8 January 2026: Higher English Language Threshold
From 8 January 2026, the English language threshold for first time applicants under Skilled Worker, Scale up and High Potential Individual is expected to increase from B1 to B2. Transitional treatment generally turns on the date the application is submitted, so late submission can shift a candidate from one requirement to another, even where the role and the offer have not changed.
Recruitment timelines are likely to lengthen where candidates rely on a Secure English Language Test booking, re sits or late evidence collation. Offer management becomes more fragile where start dates are fixed around training cohorts, project mobilisation or client delivery. Candidate experience can also deteriorate quickly when the requirement is treated as a last minute hurdle rather than a planned part of the hiring journey.
English readiness checks should move earlier in recruitment, ideally before final interviews for roles where sponsorship is the default. Hiring managers and recruiters should work to an internal deadline for when English evidence needs to be in place, and the business should plan for the possibility of one re sit when setting start dates. Where volume hiring is involved, central tracking of test status across candidates is usually more reliable than relying on individual updates and emails.
Offer documentation should reflect that the start date is dependent on immigration submission timing and evidence readiness. Onboarding planning should allow for slippage where a candidate is still working towards B2 and the organisation is aiming to submit close to the commencement date. HR teams also benefit from a short internal checklist that covers English evidence, identity documents and any dependants, because dependants often trigger late requests for additional documentation.
12 February 2026: Earned Settlement Consultation Closes
The government consultation closes in February 2026, after which more definitive plans are expected.
Under initial proposals to reform UK indefinite leave to remain through a new earned settlement programme, long term residence is being framed less as a predictable time based step and more as something connected to meeting ongoing requirements, including higher English and earnings related expectations.
Sponsored workers often plan careers and family decisions around settlement timelines. Any shift that makes settlement feel further away, more conditional or more dependent on pay progression increases churn risk, particularly in competitive sectors. Employers can also see more internal pressure for accelerated promotions or salary changes that are framed as immigration driven rather than performance driven, which can create inconsistency and internal equity issues if governance is not clear.
Even where sponsorship arrangements are stable, settlement applications tend to pull in detailed evidence of employment continuity, salary history and role details. Employers that change job titles frequently, move people between group entities or restructure teams should plan for a higher administrative burden and more frequent requests for confirmation letters and payroll evidence in formats UKVI accepts.
Employers should map sponsored cohorts by likely settlement horizon, pay progression and planned internal moves. The aim is not to predict the final rules, it is to identify where workforce planning is most sensitive to settlement becoming harder to reach. That mapping also helps leadership make pay and progression decisions with visibility of potential immigration consequences.
25 February 2026: ETA Full Enforcement
From late February 2026, Electronic Travel Authorisation (ETA) affects most visa-free travellers coming to the UK. The key point for employers is that enforcement happens at boarding and check in, because carriers check permission before travel. A traveller who needs an ETA and does not have one is likely to be denied boarding.
Short notice business travel is the main risk area, including client meetings, group onboarding, internal training and candidates travelling for interviews. Travel disruption can cascade into missed project milestones, delayed starts and reputational damage with clients, particularly where the organisation has promised attendance or delivery dates.
ETA checks should be built into travel booking workflows. If travel is arranged centrally, the travel function should hold responsibility for confirming ETA status before tickets are issued. If travel is booked by individuals, the organisation should provide clear written instructions and a simple ownership model that identifies who confirms eligibility, who pays and what happens if travel is denied.
Recruitment teams should avoid assuming that a candidate can fly at short notice for a final interview. Where the organisation wants in person interviews for overseas candidates, scheduling should allow time for ETA steps and any identity verification delays. Remote interview alternatives should be in place as a fallback, particularly for senior hires where time pressure is highest.
Spring 2026: Likely Window for Settlement Rule Changes
April is often used for Immigration Rules changes, but employers should avoid planning around a single assumed go live date for settlement reforms. The more useful approach is to plan for the operational effects if settlement becomes more closely linked to English and earnings over a period of time, because those effects tend to land on HR and reward structures before the legal detail feels settled.
If settlement outcomes become more sensitive to earnings patterns, annual pay review timing becomes more than a compensation issue. Organisations that run pay reviews later in the year should consider how they would respond if sponsored populations face pressure for earlier progression. Without a plan, managers can make inconsistent decisions that create internal comparisons and legal risk in the employment context.
Where internal mobility is frequent, HR should treat continuity of role evidence as a planning factor. Role changes, title changes and entity transfers can be perfectly legitimate, but they often create evidence gaps and confusion later if documentation and payroll records are not aligned. Strong internal documentation standards reduce the risk of late stage evidence scrambling.
Employers benefit from a controlled communications approach. Sponsored workers will ask about settlement implications, and informal answers from managers can undermine trust if they later prove inaccurate. A short internal briefing note and a clear escalation route to HR or legal helps keep messaging consistent and reduces unnecessary anxiety.
Mid 2026: MAC Reports
MAC activity in 2026 matters because it influences which roles remain viable for sponsorship, and under what conditions, beyond the current interim position. For employers relying on roles near the boundary of eligibility, engagement with evidence exercises can be commercially significant.
