In this guide, you will learn:

• What a skilled worker visa is
  
  
• Who can apply for a skilled worker visa
  
  
• The documents you’ll need
  
  
• The step by step guide to applying
  
  
• Skilled worker visa application costs and decision timeline
  
  
• Common reasons for Skilled Worker visa application refusals
  
  
• Whether you can change jobs while on a skilled worker visa

What is the UK Skilled Worker visa?

There is no limit on how many times a Skilled Worker Visa can be extended as long as the worker remains employed by an approved sponsor, meets the relevant salary thresholds, and complies with UK immigration laws for up to five additional years per application. A Skilled Worker visa provides a direct, accelerated pathway to permanent residency, currently allowing individuals to apply for Indefinite Leave to Remain (ILR) after five years of continuous lawful residence to live, study, and work in the UK permanently without further restrictions before applying for British citizenship.

Who can apply for a Skilled Worker visa?

You can apply for a UK Skilled Worker visa if you have a job offer from an approved British employer and meet specific salary, language, and skill criteria. This visa allows qualified professionals to live and work in the UK for a sponsoring company. 

Key things to note before applying:

• Your job offer must come from a company that holds a valid UKVI Sponsor Licence.
  
  
• Your employer must assign you a valid Certificate of Sponsorship (CoS) detailing your role, salary, and start date.
  
  
• The job must be at an eligible skill level, typically classified as RQF Level 3 or above (equivalent to a UK A-level or higher).
  
  
• The role’s occupation code must match a specific list of eligible jobs. You can verify your role using the official UK eligible occupation list.
  
  
• A standard baseline salary set by the Home Office (frequently updated, currently set at £41,700 for most standard routes).
  
  
• The specific minimum salary (going rate) standard set for your unique occupation code. 
  
  
• Lower salary thresholds apply if you are a “New Entrant” (e.g., under 26, a recent UK graduate), have a PhD relevant to your job, work in a Health and Care visa role, or are applying for a role on the Immigration Salary List (ISL).
  
  
• You must prove you can speak, read, write, and understand English to at least Level B2 on the Common European Framework of Reference for Languages (CEFR) scale. You can meet this requirement by passing an approved English language test, holding a degree taught in English, or being a citizen of a majority English-speaking country.
  
  
• You must show you have at least £1,270 in personal savings held for 28 consecutive days to support yourself upon arrival. You are exempt from this if you have already been living in the UK with a valid visa for 12 months, or if your A-rated sponsor certifies on your CoS that they will cover your costs.

The documents you’ll need

Are there priority services available?

Other costs

Immigration Health Surcharge:

Standard Rate: Main adult applicants pay a mandatory £1,035 per year.

Dependants under the age of 18 and Youth Mobility applicants pay a reduced rate of £776 per year.

Health and Care Worker visa applicants are completely exempt from paying the IHS.

Document Translations: Expect to pay £30 to £60 per page to a certified translator for non-English supporting materials.

Tuberculosis (TB) Test: Approved clinics typically charge £70 to £150 depending on the country you are applying from.

Secure English Language Test (SELT): Standard B1 level tests cost roughly £150 to £200.

Legal Advice: Hiring a regulated immigration solicitor for full application representation usually ranges from £500 to £2,500 depending on case complexity.

How long does the application take?

The official processing clock begins only after you successfully verify your identity, either by attending a biometric appointment at a visa application centre or by uploading your documentation via the “UK Immigration: ID Check” smartphone app. 

Applications Made Outside the UK: 3 weeks (15 working days). You can submit your application up to 3 months before the official job start date listed on your Certificate of Sponsorship (CoS). 

Applications Made Inside the UK (Switching or Extending): 8 weeks. You must remain physically within the UK, Ireland, the Channel Islands, or the Isle of Man while your application is pending; leaving the Common Travel Area automatically voids your application. 

If your application is marked as “non-straightforward” by UK Visas and Immigration (UKVI), processing times can extend significantly past standard timelines due to documentation reviews, such as:

• Missing or Inadequate Evidence: Failing to provide mandatory paperwork, such as missing bank statements covering the full consecutive 28-day window or uploading non-certified English translations. 
• Employer Sponsor Licence Audits: Additional processing delays frequently occur if UKVI pauses the application to verify the legitimacy of your employer’s sponsor licence, or if the company is new to the immigration register. 
• Background Check Flags: Complex personal histories, active criminal records, or inconsistencies in your travel or immigration history require targeted manual review by case officers. 
• Document Verification: Extra time spent by the Home Office contacting third-party institutions (such as foreign banks or specific universities) to independently verify the authenticity of your financial or academic certificates.

Common reasons for Skilled Worker visa application refusals

Even a minor administrative error can lead to UK Visas and Immigration (UKVI) refusing your Skilled Worker visa application, resulting in lost fees and delayed start dates. 

Financial Maintenance Failures: Submitting bank statements that drop below the required £1,270 balance at any point during the 28-day window, or using statements that are more than 31 days old when submitted.

Missing Translations: Uploading mandatory documents in a foreign language without a certified English or Welsh translation that contains the translator’s credentials and date.

Incorrect Salary Calculation: The salary calculation in relation to your role may have been calculated incorrectly.

Expired Allocation: Submitting your visa application more than 3 months after the CoS was assigned to you by your employer.

Sponsor Licence Suspension: The Home Office revoking or suspending your employer’s sponsor licence after they issue your CoS but before your visa is officially processed.

