Earned Settlement UK: 2026 ILR Reform Guide

Section A: UK Earned Settlement ILR Reforms

Earned settlement is a proposed reform of the UK’s Indefinite Leave to Remain (ILR) system. Under the model set out in the 2025 Immigration White Paper, most five-year settlement routes would be replaced with a ten-year baseline period, combined with new mandatory conditions tied to income, conduct, English language and financial responsibility.

The proposals have not yet been implemented. The consultation closed on 12 February 2026 and the Home Office is reviewing responses. No draft Immigration Rules have been laid before Parliament and all existing five-year and ten-year ILR routes remain in force unless and until amended.

1. What would change under Earned Settlement?

Under the proposed framework, settlement would no longer follow automatically after five years on the correct visa route. Instead, most applicants would begin from a ten-year baseline. Time could then be reduced or extended depending on income level, skill level, compliance history and use of public funds.

The consultation materials describe four core pillars: suitability, integration, contribution and lawful residence. In practical terms, this means applicants would be expected to show:

a. a clean suitability record under a proposed new Part Suitability framework
b. at least B2 level English
c. passage of the Life in the UK test
d. sustained earnings above the personal tax threshold, currently £12,570, for a minimum period under consultation
e. no outstanding NHS, tax or other government debt

These conditions would apply regardless of how long someone has already lived in the UK.

The proposals also include abolition of the stand-alone ten-year long residence route, with long residence absorbed into the broader earned settlement structure. At present, however, the existing long residence rules continue to apply.

2. Ten-year baseline, three-year and five-year routes

The headline change is the proposed ten-year qualifying period for most routes.

The consultation sets out two income-linked reductions:

a. Applicants with taxable income above £50,270 for three consecutive years could receive a five-year reduction from the ten-year baseline, resulting in an effective five-year route.
b. Applicants with taxable income above £125,140 for three consecutive years could receive a seven-year reduction, resulting in a three-year settlement route.

The Government has indicated that routes such as Global Talent and Innovator Founder are intended to benefit from accelerated timelines in line with the highest earning tiers, subject to final drafting of the Rules.

These reductions would only apply if all mandatory conditions are satisfied.

3. Who could face longer routes?

The consultation includes illustrative examples of upward adjustments. Roles below RQF level 6, including certain Skilled Worker and Health and Care Worker positions, are shown with a proposed fifteen-year standard timeline. Periods of public funds use could add five years where less than twelve months are involved, or ten years where use exceeds twelve months. Examples also show potential additions of up to twenty years for illegal arrival, entry as a visitor followed by switching, or significant overstaying.

These examples are not law. They demonstrate the scale of extension the Government is considering.

4. What is the position now?

No changes to settlement eligibility have taken effect. Anyone currently eligible for ILR under existing five-year or ten-year rules continues to qualify under the current framework.

Transitional arrangements remain unconfirmed. Parliamentary debate has highlighted concern about whether the new system would apply to people already part-way through a settlement route. Until draft Rules are published, there is no final position on how transitional protection would operate.

For individuals close to qualifying under the current system, timing and planning remain important. Anyone considering whether to apply for ILR under the existing Rules should assess their position carefully in light of potential future reform.

Section B: How Would Earned Settlement Operate in Practice?

Under a new Earned Settlement regime, residence, income, conduct and compliance would all be examined together, and time spent in the UK would no longer be sufficient on its own to secure ILR.

1. The Ten-Year Baseline in Operation

The proposed ten-year baseline operates as the starting point for most routes. The consultation makes clear that ten years would not produce settlement automatically. An applicant would need to meet every mandatory condition at the point of application.

This changes the character of settlement assessment. Instead of asking whether five years have been completed on the correct route, caseworkers would examine a decade of immigration history, earnings data and compliance records.

The consultation also proposes removal of the stand-alone ten-year long residence route. If that proposal proceeds, ten years of lawful residence without meeting income or suitability criteria would not provide an alternative route to settlement.

Switching between visa routes, salary variations and historic periods of non-sponsorship are likely to become more relevant under a longer qualifying period. A ten-year record increases the scope for past issues to be revisited.

