Immigration Statement of Changes HC 997 July 2025

update

IN THIS SECTION

On 1 July 2025, the Home Office released Statement of Changes HC 997, accompanied by a press release, setting out the Government’s ambition to “restore order and control” to the immigration system.

The 140-page instrument is wide-ranging, but in headline terms, it gives effect many of the skilled worker reforms outlined in the Immigration White Paper.

The Skilled Worker route’s minimum skill level is being restored to the higher RQF 6 (degree level), and all sponsored work visa salary thresholds are increasing in line with the 2024 Annual Survey of Hours and Earnings. Two interim shortage occupation lists are also set out.

Care workers and senior care workers are to be removed from the list of eligible occupations for sponsorship from 22 July, and dependant rights for most sub-degree roles are being withdrawn.

With most provisions commencing on 22 July 2025, employers should urgently audit pay scales, recruitment plans and sponsorship processes, while preparing for forthcoming consultations on a higher Immigration Skills Charge, stricter English language requirements and wider family migration reforms.

To discuss the impact of the changes on your organisation, contact us.

 

Key changes in July 2025

 

The following is a summary of the key developments:.

 

Higher sponsored work visa salary thresholds

Effective for CoS issued on or after 22 July 2025

All general salary thresholds and going rates in the Skilled Worker, Global Business Mobility and Scale-up routes have been uprated using the 2024 Annual Survey of Hours and Earnings.

There are no transitional arrangements for applicants extending or changing employer after 22 July 2025, who will be required to meet the higher figures.

Read our detailed guide to the salary changes here >> 

 

Skilled worker visa skill threshold increase

Effective for CoS issued on or after 22 July 2025

From 22 July 2025, Skilled Worker applications must relate to an occupation assessed at Regulated Qualifications Framework (RQF) level 6 or above. The Home Office estimates that this change removes between 100 and 180 occupations from general sponsorship eligibility.

Appendix Skilled Occupations now contains two sets of tables: Tables 1–3 list occupations at RQF 6+ that remain fully eligible, while Tables 1A, 2A and 3A cover RQF 3–5 roles that continue to qualify under specific exceptions—such as inclusion on the Immigration Salary List or Temporary Shortage List, or where the worker is already sponsored in that role before 22 July 2025 and is continuing in the same SOC code.

Existing sponsored workers in sub-degree occupations may continue to be sponsored under transitional provisions, but the Explanatory Memorandum confirms that these concessions “will not be in place indefinitely and will be reviewed in due course.”

Read our detailed guide to the skill level changes here >> 

 

Two interim shortage lists

Effective 22 July 2025

Until a permanent model is agreed, sponsors can still recruit below-degree staff only where the job appears on: (i) an expanded Immigration Salary List that folds in all RQF 3-5 occupations the MAC judged to be in shortage, or (ii) a Temporary Shortage List that the Treasury and DBT view as critical to the Modern Industrial Strategy.

Both lists will expire on 31 December 2026, and ministers reserve the right to shorten that period.

Read our detailed guide to the Immigration Salary List here >> 

 

Read our detailed guide to the Temporary Shortage List here >> 

 

Care workers removed from eligible occupations list

Effective 22 July 2025

New entry clearance applications for SOC codes 6135 (care workers) and 6136 (senior care workers) end on 22 July 2025.

In-country switching into these codes remains possible until 22 July 2028, but only where the employee has already worked for the sponsoring provider for at least three months. After July 2028 the roles will disappear from all shortage lists entirely.

Read our detailed guide to the route closure here >> 

 

Loss of dependant rights for sub-degree shortage roles

Effective 22 July 2025

Anyone sponsored into an RQF 3-5 occupation on either list after 22 July will be barred from bringing family members. The restriction does not affect workers already in the route, nor those sponsored in RQF 6+ jobs. The policy mirrors the existing rules for care workers.

 

ARAP route shut to new principal applicants.

Effective 1 July 2025

Separately from employer sponsorship, Appendix ARAP closed at 15:00 BST on 1 July 2025. Afghan citizens who have not submitted an MOD application by that exact time can no longer start the two-stage relocation process, although family members of existing principals retain a path.

 

Employer takeaways

 

In response to the changes, employers should act quickly to audit all sponsored salaries against the rules effective from 22 July 2025. Most sponsored workers will need to be paid whichever is higher of (i) the relevant Option A–E threshold or, for pre-22 July continuing-employment cases, the Option F–J floor, and (ii) the required percentage of the new going rate. For ISL occupations at RQF 3–5 such as care-worker SOC 6135/6136, the minimum is £23,200 plus the full going rate and the hourly £17.13 test is deemed satisfied. There is no transitional relief beyond the continuing-employment bands, so any Skilled Worker application submitted on or after 22 July 2025 must meet these figures regardless of when the CoS was issued.

If you plan to sponsor a role below RQF 6, confirm that its SOC code appears in Tables 1A, 2A or 3A of Appendix Skilled Occupations and is marked either “ISL” or “TSL”. A sub-degree job that is absent from both lists is, from 22 July 2025, no longer eligible for new sponsorship.

Care sector sponsors face an additional restriction: from 22 July 2025 overseas recruitment into SOC 6135 (care-worker) and SOC 6136 (senior care-worker) ends. You may still switch a worker already in the UK into these codes until 22 July 2028, but you must retain evidence that the employee has been on your payroll for at least three months before the CoS is issued.

Because all RQF 3–5 ISL/TSL roles now carry a ban on bringing new dependants, you should update offer letters, onboarding material and internal guidance accordingly. At the same time, refresh HR templates and Sponsor Management System workflows to reflect the renumbered salary tables and ensure staff responsible for sponsorship are trained on the new rules before they take effect.

Finally, the Government has signalled further consultations in 2025 on a higher Immigration Skills Charge and a move from CEFR B1 to B2 English for most routes. Monitoring those proposals now will allow you to build likely fee rises and eligibility changes into 2026 budgets and workforce plans.

 

Need assistance?

 

To discuss the implications of these changes – or those announced last week – on your organisation or your individual plans, contact us.

 

The full document can be viewed here >> 

 

Author

Founder and Managing Director Anne Morris is a fully qualified solicitor and trusted adviser to large corporates through to SMEs, providing strategic immigration and global mobility advice to support employers with UK operations to meet their workforce needs through corporate immigration.

She is a recognised by Legal 500 and Chambers as a legal expert and delivers Board-level advice on business migration and compliance risk management as well as overseeing the firm’s development of new client propositions and delivery of cost and time efficient processing of applications.

Anne is an active public speaker, immigration commentator, and immigration policy contributor and regularly hosts training sessions for employers and HR professionals

About DavidsonMorris

As employer solutions lawyers, DavidsonMorris offers a complete and cost-effective capability to meet employers’ needs across UK immigration and employment law, HR and global mobility.

Led by Anne Morris, one of the UK’s preeminent immigration lawyers, and with rankings in The Legal 500 and Chambers & Partners, we’re a multi-disciplinary team helping organisations to meet their people objectives, while reducing legal risk and nurturing workforce relations.

Read more about DavidsonMorris here

 

Legal Disclaimer

The matters contained in this article are intended to be for general information purposes only. This article does not constitute legal advice, nor is it a complete or authoritative statement of the law, and should not be treated as such. Whilst every effort is made to ensure that the information is correct at the time of writing, no warranty, express or implied, is given as to its accuracy and no liability is accepted for any error or omission. Before acting on any of the information contained herein, expert legal advice should be sought.

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