The Temporary Shortage List (TSL) is being introduced under reforms announced in the Government’s May 2025 Immigration White Paper. It will replace the Immigration Salary List.
The TSL will apply to occupations requiring RQF Level 3–5 skills, and is designed to provide time-limited access to the Skilled Worker route only where there is clear evidence of persistent shortages and a commitment to reducing reliance on overseas workers.
While specific details are yet to be published, the following guide sets out what we know to date.
What is the Temporary Shortage List?
The TSL is billed by the government as a new, dynamic list aimed at addressing immediate labour shortages in specific occupations, particularly those below the RQF Level 6 (sub-degree level). It is designed to be more responsive to the UK’s evolving labour market needs and will be reviewed regularly to ensure it reflects current shortages.
Unlike the former Immigration Salary List, which allowed salary discounts, the TSL will offer only time-limited access to the Skilled Worker route and will operate under stricter conditions.
Key features of the TSL are to include:
Targeted occupations
The TSL will focus on roles that are essential to the UK’s industrial strategy or critical infrastructure, such as certain construction jobs.
Time-limited inclusion
Occupations will be included on the TSL for a limited period, providing temporary relief to sectors facing acute shortages.
Conditional access
Employers seeking to sponsor workers for roles on the TSL must demonstrate active efforts to recruit and train domestic workers, including presenting credible workforce development plans.
Restrictions on dependants
Some roles on the TSL may come with limitations, such as restrictions on bringing family members to the UK.
How will the TSL work?
While full details are yet to be published, we know from the White Paper that the government intends for the TSL to be a flexible, dynamic tool for managing short-term labour shortages in specific occupations. The TSL will apply only to occupations requiring RQF Level 3–5 skills i.e. below degree level. For these roles, access to the Skilled Worker visa route will only be allowed on a temporary, conditional basis.
To be eligible for inclusion on the TSL, a role must meet several criteria. First, the Migration Advisory Committee (MAC) must advise that there is a genuine labour shortage. Second, the sector must have a credible workforce strategy in place which demonstrates efforts to maximise use of the UK workforce through domestic recruitment, training plans and cooperation with organisations such as Skills England and the Department for Work and Pensions. It must also address worker protection, particularly for migrant workers, and be ambitious in its scope.
The MAC will assess these workforce strategies and provide recommendations to the Home Secretary, including visa conditions such as caps, time limits and restrictions on bringing dependants. Access will be temporary and regularly reviewed.
The Labour Market Enforcement (LME) Group will be playing a role in reviewing occupations at RQF Level 6 and above. If over-reliance on international workers is identified in these roles, the LME may recommend that the sector develop a workforce strategy. Over time, the MAC could restrict visa access to these roles if insufficient progress is made.
When will the Temporary Shortage List take effect?
The MAC is expected to provide recommendations on the TSL and revised salary thresholds in autumn 2025. Following this, legislative changes and updates to the Immigration Rules are expected to be enacted, with the first changes anticipated before January 2026.
Until this framework is fully operational, the TSL will temporarily include roles recently identified by the MAC as being in shortage or those considered essential to the UK’s industrial strategy and critical infrastructure.
What will the Temporary Shortage List mean for sponsors?
The introduction of the Temporary Shortage List will impact UK sponsors and employers seeking to recruit overseas workers into sub-degree level roles (RQF Level 3–5). Under the new system, these roles will only be eligible for Skilled Worker visa sponsorship if they are included on the TSL. Significantly, inclusion will be temporary, conditional and more tightly controlled than under the previous Immigration Salary List.
Employers will also no longer benefit from salary threshold discounts. All Skilled Worker sponsorship will require the full minimum salary to be paid, even for shortage roles. This will represent a cost increase for many employers, especially those in traditionally lower-paying sectors.
Access to the TSL will depend on whether the sector has a credible workforce strategy, approved by the MAC. Employers will need to demonstrate their role in supporting domestic recruitment and skills development, including working with Skills England, relevant sector bodies and the Department for Work and Pensions. Employers should therefore begin gathering evidence of UK-based recruitment efforts, apprenticeships, training investment and fair working conditions.
The MAC will review these workforce strategies when advising the Home Secretary on which roles should be added to the TSL, and may recommend additional conditions such as visa caps, time limits, and restrictions on dependants.
To prepare, sponsors should:
- Review their current and projected use of RQF Level 3–5 sponsorship
- Engage with industry bodies to shape and align with sector workforce strategies
- Strengthen recruitment and retention plans for UK workers
- Audit salaries and job descriptions to ensure compliance with the standard thresholds
- Plan for disruption, as occupations may be removed from the TSL with limited notice
DM Perspective
While the new Temporary Shortage List is being positioned as a more “flexible” alternative to the outgoing Immigration Salary List, in practice, employers should read that as less predictable, more conditional and harder to rely on.
