UK Immigration 2025: Essential Updates for Employers

In our most recent and timely webinar held on 7 May 2025, the immigration law experts here at Clarkslegal LLP provided employers with a critical update on recent and upcoming changes to UK immigration policies and laws. The session, led by Senior Associate, Ruth Karimatsenga, and Trainee Solicitor, Monica Mastropasqua, addressed key legal developments, compliance obligations, and strategic recommendations for businesses navigating a fast-evolving immigration landscape.

Key Changes Impact on Employers

1. Sponsorship Licence Reforms

Effective 31 December 2024, new rules mandate that all organisations applying for a sponsorship licence must nominate a Level 1 user who is both a settled worker and an internal employee, director, or partner. Legal representatives are explicitly excluded from this role at the application stage.

2. Prohibition on Recouping Costs

From the same date, employers are prohibited from recovering certain sponsorship-related costs from employees. These include:

• Sponsor Licence Fees
• Immigration Skills Charge
• Certificate of Sponsorship (CoS) Fees

Prior to this announcement the Home Office guidance did not make clear what costs could be recouped by Sponsors.

3. Fee Increases

Significant fee hikes came into effect on 9 April 2025, with increases ranging from £8.50 to £286 across various visa and sponsorship categories. While premium services remain largely unchanged, the financial impact on employers and skilled workers is considerable.

Immigration Route-Specific Developments

• Ukraine Scheme

Changes effective 4 February 2025 now allow Ukrainians with valid status under the scheme to extend their stay by 18 months. Employers should also note that as of 9 April, the minimum salary for care workers under this route rose to £25,000.

• Skilled Worker Route (Care Workers only)

To combat exploitation, employers are now required to prioritise recruitment from the domestic pool of care workers before hiring from overseas.

• EU Settlement Scheme (EUSS)

Updates to the EUSS now allow expired biometric residence cards (valid up to 18 months) to serve as proof of identity and work rights.

• Electronic Travel Authorisation (ETA)

New ETA requirements apply to EU/EEA/Swiss nationals from 2 April 2025, with earlier implementation for other countries such as the US and Canada beginning 8 January 2025.

• Trinidad and Tobago Visa Requirements

As of 12 March 2025, nationals of Trinidad and Tobago require a visa to enter the UK.

Future Legal and Compliance Obligations

1. E-Visa Account Maintenance- By 1 June 2025, all UKVI e-visa account holders must meet newly introduced maintenance requirements. Non-compliance could result in penalties up to £1,000 and visa-related restrictions.
2.  Right to Work Checks for Flexible Labour – From 30 March 2025, businesses using gig or zero-hour workers must treat such workers as full-time employees and perform right to work checks. Failure to comply may result in civil penalties of up to £60,000 per illegal worker.
3.  Child Student Visa Rules – Effective 29 May 2025, stricter care and guardianship requirements will apply to Child Student visa applicants. Criminal offences by nominated guardians can now be grounds for visa refusal.

Practical Guidance for Employers

To avoid incurring onerous civil penalties and breaching immigration laws, we suggest employer must periodically:

• Review Contracts and Clawback Agreements: Ensure employment contracts and cost recovery terms comply with the new rules.
• Implement Training and Mock Audits: HR teams must stay current with changes and conduct internal audits to ensure ongoing compliance.
• Adjust Financial Planning: Budget for increased sponsorship costs and assess tax implications of benefits-in-kind.

The Home Office has framed these reforms as a necessary step toward building a more robust and equitable immigration system. One of the primary objectives is to strengthen protections for migrant workers, ensuring they are not subjected to exploitation, particularly in vulnerable sectors such as social care. Alongside this, the changes are designed to enhance overall compliance with immigration rules, reinforcing the system’s long-term viability and integrity.

Ultimately, the government seeks to strike a careful balance, meeting the UK’s evolving economic demands while upholding political accountability and maintaining a fair and controlled immigration framework.

If your business needs tailored guidance on navigating these changes, our immigration lawyers are here to help. Please feel free to contact Ruth Karimatsenga via email at ruth.karimatsenga@clarkslegal.com  or Monica Mastropasqua at monica.mastropasqua@clarkslegal.com. We are here to help you every step of the way.