The Home Office has published Statement of Changes HC 1333, laid before Parliament on 14 October 2025. The update delivers a wide package of reforms under the government’s Plan for Change.
For employers, the key measures are the higher English language requirement for key work visa routes, a shorter Graduate route and structural rule changes to refusal and suitability provisions.
The changes come into effect on a staggered timetable, so workforce planning and compliance updates should begin immediately.
Key dates and changes
The visit visa requirement for nationals of Botswana took effect immediately at 15:00 BST on 14 October 2025, alongside the withdrawal of ETA eligibility. Nationals with confirmed travel bookings made before that time have until 25 November 2025 at 15:00 GMT to travel visa-free under a six-week transition period. Most other rule changes take effect from 11 November 2025, with exceptions including 4 November for High Potential Individual route updates, 25 November for student transitions to the Innovator Founder route, 8 January 2026 for the new English language requirement, and 1 January 2027 for the Graduate route reduction.
English language uplift for work routes
From 8 January 2026, the English requirement for Skilled Worker, High Potential Individual and Scale-up routes rises from B1 to B2 under the Common European Framework of Reference for Languages. Applicants will need to demonstrate A-level equivalent English in speaking, listening, reading and writing through a Secure English Language Test from a Home Office-approved provider. The higher threshold applies to new applicants only; those extending permission on the same route remain subject to the previous B1 level. Employers will need to allow more time for testing, update internal processes, and review recruitment materials to reflect the new standard.
Graduate route shortened
From 1 January 2027, the Graduate route stay period will be reduced from two years to 18 months. PhD graduates will continue to receive three years’ permission. The government has linked the change to evidence that too few graduates move into graduate-level work, stating the shorter route is intended to encourage progression into skilled employment. Employers that rely on graduate-to-sponsored conversions will need to bring forward recruitment timelines and sponsorship transitions to avoid losing access to candidates.
High Potential Individual expansion and cap
From 4 November 2025, the High Potential Individual route doubles the number of eligible overseas universities while introducing a cap of 8,000 approvals per year. The expansion provides more scope to attract global graduates, but the new cap means planning and timing applications will become more important for employers recruiting through this route.
Immigration Skills Charge increase
The government has announced a 32 per cent increase to the Immigration Skills Charge as part of the wider Plan for Change. This increase is not contained in HC 1333 but will take effect via separate legislation and commencement. The change is intended to channel additional revenue into domestic training and skills development. For employers, it will add further cost pressures to existing sponsorship and compliance expenses. HR and finance teams should model the potential financial impact across recruitment budgets and headcount planning.
Part 9 replaced by Part Suitability
The long-standing Part 9: Grounds for Refusal has been replaced by a new Part Suitability, simplifying terminology and aligning it with newer immigration routes. Paragraph 39E, which deals with exceptions for overstayers, has been moved under Part Suitability. Appendices covering Family, Private Life and Adult Dependant Relative routes now refer to common suitability provisions rather than bespoke refusal grounds. Employers should note that the change affects the language used in decision notices and internal policy references, though it does not alter substantive sponsor duties.
Seasonal Worker adjustments
Seasonal Worker visa holders can now spend no more than six months in the UK during any rolling ten-month period, a tightening from the previous twelve-month calculation. Sponsors should check workforce planning and re-entry scheduling to ensure compliance with the new limits.
Country and travel measures
Nationals of Botswana are now subject to a visit visa requirement and must hold a Direct Airside Transit Visa for UK transit. Palestine has been added to the visa national list following the UK’s recognition of the state of Palestine, with a corresponding DATV requirement.
Travel rules for German school groups have been eased, allowing students aged 19 and under to travel as part of organised school parties without a visa or ETA, mirroring existing arrangements with France.
Statelessness, Ukraine and student changes
Partners and children of recognised stateless persons can now apply under Appendix Statelessness where they formed part of the family unit before the main applicant’s grant of permission. The Ukraine Permission Extension Scheme has been updated so that children’s permission aligns with that of a legal guardian, alongside other safeguarding refinements. Student rules now permit post-study business activity when switching into the Innovator Founder route. Maintenance levels and accommodation offsets have been updated for the 2025–2026 academic year to reflect the higher cost of living.
Other technical amendments
Global Talent now allows architects to show achievements as part of group work and expands the Prestigious Prizes list. The Tier 1 (Entrepreneur) rules have been deleted, reflecting the route’s closure. The EU Settlement Scheme rules are clarified following earlier amendments to pre-settled status. The list of recognised sports governing bodies has expanded, and updates have been made to Government Authorised Exchange scheme names and Child Student safeguarding provisions.
DMS Perspective
Statement of Changes HC 1333 brings further tightening of the UK immigration framework. The combined effect of higher English standards, shorter post-study permission and additional sponsorship costs means employers will face more planning and administrative pressure in the months ahead. However, while migration access will continue to be selective, it remains possible for those that prepare well and early.
Employers should run an early impact review to understand how these changes affect existing pipelines, budgets and timescales. Recruitment processes and offer documentation will need to reflect the B2 English requirement from January 2026. Graduate recruitment and transition programmes should be restructured around the shorter 18-month stay. Sponsorship budgets should be updated to accommodate the forthcoming ISC increase and associated costs. For those using Seasonal Worker or HPI routes, workforce planning should be reviewed against the new limits and caps.
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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 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.
