The Migration Advisory Committee (MAC) has published its Stage 1 report on the Temporary Shortage List (TSL).
Stage 1 sets out the proposed framework for how the TSL should work and lists 82 RQF 3–5 occupations that the MAC believes are potentially crucial to the Industrial Strategy or critical infrastructure. These roles will move to Stage 2 for a Call for Evidence.
The final Stage 2 report is due in July 2026 and will recommend which of those occupations should sit on the TSL.
MAC Stage 1 TSL Review
Since July 2025, the Skilled Worker route has been restricted to roles at RQF 6 or higher. The TSL provides a limited, time-bound route for certain mid-skilled (RQF 3–5) roles to access sponsorship where there is clear evidence of strategic importance or shortage.
The Immigration Salary List (ISL) and the interim TSL are expected to end on 31 December 2026. After that date, RQF 3–5 access will depend entirely on which roles are included on the permanent TSL. Dependants for new applicants in RQF 3–5 occupations have already been ruled out under the current Immigration Rules.
Following the July 2025 rule changes that introduced the Temporary Shortage List, the Home Office formally commissioned the MAC to conduct a two-stage review into its design, scope and eligible occupations. The aim was to determine which RQF 3–5 occupations should continue to have access to the immigration system on a time-limited basis and under what conditions.
Stage 1 of the MAC review, published yesterday on 9 October 2025, sets out the proposed structure of the TSL and identifies a provisional list of 82 occupations considered potentially vital to delivering the UK’s Industrial Strategy or maintaining critical infrastructure. These roles now move forward to Stage 2, which will involve a formal Call for Evidence from employers, industry bodies and other stakeholders.
The MAC’s final Stage 2 report, due in July 2026, will make recommendations on which occupations should be formally added to the TSL and how the scheme should operate in practice — including visa length, salary thresholds, and sector-specific conditions.
The MAC recommends:
- A default TSL occupation duration of three years, with an option for a shorter initial period of around 18 months if the Jobs Plan lacks sufficient detail.
- Visa durations between three and five years, with no renewals beyond five years if the TSL is not intended to lead to settlement. The report supports in-country switching to higher-skilled (RQF 6+) roles to encourage career progression.
- English language requirements of at least B1.
- No specific recommendation on settlement, sponsorship models, fees, or caps, but guidance to the Home Office to prioritise simplicity, flexibility, and continued exploration of alternative sponsorship approaches for roles at risk of abuse.
- No salary discounts or new entrant discount. Salary thresholds for TSL roles should be at least equivalent to Skilled Worker levels, and fees should align with Skilled Worker, including the Immigration Skills Charge.
The Stage 1 report lists 82 SOC 2020 occupations for Stage 2. These include health and care-related roles such as SOC 3111 (laboratory technicians) and SOC 3213 (medical and dental technicians). Notably, SOC 6131 (nursing auxiliaries and assistants) and SOC 3212 (pharmaceutical technicians) are not included. The full list is available in the report’s Table 2.2 and Annex A.
DMS Perspective
With the Temporary Shortage List now in force, employers should be taking a strategic, forward-looking approach to how they use and plan around the route. The MAC’s Stage 1 report provides important clarity on how the list will operate and what the government expects from employers in return for continued access to mid-skilled immigration. The message is clear: the TSL is not a long-term substitute for workforce planning but a short-term mechanism to support sectors while domestic capability is developed.
Effective workforce planning starts with visibility. Employers should map all RQF 3–5 roles within their organisation against the MAC’s Stage 1 list and the current Immigration Salary List to identify where access to overseas recruitment may end after 31 December 2026. Recruitment cycles need to align with the three- to five-year visa duration, ensuring business continuity when permissions expire. Employers should also focus on progression — creating pathways that allow sponsored workers to move into higher-skilled, RQF 6+ positions under the Skilled Worker route.
Financial planning will be critical over the coming months. Employers should budget for Skilled Worker-aligned salary levels, fees and charges, as no new entrant or regional discounts apply under the TSL. This includes factoring in the Immigration Skills Charge and Health Surcharge at full rate. Organisations that plan early for these costs will be better positioned to manage pay parity issues and sustain compliance without disrupting pay structures.
Compliance and policy alignment are equally vital. Internal processes should be updated to reflect the B1 English requirement and the exclusion of dependants for new TSL applications. The sponsorship framework currently mirrors Skilled Worker, but the MAC has urged the Home Office to explore simplified or alternative models for roles at higher risk of exploitation. Employers should stay alert to further developments and be ready to adapt their procedures. The possible reintroduction of a Resident Labour Market Test remains under consideration but has not been confirmed.
The focus now shifts to Stage 2 of the MAC review. This will test whether each occupation is genuinely in shortage and supported by a credible Jobs Plan. Employers should work closely with sector bodies to provide data on vacancies, training investment, retention, and domestic recruitment outcomes. Evidence showing proactive engagement with the Department for Work and Pensions and steps to prevent worker exploitation will carry weight. Submissions grounded in real workforce data will help shape which occupations stay on the list.
Over the next year, preparation will make the difference. Employers should conduct a TSL exposure audit, identify critical mid-skilled roles, and assess how many will lose eligibility once the interim arrangements close. They should also begin adjusting pay models to reflect TSL thresholds and strengthen domestic recruitment pipelines. The Call for Evidence in early 2026 will be the opportunity to influence outcomes — employers that can demonstrate genuine shortage and tangible workforce planning will be best placed to retain migration access.
In the longer term, the TSL represents a shift towards a more targeted and accountable approach to migration. It links immigration access to industrial priorities and domestic skills strategies rather than ongoing dependence on overseas labour. Employers that invest early in training, workforce resilience, and evidence-based Jobs Plans will be more competitive, compliant, and ready for the post-2026 immigration landscape.
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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.
