Statement of Changes to the Immigration Rules: HC 997 (1 July 2025)

Key document

A Statement of Changes to the Immigration Rules (HC 997) was published on 1 July 2025 and can be read here, alongside its accompanying Explanatory Memorandum.

The first change listed below (numbered 1) took effect at 15:00 BST on Tuesday, 1 July 2025.

  1. The closure of the Afghan Relocations and Assistance Policy (‘ARAP’) to new principal applications

The eligibility requirement in ARAP 3.3(a) of Appendix Afghan Relocation and Assistance Policy (ARAP) to the Immigration Rules has been amended, to provide that new principal applications by Afghan Citizens must have been submitted to the Ministry of Defence before 15:00 BST on 1 July 2025, the day the SoC was laid. This means that the relocation route under ARAP closed to principal applications submitted after that time. Applications submitted before that time continue to be processed.

Provided that the application for the principal applicant was submitted prior to 15:00 BST on 1 July 2025, immediate and additional family members of eligible Afghan citizens can still apply after this date. 

Similarly, the Afghan Citizen’s Resettlement Scheme (‘ACRS’) will also be closing, meaning that the Government will not launch further pathways or accept further referrals. However, the Explanatory Memorandum does provide some reassurance at paragraph 5.24, namely that the ‘Home Office will continue to consider those referrals made under the ACRS Separated Families pathway but have not yet received a decision. This Government will honour our commitments to anyone found eligible, and to those who have already been found eligible for the ACRS but are not yet in the UK.’

ILPA is deeply disappointed with the news of the closure of these two safe routes for Afghans, with such short notice, and in breach of the 21-day rule. The reason provided in the Explanatory Memorandum, at paragraph 9.6, is to ‘prevent a spike in last minute applications and mitigate against an increase to the backlog of outstanding applications that need to be considered for eligibility by the MOD’. We are writing to Ministers to express our concerns.

Members may also wish to note that the two-stage process for ARAP applications has been clarified in the Introduction to Appendix ARAP. In the introductory wording ‘Where an applicant is eligible for relocation to the UK, the ARAP leads to a grant of settlement in the UK’ has been changed to ‘Where an applicant satisfies the requirements for entry clearance or settlement under Appendix ARAP, they will be granted settlement in the UK.’

The rest of the below changes to work routes take effect on Tuesday, 22 July 2025. However, where an application is made using a Certificate of Sponsorship (‘CoS’) that was issued prior to 22 July 2025, or, where a CoS is not required for an application and the application is made before that date, the application will be decided in accordance with the Immigration Rules in force on 21 July 2025.

Overall, members should note the focus on employer’s compliance in the Explanatory Memorandum, with suggestions being made that some of the changes (relating to the Immigration Salary List and adult social care) could be reviewed if non-compliance and exploitation occurs in future.

  1. Changes to Immigration Rules Appendix Skilled Worker (‘Appendix Skilled Worker’) and other work routes

Skill level 

As indicated in the recent White Paper, the skill level required for a Skilled Workers’ role will increase from Regulated Qualifications Framework (‘RQF’) level 3 to RQF level 6, which the Explanatory Memorandum states ‘will mean a reduction of around 180 eligible occupations’. Transitional provisions will apply to these changes and are discussed below.

In order to implement the change in skill level, Immigration Rules Appendix Skilled Occupations will be split into different tables, separating out occupations at RQF Level 6 and above (tables 1, 2 and 3) from occupations at RQF levels 3-5 (tables 1a, 2aa and 3a). The other tables will remain, with some corrections being made to the salary rates in Scotland in Table 4 and some amendments to the introductory paragraphs.

In order to meet the skill requirement, individuals will need to be sponsored for an occupation that comes within any of the following (see APP SW7 of the SoC which replaces the skill level requirement at paragraphs SW 6.1 to SW 6.1C of Appendix Skilled Worker):

  • the RQF level 6 occupation in tables 1, 2 and 3;
  • the Immigration Salary List or the new Temporary Shortage List;
  • The tables for RQF levels 3-5, namely tables 1a, 2aa or 3a, if:
    • ‘the applicant was granted permission as a Skilled Worker under the rules in place before 22 July 2025, and they have had continuous permission as a Skilled Worker since then (except that where paragraph 39E applies, that period of overstaying will be disregarded)’; or
    • Is relying on salary points under options F to J and meets the requirements of SW 4.2(b)(ii) (‘the date of application is before 4 April 2030, they were granted permission as a Skilled Worker under the rules in place before 4 April 2024, and they have had continuous permission as a Skilled Worker since then (except that where paragraph 39E applies, that period of overstaying will be disregarded). 

Therefore, those granted on the basis of a CoS issued on or before 21 July 2025 can continue to renew, change employment and take supplementary employment, in occupations below RQF level 6. Accompanying amendments have been made to the definition of supplementary employment in the introduction to the Immigration Rules to reflect this. Members should note that a warning is given in paragraph 5.5 of the Explanatory Memorandum that the transitional provisions will be reviewed in due course. 

  • Within Table 2a, where the individual is awarded points under options F to J, meets the requirements of SW 4.2(b)(ii) and is applying to stay with the same sponsor as the most recent permission. 

