In the second half of 2025, the UK is experiencing significant changes to its immigration landscape. On 1 July 2025, the Home Office released the Statement of Changes HC 997, marking a significant shift in the country’s immigration policy. These amendments expand upon the recommendations outlined in the Government’s Immigration White Paper from May 2025, bringing significant updates to the Skilled Worker visa pathway. Key updates in the Statement of Changes HC 997 include the reinstatement of a higher skill threshold and the implementation of stricter salary requirements, both of which reshape the eligibility criteria for sponsorship under the Skilled Worker visa route.
Reintroduction of RQF Level 6 as the Minimum Eligibility Threshold
One of the most consequential changes under Statement of Changes HC 997 is the reinstatement of the higher skill threshold for Skilled Worker visa eligibility. Specifically, Statement of Changes HC 997 reintroduce RQF Level 6 (degree-equivalent) as the baseline skill level for new Skilled Worker visa applicants. This marks a reversal of the 2020 reform, which had lowered the threshold to RQF Level 3 (equivalent to A-levels).
From 22 July 2025, roles eligible for sponsorship under the Skilled Worker visa route must generally align with RQF Level 6 (degree-level qualifications), reversing the previous policy that permitted occupations at RQF Levels 3 to 5. This change aligns the Skilled Worker visa’s skill criteria with those applied to the Global Business Mobility and Scale-up routes.
To facilitate understanding, Appendix Skilled Occupations has been reorganised as follows:
- Tables 1–3: List occupations classified at RQF Level 6 or higher that qualify for full Skilled Worker visa sponsorship.
- Tables 1a, 2aa, 3a: Includes RQF 3–5 roles, reserved for limited circumstances.
Vacancies not aligned with RQF level 6 and not appearing on either the immigration salary list or the temporary shortage list will no longer qualify for visa sponsorship. Employers are therefore strongly advised to audit job roles and associated SOC codes to determine sponsorship eligibility.
Introduction of the Temporary Shortage List (TSL)
The Temporary Shortage List (TSL), introduced under Statement of Changes HC 997, provides a narrow window for sponsoring specific RQF 3–5 roles. Designed to replace the Immigration Salary List in the long term, eventually, the TSL operates alongside it until 31 December 2026 (Pg 5, Statement of Changes PDF)
The TSL applies to a curated list of lower-skilled occupations deemed essential to the UK’s economic infrastructure or industrial strategy. These include:
- Certain construction, logistics, and technical roles,
- IT support, design, and technician positions,
- Selected financial, administrative, and engineering occupations.
Employers relying on TSL roles must document recruitment practices, pay structures, and worker protections to prepare for future MAC assessments.
Co-Existence of TSL and ISL
Until 31 December 2026, the TSL and ISL will operate concurrently. Employers must confirm that any RQF 3–5 occupation is listed on the Appendix Skilled Occupation Table before proceeding with a Certificate of Sponsorship (CoS). From 1 January 2027, this structure is expected to be replaced following a MAC review, which will define a new permanent structure.
Revision of Salary Threshold
Another critical component of Statement of Changes HC 997 is the overhaul of the salary thresholds applicable under the Skilled Worker visa route. For applications made with a CoS assigned on or after 22 July 2025, salaries must meet the higher of the following:
- General Threshold: Increased to £41,700 per annum from £38,700 per annum (Pg 4, Statement of Changes PDF)
- Hourly Minimum: £17.13 per hour (Pg 13, Statement of Changes PDF)
- Going Rates: Updated to align with the Annual Survey of Hours and Earnings (ASHE) data (Pg 13, Statement of Changes PDF)
This hourly floor applies across all SOC codes and eliminates flexibility to use longer working hours to meet the annual minimum. However, these roles remain subject to restrictions, including time-limited eligibility and a prohibition on sponsoring new dependants.
Changes to the Global Business Mobility Route
While the Global Business Mobility (GBM) route remains unaffected mainly in terms of skill level (which already sits at RQF 6), the salary threshold has been raised to £52,500 (Pg 127, Statement of Changes PDF). Sponsors using the GBM route must also reassess remuneration packages and ensure updated job adverts reflect the new criteria.
