The UK’s immigration landscape continues to evolve at pace, with September 2025 marking another wave of policy updates, procedural adjustments, and forward-looking proposals. For applicants, sponsors, and businesses, staying informed is no longer optional, it’s essential.
This guide provides the latest updates on UK immigration law as of September 2025, together with insights into what may lie ahead.
Whether you are preparing a visa application, managing compliance as an employer, or exploring settlement routes, this article is designed to give you a clear, authoritative overview of the changes that matter most.
Key Takeaways
- ILR reforms: Qualifying period may extend from 5 to 10 years for most work visa holders, with a new “earned settlement” model and higher English requirement (B2).
- Impact on migrants: Longer ILR timelines increase costs, extend dependence on employers, and delay eligibility for citizenship and family sponsorship.
- Impact on UK businesses: Higher sponsorship costs, longer commitments, and reduced attractiveness for global talent.
- Skilled Worker visa changes (July 2025): Salary thresholds raised, skills requirement increased to degree level (RQF 6), care worker sponsorship phased out, and new restrictions on dependants.
- Refugee Family Reunion route: Paused in September 2025; new, stricter system expected in Spring 2026 with higher income and English requirements.
- Visa sanctions policy: The UK will limit or suspend visas for countries refusing to take back their nationals, working with “Five Eyes” partners.
- Asylum reforms: Hotels being phased out by 2029, shorter move-on period (28 days), new appeals body, stronger enforcement, and Article 8 review.
- E-Visa rollout: BRPs replaced with digital records, but concerns remain over technical failures, digital exclusion, and data security.
- Leadership changes: New Home Secretary Shabana Mahmood signals tougher enforcement, visa restrictions, and faster asylum reform.
- Future outlook: UK considering a reassessment of its obligations under the ECHR, which could reshape rights-based challenges to asylum, deportation, and family migration.
A New Era in UK Immigration
September 2025 is a critical turning point in UK immigration policy due to the implementation of significant and long-awaited reforms outlined in the government’s Immigration White Paper of May 2025.
These changes, debated in Parliament and now taking effect, are fundamentally restructuring the UK’s approach to migration with a clear focus on reducing overall numbers and tightening routes to settlement.
Proposed Changes to Indefinite Leave to Remain (ILR)
One of the most closely watched areas of reform is Indefinite Leave to Remain (ILR), the gateway to permanent settlement in the UK. Indefinite Leave to Remain is going to undergo the following changes:
Extended Qualifying Period: The standard qualifying period for ILR will be increased from the current five years to ten years for most applicants under the Points Based System, such as those on a Skilled Worker visa.
Earned Settlement Model: The government intends to introduce a points-based system where individuals can “earn” a shorter route to settlement through “meaningful contributions to the UK economy and society.” The specific criteria for earning these points have not yet been defined.
Higher English Language Requirement: The required English language proficiency for ILR applicants will be raised from the current B1 level to B2.
Extended Qualifying Period
According to the White Paper, the qualifying time for most ILR applicants would be raised from five years to ten years.
An expedited settlement may still be an option for some individuals. Furthermore, individuals who enter the UK on a Family Visa and then apply to settle do not have their qualifying residence requirement extended under the present proposals. Spouses and other Family Visa holders can still apply for ILR after meeting a five-year residence requirement.
A key proposal under review is to extend the qualifying period for Indefinite Leave to Remain from five years to ten years for Skilled Worker Visa holders and other work visa routes. This shift is raising concern among overseas employees and UK businesses, as it would significantly delay the path to permanent settlement.
Impact of Extending the ILR Qualifying Period
The effects of a longer ILR qualifying period on visa holders include:
- Applicants and their families will face significantly higher costs due to the need for multiple visa renewals and the extended payment of the Immigration Health Surcharge.
- The path to ILR may remain tied to a single employer for ten years, restricting job changes and professional growth.