Wrong CoS Type: Your employer mistakenly assigning the wrong type of CoS.

Unapproved Providers: Using a provider that has not been approved by the Home Office.

Missing Ecctis Validation: Submitting a foreign university degree taught in English without the mandatory Ecctis (formerly UK NARIC) certificate to officially prove its UK equivalence.

Inconsistent Data: Typing a passport number, name spelling, or date of birth on your online application form that does not perfectly match the data entered on your digital CoS.

Wrong Occupation Code: Selecting an incorrect Standard Occupational Classification (SOC) code that does not accurately reflect your daily duties, leading case officers to believe you are circumventing the skill or salary rules.

Changing employer

If you decide to leave your current company for a new one, you must go through the sponsorship process again.

• The New Sponsor: Your prospective employer must hold a valid Home Office Sponsor License.
• The Certificate: They must assign you a brand new Certificate of Sponsorship (CoS) detailing your new salary and duties.
• The Application: You must submit a fresh visa application from within the UK and pay the associated application fees and Immigration Health Surcharge (IHS).

Changing occupation code

Even if you stay with the same employer, a promotion or sideways move might require a new visa. 

• New SOC Code: If your new duties mean your job transitions into a completely different Standard Occupational Classification (SOC) code, you must apply for a new visa.
• Salary Adjustments: Your new role must meet the specific “going rate” for that new SOC code, as well as the standard Skilled Worker salary thresholds. 
• Exception: If you are promoted within the same SOC code and your duties remain the same (e.g., moving from a Junior Software Developer to a Senior Software Developer under the same code), a new visa is generally not required, provided your salary still meets the rules.

Conclusion

Applying for a UK Skilled Worker Visa involves a structured process of meeting specific eligibility requirements, securing formal sponsorship from a licensed employer, preparing the correct documentation, and completing the final application accurately. 

Careful preparation is the most effective way to reduce processing delays and minimise the risk of a visa refusal. By double-checking standard occupational classification (SOC) codes, ensuring salary thresholds are met, and organising flawless supporting evidence beforehand, applicants can ensure a much smoother journey through the immigration system. 

For applications involving complex circumstances such as unusual corporate structures, transitional salary rates, or previous immigration issues, seeking professional immigration advice from an IAA-regulated adviser may be highly beneficial to ensure a successful outcome.

Why is the illegal working civil penalty regime changing?

Which businesses may be affected by the expanded right to work rules?

Why the changes matter for UKVI sponsor licence holders

Sponsor licence holders are already expected to have strong HR systems and immigration compliance controls. UKVI expects sponsors to know who they employ, what sponsored workers are doing, where they are working, whether they are being paid correctly, whether their role matches the Certificate of Sponsorship and whether right to work checks are being completed properly.

Poor right to work systems, weak record keeping or unclear labour arrangements can create problems beyond a civil penalty. A right to work failure may lead UKVI to question whether the business is capable of complying with its sponsor duties.

Depending on the circumstances, this could result in:

• sponsor licence suspension;
• sponsor licence revocation;
• refusal of a future sponsor licence application;
• refusal of Skilled Worker visa applications;
• increased scrutiny during a Home Office audit;
• reputational and commercial damage.

For sponsor licence holders, the expanded illegal working regime should therefore be reviewed as part of wider UKVI compliance, not as a separate HR administration issue.

Businesses considering a sponsor licence application should also make sure their wider workforce model, right to work processes and labour supply controls are robust before applying.

Why contracts alone will not be enough

1.  Right to work compliance: check whether current right to work procedures, follow-up checks and record-keeping processes are correct.
2. Subcontractor and labour supply chain risk: map how non-employed labour is used, identify arrangements that may fall within the wider regime and introduce practical controls.
3. Sponsor licence compliance and planning: review whether existing systems meet UKVI expectations and whether a sponsor licence application should form part of the business’ future workforce strategy. 

Why more businesses may consider applying for a sponsor licence

Final considerations for UK businesses and sponsor licence holders

The proposed illegal working civil penalty changes are likely to make right to work compliance more important, more visible and more difficult to confine to the traditional employer and employee relationship.

Businesses that hire, supply, organise or benefit from labour carried out by individuals may need to take greater responsibility for checking and evidencing right to work compliance.

For UKVI sponsor licence holders, the stakes are higher because illegal working failures can affect sponsor licence stability, future visa sponsorship and UKVI audit outcomes. 

For businesses without a sponsor licence, the changes may be a prompt to review whether sponsorship should form part of a lawful and sustainable workforce strategy.

Businesses that prepare early will be better placed to reduce penalty risk, protect commercial continuity and show UKVI that their workforce systems are properly controlled.

How can we help

We support UK businesses with practical immigration compliance, right to work and sponsor licence advice.

We can help you review right to work systems, assess subcontractor and labour supply chain risk, prepare for the expanded illegal working regime, review sponsor licence compliance, prepare for a UKVI audit and assess whether your business is ready to apply for a sponsor licence.

If your business uses employees, subcontractors, agency workers, self-employed individuals, casual labour, outsourced services or sponsored workers, now is the time to review your compliance position.

We can also advise on whether a sponsor licence application may be appropriate where your business needs lawful access to overseas recruitment to address skills shortages and reduce reliance on higher-risk labour supply models.

Contact us today to discuss how the expanded illegal working regime and UKVI sponsor licence requirements may affect your business.

