The 2025 Immigration White Paper: A Turning Point in UK Immigration Policy

On 12 May 2025, the UK Government unveiled its Immigration White Paper titled “Restoring Control Over the Immigration System”, outlining the most substantial proposed changes to immigration law since the post-Brexit overhaul. The paper is framed around the government’s objective to substantially reduce net migration, improve domestic skills supply, and increase public confidence in the immigration system. However, many of the proposals signal a restrictive shift that will likely reshape employer sponsorship, migrant settlement, and human rights-based immigration routes.

This article provides a comprehensive breakdown of the White Paper’s proposals and their implications for businesses, individuals, and legal advisers.

1. Skilled Worker Route: Raising the Bar

The Skilled Worker visa route, which replaced Tier 2 (General), is central to the UK’s points-based immigration system. The 2025 White Paper proposes key changes designed to limit eligibility and prioritise only “exceptionally skilled” migrants.

Proposed Changes:

• Increased Salary Threshold: To complement the revised skills threshold, the Government has also implemented a new salary framework. From April 2024, the general salary threshold for most Skilled Worker roles was raised to £38,700 per year, up from £26,200 previously.
• Educational Requirement: Only applicants holding a graduate-level qualification or above will be eligible— the minimum skill level for sponsored roles under the Skilled Worker route will be restored from RQF Level 3 (broadly A-level equivalent) to RQF Level 6, which corresponds to degree-level occupation
• Suspension of the Shortage Occupation List (SOL): The SOL, which permits lower salary thresholds for in-demand roles, will be temporarily suspended for review, reducing employer flexibility. In place of the ISL, the Migration Advisory Committee (MAC) will undertake a comprehensive review of the new salary requirements, including any exemptions or reduced thresholds for newly qualified workers, public sector roles, or specific regions
• Abolition of the Resident Labour Market Test (RLMT): Although aimed at reducing administrative burden, this will be replaced by an obligation to demonstrate genuine recruitment efforts within the domestic labour market.

Implications for Employers:

These reforms will severely limit recruitment options in sectors reliant on mid-skilled, non-graduate labour—including construction, hospitality, and logistics. Employers will need to reassess workforce planning and may see increased costs related to salary uplift and compliance. 

2. Health and Care Visa: Tighter Restrictions on Overseas Recruitment 

Perhaps the most contentious proposal is the restriction on international recruitment within the care sector.

Proposed Changes:

• End of Care Worker Visa: No new visas will be issued for overseas care workers or senior care workers after a transition period ending in 2028.
• Revised Sponsorship Criteria: Employers will be required to demonstrate that they have first attempted to recruit from the existing migrant and settled worker pool before offering roles to overseas applicants.
• Enhanced Oversight: Increased scrutiny and audit requirements will be placed on care providers to prevent abuse of the visa system and labour standards.

Implications for the Sector:

The social care sector—already grappling with chronic understaffing—is likely to be disproportionately affected. Employers should begin investing in domestic workforce strategies and explore alternative routes for staffing, such as apprenticeships and government training schemes.

3. Graduate and Post-Study Work Visas: A Rebalancing Act

The Graduate visa route, introduced in 2021, allowed international students to remain in the UK for two years after completing their studies to work or look for work. This route will now face curtailment.

Proposed Changes:

• Duration Reduction: Graduate visa validity will be reduced from two years to 18 months.
• Tightening Eligibility: Applicants may be required to demonstrate they are working in a graduate-level role within six months of visa grant.

Legal Consideration:

While intended to prevent perceived “abuse” of the route, the changes may harm the UK’s attractiveness to international students—a key economic and soft-power asset. Education institutions and legal advisers must prepare for additional student queries and appeals. These measures reflect the Government’s broader goal of reasserting the academic purpose of the student visa system and reducing secondary migration flows linked to post-study work. Outcomes of the Graduate Route review are expected by the end of 2025

4. Settlement and Citizenship: Extended Pathways

Perhaps the most dramatic reform lies in changes to the long-residence route and Indefinite Leave to Remain (ILR). This new framework is designed to recalibrate the conditions under which migrants can obtain indefinite leave to remain (ILR) and subsequently British citizenship by placing a far greater emphasis on long-term contribution, integration and civic participation.