2. The Proposed Part Suitability Framework

The consultation refers to a new Part Suitability tailored specifically to long-term status. Full drafting has not yet been published, but the intention is clear. Suitability at settlement stage would be assessed through a framework designed for permanence rather than for temporary leave.

Under the current system, suitability is assessed primarily under Part 9 of the Immigration Rules. The proposed model signals closer scrutiny of conduct across the full qualifying period. Patterns of behaviour, compliance history and immigration breaches are likely to carry greater weight when assessing eligibility for settlement than they do at extension stage.

In practical terms, this means that historic overstaying, minor criminal convictions, civil penalties or sponsor reporting errors linked to the worker may all be revisited at the point of settlement. Issues that did not prevent previous grants of limited leave could become material when assessing whether long-term status is appropriate.

Residence alone would not secure ILR. If the proposed suitability thresholds are not satisfied at the date of decision, settlement could be refused even where the residence requirement has been met.

3. Earnings Thresholds and HMRC Data

The consultation proposes that applicants demonstrate annual earnings above the personal tax threshold, currently £12,570, for a minimum period under consideration of three to five years. It also sets out potential time reductions for those earning above £50,270 and £125,140 for three consecutive years.

Income would be assessed by reference to HMRC data rather than general assertions of economic contribution. That approach introduces technical and evidential issues which will only be resolved once draft Rules are published.

Questions arise in relation to how self-employed income will be treated across tax years and whether dividends or retained profits will be taken into account in the same way as PAYE earnings. Periods of maternity leave, statutory sick pay or unpaid leave may interrupt an otherwise consistent earnings record. Discrepancies between visa grant periods and tax years could also create gaps, particularly where income straddles different assessment windows.

For sponsored workers, salary adjustments during renewals or short periods of reduced hours may affect eligibility if the final framework requires strict continuity above the relevant threshold. A brief dip in earnings could become material where settlement depends on meeting a defined income pattern over consecutive years.
Under this model, income becomes a structured data requirement grounded in tax records, rather than a broad assessment of overall contribution.

4. Public Funds, Debt and Financial History

The consultation includes examples in which access to public funds could extend the ten-year baseline by five years where use is less than twelve months, and by ten years where use exceeds twelve months. Other illustrative examples show significant additional years for illegal arrival, entry as a visitor followed by switching, or overstaying of six months or more.

The framework also proposes that applicants have no outstanding NHS debt, tax liability or other government debt at the date of application.

Taken together, these proposals place financial history at the centre of settlement assessment. Short periods of public funds use, unresolved tax issues or gaps in National Insurance contributions could have long-term impact on eligibility.

5. Income-Linked Reductions and Accelerated Routes

The consultation proposes that applicants earning above £50,270 for three consecutive years could receive a five-year reduction from the ten-year baseline. Those earning above £125,140 for three consecutive years could receive a seven-year reduction, resulting in an effective three-year route to settlement.

Routes such as Global Talent and Innovator Founder are identified as benefiting from accelerated timelines aligned to the higher earning tiers. The policy intent is to link faster access to ILR with sustained high taxable income.

The specifics of how these reductions would operate remain unclear. It is not yet confirmed whether the qualifying income period would need to fall immediately before the settlement application or whether earlier qualifying years could be relied upon.

The treatment of partial tax years has not been set out. It is also uncertain whether dependants would benefit automatically from a main applicant’s reduced timeline or whether they would need to meet separate criteria. The interaction between income-based reductions and route switching is another unresolved issue, particularly where an applicant moves between sponsored and unsponsored categories.

Until draft Immigration Rules are published, the accelerated route model remains indicative rather than fixed.

6. Continuous Compliance Over a Decade

A ten-year framework places sustained emphasis on accurate compliance. Over that period, changes in sponsor, role, salary and working pattern are common. Each change creates a potential evidential trail that may later be examined at settlement stage.
Assessment could involve scrutiny of sponsor reporting history, adherence to visa conditions, consistency between declared salary and HMRC records, periods spent outside the UK and any historic breaches, even where those breaches were later regularised.