Sponsor licences are now generally indefinite – but that does not mean they are permanent

Why ownership changes matter for sponsor licence holders

The key principle: a sponsor licence is not transferable

The starting point is simple: a sponsor licence cannot simply be transferred from one owner to another. 

If there is a relevant change, the sponsor must report it to UKVI through the Sponsorship Management System, usually within 20 working days of the change taking place. 

UKVI will then consider what has changed and what action is required. Depending on the circumstances, this may involve the existing sponsor reporting the change; the new organisation applying for a sponsor licence; sponsored workers moving to another sponsor; the old licence being made dormant, being surrendered or revoked. 

The correct action depends on the type of transaction and whether there has been a change in direct ownership.

What is a change in direct ownership?

TUPE transfers and sponsor licences

Does TUPE remove the need to consider UKVI requirements?

A common mistake is assuming that because TUPE protects the employment relationship, immigration compliance is automatically protected as well. 

That is not the case. 

TUPE may transfer the employment contract, but it does not transfer the sponsor licence. 

The new employer still needs to consider the type of licence held and whether a new licence is required, whether there are any changes to the roles being sponsored and what reports need to be made via the SMS. 

For this reason, TUPE and sponsor licence planning should be handled together.  

Employment law advice and immigration compliance advice should not be treated as separate afterthoughts. 

Complete takeover or merger

Where a sponsor organisation is completely taken over or merged into another organisation, and sponsored workers move to the new organisation, the existing sponsor must report the change to UKVI within 20 working days. 

The report should include details of the sponsored workers who are moving to the new organisation. If any sponsored workers are not moving to the new sponsor, this must also be reported because their permission may be affected. 

The new organisation must then consider whether it already has the correct sponsor licence. If it does, it must report that it has accepted sponsorship responsibility for the workers. If it does not, it must apply for the appropriate sponsor licence within the required period. The previous sponsor’s licence may then be made dormant where appropriate. 

Partial takeover, de-merger or sale of part of a business

A partial takeover or de-merger can be more complex. 

Some sponsored workers may move to the new organisation while others remain with the existing sponsor. In that situation, both organisations may have sponsor duties. 

The existing sponsor may need to: 

• report which sponsored workers are transferring; 

• continue sponsoring and reporting on any workers who remain with it; 

• consider whether its CoS allocation should be reduced; and 

• decide whether it still needs the licence. 

The new sponsor may need to: 

• apply for a sponsor licence if it does not already hold the correct licence; 

• report that it has accepted full sponsorship responsibility; 

• request an increase in CoS allocation if needed; and 

• report future changes affecting transferred sponsored workers. 

Where the new sponsor cannot see the transferred workers on its SMS account, it may still need to report relevant changes to UKVI by email. The duty to report does not disappear simply because the worker does not appear on the new sponsor’s SMS in the usual way. 

Do internal group restructures affect a sponsor licence?

Internal restructures can also trigger sponsor licence issues. 

Businesses often assume that no UKVI action is needed where the ultimate ownership remains the same. That assumption can be dangerous. 

The key question is not only whether the ultimate owner has changed. The more important question may be whether the direct owner of the sponsor licence holder has changed. 

For example: 

• If the sponsor licence holder remains directly owned by the same immediate parent, a new licence may not be required, although the change may still need to be reported. 

• If the sponsor licence holder is transferred to a new immediate parent company, this may be a change in direct ownership and a new sponsor licence may be required. 

• If sponsorship responsibility is moved to a parent company while the worker’s actual employer remains the same, UKVI may allow this in some circumstances, but the sponsor must still obtain UKVI approval and demonstrate that the parent company can properly discharge sponsor duties. 

This is why corporate restructuring should always include a sponsor licence impact assessment. 

What happens if the new owner does not have a sponsor licence?

If sponsored workers transfer to a new employer and the new employer does not have the correct sponsor licence, the new employer will usually need to apply for one within 20 working days of the transfer or change.

This is a strict and important deadline. UKVI will assess whether the new sponsor is genuine, suitable and capable of meeting its sponsor duties. This may include reviewing HR systems, right to work processes, payroll arrangements, reporting structures, key personnel and compliance history. 

If UKVI refuses the application, the sponsored workers’ immigration permission may be affected. Businesses should therefore consider sponsor licence requirements before completing any acquisition involving sponsored workers.

Conclusion

Changes in company ownership can have a major impact on a UKVI sponsor licence. Although sponsor licences are now generally indefinite, employers must still meet ongoing compliance duties. A sponsor licence also cannot transfer to a new owner.

Mergers, acquisitions, share sales, TUPE transfers or group restructures can all trigger reporting duties. In some cases, the new owner must apply for a brand-new sponsor licence. Whether this is necessary often depends on whether there has been a change in direct ownership. 

The most important issue is often whether there has been a change in direct ownership. If there has, the existing licence may be revoked or made dormant, and the new owner may need to apply for a new licence to continue employing sponsored workers. 

Businesses that rely on sponsored workers should treat immigration compliance as part of their transaction planning from the outset. Early advice, proper due diligence and timely UKVI reporting can protect both the business and its sponsored workforce. 

What is a sponsor licence?

• the role being eligible for sponsorship;
• the salary meeting the relevant threshold;
• the worker having the necessary skills and English language ability;
• the sponsor offering genuine employment; and
• the sponsor being able to comply with its ongoing duties.

Why sponsor licences still matter

When might a sponsor licence be particularly useful?

