,000 in 2019 to over 150,000 in 2023 – many of whom have entered the UK labour market.

Stricter compliance requirements will also be imposed on sponsoring institutions. In order to retain a Student Sponsor Licence, providers must meet:

• A 95% enrolment rate, ensuring students commence their courses as intended; and
• A 90% course completion rate, to limit misuse of the route by individuals who disengage and seek to switch to other visa categories.

Non-compliant providers may face downgrading or licence revocation, with the Home Office promising increased audits and enforcement.

The White Paper also announces a full review of the Graduate Route, which currently allows international students to remain in the UK for two to three years after completing their studies, with unrestricted work rights and no sponsorship requirement. The review will explore whether to:

• Introduce eligibility restrictions based on institutional compliance;
• Limit the route to specific high-skilled disciplines;
• Impose job offer or salary requirements;
• Or cap the overall number of Graduate Route visas.

These measures reflect the Government’s broader goal of reasserting the academic purpose of the student visa system and reducing secondary migration flows linked to post-study work. Outcomes of the Graduate Route review are expected by the end of 2025.

Richmond Chambers continues to advise students, education providers and post-study visa holders on the evolving legal framework and future immigration planning.

8. Final Thoughts: A System in Transition

The 2025 White Paper marks a profound shift in the trajectory of UK immigration policy. In place of demand-led migration across wide swathes of the economy, the Government intends to impose a contribution-based, skills-focused model tied directly to domestic labour market reform. While many of these reforms will require legislative change and will take months to implement, the direction of travel is unambiguous.

For individuals and sponsoring employers alike, these changes raise significant legal and strategic considerations. Routes that are currently viable may soon close or become more restrictive. Pathways to settlement will become longer and more conditional. And the burden on employers to demonstrate workforce strategies and investment in domestic talent will only grow.

9. Contact Our Immigration Barristers

Richmond Chambers is monitoring developments closely. For tailored legal advice on how the Government’s proposed reforms may affect your immigration plans or business strategy, please contact our team of specialist immigration barristers on +44 (0)203 617 9173 or complete our online enquiry form.