Impacts of the changes to the UK immigration policy - NHS Employers

Increased salary thresholds will apply to both new applications and to extensions to existing visas.

When assessing salary thresholds, employers who recoup business costs, immigration costs or business investments (such as visa fees) via repayment clauses (i.e. which are guaranteed and not conditional) will need to count this against the salary stated on their Certificate of Sponsorship. If this takes the salary below the relevant eligibility requirements, then the individual will not be able to apply for a visa.

Those already on a Skilled Worker Visa before 4 April 2024 are exempt from the £41,700 salary threshold (and standard going rates) when they change occupation or sponsor, or settle. Generally, they will have to meet at least £31,300. However, they will be required to meet the lower salary threshold (and lower going rate) for their role (and their pay should progress in line with resident workers).

The Migration Advisory Committee (MAC) have been commissioned to review salary thresholds.

Actions for employers Identify staff that are impacted by changes to skill and salary threshold and open clear communication about what the changes mean for them.

Review roles on the Immigration Salary List and Temporary Shortage Lists. If RQF 3-5 level roles do not appear, they will no longer be eligible for sponsorship and domestic workforce strategies will need to be in place.

If recruiting to RQF 3-5 roles that do appear on the Immigration Salary List or Temporary Shortage List, have clear communication on what it means for them such as restrictions on dependants. The Migration Advisory Committee (MAC) will review the lists over the next year and domestic workforce strategies will need to be in place to justify continued inclusion.

The Immigration Health Surcharge has increased to £1,035 per person per year for those required to pay, such as skilled workers and their dependants. There is a lower surcharge of £776 per year for applicants under age 18. All Health and Care Visa holders will continue to be exempt from paying the Immigrational Health Surcharge (IHS). Some roles are also eligible for a reimbursement.

Certificate of Sponsorships and Visas costs

From 9 April 2025, Certificate of Sponsorship fees increased from £239 to £525, and immigration and visa fees increased by 7 per cent. Certificate of sponsorship costs should be paid by the sponsor and not passed on to the individual. The new fees will apply to new visa applications and renewals for all working visas, including Skilled Worker Visa and Health and Care Visa.

The Immigration Salary List (ISL) will be phased out but remain in place until December 2026 and occupations on the ISL can be recruited to below the general salary threshold. These occupations will still need to meet a threshold of the higher of either their occupation-specific threshold or:

£25,000 (for Health and Care Visas)

£33,400 (for general Skilled Worker visas applicants after April 2024)

£25,000 (for general Skilled Worker visas applicants before April 2024).

The following Health and Care Visa roles now appear on the expanded ISL:

SOC 1232 – residential, day and domiciliary care managers and proprietors

SOC 3111 – laboratory technicians – only jobs requiring 3 or more years’ related on-the-job experience

SOC 3212 – pharmaceutical technicians

SOC 6131 – nursing auxiliaries and assistants (only applies to roles in environments where registered nurse or other registered health care professional roles also exist*). *Updated wording coming into effect on 11 November 2025.

Care workers (SOC 6135) and senior care workers (SOC 6136) both appear on the ISL however, new visa applications are closed and in-country switching applications will only remain open until 22 July 2028, with this kept under review.

A full list of the ISL if available on GOV.UK.

Interim Temporary Shortage List

In the interim, a time-limited Temporary Salary List (TSL) will sit alongside an ISL. This will enable international recruitment only where occupations are key to industrial strategy or building crucial infrastructure.

Laboratory technicians (SOC 3111) are the only Health and Care Visa occupation that appear on the TSL, regardless of years of experience.

The MAC has been commissioned to conduct a review of the TSL including occupations, salaries and benefits. Occupations on the TSL will not be permitted salary and visa fee discounts. The occupations included on the TSL are time-limited until the end of 2026 and will only remain beyond that date if the independent MAC recommend it.

The Migration Advisory Committee (MAC) will review the lists over the next year and domestic workforce strategies will need to be in place to justify continued inclusion. The MAC have published the Stage 1 report on its review of the Temporary Shortage List (TSL). The Stage 2 consultation is now open. The MAC is seeking further evidence in a call for evidence (CfE) on the occupations that passed stage 1 to identify which it will recommend adding to the TSL. For the health and care sector, this includes: SOC 3111 – laboratory technicians

SOC 3123 – medical and dental technicians Learn more about the stage 2 consultation and more information on our website.

A full list of TSL is available on GOV.UK.