A sponsor licence is often most valuable when a business identifies a clear recruitment or retention need. The following scenarios commonly highlight where sponsorship becomes a practical commercial tool:

Eligible roles under the Skilled Worker route

The Temporary Shortage List and future workforce planning

Many UK employers are becoming increasingly familiar with Skilled Worker sponsorship, sponsor duties and UKVI compliance. But there is another layer of compliance that can easily be overlooked, particularly in agriculture, horticulture, food production, food packing and shellfish-related work, and this is gangmaster licensing.

This is often still referred to as GLAA licensing, although from April 2026 the relevant licensing function sits with the Fair Work Agency (FWA). The underlying point remains the same: if your business is in, or supplies labour into, a regulated sector, you need to understand whether a gangmaster’s licence is required.

That matters even more if you hold a UKVI sponsor licence. A breach of gangmaster licensing legislation is not just a regulatory issue. It can be a criminal offence, and it may also place your sponsor licence at risk because sponsors must comply with wider UK law. 

Who is responsible for gangmaster licensing?

The Gangmasters and Labour Abuse Authority, commonly known as the GLAA, was the body associated with licensing labour providers in certain high-risk labour sectors.

From 7 April 2026, the relevant functions now sit within the Fair Work Agency (FWA), an executive agency sponsored by the Department for Business and Trade. The FWA is responsible for enforcing workers’ rights, including the applications and management of gangmaster licences and investigating whether a labour provider is licensed.

Which sectors are governed by gangmaster licensing?

The licensing scheme is focused on work in:

• agriculture;
• horticulture;
• shellfish gathering;
• processing and packaging of products derived from agriculture, fish or shellfish.

The Fair Work Agency protects workers from exploitation by operating a licensing scheme in agriculture, horticulture, shellfish gathering and associated processing and packaging sectors. If an individual or an organisation supplies labour or uses workers to provide services in these sectors, they may need a gangmaster’s licence.

Examples of businesses that may be affected include farms, growers, food manufacturers, fresh produce businesses, meat processing businesses, fish and shellfish processors, poultry businesses, flower packing businesses, and businesses involved in associated processing or packaging.

What about construction, care, hand car washes and other sectors?

The GLAA historically held a wider labour exploitation role and has been associated with monitoring and investigating exploitation risks in sectors such as construction, care, hand car washes, recycling, garment manufacturing, warehousing, hospitality, nail bars and taxi driving. However, those sectors are not generally within the gangmaster licensing scheme.

It is likely that the FWA will expand its investigations into these wider sectors, notably they have been urged to act on reports identifying construction as a sector plagued by “systemic” labour exploitation, particularly regarding subcontractors and agency worker chains.

Under its new guise, the FWA has also stated it will prioritise industries with high numbers of low-paid, precarious, and zero-hours workers, which includes the care sector. The agency has the power to carry out both planned and unannounced inspections of labour users, including in-person or virtual visits to sites.

Furthermore, under the Employment Rights Act 2025, the FWA also has broadened powers to inspect workplaces, demand documentation, and interview workers to ensure compliance, particularly regarding payroll, holiday pay, and statutory sick pay.

Who needs to be licensed?

A licence may be required where a person or business is acting as a gangmaster in a regulated sector. The official guidance explains that acting as a gangmaster includes supplying labour to agriculture, horticulture, shellfish gathering, and food processing and packaging; using labour to provide a service in the regulated sector and using labour to gather shellfish.

The concept of “supply” is deliberately wide. It can include supplying temporary workers, introducing workers for direct employment, sourcing candidates, forwarding CVs or application forms, and screening candidates for work in licensed sectors. The Home Office makes clear that it does not matter whether the arrangement is formal or informal, or whether the end client makes the final decision to employ the worker.

This is where some employers fall foul of the rules. They may think “it’s only the introduction of candidates” or “they’re only helping with recruitment”. In a regulated sector, that may still be enough to bring the activity within the licensing regime.

Do you need a licence if you directly employ staff?

Usually, you do not need a gangmaster’s licence simply because you directly employ staff to work exclusively for your own business. For example, a farm advertising for workers, recruiting them directly and employing them to work only on that farm would not normally be “supplying” workers to another labour user.

However, the position can change if the farm were to:

• supply those workers to another business;
• introduce workers to another business;
• use their workers to provide a service to another person in a regulated sector.

The official guidance states that a business needs a licence if it supplies a worker to a labour user for work covered by licensing, or if it uses a worker to provide a service to another person to do work covered by licensing.

So, the key question is not only “do we employ the worker?” It is also “what are we doing with that worker, and for whom?”

What are the two main breaches employers need to understand?

There are two common risk areas.

• Supplying labour without holding the required licence. It is illegal to act as a gangmaster without a licence. The maximum penalty for operating without a licence is 10 years in prison and a fine.
• Using an unlicensed gangmaster. It is also illegal to use an unlicensed gangmaster. The maximum penalty for this offence is 6 months in prison and a fine.

There is also a specific offence relating to false documents. A person commits an offence if, in an attempt to make another person believe they are licensed, they possess or control a false, improperly obtained or third-party document connected with licensing.

In practical terms, the compliance message is simple: do not supply workers into a regulated sector without checking whether a licence is required, and do not use a labour provider unless you have checked that they are properly licensed.

You can check whether a labour provider is licensed using the official public register of licensed labour providers.

Why does this matter for UKVI sponsor licence compliance?

Sponsor licence holders must comply with their sponsor duties. One of those duties is to comply with wider UK law, not just immigration law.