Continuing Employment Provisions
Transitional provisions allow workers who were granted Skilled Worker visa status under the rules in place before 22 July 2025 to continue in their occupation, including when switching employers. However, these individuals will still need to meet the updated salary thresholds during future applications for extension, employer changes, or settlement.
A specific set of lower salary bands (Options F–J) is available under these transitional provisions for workers who were granted Skilled Worker visa status under the rules in place before 04 April 2024.
Impact on Dependants and Family Members
Statement of Changes HC 997 imposes new limits on family reunification for specific Skilled Worker categories. From 22 July 2025, workers sponsored in RQF 3–5 occupations will no longer be able to sponsor new dependants. Family members who have already been granted leave are unaffected. Exceptions may apply in limited circumstances, such as cases involving sole parental responsibility or children born in the UK.
Implications for Current Skilled Worker Visa Holders
Workers already holding Skilled Worker visas in RQF 3–5 occupations are not required to transition to graduate-level roles immediately. They may:
- Continue in their current job
- Change of employer
- Extend their leave under transitional arrangements
However, they must meet the new salary thresholds upon renewal or when applying for settlement. The concessionary salary bands (Options F–J) apply only to continuing employment and remain higher than the pre-July levels.
Employers must therefore budget for the required pay increases and plan in advance for visa renewals.
Impacts on New Skilled Worker Applicants
For any new Skilled Worker visa applications made with a CoS assigned on or after 22 July 2025, eligibility is restricted to RQF Level 6+ occupations or those listed on the ISL or TSL.
If a job does not meet the graduate-level threshold and is not included on the relevant shortage lists, it cannot be sponsored, regardless of the salary offered. Employers with low-skilled roles must therefore consider:
- Upgrading the role’s duties and responsibilities to align with RQF Level 6,
- Recruiting domestically, or
- Ceasing overseas sponsorship for the position.
Applications for shortage list roles will also face additional conditions, including:
- Ineligibility to sponsor new dependants,
- Explicit classification as a temporary route, and
Practical Implications for Sponsors
With these substantial changes taking effect on 22 July 2025, sponsors must take proactive steps to ensure compliance and avoid disruptions to their workforce planning. Key recommendations include:
- Audit Current and Planned Sponsorships: Employers should identify all workers currently in or expected to be in RQF 3–5 roles and assess their eligibility under the new regime.
- Accelerate CoS Assignments: Assign CoS before 22 July 2025, where possible, to take advantage of more favourable transitional provisions. A CoS assigned before this date allows a worker to apply under the previous criteria, provided the application is submitted within three months of the assignment.
- Review CoS Allocations: Ensure there are sufficient Undefined CoS available for assignment before the deadline, particularly for in-country applications.
- Update Recruitment Documentation: Amend job descriptions, adverts, and internal portals to reflect RQF 6 requirements and updated salary thresholds for visa sponsorship.
- Provide Staff Training: HR and recruitment teams should receive updated training to ensure they understand the revised rules and are equipped to implement them.
- Maintain Robust Record-Keeping: Documentation supporting role classification, salary benchmarking, and SOC code alignment must be retained in anticipation of potential Home Office audits.
Monitoring Future Developments
Given that many of the Statement of Changes HC 997 reforms are time-limited or subject to further review, sponsors need to monitor ongoing MAC evaluations and policy announcements. In particular, the MAC’s 2026 review will determine the structure and content of a permanent TSL.
Employers may also wish to begin documenting domestic recruitment efforts, training programmes, and compliance policies, as these will likely be prerequisites for retaining TSL eligibility beyond 2026.
Conclusion
The Statement of Changes HC 997 introduces far-reaching reforms to the Skilled Worker visa route, redefining who can be sponsored, under what conditions, and at what cost. The shift back to RQF 6 as the standard skill threshold, coupled with higher salary requirements and stricter compliance rules, signals a new era in UK immigration policy.
Employers must act quickly to review their existing sponsorship practices, adapt to the revised eligibility framework, and implement internal controls to ensure compliance. Proactive preparation now will not only secure the continued employment of valued international workers but will also safeguard sponsor licences against future scrutiny.
The new landscape is complex and fast-moving. Regular monitoring of official guidance, MAC updates, and Home Office announcements will be essential for businesses that rely on the Skilled Worker visa route to access global talent.