Under a longer qualifying period, small administrative errors or short periods of non-compliance may assume greater significance.

The extension of the assessment window increases the likelihood that historic issues resurface when ILR is finally considered.

7. Areas of Uncertainty

Several core elements of the earned settlement framework remain undefined. Transitional protection for those already part-way through a five-year route has not been confirmed. The treatment of dependants, including whether income may be assessed at household level, remains under discussion. The consultation refers to volunteering and non-financial contribution, but does not set out how these would be measured or evidenced. Sector-specific adjustments for lower-paid occupations are also under consideration, without final parameters.

The drafting of the proposed Part Suitability is another outstanding issue. Without sight of the final text, it is not possible to assess how strictly conduct thresholds will be applied at settlement stage.

No draft Immigration Rules have yet been laid before Parliament. The operational detail will determine how restrictive or flexible the final system becomes in practice.

Section C: Impact on Workers & Entrepreneurs

The earned settlement proposals substantially change the long-term expectations that workers and entrepreneurs can have when planning their future in the UK. The shift from a standard five-year route to a proposed decade-long baseline, with strict suitability and contribution conditions, introduces both opportunities and risks depending on an individual’s income, occupation, compliance history and personal circumstances. The examples and structures set out in the consultation are illustrative rather than final rules, but they provide a clear indication of how different categories of workers and business founders could be treated if the proposals are implemented.

1. Workers in standard salary bands

For most workers earning below the higher-rate tax threshold, the starting position in the consultation is a ten-year qualifying period as the baseline. This would, if implemented in its illustrative form, double the time currently required for the Skilled Worker route and other mainstream work categories. The consultation acknowledges that this would be a significant change but argues that a longer period is justified where settlement is being more closely linked to contribution and behaviour.

To move through a decade-long route under the proposals, workers would need to sustain stable employment, continuous earnings above the income tax and National Insurance threshold for a prescribed period and ongoing compliance with immigration conditions. Any gaps in employment, short-term reductions in hours or periods where earnings fall below tax thresholds may result in delays or upward adjustments depending on how the final criteria are drafted following the consultation.

Benefit use is given particular prominence in the Command Paper’s example scenarios. A period of access to public funds triggered by unemployment, reduced hours, sickness absence or family circumstances is shown as carrying substantial consequences.

The examples indicate that a single period of public funds use lasting less than twelve months could add five years to the qualifying timeline. Use lasting twelve months or more could add ten years, turning a ten-year route into a fifteen or twenty-year pathway.

These examples are not yet binding rules, but they illustrate the kind of extensions the Government is considering. They introduce considerable uncertainty for workers whose industries experience seasonal variation, economic downturns or contract-based employment patterns, or where short-term reliance on benefits may be difficult to avoid.

The combination of the ten-year baseline and strict mandatory conditions means that workers could, under the model described in the consultation, accumulate long periods of lawful residence without ever meeting all settlement requirements. For example, a worker with strong residence but weaker English, a small tax debt or gaps in NI contributions could be unable to qualify for ILR under the earned settlement framework, unless transitional or mitigating provisions are introduced in the final Rules.

2. High earners and priority talent routes

High earners are among those who stand to benefit most under the earned settlement proposals. Individuals who consistently earn above £125,140 in taxable income over a three-year period are, in the consultation’s examples, candidates for a three-year settlement route through a seven-year reduction to the ten-year baseline. This is faster than many current accelerated routes and is presented as a way to enhance the UK’s competitive offer for senior specialists and internationally mobile professionals.

Applicants earning between £50,270 and £125,140 for three consecutive years may still benefit from a five-year route—a restoration in practice of the current standard timeline. The Home Office frames these reductions as a way of recognising economic contribution through sustained tax and NI payments. The consultation also indicates that assessments would be based heavily on HMRC-verified data, which could have different implications for employed workers and those with more complex income patterns.