The Home Office sponsor guidance states that sponsors have a duty to comply with wider UK law, including employment law, legally required licences, registrations or approvals needed to run the business lawfully, licensing by statutory bodies where required, and not engaging in criminal activity.

This means a breach of gangmaster licensing legislation or involvement in labour exploitation can create two problems at once:

• A potential criminal or regulatory issue under the gangmaster licensing regime; and
• A sponsor compliance issue because the organisation may no longer be complying with wider UK law.

For regulated businesses that sponsor Skilled Workers, Seasonal Workers or other sponsored workers, this is particularly important. UKVI is likely to look closely at whether the sponsor is operating lawfully, whether workers are being recruited and managed appropriately, and whether the sponsor’s wider compliance arrangements are robust.

If I sponsor Skilled Workers, do they still need to be placed by a licensed provider?

Sponsorship does not remove the need to comply with gangmaster licensing rules.

If a third party is supplying, introducing, sourcing, screening or otherwise arranging workers for roles in a regulated sector, that third party may need a gangmaster’s licence, regardless of whether the workers are sponsored.

Equally, if your business is both a sponsor and a labour provider, you may need to consider both regimes together: sponsor duties on one side, and gangmaster licensing obligations on the other.

Do UKVI and the Fair Work Agency talk to each other?

Employers should not assume that immigration compliance and labour market enforcement operate in separate silos.

The Fair Work Agency licensing standards refer to the Gangmasters Licensing Act offences being enforced by the FWA on behalf of the Home Office. The licensing standards also state that the FWA may consider whether relevant individuals have contravened requirements or standards of other regulatory authorities, including UKVI.

That does not mean every issue will automatically be referred to UKVI, or that every UKVI compliance issue will automatically trigger FWA action. But it does mean businesses should treat labour licensing and sponsor licence compliance as connected risk areas.

How can employers prevent a breach?

A practical compliance plan should include:

• mapping which parts of the business involve agriculture, horticulture, shellfish gathering, or associated food/fish/shellfish processing and packaging;
• identifying whether workers are directly employed, supplied by an agency, introduced by a recruiter, provided by an intermediary or used to deliver services to another business;
• checking the public register before using any labour provider in a regulated sector;
• keeping evidence of licence checks, including screenshots or dated records;
• reviewing contracts with agencies, recruiters, umbrella companies and subcontractors;
• training HR, operations, procurement and site managers to spot when GLAA/FWA licensing may be relevant;
• adding gangmaster licensing checks to sponsor licence compliance audits;
• taking advice before moving sponsored workers between sites, clients, group companies or third-party arrangements.

Official government guidance does illustrate that exclusions exist, but employers should check carefully whether an exclusion applies before relying on it.

Key takeaway for sponsor licence holders

If your business operates in agriculture, horticulture, shellfish gathering, or associated processing and packaging, gangmaster licensing should be part of your sponsor licence compliance framework.

A breach is not a minor technical issue. It can involve criminal offences, fines, imprisonment, licence revocation risk and UKVI sponsor compliance consequences.

For employers using sponsored workers, the safest approach is to ask three questions:

1. Are any roles or sites within a regulated sector?
2. Are any workers supplied, introduced, screened, sourced or managed by a third party?
3. Have we checked and documented whether a gangmaster’s licence is required?

If the answer to any of those questions is unclear, it is worth getting advice before the issue becomes a UKVI or FWA compliance problem.

Useful links:

• Public register of licensed labour providers

UK Right to Work check requirements have recently been expanded within the updated sponsor guidance, issued by the Home Office. These changes are important for all UK employers, given that they are likely to be implemented across all UK employers and organisations later this year. Currently, these changes are vitally important for those holding a UKVI sponsor licence.

While some of these changes reflect existing practice, they signal a broader shift towards stricter compliance and increased accountability. 

Why are these changes happening?

The recent changes to the guidance on Right to Work checks have largely been reversed. As a result, employers are not currently subject to the additional checking requirements that had previously been proposed.

However, employers should continue to monitor developments as wider changes to the Right to Work regime are expected in the future. Sponsors continue to be obliged to conduct Right to Work checks on all employees and sponsored workers. 

A new Code of Practice is expected to come into force in October 2026, which is likely to formalise and expand these requirements.  

What changes have been implemented to the sponsor guidance?

The updated guidance introduces several important clarifications:

• RTW checks apply to all employees
  • Home Office guidance now clarifies that correct right to work checks must be carried out for all employees and not just sponsored workers in order to be compliant with record keeping duties. While this reflects existing practice, it is now explicitly stated in the guidance.
• Checks must be completed before work begins
  • The guidance also now makes clear that right to work checks must be carried out on any worker you wish to sponsor, employ or directly engage prior to any work beginning.  

Consequences for non-compliance (all employers):

Failure to comply with RTW obligations can result in serious penalties: 

• Up to £60,000 civil penalties per illegal worker imposed in the event of illegal working, where no right to work check has been conducted or where checks have been conducted incorrectly   

• Potential prosecutions 

• Exclusion from becoming a company director  
• Negative impact on future immigration applications where applicable

Additional consequences for Sponsor Licence holders:

For sponsor licence holders, the risks are significantly higher:

• Likely revocation of the sponsor licence  
• Cooling off period before reapplying for a licence (likely to be 12 months but can be as much as 5 years if there are multiple civil penalties) 

When to carry out Right to Work checks:

• Before employment or work begins – mandatory in all cases.
• If the employee is a British citizen or has settled/ILR status you are only required to carry out this check once.
• For anyone with a temporary leave to remain, you will be required to carry out further checks.  