- Individuals and families will experience a prolonged period of personal and legal insecurity without the stability of permanent residency.
- Meeting continuous residency requirements over a longer timeframe will further restrict time spent outside the UK.
- The timeline for applying for British citizenship will be pushed back, as ILR is a prerequisite.
- The longer qualifying period increases the chance that an applicant may no longer meet the eligibility criteria due to changes in personal, financial, or health circumstances.
- Applicants must wait longer to secure ILR before they can sponsor partners and other family members to join them in the UK on certain visa routes.
- The inability to vote in local elections will continue for an extended duration.
Impact on UK Business Owners & Sponsor Licence Holders
Sponsor licence holders and company owners in the UK would be affected by a longer ILR qualifying period in the following ways:
Reduced attractiveness of the UK for talent: Highly skilled overseas professionals may choose alternative destinations where settlement can be achieved more quickly, rather than waiting ten years in the UK.
Increased costs for businesses: Employers will need to maintain sponsorship for a longer period, meaning higher expenditure on Certificates of Sponsorship, immigration skills charges, and other visa-related costs linked to Skilled Worker or Global Business Mobility visas.
Extended sponsorship obligations: If an employee remains in post, a sponsor licence holder may be required to continue sponsorship for up to ten years instead of five. This long-term commitment can reduce flexibility in workforce planning.
Restrictions on employee progression: Sponsored workers can only be promoted into roles that are eligible for sponsorship. With the qualifying period doubled, this limitation may hinder internal career progression and make retention more challenging.
Earned Settlement Model
The second suggestion for improving ILR is to make the eligibility requirements more earnings-based, rather than based on present-day circumstances.
What exactly is meant by “earned settlement”? Nobody knows for sure right now. However, UK Immigration Solicitors foresee a higher emphasis on an applicant’s contributions and commitment to the UK, with Indefinite Leave to Remain obtained through a points-based immigration system for settlement.
English Language Requirement
The White Paper makes reference to modifying the English language requirement for ILR applicants and the earned settlement criterion. Instead of needing to pass the English language test at level B1, the required level will be B2.
Are Current UK Migrants Affected by ILR Changes?
The government has not specified whether persons already on affected immigration routes will have to wait longer for settlement, or whether the change will solely apply to those arriving after the implementation date.
During a statement regarding the white paper on 12 May 2025, this was brought up by the questioner to the Home Secretary, Yvette Cooper. In her response, she indicated:
“ We will set out further details of the earned settlement and citizenship reforms later this year, and we will consult on them. There will be plenty of opportunities for people to comment on and consider the details, but it is important that we extend the sense of contributions and the points-based system to those reforms as well (HC Deb 12 May 2025 c53).
[…]
We want the settlement rules to be amended as swiftly as possible and to apply widely, but we will consult on the details, and it is right that we do so (HC Deb 12 May 2025 c68).”
How to Approach Your ILR Application Under the New Rules
While the proposed changes from the White Paper may not be fully enacted, the UK immigration landscape is undeniably shifting. Regardless of the final legislation, we anticipate significant alterations to the ILR rules.
Immediate Actions to Consider
Public Consultation: A public consultation on these proposals is expected. We highly recommend that individuals and businesses engage with this process to provide crucial feedback.
Transitional Provisions: While a definitive commitment has not been made, there is a possibility that the government will introduce transitional provisions for current visa holders. However, relying on this is not advisable.
If you are already in the UK with a view to settling, we strongly advise the following:
- Submit your application for ILR as soon as you meet the current eligibility criteria to avoid being impacted by any new rules.
- Before travelling, consult an immigration solicitor to ensure your time outside the UK does not jeopardise your application by exceeding the absence thresholds.
- If your application is complicated by issues such as a poor immigration history, character concerns, or other unique circumstances, seek expert legal advice to increase your chances of a successful outcome.
If you hold ILR but reside outside the UK, you should consult an immigration solicitor to determine if you need to apply for a Returning Resident visa and if you meet its strict eligibility requirements.