Health and Care Visa roles removed from the Skilled Worker route

Six roles previously eligible under the Health and Care Visa no longer meet the skills threshold and are not on either the ISL or TSL. Therefore, they will no longer be eligible for sponsorship and domestic workforce strategies will need to be in place. A transition period applies, where skilled workers can continue to be sponsored in RQF 3-5 level occupations if they are already in the route (have a visa or have a Certificate of Sponsorship issued) before 22 July 2025, even where an occupation is not on the Immigration Salary List or the interim Temporary Shortage List. The roles are:

SOC 1231 – healthcare practice managers

SOC 3211 – dispensing opticians

SOC 3213 – medical and dental technicians

SOC 3219 – health associate professions n.e.c

SOC 6132 – ambulance staff (excluding paramedics)

Workers sponsored in occupations on either the TSL or the ISL at RQF levels 3-5 will not be able to bring dependants. This does not apply to occupations at RQF 6 or above, or workers sponsored in occupations at RQF levels 3-5 who are already in the skilled worker route and able to bring dependants before these changes come into effect.

The minimum income requirement for family visas increased to £29,000 from 11 April 2024. MAC published the results of their commission into reviewing this threshold, and did not recommend a specific threshold but did suggest a range between £24,000-£28,000. The government have not yet formally responded.

Immigration White Paper In May 2025, the government published the immigration white paper that outlined changes to the UK immigration system to prioritise "control, contribution, and community cohesion". Changes will impact the whole immigration system including illegal and legal migration routes of work, study, and family. For more details of the impact of the changes in the Immigration White Paper please see our latest news. Further changes to be implemented by the end of this year also include: unveiling a new family policy framework to Parliament

streamlining Skilled Worker Visa applications and processes through technological advancements in eVisas and eGates

changes to refugee employment, allowing a limited pool of United Nations High Commissioner for Refugees (UNHCR) refugees to access the Skilled Worker route if they have the skills to do so. More information can be found on the GOV.UK website.

Below is a description of how these changes will impact various international staff across the NHS and social care. All scenarios are based on the Agenda for Change pay scales 2025/26, which are subject to annual review.

The Home Office intends to continue updating going rates each April based on the latest available salary data. Employers should bear in mind that the current going rates may increase for future applications.

Applies to those on a Health and Care Visa (such as nurses, doctors, allied health professionals, etc).

The Health and Care Visa is a sub-type of the Skilled Worker Visa. During the application process, candidates will be asked if they are applying for a Health and Care Visa and will need to select ‘yes’.

Only CQC-registered providers in England will be able to sponsor care workers or senior care workers.

The cost of a Certificate of Sponsorship is £525 and applies to both new work visas and renewals. The fee should be paid by the sponsor and not passed on to the individual.

Salary threshold – national pay scale roles: the minimum salary threshold is £25,000 for occupations on national pay scales where applicable. This will apply to both new applications and to extensions to existing visas.

Salary threshold – not on national pay scale roles: the general salary threshold is £31,300 for occupation not on national pay scales (such as biomedical scientists) or their occupation specific threshold, whichever is higher. This will apply to both new applications and to extensions to existing visas.

Salary threshold – assessments: employers who recoup business costs, immigration costs or business investments (such as visa fees) via repayment clauses (i.e. which are guaranteed and not conditional) will need to count this against the salary stated on their Certificate of Sponsorship. If this takes the salary below the relevant eligibility requirements, then the individual will not be able to apply for a visa.

Immigration Salary List: for Health and Care Visa occupations on the ISL, the salary threshold is set at either £25,000 or their occupation-specific threshold, whichever is higher.

Temporary Shortage List: Laboratory technicians (SOC 3111) are the only Health and Care Visa occupation that appear on the TSL, regardless of years of experience. These roles do not have a salary threshold reduction and therefore will meet to meet £33,400 or their occupation-specific threshold, whichever is higher.

Immigration Health Surcharge: current and new visa holders will continue to be exempt from the IHS.

Immigration Skills Charge increase: For applications on or after 16 December 2025, the Immigrations Skills Charge will increase by 32 per cent to £1,320 per person per year.

Dependants: Health and Care Visa holders can still bring dependants to the UK as part of their visa (except new applicants who hold roles below degree level). Dependants have a general right to work meaning that they can be employed by the NHS, in another sector or not work.

Individuals who are in the UK on any other route, including where that route permits dependants, who switch into a below graduate level role after 22 July 2025, will not be able to stay with (or bring over) dependants. This applies to those switching from a Graduate Visa to a Health and Care Visa.

Regional partnerships: the requirement for sponsors to first try to recruit from the pool of skilled workers seeking new sponsorship has been removed before sponsoring new recruits for visas. Providers are still encouraged to engage with regional partnerships to employ displaced workers.

To prevent the occupation SOC 6131 (nursing auxiliaries and assistants) being misused, a clarification is being added to confirm this occupation code only applies to roles in environments where registered nurse and other registered health and care professional roles also exist.*

*Updated wording coming into effect on 11 November 2025