• Ideally you should also carry out checks prior to considering sponsorship of any individual. This check will indicate whether they are eligible for sponsorship. 

Employers must ensure full compliance with UK Right to Work check obligations to avoid penalties.

Useful links:

• Code of Practice
• How to conduct a Right to Work check

UK care providers have experienced significant disruptions since the government ended overseas recruitment for care workers last year. Recent Home Office data shows a sharp fall in Health and Care Worker visa applications following these changes, with main applications down 54% year-on-year and a staggering 92% below the November 2023 peak.

For many providers, the real concern isn’t just the policy headlines; it’s the practical reality of day-to-day operations. Questions keep coming up:

• Can we still sponsor existing staff?
• Can workers already in the UK switch into sponsored roles?
• What does this mean for our sponsor licence?
• Is sponsorship still a realistic option at all?

Below we examine what has changed, what remains possible in 2026, where the main risks lie now, and how care providers should be thinking about compliance going forward.

What changed for care worker sponsorship?

The sponsorship landscape for care workers (SOC 6135) and senior care workers (SOC 6136) shifted significantly following a series of policy announcements and changes to the Immigration Rules during 2025.

April 2025 changes: The “Displaced Worker” Rule

From April 2025 to July 2025, care providers in England were required to prioritise workers already in the UK before turning to overseas workforce. In practice, this meant demonstrating an attempt to recruit from a pool of displaced care workers – individuals who lost their sponsorship through no fault of their own (e.g. due to a previous sponsor unable to offer sufficient work or losing their licence). It’s important to note that this displaced worker rule is now no longer in force.

At the same time, the minimum salary thresholds for care worker sponsorships rose from £23,200 per year to £25,000 per year (or £12.82 per hour).

July 2025 Changes: The Overseas Ban

In July 2025, the Immigration Rules officially closed overseas recruitment altogether for frontline care roles

• Care workers and home carers (SOC 6135)
• Senior care workers (SOC 6136)

From this point new sponsorship for these roles became restricted to two groups:

• Displaced workers already in the UK on the care route
• In-country switchers – eligible individuals on other visa types such as Students, Graduates or Dependents, provided they have worked legally for the provider for at least three months.

Taken together these changes have fundamentally changed how sponsorship operates in adult social care. Overseas recruitment is no longer an option, and sponsors now operate under far tighter compliance expectations.

Why has adult social care been hit harder than other sectors?

Unlike other industries that had time to adjust to higher salary thresholds, adult social care lost an entire recruitment route overnight. For a sector reliant on overseas workers to fill persistent gaps, the impact was immediate. Many providers had to rebuild their recruitment strategies from scratch, relying solely on the in-country workforce while navigating far more complex compliance demands at the same time.

Can care providers still sponsor anyone at all?

Many employers still ask this because “care sponsorship” is discussed too broadly in the media. The answer is not a simple “no,” but it is highly conditional. It depends on the role, the worker’s current status, and whether the case falls within the remaining lawful routes or transitional arrangements. 

Although most Skilled Worker roles now need to meet RQF Level 6, care sponsorship continues to operate under a unique framework of exceptions: 

• In-Country Extensions and Changes of Employer: You can still sponsor existing Health and Care visa holders who need to extend their stay or are looking to switch into your sponsorship.

• In-Country Switching (The Three-Month Rule): Students, Graduates and Dependents, may be able to switch into the care route, provided the sponsor can evidence that they have legally employed the applicant for three months before assigning the Certificate of Sponsorship (CoS).

• Immigration Salary List (ISL) or Temporary Shortage List (TSL): Care and Senior Care roles remain on the ISL, allowing sponsorship below RQF Level 6 until at least 22 July 2028, provided the worker is already in the UK. 

Other roles within care may still be eligible for sponsorship, including under transitional rules, but this is something which would require consideration on a case-by-case basis. 

What are the main risks for care businesses now?

The government has made clear that these reforms are driven by concerns about “rogue providers”. This is the point where every provider should pause and review their files against these five risks: 

• Weak Sponsor Licence: Holding a licence is no longer enough. It is about proving you deserve to keep it. The Home Office no longer treats administrative gaps in compliance as mere technicalities. Poor record-keeping or unclear recruitment trails can lead to licence suspension or, revocation, and serious consequences for sponsored staff.

• Role Inflation: There is a significant temptation to “promote” a care worker to a “Manager” or “Specialist” role that fits RQF Level 6 simply to meet the new skill threshold. The Home Office is actively targeting cases where the job description on paper doesn’t match the day-to-day reality of the staff member’s duties.

• Sponsorship without a Genuine Vacancy: You must prove that the role actually exists and is commercially needed. Speculative or forward-planning sponsorship is regularly challenged.

• Right-to-Work Checks and Reporting Failures: Missed reports, late updates, or inconsistent records can quickly escalate into audits under the tighter post-2025 regime.

• Outdated Recruitment Models: Treating sponsorship as a routine HR process rather than a regulated immigration function often leads to accidental non-compliance.

What should care providers do now?