The consultation specifically highlights Global Talent and Innovator Founder visa holders as groups intended to benefit from accelerated settlement, aligning them with the highest-earning tiers even where income may fluctuate due to entrepreneurial activity. This reinforces the policy emphasis on attracting high-skill, high-value individuals and aligning settlement incentives with the Government’s growth and innovation agenda.

However, even high earners must satisfy all mandatory conditions. A criminal conviction, unresolved tax debt, or failure to meet B2 English would block settlement despite meeting the income threshold for accelerated timelines. The consultation explicitly seeks views on how far income should mitigate other factors, making clear that contribution alone will not override suitability concerns.

3. Lower-paid workers and care sector roles

Workers in roles below RQF level 6, including many in the Health and Care sector, feature in some of the most challenging example scenarios in the consultation. The Command Paper sets out a potential standard qualifying period of 15 years for workers sponsored in sub-RQF 6 roles, reflecting a policy view that such roles should not necessarily lead quickly to settlement, even where there is ongoing labour need.

This creates a stark contrast between higher-paid routes that may reach settlement in three or five years and lower-paid workers who may face 15–20-year routes, particularly if periods of benefit use occur. The impact is not only economic but also personal: prolonged immigration control over many years can affect family stability, job mobility and integration outcomes for workers who are, in practice, providing essential frontline services in the UK.

Care sector roles, already subject to high turnover and demanding working conditions, may become less attractive if settlement becomes significantly less accessible. Workers who might otherwise have seen the UK as a long-term home could reassess their options if the route to permanence is perceived as too long or too conditional. This in turn may have consequences for workforce planning across health and social care.

The consultation acknowledges that some of these proposals raise issues of fairness and sustainability and specifically invites feedback on how long qualifying periods and public funds penalties should interact in sectors where pay is structurally low. It does not yet clarify, however, whether years spent in a lower-paid role would permanently “lock” a worker into a longer route even if they progress into higher-paid, higher-skilled work later.

4. Entrepreneurs and self-employed contributors

Entrepreneurs and founders face distinct challenges under a system where taxable income and NI contributions play a central role in settlement eligibility. Business owners frequently experience early periods of low or volatile income, which could affect their ability to meet both the proposed mandatory earnings condition and the higher thresholds for time reductions.

The consultation indicates that Global Talent and Innovator Founder visa holders may be treated more flexibly through accelerated tiers that recognise innovation and high potential rather than income alone. For other founders and self-employed individuals, however, the model places greater weight on the sustainability and tax profile of their businesses.

Gaps in NI contributions, losses, or years of low revenue may expose founders to longer settlement timelines or even permanent ineligibility if the mandatory conditions are not met. Journalistic or academic entrepreneurs, creatives and self-employed specialists may also encounter difficulty if earnings fluctuate seasonally or if income patterns do not align neatly with tax-year thresholds used in HMRC data. The consultation acknowledges these complexities and seeks stakeholder input on how contribution should be assessed for non-salaried individuals, but it does not yet provide a detailed mechanism.

Section D: Impact on Family Members

The earned settlement proposals extend beyond principal applicants, drawing family members into a system where residence, contribution and compliance determine timelines for permanence. This represents a major shift away from the long-standing principle that dependants generally qualify for ILR in line with the main applicant.

Under the consultation, family members may have their own independent qualifying periods, their own exposure to mandatory suitability and contribution conditions and a separate risk of upward adjustments linked to income, benefit use and integration indicators. These elements are presented in the Command Paper as indicative and exploratory, with the Government expressly seeking feedback on their fairness and practicality.

1. Inclusion of family routes in the earned settlement framework

Although the proposals preserve a form of the five-year route for partners of British citizens and settled persons, this protection is achieved through a fixed five-year reduction from the proposed ten-year baseline. This retains an effective five-year pathway, but it now sits within a broader earned settlement model where mandatory conditions would still apply if implemented as outlined.

