Employment Law Digest November 2025: Rising costs and stricter rules: A guide to the Latest UK immigration changes for employers

3rd November, 2025

The changes are plentiful and significant, reflecting the Government’s ongoing aim of creating a selective immigration system designed to ultimately reduce UK net migration figures.

Most notably, the changes include the implementation of stricter English language requirements for economic migration routes, a reduction of duration of stay under the Graduate route, and changes to both the High Potential Individual (“HPI“) and Innovator Founder visa.

What has changed?

English language requirement

For initial Skilled Worker, HPI and Scale-up visa applications made on or after 8 January 2026, stricter English language requirements will apply as the requirement increases from B1 (intermediate) to B2 (upper-intermediate). Individuals must therefore demonstrate an A-level equivalent standard in speaking, listening, reading and writing English before they are eligible to be granted a visa under these routes. As it stands, there will be no increase to those seeking an extension on the same routes.

This change to the required proficiency is an example of a further barrier to be overcome by those seeking permission to enter the UK or stay in the UK under a new visa type, which places tougher financial and administrative burdens on applicants in preparing for the B2 test.

Duration of the Graduate visa

Effective from 1 January 2026, the duration of stay under newly granted Graduate visas will reduce from 2 years to 18 months. This is a significant adjustment which the Home Office says has been implemented as a result of too many graduates failing to move into graduate-level roles on completion of their degree at a UK education provider. The change will not affect those currently on a Graduate visa.

It is thought that in shortening the duration of the stay, this will enable a swifter transition into graduate-level jobs. However it is needless to say that this change will cause a number of problems for employers and individuals alike. For example by reducing the candidate pool not requiring visa sponsorship and increasing the pressure on both parties to secure an alternative right to work.

Targeted expansion of the HPI visa

Amendments have been made to the HPI route to better align the scheme with the Government’s objective to attract top global talent. The new rules introduce an annual cap of 8,000 visas per year that will be granted under this route. At the same time, the rules have doubled the list of institutions whose graduates are eligible to apply. Previously limited to the top 50, from 4 November 2025 this list will increase to the top 100 universities worldwide (subject to any exemptions based on national security or foreign policy grounds).

Whilst the expansion broadens the potential pool of international talent from leading institutions, the cap ensures that the programme remains competitive and focused.

Innovator Founder

From 25 November 2025, the new rules will enable Student visa holders who have completed their studies to switch within the UK to the Innovator Founder visa. This has been brought about by an amendment to the Student visa work conditions, which permits self-employment where the Student has applied for permission on the Innovator Founder route.

This change addresses a significant gap left by the previous closure of the Start-up visa route to new applicants, making the Innovator Founder visa the primary entrepreneurial visa option for international talent seeking to launch innovative businesses in the UK. This encourages innovation and investment to the UK economy and is a change that will be welcomed by students who will be able to pursue business ventures without the cost and disruption of having to leave the UK and apply from overseas.

Increase to Immigration Skills Charge (ISC) and priority fees

In further news, we have firstly seen an update in respect of the Home Office’s promise to increase the ISC by 32%. The ISC is payable by employers sponsoring migrants on a Skilled Worker visa and while the increase will be the first since 2017, the effect on businesses who rely on overseas recruitment will be substantial.

This increase will take effect for Certificates of Sponsorship assigned on and after 16 December 2025 and means that a medium/large employer will pay £1,320 to sponsor a worker for one year and a small/charitable sponsor will pay £480.

Secondly and with no warning, on 21 October 2025, the Home Office increased the pre-licence priority fee payable for expediting a sponsor licence application from £500 to £750 as well as the post-licence priority fee to fast-track certain applications from £200 to £350. This is a particularly interesting change given that the post-licence priority service continues to be oversubscribed with it taking many weeks to be allocated a priority slot at present.

What does this mean and how can employers prepare?

The Home Office’s Statement of Changes represents a significant step towards reshaping the UK’s immigration landscape in line with a vision of a more selective system. As has been set out, businesses will need to navigate stricter eligibility criteria, evolving visa conditions and a more expensive sponsorship process. Now is an excellent time to review workforce strategy and recruitment plans. The 32% hike in the ISC must be taken into account when cost planning for the year ahead. To avoid the price increase, it is a good idea to consider bringing forward any sponsored visa renewals and new recruitment to assign the CoS before 16 December 2025.

An additional approach worthwhile considering would be to switch staff currently on Student visas to the Skilled worker route as opposed to the soon to be reduced duration Graduate visa. A key benefit to this is that sponsors are exempt from paying the ISC, and will not be subject to the time-limited restraints associated with the Graduate visa.

With regards the changes to the Graduate visa, it will be necessary to review whether current recruitment plans are still viable, noting common graduate cycles and seasonal peaks.

As always, we encourage you to stay informed and proactive to change to enable continued access to the ever increasingly competitive global market and to contact a member of our Immigration Team for further support.