Practicality is key here. To retain your care team and remain compliant, care providers should focus on a few core actions:

1. Audit compliance systems and reporting processes
2. Check existing workforce visa expiries to identify who needs an extension soon
3. Review recruitment plans against the ISL, TSL and rule change timelines
4. Restructure if necessary, rather than forcing roles into categories that no longer fit
5. Ensure HR teams understand the post-July 2025 rules, including which roles can and cannot be advertised overseas
6. Seek legal advice before assigning a CoS in complex or borderline cases

Ultimately, sponsorship remains a viable, although more restricted, option for adult social care providers. In 2026, the focus is whether your recruitment model still works comfortably under the current rules.

The fishing sector is an industry where UKVI sponsorship changes can quietly cause big operational problems if people don’t see them coming.

This article focuses on the ‘Deck Hand’ role and is designed for fishing vessel owners and operators HR/admin staff supporting recruitment and anyone responsible for compliance, payroll, or workforce planning.

Salary Levels

The minimum salary allowable for the Deck Hand role is currently £33,400 per annum. This is due to the fact the role is listed on the Immigration Salary List. Currently, there is no indication that this minimum salary level will be changing before December 2026.

What does this mean?

There is no short-term impact forecasted in relation to salary levels.

English Language Requirement

The English Language Requirement for individuals new to the Skilled Worker route has recently changed. The new requirement for those qualifying via the Secure English Language Test (SELT) now sits at the higher ‘B2’ level, this is classed as upper intermediate level and the individual should be able to understand complex, technical, or abstract topics.

If a worker is already in the UK on a Skilled Worker visa and their previous permission required B1, they may not need to meet the higher B2 threshold if they are extending or switching. However, specific circumstances should always be considered before making any immigration application.

The Secure English Language Test (SELT) is not the only way an individual can prove their level of English and qualify for the points required for their visa. Some individuals may also qualify for the English language requirement via their nationality, school qualification and degree level qualifications taught in English.

What does this mean?

This change has already taken place – consider this higher English language requirement and which regions of the world you are looking to recruit from.

Deck Hand – Sponsorship Eligibility Changes

The role of ‘Deck Hand’ is currently eligible for Skilled Worker sponsorship due to its placement on the Immigration Salary List (ISL).

Deck hands (specifically, those on large fishing vessels of 9 metres and above, classified under SOC code 9119) are currently scheduled to be removed from the UK ISL on 31 December 2026.

Whilst the role remains on the ISL, new entrants can enter the skilled worker route with the minimum annual salary of £33,400.

Please note any new entrants to this route as a Deck Hand cannot bring dependents to the UK.

What happens after 31 December 2026?

Sponsorship as a Deck Hand may not be possible after 31 December 2026.

If the current rules remain in place, then transitional arrangements for those sponsored as Skilled Workers prior to 22 July 2025 will still be available for those extending and switching.

Those on the skilled worker route prior to 22 July 2025 may still qualify for extensions or switching sponsors with a minimum annual salary of £41,700.

Those on the skilled worker route prior to 04 April 2024 may still currently qualify for extensions or switching sponsors with a minimum annual salary of £31,300 – this concession is only available for applications made on or before 04 April 2030.

What does this mean?

Any direct overseas sponsorship for the Deck Hand role is likely to end on 31 December 2026 (unless new rules are implemented to allow continued overseas sponsorship). Transitional arrangements will still be in place for those sponsored in the Skilled Worker route prior to 22 July 2025.

If you are considering the employment of overseas Deck Hands via the UKVI sponsorship route we recommend you prioritise this now to ensure any overseas workers are onboarded prior to the rule changes.

Indefinite Leave to Remain (ILR) Proposals – Earned Settlement

The Government has confirmed its intention to proceed with a new ‘Earned Settlement’ model.

The standard ILR qualifying period of 5 years is expected to increase to 10 years for most routes.

Whether these changes apply to people already in the UK remains under consultation.

What does this mean?

We do not know if there will be any transitional protection in place for those already in the Skilled Worker route. We are currently unable to provide any advice in relation to future ILR applications. Any individuals who believe they currently qualify for ILR should consider making an application before any new rules are imposed.

Continued compliance activity:

The Home Office has increased scrutiny on:

• Sponsor Management System (SMS) accuracy
• Absences and location tracking
• Contract and payslip alignment 
• Ongoing reporting and HR processes

Legal/compliance impacts:

• Sponsor licence downgrade, suspension or revocation
• Civil penalties for right-to-work failures (illegal working)
• Reputational damage in the sector

What fishing businesses should do now:

1. Review who is managing your sponsorship and compliance – are they competent?
2. Tighten right-to-work processes
3. Strengthen compliance records
4. Prepare for UKVI audit readiness

From 11 November 2025, the UK Immigration Rules introduced a major update. Part Suitability now replaces the old “Part 9 – General Grounds for Refusal”. 

This reform aims to create greater consistency in how the Home Office evaluates character, conduct and public interest factors across most visa categories. In this blog, we explain what the changes mean for applicants, sponsors and legal advisers.

What is Part Suitability?

Part Suitability provides a unified framework for deciding whether a person should be refused entry clearance (a visa), permission to stay or have their existing permission cancelled, based on various “suitability” grounds. 

Unlike the old system, the new rules distinguish clearly between mandatory and discretionary decisions:

• Mandatory refusal: applies where the applicant has been convicted of a criminal offence resulting in imprisonment of 12 months or more, regardless of when the conviction occurred.
• Discretionary refusal: applies to individuals with lesser convictions, non-custodial sentences or out-of-court disposals.