Skilled Worker Visa Changes (July 2025)
A new Statement of Changes in Immigration Rules, published by the Home Office on 1 July 2025, confirms that numerous work route restrictions mentioned in the May 2025 Immigration White Paper will be enforced for applications submitted with a Certificate of Sponsorship (CoS) assigned on or after 22 July 2025. This is especially true for the Skilled Worker visa.
Since July 2025 has already passed, the following changes to UK immigration rules are now in effect, as of late September 2025. These changes, which came into force on or after July 22, 2025, impact the Skilled Worker, Global Business Mobility, and Scale-up routes.
Increased General Salary Thresholds
The general salary thresholds for several visa routes have been raised in line with the latest 2024 Annual Survey of Hours and Earnings (ASHE) data. For any Certificates of Sponsorship (CoS) assigned on or after July 22, 2025, the new thresholds apply.
| General Threshold Type | Current Threshold (GBP) | New Threshold (GBP) for CoS Assigned on or after 22 July 2025 |
| Skilled Worker (new applicants not eligible for salary discounts) | 38,700 | 41,700 |
| Skilled Worker (PhD) | 34,830 | 37,500 |
| Skilled Worker (PhD STEM, Immigration Salary List, and new entrants not eligible for pre-4 April 2024 transitional arrangements) | 30,960 | 33,400 |
| Skilled Worker not eligible for salary discounts, but eligible for pre-4 April 2024 transitional arrangements | 29,000 | 31,300 |
| Skilled Worker (PhD eligible for pre-4 April 2024 transitional arrangements) | 26,100 | 28,200 |
| Global Business Mobility | 48,500 | 52,500 |
| Scale-up | 36,300 | 39,100 |
Note the following:
- Individuals applying under the new Skilled Worker interim Temporary Shortage List (TSL) must meet the new undiscounted general salary threshold of £41,700, or £31,300 if the pre-April 4, 2024, transitional arrangements apply.
- The ‘high earner’ threshold of £73,900 for the Senior or Specialist Worker and UK Expansion Worker routes remains unchanged.
- The lowest Skilled Worker general salary thresholds for those in the listed health and education occupations and for those under pre-April 4, 2024, transitional arrangements for STEM PhD, Immigration Salary List, and new entrants, which were increased to £25,000 on April 9, 2024, remain at that level.
Increased Occupation-Based Going Rate Salary Thresholds
The occupation-based going rate salary thresholds for the Skilled Worker, Global Business Mobility, and Scale-up routes have also been adjusted in line with 2024 ASHE figures.
These new rates apply to all individuals applying with a CoS assigned on or after July 22, 2025.
Raised Skilled Worker Route Minimum Skills Threshold
The minimum skills threshold for the Skilled Worker route has been raised from Regulated Qualifications Framework (RQF) Level 3 (A-level) to RQF Level 6 (bachelor’s degree level).
This change has removed approximately 180 medium-skilled occupations from eligibility, unless they are on the Immigration Salary List (ISL) or the new interim Temporary Shortage List (TSL).
Individuals already sponsored under the Skilled Worker route in RQF levels 3 to 5 occupations when the changes were implemented (including those who applied under the rules in effect until July 21, 2025) may continue to be sponsored under transitional arrangements, including extending their permission and changing employment. However, these arrangements are not indefinite and are subject to review.
Changes to the Immigration Salary List (ISL) and the New Interim Temporary Shortage List (TSL)
The government is in the process of replacing the ISL with a new TSL. As an interim measure, and until the Migration Advisory Committee (MAC) completes its review by early July 2026, the ISL has been expanded to include RQF levels 3 to 5 occupations that the MAC identified as being in shortage in its 2023 or 2024 reviews.
A new interim TSL has also been introduced to include medium-skilled (RQF level 3 to 5) occupations deemed important for the UK’s Modern Industrial Strategy.