Submissions are most valuable where the organisation relies on roles that are only workable with sponsored hiring, or where domestic recruitment pipelines exist but cannot meet demand at the required speed or quality. The strongest employer evidence is specific, data driven and operationally grounded, rather than relying on general statements about labour shortages.
Useful evidence normally covers vacancy rates, time to hire, wage movement, regional recruitment challenges, training and apprenticeship pipelines and what fails operationally when roles cannot be filled. Where possible, it also explains how the organisation has tried to recruit domestically and what constraints remain, because that is the lens through which policy makers assess employer reliance on sponsorship.
MAC timelines can act as internal decision triggers. If you rely on interim eligibility positions, treat evidence deadlines and report milestones as points to review your workforce plan, rather than waiting for a formal Immigration Rules change. That approach reduces the risk of being forced into rushed role redesign or emergency salary recalibration later.
End of 2026: End of Skilled Worker Transitional Arrangements
The end of 2026 is being used as a policy horizon for interim arrangements that followed 2025 changes to work route eligibility and shortage related lists. Employers should treat late 2026 as a planning deadline for any workforce segment that depends on transitional eligibility or list based concessions.
If eligibility tightens again, responding is not quick. Role redesign, salary band changes, recruitment model changes and internal approvals can take months even before any immigration work begins. Organisations that wait for published rule text often discover that internal change runs slower than the immigration timeline.
Stress testing should focus on functions that rely on medium skilled roles, regional hiring challenges and roles where salary norms sit close to relevant thresholds. Consider what you would do if sponsorship stopped being available for a subset of roles and what alternative resourcing plan would deliver the same output without undermining service levels.
Contingency plans work best when they are operational rather than theoretical. Identify which roles could be redesigned, which roles could move to different locations, where training pipelines could expand and what pay changes are commercially viable. Build a decision framework that can be executed quickly if policy tightens.
Employer Action Plan for 2026
Employers can reduce disruption in 2026 by tightening process discipline and planning for the direction of travel rather than waiting for final rule text. The steps below prioritise changes that reduce risk quickly and improve predictability across recruitment, travel and retention.
1. Recruitment Implications – January 2026
Update recruitment checklists so English capability is checked early for routes affected by the B2 threshold. Set internal deadlines for evidence readiness and application submission, and build realistic start date assumptions into offers, particularly where candidates are testing close to the commencement date.
2. Travel Implications – February 2026
Embed ETA checks into travel booking and candidate travel instructions. Assign ownership clearly, and ensure teams understand that enforcement is likely to happen at boarding. Treat ETA status as a gating item, alongside passport validity and travel approvals.
3. Retention Planning through 2026
Map sponsored cohorts against settlement horizons, pay progression and planned internal moves. Put governance around immigration related pay pressure so managers do not make inconsistent decisions. Prepare a controlled internal briefing for sponsored workers so messaging stays consistent and realistic as policy develops.
4. Workforce Planning against the end of 2026 horizon
Identify any workforce segment that relies on interim eligibility positions and treat the end of 2026 as a planning deadline. Develop operational contingencies that are executable, including job redesign options, training pipeline expansion and salary band adjustments that the business can sustain.
DMS Perspective
Employers often treat immigration changes as a legal update that sits with HR or in house counsel, but the risks are operational. Small changes in entry requirements, travel permissions and long term residence policy can hit hiring timelines, inflate cost per hire and increase churn among sponsored workers. The organisations that cope best do not wait for a refusal or a delayed start date to expose the weakness. They tighten recruitment readiness, build predictable evidence trails and treat retention planning as part of immigration governance.
For example, consultation headlines often create a false sense of distance, as if the business can wait for final rules. Sponsored workers don’t operate like that. When settlement starts to look more conditional, salary linked or harder to reach, workers respond early. They look for employers with faster progression, cleaner role continuity and clearer internal support. That creates two employer risks. First, churn increases among the very people you invested in. Second, managers start making inconsistent pay and promotion decisions framed as immigration driven, which can create internal equity issues and employee relations risk. A controlled retention strategy, aligned to sponsorship and progression governance, is usually the difference between stability and reactive firefighting.
Remember also that when routes tighten, scrutiny rises. Employers can expect to see more pressure around evidence quality, genuine vacancy assessment and consistent record keeping, particularly where the organisation is hiring at volume or relying on roles that UKVI views as borderline. The avoidable mistakes are nearly always the same. Late changes to job details after sponsorship decisions, mismatched job descriptions versus actual duties, weak evidence trails for salary and work location and internal stakeholders treating the sponsorship process as administrative rather than regulated. A tighter internal control framework reduces both the refusal risk and the risk of sponsor compliance action.
Need Assistance?
If you are recruiting internationally in 2026, or you are trying to retain sponsored workers through policy change, early advice saves the most time and cost. DavidsonMorris can advise on sponsorship strategy, role and salary planning, application risk management, evidence preparation and practical retention planning for foreign national workers where routes are tightening and scrutiny is increasing.
If you would like to discuss an application, a recruitment plan or a retention strategy, you can book a fixed-fee telephone consultation.