Key Grounds Under Part Suitability

Part Suitability covers several areas that can lead to refusal or cancellation. These include:

• Exclusion, deportation or travel ban: Permission must be refused or cancelled if the individual is subject to an exclusion or deportation order.
• Non-conductive conduct: Applications may be refused where a person’s conduct, character or associations make their presence in the UK undesirable.
• Criminality: Mandatory refusal or cancellation applies in cases involving serious criminal convictions. For example:
  • sentences of 12 months or more
  • repeat offending
  • offences that cause serious harm.
• Previous breach of immigration law: Overstaying or other immigration violations can impact new applications or lead to cancellation of existing permission.
• Debt to NHS or litigation costs: Outstanding NHS charges above the relevant threshold, or Home Office litigation debts, may be considered under suitability. 

Applications for leave that do not align with the Immigration Rules may be refused.

Why Does This Change Matter?

Part Suitability represents one of the most significant structural changes to the Immigration Rules in recent years. The biggest shift is in consistency. Under Part Suitability, most applicants are now assessed against a single, unified standard rather than route-specific tests. 

However, this shift also makes the system stricter, particularly for family and private-life routes that previously benefited from exemptions around overstaying or certain convictions.

As a result, applicants and sponsors need to be more vigilant in preparing their cases. 

Practical Tips for Applicants and Sponsors

• If you have any past criminal records, immigration breaches, unpaid NHS costs, don’t assume they don’t matter.
• Build a strong documentary record as a way of gathering evidence. Mitigating factors such as rehabilitation and compelling personal circumstances may help in discretionary cases.
• Full disclosure is key. Failing to tell the truth or under-reporting past problems could result in long-term reputational damage in future applications as well as risk refusal.
• Given the technical complexity, consult with an immigration advisor to assess risk and prepare submissions. Contact us for support. 

If you are a sportsperson, athlete or coach aiming to live and work in the UK, the International Sportsperson visa is your primary route. 

This specialist temporary visa is designed to attract top-level athletes and coaches to the UK and allows sports professionals with international recognition to work, reside and compete in the UK. 

Understand the Eligibility Criteria

To qualify for the International Sportsperson visa, you must:

• Be 16 years or older
• Have a valid Certificate of Sponsorship (CoS) from a UK-based sponsor with a valid sponsor licence.
• Obtain an endorsement from a recognised governing body in your sport, confirming your elite status and contribution to the sport in the UK.
• Meet the English language requirement (level A1 in speaking and listening) if applying for a visa longer than 12 months. 
• Demonstrate you can maintain and accommodate yourself in the UK, either through personal savings (£1,270 minimum for 28 days) or a sponsor guarantee. 

Securing a Governing Body Endorsement (GBE)

Each sport has its own governing body responsible for issuing endorsements. These bodies assess your achievements and potential contribution to the sport in the UK. Contact the relevant body early to understand their specific requirements and timelines.

1. Identify the governing body https://www.gov.uk/guidance/immigration-rules/immigration-rules-appendix-sports-governing-bodies
2. Contact them to understand their application process.
3. Prepare your portfolio (international results, awards, references, etc). 
4. Submit your application following their guidelines.
5. Receive the endorsement letter or certificate which must be valid for submission with your visa application. 

Obtain a Certificate of Sponsorship (CoS)

Your UK sponsor, such as a sports club or organisation, must issue you a CoS. This document 

• Confirms your job offer
• Details your role, salary, and employment conditions 
• Is essential for your visa application

Gather Required Documents

Prepare the following documents for your application: 

• A valid passport or travel document.
• The Certificate of Sponsorship reference number.
• Proof of English language proficiency (if applicable).
• Evidence of maintenance funds (bank statements or sponsor’s guarantee).
• The endorsement letter from your sport’s governing body

Application Process

1. Apply online via the UK government website. 
2. Fill in personal info, job details and endorsement info. 
3. Upload documents: include endorsements, CoS, financial proof, English proficiency, passport. 
4. Pay fees: £319 (up to 12 months) or £769-£885 (over 12 months), plus Immigration Healthcare Surcharge (£1,035/year).
5. Review and submit, receive a reference number. 
6. Verify identity by biometric appointment or UK Immigration ID Check app. 

Immigration Skills Charge Exemption

Individuals applying via this route are now exempt from the UK’s Immigration Skills Charge (ISC).

The exemption includes not only elite sportspeople but also those in supporting roles such as coaches, instructors, and officials.

Await a Decision

Processing times vary:

• Outside the UK: Typically within 3 weeks.
• Inside the UK: Usually within 8 weeks.

You may be eligible to pay for a faster decision.

After Your Visa is Granted

With the International Sportsperson visa, you can: 

• Work for your sponsor in the specified role.
• Engage in voluntary work.
• Study, provided it doesn’t interfere with your sponsored role.
• Travel abroad and return to the UK.
• Bring eligible dependents (partner and children) with you.

The visa is initially valid for up to 3 years. After 5 years, you may be eligible to apply for Indefinite Leave to Remain (ILR), allowing permanent settlement in the UK.

Visa holders cannot claim public funds, start or run a business.

Tips for a Successful Application

• Start Early: Begin the process well in advance to accommodate time for endorsements and document preparation.
• Stay Informed: Regularly check the official UK government website for any updates or changes to the visa requirements.
• Seek Professional Advice: Consider consulting with an immigration solicitor or advisor to navigate the application process smoothly.

For more detailed information, visit the official UK government page on the International Sportsperson visa: Overview – GOV.UK