For dependants of workers and entrepreneurs, however, the consultation suggests that qualifying periods may be assessed independently of the main applicant. This is a significant departure from the current system, where dependants typically qualify for ILR alongside the primary visa holder if they have accrued five years of residence as dependants. Under the earned settlement proposals, alignment cannot be assumed. The consultation’s intent is to link settlement outcomes more closely to individual contribution and conduct, though it invites stakeholder views on the extent to which dependants should face parallel requirements. This independent assessment means dependants may qualify earlier, later or at an entirely different time from the main applicant depending on their personal circumstances.

2. Income, work and benefit use for dependants

One of the most consequential features of the consultation is the potential extension of benefit-related penalties and contribution assessments to dependants in their own right. A partner who takes a break from work due to childcare, caring responsibilities or study could, under the illustrative scenarios, lose access to income-linked reductions and be exposed to upward adjustments if their circumstances trigger entitlement to public funds.

In the Command Paper’s examples of the time-adjustment model:

• An applicant who has been in receipt of public funds for less than twelve months could have five years added to their qualifying period.
• An applicant who has been in receipt of public funds for twelve months or more could have ten years added, potentially creating a fifteen- or twenty-year route.

Although the examples refer to “the applicant” in general terms, the same approach would apply where a dependant is the one applying for settlement. In practice, this means that periods on public funds could extend a dependant’s own timeline even if the main applicant has remained in full-time work and has not claimed benefits.

These extensions may occur even if the main applicant remains in full-time work, never claims benefits and remains fully compliant. Households where one partner pauses work temporarily for legitimate reasons could, therefore, find themselves split across different settlement timelines if the proposals are implemented without modification.

The consultation also raises questions about how income-based reductions would apply to dependants. It does not yet confirm whether dependants would need to demonstrate independent earnings above tax and NIC thresholds or whether income from the household could be aggregated. The Home Office has sought views on this but has not yet provided a proposed mechanism.

3. Children and the transition to adulthood

The consultation raises a specific set of issues relating to children, particularly those close to turning eighteen. The current system often aligns children’s settlement with their parents’ ILR, allowing families to obtain settled status together. Under the earned settlement model, this automatic alignment is questioned. The consultation suggests that the Home Office is considering a more individualised approach for children’s settlement, based on factors such as residence duration, integration indicators and personal history.

However, the Command Paper provides no definitive criteria and explicitly invites views on how children should be treated. Several issues arise from this lack of clarity:

• Children who arrive in the UK at an older age may not easily accumulate ten years’ residence before turning eighteen.
• Teenagers in full-time education may not meet contribution-related criteria tied to earnings or NI requirements.
• The transitional phase from child to adult could become a period of immigration vulnerability rather than stability.
• Families may experience differing timelines for each child depending on their age at arrival, school attendance patterns and periods of absence.

Until final Rules are drafted, it remains uncertain how closely children’s settlement pathways would track those of their parents or whether standalone criteria would be applied.

4. Divergence of timelines within families

The combined effect of independent assessment, benefit penalties and occupation-based extensions is that family members within the same household could accrue significantly different qualifying periods. The consultation gives examples where one household member’s benefit use or occupation affects their own settlement timeline while leaving the main applicant’s route unchanged.

Possible outcomes under the model described in the consultation include:

• A main applicant earning £55,000 may remain candidates for a five-year route, while a partner who takes time out of work may fall onto a ten-year baseline.
• A dependant in a lower-paid or sub-RQF 6 role may face a proposed fifteen-year route even when the main applicant qualifies in five years.
• Two children in the same household may have different settlement timelines depending on age at arrival.

Long-term planning for families therefore becomes more complex. Decisions around childcare, study, work breaks, part-time employment and benefit use become central to future settlement outcomes. Families may need to approach settlement planning collectively, integrating immigration considerations into household financial and employment decisions.

Section E: Impact on Employers

The earned settlement proposals, if implemented, would reshape the long-term environment in which UK employers recruit, support and retain overseas workers. Replacing the established five-year ILR expectation with a conditional ten- to fifteen-year model fundamentally changes the attractiveness of sponsored roles, the stability of employment relationships and the operational burden placed on HR teams. The consultation presents these changes as indicative and invites employer views, meaning the final structure may differ. The proposals indicate a longer-term and more compliance-intensive relationship between employers and sponsored workers.

