UK Immigration Law Changes 2025
Executive Summary
The UK has embarked on the most far‑reaching immigration overhaul in years. A May 2025 Government White Paper sets out proposals to extend standard settlement to 10 years and introduce “earned settlement/citizenship” based on measurable contribution. Separately, a 1 July 2025 Statement of Changes (HC 997) took effect on 22 July 2025, raising salary thresholds, revising eligibility lists, and ending new overseas recruitment of care and senior care workers. Student dependants remain tightly restricted (from 2024 rules), and the Graduate Route is signalled for reform (proposed reduction to 18 months). Partner‑visa minimum income remains £29,000, with further increases paused pending review. In September 2025 the Government announced a temporary suspension of refugee family reunion while new rules are designed.
Bottom line: Employers, universities, and applicants should expect a two‑track landscape—(1) rules already in force from July 2025, and (2) structural reforms from the White Paper that require consultations and (likely) primary legislation.
1) Settlement & Citizenship — Toward a 10‑Year Baseline
“Earned Settlement” and a longer qualifying period
The White Paper proposes: - Raising the standard qualifying period for settlement to 10 years across economic routes. - A new points‑based “earned settlement” model allowing accelerated ILR for demonstrable contribution (economic, skills, civic), alongside safeguards for vulnerable groups. - Aligning citizenship with “earned” principles and refreshing the Life in the UK test.
Legal view: These proposals will require consultation, detailed criteria and (in places) primary legislation. Key challenges will include legal certainty (predictability of points), equality impacts, and proportionality if applied to applicants already in the system. Businesses should plan migration cycles on a 10‑year horizon, while watching for fast‑track criteria once published.
2) Skilled Worker & Business Mobility — Changes in Force from 22 July 2025
What changed immediately on 22 July 2025 (HC 997): - General salary threshold for Skilled Workers increased to £41,700, with uplifts to going‑rates based on ASHE 2024. - Significant reductions to eligible occupations; more than one hundred roles lost eligibility. - International recruitment of care workers (6135) and senior care workers (6136) closed to new entrants from overseas; transitional protections remain for those already in route. - The Immigration Salary List (ISL) and an interim/transition list continue in the short term, with a stated plan to retire shortage lists by end‑2026 in favor of tighter, time‑limited access based on labor market evidence.
What’s proposed (White Paper signals): - Lifting the skills bar back to RQF 6+ for general access, with Temporary Shortage access for selected RQF 3‑5 roles on a time‑limited basis and linked to sector workforce strategies. - Stronger incentives and compliance levers to push domestic training.
Practical effects for sponsors: Immediate audits of CoS, salary modeling against new going‑rates, pipeline hiring strategy for roles becoming ineligible, and HRIS updates for right‑to‑work and document trails.
3) Students & Graduates — Tightening Continues
•Dependants: Since January 2024, only postgraduate research students (or government‑sponsored students) can bring dependants; this remains the position in 2025.
•Graduate Route: The White Paper proposes reducing post‑study permission to 18 months (from 2 years; 3 for PhD) and imposing additional quality and compliance levers on providers. Expect consultations and transitional rules; MAC previously found no systemic abuse but noted labor‑market mismatches.
•Sponsor standards: Higher Basic Compliance Assessment standards and potential sanctions for under‑performance on enrolment/completion.
For universities and graduates: Admissions messaging should reflect dependant limits; careers teams should fast‑track SW route switching within salary/skills constraints; compliance teams should uplift BCA tracking and CAS issuance controls.
4) Family, Humanitarian & ECHR Considerations
•Partner/Spouse Minimum Income Requirement: The MIR remains £29,000 (since April 2024). Earlier plans to lift to £38,700 have been paused, with the Government commissioning a review (MAC has reported; policy outcome pending). Legacy applicants pre‑11 April 2024 remain on the £18,600 track for extensions.
•Refugee Family Reunion: In September 2025, the Home Secretary temporarily suspended refugee family reunion applications pending new rules—expect litigation framed around Article 8 ECHR and non‑retrogression of safe routes.
Risk notes: Family routes consistently generate proportionality and discrimination challenges; sponsors and applicants should build documentary records evidencing integration, income, and best‑interests of children for review/appeals.
5) Implementation Timeline — Two Tracks to Watch
Already in force (22 July 2025): salary thresholds & going‑rates; reduced eligible occupations; closure of new overseas recruitment in adult social care; limited transitional protections.
Proposed / in development: 10‑year settlement baseline with “earned” acceleration; Graduate Route to 18 months; RQF 6+ baseline with time‑limited access for RQF 3‑5; enhanced English‑language requirements for more routes; refreshed Life in the UK test; family‑route clarifications and potential refugee reunion redesign. Expect secondary legislation and, in places, primary legislation through 2026.
6) What Employers, Universities, and Applicants Should Do Now
Employers & Sponsors
•Run a Sponsor Licence health‑check: SOC code mapping, CoS issue dates, salary deltas to new going‑rates; diarise July 2025 transitional cut‑offs.
•Care sector: Cease overseas hiring in 6135/6136; map transitional staff; review dependant policies under March 2024 rules.
•Workforce strategy: Build domestic training plans; gap‑fill via permitted Temporary Shortage access; prepare for RQF 6 baseline.
Universities & Ed Providers
•Update marketing & CAS guidance on dependants; strengthen BCA metrics; support Graduate Route to SW switching where appropriate.
Individuals & Families
•Timing: Consider ILR applications where eligible before any 10‑year baseline is enacted; assess Graduate Route strategies; plan for MIR and documentary evidence.
•Evidence: Keep comprehensive records of residence, tax, earnings, and community contributions—these may be relevant to any earned settlement fast‑track once defined.
7) Litigation & Policy Outlook
Expect challenges around: retroactivity (settlement periods), equality impacts (sector‑specific exclusions), family life (MIR; refugee reunion pause), and procedural fairness (consultation, transitional protections). The courts will likely be active in 2025–26, with Parliament balancing control objectives against economic and rights‑based considerations.
About Shift by M Legal
Shift by M Legal is the immigration and global mobility desk of M Legal. We advise corporates, universities, and high‑skill migrants on strategy, compliance, and disputes across the UK, EU and India. Contact: hello@shiftbymlegal.com
This content is for general information only and is not legal advice. Rules change fast—seek tailored advice for your facts.