To be eligible for this list, an applicant must have a CoS assigned between July 22, 2025, and December 31, 2026. The government reserves the right to remove occupations from the TSL earlier if compliance issues are identified.
A significant change affecting these lists is that individuals sponsored under the ISL or the interim TSL are now ineligible to bring dependents if their CoS was assigned on or after July 22, 2025. Transitional arrangements are in place for Skilled Workers who were already eligible to be accompanied by dependents under the previous rules.
Phasing Out Care Worker and Senior Care Worker Sponsorship
It is no longer possible to sponsor a care worker or senior care worker for entry clearance under the Skilled Worker route, unless a defined CoS was assigned before July 22, 2025.
In-country switches into these occupations are still permitted for applications made before July 22, 2028, provided the applicant has been legally working for the sponsor for at least three months before their CoS is assigned. This arrangement is under review and could end earlier.
Amended Requirements for Nursing Auxiliaries and Assistants
To prevent the misuse of the nursing auxiliary and assistant occupation code for roles that are effectively care worker or senior care worker roles, the requirements have been clarified. This occupation now only applies in environments where registered nurse roles are also present.
Upcoming Changes to UK Work Visas
While a number of significant changes to the Skilled Worker visa took effect in July 2025, several other proposals have been postponed. Here’s a look at what’s been deferred and is expected to change later in the year and beyond:
Immigration Salary List Review
The government’s plan to completely abolish the Immigration Salary List (ISL) has been put on hold. The Migration Advisory Committee (MAC) has been tasked with conducting a thorough review of all work route salary thresholds and associated discounts. Their report is expected by early January 2026.
Increased English Language Requirements
Tighter English language rules are on the horizon.
- The proficiency level for main applicants is set to increase from CEFR Level B1 to B2 (upper intermediate).
- A new, staggered requirement will be introduced for adult dependants, starting at CEFR Level A1 for the first application, rising to A2 for extensions, and finally to B2 for settlement.
- These changes are due to be implemented by the end of 2025.
Higher Immigration Skills Charge
Employers will soon face a 32% increase in the Immigration Skills Charge (ISC). This will raise the fee to £1,320 per year for medium or large sponsors and £480 per year for small or charitable sponsors. This is also expected by the end of 2025.
New Rules for Dependants
The introduction of new, broader requirements for dependants on work visas is also being delayed. These changes will be part of a new, comprehensive family policy that is scheduled to be announced by the end of 2025.
Changes to Refugee Family Reunion Route
As of early September 2025, there has been a major and immediate change to the UK’s Refugee Family Reunion route.
Former Home Secretary Yvette Cooper put a hold on new applications for refugee family
reunion on September 1, 2025. The administration claims this is a temporary pause while new rules are created for Spring 2026.
The pause began on September 4 at 3 p.m.
- No new refugee family reunion applications can be made after this point.
- All applications received prior to the due date will be considered.
- In all other cases, if a refugee or humanitarian protection status holder wishes to bring their partner or child to the UK, they must apply under the existing Immigration Rules, which have higher restrictions.
New Requirements for Family Refugee Reunion
While the path is closed, refugees who want to bring family members to the UK can apply under the Immigration Rules’ Appendix FM.
They’ll have to meet certain standards, such as
Minimum income requirement: The sponsor in the UK must meet a minimum income threshold, which is currently £29,000 per year. Many refugees may not be able to meet this requirement due to their circumstances.
English language requirement: The applicant must prove a basic level of English proficiency.
Fees: The application fees associated with the standard family visa routes are high, and while fee waivers are available, they are not guaranteed.
What Happens to Existing Applications?
Applications submitted before the 3 pm, September 4, 2025, deadline will continue to be processed under the previous, more lenient Refugee Family Reunion rules.
What’s Coming Next?
The government has stated that this is a temporary pause and that a new, reformed family migration system will be introduced in Spring 2026.
