Skilled Worker after the 2025 rules: what sponsors must reassess

What changed on 22 July 2025

Statement of Changes HC 997, laid on 1 July 2025 and in force from 22 July, implemented the first tranche of the May 2025 immigration White Paper. For Skilled Worker it did four things. It raised the skill threshold for new entrants to the route from RQF 3 to RQF 6, which the Home Office's explanatory memorandum says removed around 180 occupations from eligibility. It raised the general salary threshold from £38,700 to £41,700 and the relevant-PhD threshold to £37,500, with £33,400 for STEM PhDs, new entrants and Immigration Salary List roles, each paired with a percentage of the going rate. It introduced a Temporary Shortage List of sub-degree occupations judged critical, available only for certificates assigned before 31 December 2026, alongside the Immigration Salary List. And it removed the right to bring dependants for workers newly sponsored into those listed sub-degree roles, while ending overseas recruitment for care workers.

Two further changes followed. From 8 January 2026 the English requirement for new Skilled Worker applicants rose from B1 to B2, with B1 preserved for those extending permission granted before that date. And on 5 March 2026 a further Statement of Changes raised the settlement English requirement to B2 in speaking and listening for applications from 26 March 2027. The qualifying period for settlement remains five years; the consultation that proposed a ten-year baseline closed on 12 February 2026 and had not produced a government response at the time of writing.

Re-test the role map, not just the new hires

Most sponsors maintain a list of roles they have historically filled through the route. That list now needs three columns it did not have before: the RQF level of the occupation code under Appendix Skilled Occupations, whether the code is on the Immigration Salary List or the Temporary Shortage List, and whether the worker was in the route before 22 July 2025. A code that was eligible in 2024 may now be sponsorable only for existing workers under the transitional provisions, or only until the end of 2026 under the Temporary Shortage List, or not at all.

The transitional provisions are narrower than they look. A worker who held Skilled Worker permission before 22 July 2025 may extend, change employer or take supplementary work in a sub-degree occupation, but only while the arrangements last and only if the salary rules are met. A sponsor who plans to rely on that worker for five years should assume the arrangements may be withdrawn and should map the worker to an RQF 6 role, or to a different route, before the next extension. A worker who left the route and returns is a new entrant and is tested at RQF 6.

The Temporary Shortage List deserves particular caution. It exists because the Migration Advisory Committee had not completed its review when the skill threshold rose; it expires for certificates assigned after 31 December 2026 unless renewed; and workers sponsored under it cannot bring dependants. A sponsor who recruits a senior technician under the list in 2026 is recruiting someone who may be unable to extend in 2029 and cannot bring a family in the meantime. That is a retention problem as much as an immigration one.

Salary bands and the going-rate trap

The £41,700 figure receives the attention, but the going rate decides more cases. Every eligible occupation code carries an annual going rate derived from national earnings data, and the Rules require the higher of the general threshold and the going rate. For many professional codes the going rate exceeds £41,700, so a salary at the general threshold fails. The lower options (£37,500 with a relevant PhD at 90 per cent of the going rate, £33,400 for a STEM PhD at 80 per cent or a new entrant at 70 per cent) each depend on evidence the sponsor must hold: the PhD's relevance, the new entrant's age or graduate status, or the Immigration Salary List entry.

Two mechanical points catch sponsors. Only pay for up to 48 hours a week counts, so a salary that meets the threshold on a 50-hour contract may fail when pro-rated. And allowances count only within the limits the Rules set; housing, relocation and discretionary bonus are generally excluded. Groups that pay a modest base and a large expatriate allowance should restructure before assigning a certificate.

There are no transitional arrangements for salary. A worker in the route since 2023 who extends in 2026 is tested against the 2026 thresholds and going rates, with the Rules' limited provisions for those whose certificates pre-date the changes. The sponsor's pay review must therefore track the Rules, and a pay freeze in a year when the going rate rises is a refusal risk at the next extension.

Dependants, English and the human consequences

The dependant restriction for listed sub-degree roles and the B2 English requirement together change who will accept a UK offer. A candidate with a family will not take a Temporary Shortage List role that excludes them; a candidate with strong technical but weaker spoken English may fail B2 and be unable to switch from a GBM transfer. Sponsors should test English early, since B2 is also the level now required for Innovator Founder, HPI and Scale-up, and since the settlement test rises to B2 in speaking and listening from 26 March 2027.

The policy question for a sponsor is whether to fund English tuition and family support as part of the package. Sponsor guidance prohibits passing on the licence fee, associated administrative costs and the certificate of sponsorship fee, and the Immigration Skills Charge (now £480 or £1,320 per year) has always been the sponsor's cost. Clawback of visa fees and the Immigration Health Surcharge from a departing worker is lawful only where the contract and the guidance permit; a clause that would deter a worker from leaving is a compliance finding. The cheapest compliant approach is usually to budget the full cost and not attempt recovery.

Settlement: plan on five years, prepare for change

Appendix Skilled Worker still requires a continuous period of five years, with no more than 180 days' absence in any 12 months under Appendix Continuous Residence, continued sponsorship at the salary threshold, the Life in the UK test and English. The earned settlement consultation proposed a ten-year baseline with reductions to five years for those earning above £50,270 and to three years for those above £125,140, and a fifteen-year baseline for sub-degree roles; it also asked whether the changes should apply to people already in the UK.

A sponsor cannot control the outcome but can control the record. Every sponsored worker's absence schedule should be maintained from day one; every worker approaching five years should be told to apply as soon as eligible; and the sponsor's salary planning should keep each worker above the thresholds that reductions, if enacted, would reward. A worker whose five years fall in 2027 and whose absence record is clean has a settlement application that is strong under any likely version of the Rules; a worker who has spent 200 days a year on group business abroad does not.

What sponsors should not do is treat the proposal as law. The operative text is the Rules in force on the application date, and a worker refused a job in 2026 on the ground that settlement will take ten years has been refused on a rule that does not exist.

A sponsor's reassessment checklist

• Re-classify every historically sponsored occupation code by RQF level, list status and the date each current worker entered the route.
• Re-test every sponsored salary against the current general threshold and going rate, with allowances and hours applied as the Rules count them.
• Identify workers relying on transitional provisions or the Temporary Shortage List and plan their move to an RQF 6 role, a different route, or departure.
• Test B2 English before offering a role to any candidate who will need to apply or switch after 8 January 2026.
• Budget the Immigration Skills Charge, licence and certificate fees and the Immigration Health Surcharge as sponsor costs and remove non-compliant clawback terms.
• Maintain an absence ledger for every worker and schedule settlement applications for the earliest eligible date.

None of this requires a prediction about the next Statement of Changes. It requires a sponsor programme built on the Rules as they stand, with a record that will survive whatever follows.