1. Recruitment and retention changes

The move from a five-year ILR route to a proposed decade-long baseline alters the long-term value proposition employers can offer overseas recruits. Historically, the five-year route provided a clear horizon of stability, family security and personal autonomy, particularly attractive in competitive international labour markets.

Lower-paid and mid-level roles may become harder to market internationally where the settlement timeline extends to ten or fifteen years. Workers may be less willing to relocate if pay progression is slow or public funds penalties create uncertainty. International candidates may prefer jurisdictions offering clearer settlement timelines. Employers recruiting for senior or higher-earning positions may gain advantage where accelerated three- or five-year routes apply.

The consultation acknowledges that the extended timelines for lower-paid roles, especially in social care and frontline health positions, may affect these sectors disproportionately. It invites views on whether occupation-specific mitigations should be included.

2. Sponsorship risk over extended periods

The extension of qualifying periods means that employers would need to manage longer sponsorship relationships, sometimes spanning a decade or more. This introduces additional compliance challenges, especially for organisations that sponsor large numbers of workers.

Longer sponsorship periods increase the risk of missed renewal deadlines, delays in reporting changes and inconsistencies in employment records. Over a decade or more, there is also greater exposure to compliance visits and audits. Changes in dependants’ circumstances may create additional evidential complexity.

Over ten or fifteen years, even relatively small administrative errors may have consequences for a worker’s eligibility for settlement, which could give rise to disputes, grievances or reputational challenges for employers.

3. HR and workforce management implications

The earned settlement proposals introduce a new set of pressures for HR teams and workforce managers, as long-term immigration outcomes become tied to factors within the employer’s operational control. The consultation signals an intention to integrate HMRC data more closely with immigration assessments, which is likely to tighten scrutiny of payroll accuracy and employment continuity.

Income stability becomes more significant where settlement eligibility depends on sustained taxable earnings. Changes in working patterns, including reduced hours or statutory leave, may affect timelines. Disciplinary processes that result in criminal convictions could have settlement consequences under the proposed Part Suitability. Workers with tax arrears or NHS debt may require documentation and support to resolve issues before settlement. Longer routes are also likely to generate increased requests for historic employment and salary evidence.

HR teams may need to invest in enhanced compliance systems, including periodic immigration audits, structured pay reviews and closer coordination with payroll teams to minimise risk.

4. Operational planning and cost management

Longer settlement timelines influence how employers plan workforce stability and operational resilience. Organisations will need to consider how the broader earned settlement model may affect recruitment pipelines, turnover rates and the availability of overseas labour in different sectors.

Employers may face higher turnover where workers perceive limited settlement prospects. Internal immigration support may need to expand. Compliance and administrative costs are likely to rise over longer sponsorship periods. Pay progression frameworks may require adjustment to help workers meet income thresholds where relevant. Workforce planning in lower-paid sectors may need to account for reduced long-term attractiveness.

The consultation emphasises that settlement reform needs to be workable for employers and invites views on proportionality, cost impact and whether specific sectors require exemptions or tailored measures.

5. Sector-specific implications

Health and social care roles below RQF level 6 could face extended fifteen-year timelines, affecting recruitment and retention. Professional services firms may benefit from accelerated settlement for high earners while facing challenges attracting junior talent. Technology and STEM sectors may remain competitive where accelerated routes apply. Hospitality and retail roles may become less attractive if settlement prospects are extended. Education and research institutions may continue to rely on Global Talent where accelerated timelines are available.

The consultation invites sector-specific evidence, particularly in relation to labour shortages, pay constraints, and how extended settlement timelines may affect different industries.

Section F: DMS Strategic Perspective

The earned settlement proposals signal a significant shift in how long-term immigration status may be structured in the UK, moving away from predictable five-year ILR routes and towards a multi-tiered, contribution-focused model. Although the proposals remain at consultation stage and may be revised following stakeholder feedback, they collectively indicate a strategic reframing of the settlement landscape.