While details are not yet fully clear, the government has indicated that the new route will likely include:
Contribution requirements: This could be a new form of financial or other requirements for sponsors.
Minimum residence periods: There may be a waiting period before a newly granted refugee can apply to bring their family to the UK.
Visa Restrictions on Uncooperative Countries
In September 2025, the British government formally unveiled a new, stricter visa policy for countries it considers “uncooperative” when it comes to returning their people.
Visa Sanctions Policy
Shabana Mahmood, the newly appointed home secretary, stated that nations that do not take back their individuals with no legal right to stay in the UK may see their visas suspended or severely limited. Possible components of the policy, which is currently under development, include:
Cutting the number of visas issued: The UK could reduce the number of visas for students, workers, or visitors from a specific country.
Suspending certain visa categories: In more severe cases, entire visa routes could be temporarily halted for citizens of a non-cooperative nation.
Collaboration with International Partners
This new strategy is part of a larger, coordinated effort with the UK’s “Five Eyes” security allies, which include the US, Canada, Australia, and New Zealand.
These countries recently met in London and settled on some “common principles of return” to help with the deportation of illegal immigrants. The goal of this partnership is to show countries that are hesitant to take their citizens back on a unified front.
UK Asylum Policy Shift (September 2025)
The UK is changing its asylum policy to relocate asylum seekers from hotels to military barracks and has reduced the “move-on” period from 56 to 28 days, which NGOs worry would result in increasing homelessness. The key policy shifts include:
Appeals Backlog:
- A new independent appeals body with statutory powers is being established to clear the asylum appeals backlog.
- It will prioritise cases from individuals in expensive asylum accommodation and foreign national offenders.
- The goal is to resolve these specific appeals within a 24-week timeframe.
Asylum Accommodation
- The use of hotels for asylum seekers is being phased out, with a target of complete closure by 2029.
- Alternatively, more permanent accommodation schemes are being explored.
- A “Failure to Travel” sanction has been introduced, penalising individuals who refuse to move to designated dispersal accommodation by potentially withdrawing their support.
Enforcement and Returns
- Resources for the removal of failed asylum seekers are being increased, including a planned expansion of detention capacity.
- New legislation, the Border Security, Asylum and Immigration Bill, aims to deport foreign nationals who commit serious offenses more quickly and strengthen powers against human smuggling.
- The government has signaled that it may impose visa restrictions on countries that do not cooperate with the return of their failed asylum seekers.
- A “one in, one out” pilot scheme with France has commenced, where the UK returns one irregular migrant per week in exchange for accepting one asylum seeker from France under strict eligibility checks.
Refugee Family Reunion
- New applications to the existing refugee family reunion scheme were temporarily suspended in September 2025.
- A new, more restrictive scheme is expected to be introduced.
- Existing pending applications will continue to be processed under the old rules.
Asylum Claim Process
- The pace of initial asylum claim decisions has significantly increased.
- The 28-day “Move On” period for single adults who have received a positive asylum decision is being reinstated.
Article 8 (Right to Family Life)
- The application of Article 8 of the European Convention on Human Rights is under review.
- The Home Office intends to give Parliament more control over how family rights are applied in asylum and family migration cases, rather than relying on ad hoc court decisions.
E-Visa Rollout
The UK’s immigration system is undergoing a major digital change, with the transition from physical documents such as Biometric Residence Permits (BRPs) to a fully digital e-Visa system.
The goal of this system is to develop a more secure and efficient process, which started with a phased rollout and is expected to be finished by 2025. However, the transition caused serious concerns, notably about vulnerable individuals’ accessibility and personal data security.
An e-Visa is a secure, online record of a person’s immigration status, replacing physical documents such as BRPs, Biometric Residence Cards (BRCs), and passport vignettes.
To access an e-Visa, individuals must create a UK Visas and Immigration (UKVI) account to view their digital status and generate a “share code.” This code is used to prove their right to work, rent, or access services to employers, landlords, and other government bodies.