Proposed Changes:

• Extended Residency Requirement: Most migrants will now need to reside in the UK for ten years (rather than five) before being eligible for ILR, unless on specific fast-track routes.
• While the ten-year threshold will become the default, the White Paper confirms that certain categories will retain accelerated pathways to settlement, including:
• Dependants of British citizens, particularly spouses and children, under the family route.
• Refugees and those granted humanitarian protection, where shorter routes to ILR are enshrined in domestic and international law.
• Vulnerable migrants, including victims of domestic abuse and trafficking, for whom longer residence requirements would be inappropriate or disproportionate.
• Tightened Good Character Tests: The Home Office will expand the list of minor criminal or civil offences (including some immigration breaches) that may lead to ineligibility.

The White Paper signals a review of the Life in the UK test, which is currently a mandatory requirement for both ILR and naturalisation. While the Government continues to support the principle of testing knowledge of British values, institutions and history, there is widespread recognition that the current test is outdated, overly focused on obscure facts, and does not adequately assess civic understanding or integration.

Implications for Migrants:

The extended route to settlement may discourage long-term integration and reduce incentives for migrants to remain in the UK. Employers sponsoring workers on multi-year contracts must consider long-term staff retention strategies.

5. Human Rights & Asylum Reform: Limiting Article 8 Claims

The White Paper proposes significant reform to the UK’s interpretation of Article 8 of the European Convention on Human Rights (right to respect for private and family life).

Proposed Changes:

• Statutory Constraints on Article 8: Courts and tribunals will be directed to give greater weight to the public interest in immigration control and less to private life arguments.
• Revised ‘Insurmountable Obstacles’ Threshold: Claimants will need to meet a stricter threshold to establish that family separation is not feasible.
• Fast-Track Appeals for Asylum Refusals: Procedural changes to reduce delays in removing failed asylum seekers.

Legal Implications:

This could lead to an increase in litigation over compatibility with the Human Rights Act and international obligations. Legal professionals must prepare for a higher volume of judicial reviews and complex family-based applications

6. Family Migration and Dependants.

The White Paper outlines a far-reaching reform of the family migration system, aimed at reducing net migration, increasing public confidence, and embedding clearer expectations around integration, contribution and self-sufficiency. While the core framework for family migration under Appendix FM   will remain in place, the eligibility criteria for joining family members in the UK – whether as a spouse, unmarried partner or dependant – will be significantly tightened.

One of the most impactful changes is the proposed increase to the minimum income requirement for sponsoring a partner under the five-year family route. As of April 2024, this threshold was raised to £29,000 (up from the previous level of £18,600). The White Paper confirms the Government’s intention to raise the threshold further in stages, with the figure set to reach £38,700 by early 2026. This amount is aligned with the average earnings of full-time workers in the UK and is designed to reflect the minimum level of financial self-sufficiency required to support a family without recourse to public funds. The revised threshold will apply both to British citizens and settled persons sponsoring a partner, and to skilled workers seeking to sponsor dependents.

In parallel, the White Paper sets out a graduated English language requirement for all adult dependents, including those accompanying workers, students, or family route sponsors. The current requirement of A1 level English at entry will be replaced with a more structured,

Advice for Employers:

Clarkslegal strongly recommends that sponsors undertake internal audits, refresh compliance manuals, and retrain HR staff to meet new expectations under the proposed regime.

Conclusion: Planning Ahead

The 2025 Immigration White Paper marks a deliberate pivot towards a more restrictive, skills-focused and domestically prioritised immigration system. While the stated objective is to reduce net migration and promote British workers, many of the proposals raise significant concerns around labour shortages, legal proportionality, and economic competitiveness.

How Clarkslegal LLP Can Help

We support employers and individuals in navigating the complexities of immigration law. Whether you require advice on Skilled Worker sponsorship, challenging visa refusals, or preparing for the incoming reforms, our experienced team is here to assist.

Contact us today to discuss how these proposed changes may affect your business or immigration status.