1. A shift from automatic to conditional permanence

The proposed earned settlement framework represents a fundamental change in how individuals progress to long-term status. Settlement is reframed as something to be earned through sustained contribution rather than an automatic benefit of route progression and residence. The ten-year baseline, paired with wide-ranging mandatory conditions, introduces a more conditional and performance-based pathway.

From a strategic standpoint, this creates a system in which permanence becomes contingent on behaviour and compliance, not simply time spent in the UK. Workers who previously relied on meeting route-specific residence requirements must now consider the broader criteria embedded in the consultation, including income stability, conduct, and integration. Employers must recognise that their sponsored workers’ long-term prospects may depend on factors that interact directly with workplace decisions, such as salary levels, hours of work, disciplinary processes and periods of leave.

2. Winners and losers under the proposed system

The consultation’s illustrative examples make clear that the proposed framework creates sharper distinctions between groups of individuals. High earners, Global Talent applicants and Innovator Founder visa holders stand to benefit from accelerated settlement, gaining access to three- or five-year routes that could be more generous than current options. These groups are positioned as economic contributors whose long-term presence is strategically desirable for the UK.

By contrast, lower-paid workers, those in sub-RQF 6 roles and individuals who experience periods of benefit reliance feature in illustrative scenarios with extended timelines of up to fifteen, twenty or thirty years. The consultation acknowledges that these proposals raise fairness concerns, particularly in sectors such as care where low pay is structural, not reflective of individual contribution. This divergence could influence the distribution of international talent across sectors and affect the long-term attractiveness of UK roles.

3. Long-term compliance risks for employers

The proposed extension of settlement timelines significantly increases compliance exposure for employers. A ten- or fifteen-year sponsoring relationship heightens the likelihood of changes in employee circumstances—changes that must be monitored and reported accurately to maintain compliance.

Some workers may decide not to pursue long-term residence if timelines extend significantly, increasing turnover. International candidates may compare settlement systems across jurisdictions. Employers may need to review pay progression and internal mobility to support income-based eligibility. Longer timelines are also likely to influence career planning and succession structures.

Employers will need to review whether their HR and compliance systems are resilient enough to manage multi-year monitoring obligations and to support sponsored workers across more complex immigration journeys.

4. Workforce planning under conditional settlement

As settlement becomes more conditional and extended, workforce planning must adapt accordingly. Employers will need to consider how different categories of sponsored workers may respond to longer or more uncertain routes to permanence. In particular:

• Some workers may decide not to pursue long-term residence due to the extended timelines, increasing turnover in sponsored roles.
• International candidates may prefer jurisdictions offering more straightforward routes to settlement or citizenship.
• Employers may need to enhance compensation packages, pay progression or internal mobility to help workers meet contribution-based criteria.
• Longer settlement timelines may influence career planning, learning and development, and organisational talent pipelines.

Planning for these shifts now will help organisations maintain continuity and resilience if the earned settlement model proceeds.

5. Preparing for transition and uncertainty

The consultation stage means significant uncertainty remains. The range of proposals in the Command Paper reflects areas where the Home Office is still seeking evidence, including how dependants should be treated, how public funds penalties should operate, whether occupation-based timelines should apply and how to ensure the system remains proportionate.

Employers should identify sponsored workers and dependants who could be affected under different scenarios, review HR and compliance systems in light of longer sponsorship periods, prepare for increased employee queries and consider engaging with the consultation process where sector evidence is relevant.

The eventual shape of the earned settlement system will depend on consultation outcomes and the drafting of new Immigration Rules. Preparing early will give employers strategic advantage and ensure smoother transition if the proposals, or a modified version of them, are adopted.

Section G: Summary

A new earned settlement system would fundamentally reshape long-term immigration in the UK. The proposals move away from the familiar five-year ILR model and outline a future system where settlement is granted only after a ten-year baseline and satisfaction of demanding suitability, income, English language and financial responsibility conditions.

Accelerated pathways for high earners and priority talent routes sit alongside potential extensions for lower-paid roles and those who experience periods of benefit use, signalling a sharper differentiation between groups than under the current framework.