Timeline & Scope
The transition has been ongoing for some years, and all BRPs expire on December 31, 2024, regardless of the visa’s end date. Even while a person’s legal status will not be affected by an expired BRP, they will need to switch to an e-Visa in order to keep proving their rights in the UK, according to the Home Office.
Starting July 2025, new e-Visa applicants for work or study visas may be directed to create an account with UK Visas and Immigration (UKVI) rather than receiving a physical vignette.
Concerns & Challenges
Issues of digital exclusion and accessibility
A major concern is the possibility of a “digital Windrush scandal,” in which vulnerable populations are left unable to verify their status.
The e-Visa system demands computer literacy, a smartphone with specified capabilities, and an active email address and phone number, which can be difficult for older people, refugees, and those with weak digital skills.
System errors and technical issues
There have been a lot of technical problems and system mistakes with the rollout. Individuals have reported being unable to access their accounts, obtaining inaccurate e-Visa information, or having their data incorrectly merged, resulting in being unable to fly, attend school, or receive benefits.
Safety of data
The Home Office emphasises the security of a digital system that cannot be lost or stolen, but digital rights groups worry about data violations.
Technical issues or data corruption could leave a person “undocumented” with no physical backup due to a single online record.
Lack of support and awareness
Despite the government’s best efforts, a large number of visa holders either do not understand or are unable to complete the necessary transfer.
Legal and community support organisations have highlighted concerns about the Home Office’s stated denial of responsibility for system-related losses and the absence of support for individuals in need.
Verification issues
E-Visa relies on employers and landlords to validate share codes. There are fears that some organisations are unprepared for this transformation, which may result in individuals being denied jobs or homes.
Find out more about the E-visas Rollout.
Cabinet & Policy Leadership Changes
A major shift in leadership on immigration policy has resulted from recent events in the UK government and may affect the course of future changes.
New Home Secretary Appointed
In September 2025, Shabana Mahmood succeeded Yvette Cooper as the Secretary of State for the Home Department. This shift is a part of a larger cabinet reshuffle.
Focus on Enforcement
In her first statements as Home Secretary, Shabana Mahmood has emphasised a commitment to strengthening border security and tackling illegal immigration. She has stated that her priority is to “explore all options to restore order to our immigration system.”
New Policy Directions
The new Home Secretary has already made announcements that indicate a tougher stance on immigration. This includes:
- Visa Restrictions: She has proposed that the UK may restrict or reduce visas for nations that refuse to return their citizens without legal status. This was an important aspect of her initial meeting with her “Five Eyes” counterparts.
- Asylum Reform: The focus remains on speeding the asylum process, lowering the appeals backlog, and eliminating the use of hotel accommodations for asylum seekers. The administration is also reviewing Article 8 (right to family life) to give Parliament more authority over its use in immigration situations.
Note: Both points have been discussed in detail above.
Momentum and continuity
Although the leadership has changed, many of the May 2025 immigration white paper’s recommendations are expected to be implemented. The next Home Secretary is responsible for carrying out the government’s aim of reducing net migration and reforming the refugee system.
Future Outlook – ECHR Review
Looking ahead, one of the most keenly observed problems is the UK’s connection with the European Convention on Human Rights (ECHR). Ministers have indicated that a reassessment of the UK’s duties under the ECHR is on the agenda, particularly in light of frequent legal challenges to asylum removals and deportations.
Supporters of the Convention point out its role in protecting basic rights, while opponents say that the government can’t impose stricter immigration controls because it is obliged by the ECHR. There would be far-reaching effects on asylum, deportation, family migration, and settlement routes if the UK were to reinterpret or distance itself from the ECHR.
The UK government has not yet announced a formal withdrawal, but its rhetoric implies that it may propose substantial changes or restrictions on the use of the ECHR in immigration cases in the coming months. These proposals will shape the immigration policy of the UK after 2025.