The government claims the TSL will allow sectors to respond dynamically to labour shortages but the reality is that “temporary” equals uncertainty. For employers, this makes long-term workforce planning precarious. Roles can be removed from the list at short notice, meaning a job that is eligible for sponsorship today could be taken off tomorrow, obligating employers to react so as not to fall foul of their compliance obligations.
Fundamentally, what is concerning is that eligibility for the TSL hinges on political and bureaucratic criteria, not just market demand. It includes the need for sector-wide workforce strategies, skills plans and cooperation with Skills England and the Department for Work and Pensions. That’s a tall order for sectors already struggling with recruitment. It also means small and mid-sized sponsors will be at the mercy of how well their industry bodies perform, rather than their own track record or demand.
There is no doubt the TSL will give ministers greater control over immigration optics, but it comes at the cost of certainty and autonomy for UK sponsors. Employers will be forced to invest more in domestic hiring, upskilling and internal mobility. Of course, these are all positive outcomes, but this will only be achievable if adequately supported. Without meaningful training infrastructure and incentives, the TSL risks being less a temporary fix and more a moving target.
For now, sponsors are advised to watch the MAC’s implementation closely, reassess salary benchmarks and build resilience into recruitment strategies.
Need assistance?
The introduction of the Temporary Shortage List will impact workforce strategies, but with careful planning and preparation, employers will be nest equipped to navigate this latest change in the visa sponsorship regime. For expert guidance on how to lead your organisation through these changes, contact us.
Temporary Shortage List FAQs
What is the Temporary Shortage List?
The Temporary Shortage List is a new mechanism introduced by the UK Government to allow time-limited access to the Skilled Worker route for certain sub-degree level roles (RQF 3–5) where there is evidence of persistent labour shortages.
How does the TSL differ from the Immigration Salary List?
Unlike the previous Immigration Salary List, the TSL will not allow any salary discounts. Instead, it will provide temporary access to the immigration system for shortage roles, subject to conditions such as workforce strategies and MAC approval.
Which roles can be included on the TSL?
Only occupations below RQF Level 6 will be eligible. A role must be essential to the UK’s industrial strategy or critical infrastructure, and inclusion will depend on advice from the Migration Advisory Committee (MAC).
What is a workforce strategy and why is it important?
A workforce strategy outlines how a sector plans to reduce reliance on migrant workers by investing in UK-based recruitment and training. A credible strategy is a key requirement for a role to be considered for the TSL.
Will employers need to do anything differently?
Employers will need to demonstrate active participation in domestic workforce development, provide evidence of recruitment efforts in the UK, and comply with full salary thresholds. They may also face visa caps or restrictions on dependants.
Can roles be removed from the TSL?
Inclusion on the TSL is temporary, and roles can be removed at short notice if shortages are addressed or if the workforce strategy is not being implemented effectively.
When will the TSL be implemented?
The full framework is expected to be introduced in stages, with interim measures in place based on existing MAC shortage recommendations. The first formal changes are anticipated before January 2026.
Glossary
| Term | Definition |
|---|---|
| Temporary Shortage List (TSL) | A new list introduced by the UK Government to allow time-limited access to the Skilled Worker visa route for sub-degree level roles facing genuine labour shortages. |
| Immigration Salary List (ISL) | The former shortage occupation list under which sponsors could benefit from salary discounts; replaced by the TSL under the 2025 White Paper reforms. |
| RQF Level | The Regulated Qualifications Framework level indicating the skill level of a role. RQF Level 3–5 refers to qualifications below degree level. |
| Skilled Worker visa | The main UK work visa route for sponsored employment. Roles must meet minimum salary and skill thresholds to qualify. |
| Migration Advisory Committee (MAC) | An independent body that advises the UK Government on immigration matters, including which roles should be included on the TSL. |
| Workforce strategy | A sector-led plan to reduce reliance on migrant labour by investing in training, recruitment, and retention of the domestic workforce. |
| Skills England | A UK body responsible for coordinating national skills development and workforce planning, involved in assessing workforce strategies for the TSL. |
| Labour Market Enforcement (LME) Group | A government-linked body responsible for monitoring labour market practices and advising on over-reliance on international workers. |
| Department for Work and Pensions (DWP) | The UK government department responsible for welfare and employment, expected to collaborate with sectors on domestic labour plans linked to TSL inclusion. |
| Dependent restrictions | Limits placed on sponsored workers from bringing family members with them to the UK, potentially applied to TSL roles. |
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