Families face new complexity, with dependants potentially assessed independently and exposed to their own adjustments, creating the possibility of staggered settlement journeys within the same household. For employers, the proposals indicate longer sponsorship horizons, greater compliance exposure and changes to recruitment and retention dynamics, particularly in sectors where pay and progression are constrained.

While nothing has yet changed in law, the consultation provides a clear indication of the Government’s intended approach to future settlement reform. Individuals and employers should review the potential implications now, monitor the consultation response closely and prepare for transition, recognising that the eventual system may reshape settlement expectations, workforce planning and household immigration strategy for many years to come.

Section H: Need Assistance?

If you are unsure how these proposals could affect your organisation, or your own long-term plans, take tailored professional advice before making any decisions. The consultation leaves many questions open, and the eventual framework may look very different once draft Rules are published.

Book a fixed-fee telephone consultation to speak with one of our specialist advisers to help prepare and protect your position under both the current system and any future earned settlement model. Early advice will give you clearer options, reduce uncertainty and ensure you are prepared for whatever changes the Government decides to implement.

Section I: FAQs

What is “earned settlement” under the proposals?

Earned settlement is the Home Office’s proposed replacement for the current five-year ILR model. Instead of qualifying automatically after a fixed period of residence, applicants would complete a proposed ten-year baseline and meet new mandatory requirements relating to income, English language, conduct, contribution and financial responsibility. The structure remains at consultation stage, and the final version may differ depending on feedback.

Have the rules changed?

The earned settlement framework is not law. The consultation closed on 12 February 2026 and the Home Office is analysing responses. Existing five-year and ten-year ILR routes remain fully in force. None of the consultation’s proposals or example timelines apply until new Immigration Rules are laid before Parliament and brought into effect.

Will most people now need ten years before applying for ILR?

The consultation proposes a ten-year baseline for most settlement routes, but this is not yet final. The model also includes reductions for high earners and upward adjustments for lower-paid roles or public funds use. The Government is seeking feedback on whether different sectors or circumstances should have tailored timelines.

Can workers still qualify for settlement in five years?

Possibly. In the consultation’s example model, workers earning above £50,270 in taxable income for three consecutive years may qualify for a five-year route through a reduction from the ten-year baseline. All mandatory conditions—including B2 English and financial responsibility—would still apply. The mechanism remains subject to consultation feedback.

Who may qualify for the three-year accelerated route?

The proposed three-year route applies to individuals earning above £125,140 in taxable income for three consecutive years, and potentially to certain Global Talent and Innovator Founder applicants. These are illustrative examples pending confirmation through the consultation process.

What happens if someone claims benefits during the qualifying period?

The Command Paper includes examples where benefit use adds substantial time to the qualifying period: five extra years for less than twelve months of public funds use, and ten extra years for use over twelve months. These are not yet binding rules, but they indicate the Government’s intended direction and the importance placed on economic self-sufficiency.

What happens to the current ten-year long residence route?

The consultation proposes abolishing the stand-alone ten-year long residence ILR route and absorbing its purpose into the new ten-year baseline and time-adjustment model. This is not yet law. Transitional arrangements will be essential for individuals already part-way through a long residence journey. At present, the ten-year long residence route continues to operate under the existing Immigration Rules unless and until formally removed.

Do dependants qualify with the main applicant?

Under the proposals, dependants may be assessed independently, meaning they could qualify earlier, later or not at the same time as the main applicant. This is a major divergence from the current alignment model. The consultation invites views on whether dependants should have identical, lighter or distinct requirements.

Will care workers face longer routes?

Potentially. The consultation suggests a fifteen-year standard qualifying period for sponsored roles below RQF level 6, which includes many Health and Care Worker positions. Benefit use could lengthen this further. These are proposals rather than confirmed rules.

What should employers do now?

Employers should monitor the consultation, review internal HR and compliance systems, identify workers who may be affected by different future models and consider submitting evidence to the Home Office. No immediate procedural changes are required, but early scenario planning will support long-term workforce stability.

Section J: Glossary

Section K: Additional Links