Although ILPA welcomes transitional provisions being introduced, the SoC does create significant complexity for individuals and sponsors alike, who will be required to navigate through a multitude of salary options and tables to assess if an occupation code and salary meet the requirements of Appendix Skilled Worker.

Additionally, SOC 2020 occupation codes in Tables 1a, 2aa, 2a, 2b and 3a are also not eligible for Global Business Mobility or Scaleup routes, except as otherwise indicated, as confirmed in APP SO8 of the SoC. 

However for Government Authorised Exchanges, the eligible roles are wider as they must appear in Tables 1, 1a, 2, 2aa, 3 or 3a of Appendix Skilled Occupations.

Salary increases – multiple work routes

Salary requirements will be updated for Skilled Workers, as well as the Global Business Mobility and Scale-up routes. The Explanatory Memorandum at paragraph 5.3 describes these as ‘routine’ and to ‘make the remainder of the standard update to general salary thresholds and going rates for individual occupations’. 

For Skilled Workers, this includes that the salary requirements under options A to G are increasing. These are set out at APP SW2 to APP SW6 of the SoC:

  • Option A is increasing to £41,700 per year;
  • Option B (for a relevant PhD) is increasing to £37,500 per year;
  • Option C (PhD in relevant STEM subject), Option D (Immigration Salary List), and Option E (new entrant) are increasing to £33,400 per year;
  • Option F is increasing to £31,300 per year; and 
  • Option G (for a relevant PhD where the transitional provisions in SW 4.2(b) applies) is increasing to £28,200 per year.

The hourly rate is also increasing to £17.13 per hour, up from 15.88 per hour and in all cases, the salary will still need to equal or exceed the relevant going rate requirement.

No further transitional provisions apply to the salary increases and the Migration Advisory Commission (‘MAC’) will be commissioned to undertake a review of the salary requirements, including the available discounts. The salary requirements for settlement for Skilled Workers have been updated accordingly, as can be seen at SoC APP SW15 to APP SW19.

There are also general salary requirement changes for Global Business Mobility and Scale-up routes:

  • Senior or Specialist Workers will be increased to £52,500 per year;
  • Graduate Trainee will be increased to £27,300 per year;
  • UK Expansion Worker will be increased to £52,500 per year;
  • Scale-up Worker will be increased to £39,100 per year.

The Immigration Salary List and a new Temporary Shortage List – Skilled Workers

While this SoC does not yet go as far as replacing the Immigration Salary List, it does introduce an additional, new list, the ‘Temporary Shortage List’. While the replacement will eventually occur, the interim measure is that both lists will be in operation, as follows:

  • The Immigration Salary List will be expanded and will include some occupations below RQF6 identified to be in shortage by the MAC in their 2023 review and 2024 rapid review (see APP ISL1 in the SoC). The occupations on the list have a removal date of 31 December 2026, except for 6135 Care workers and home carers and 6136 Senior care workers which have a removal date of 22 July 2028.
  • An interim Temporary Shortage List, which will be added as SW 6.1A of Appendix Skilled Worker, will contain occupations at RQF levels 3-5 which were identified as important for the UK’s Modern Industrial Strategy. These codes are time-limited. They will only be included on the list where an application is made using a CoS issued before 31 December 2026.

Changes have also been made to restrict the ability for individuals to apply as dependants of Skilled Workers where the Skilled Worker’s role is not RQF level 6. 

In relation to partners, the exceptions to this are if they are the dependant of a Care Worker or Senior Care Worker granted under Rules in force before 11 March 2024 or a Skilled Worker sponsored for a role in a SOC 2020 occupation code (other than care or senior care workers)  listed in the Tables for RQF Level 3-5 and granted under Rules in force before 22 July 2025. In both cases, the Skilled Worker must have been continuously resident since their grant (except that where paragraph 39E applies, that period of overstaying will be disregarded). To effect this change, the SoC introduces a new SW 29.1A into Appendix Skilled Worker in relation to partners of Skilled Workers.

The provisions for children contain almost identical restrictions, plus additional exemptions for  dependent children who were born in the UK; where the Skilled Worker has sole parental responsibility or is a sole surviving parent; or where both parents are Skilled Workers and certain conditions are met. The full details are set out in APP SW21 of the SoC (which introduces the new SW 32A.2).

In both the Immigration Salary List and the Temporary Shortage List, the end dates are subject to change. The Explanatory Memorandum, at paragraph 5.9 states that the Government ‘reserves the right to bring that date forward if compliance issues present on these lists’.

The future contents, terms and conditions of the Temporary Shortage List, will be subject to review by the MAC. As per the White Paper, the Explanatory Memorandum repeats at paragraph 5.9 that, ‘[o]ccupations will only be included or retained on the list where the MAC has advised it is justified, where there is a workforce strategy in place, and where employers seeking to recruit from abroad are committed to playing their part in increasing recruitment from the domestic workforce.’

  1. Changes in relation to adult social care

The SoC puts into effect the Home Office’s intention to close entry clearance applications for Skilled Workers sponsored under occupation codes 6135 and 6136, namely ‘care workers and home carers’ and ‘senior care workers’, by requiring, in SW 6.1B that applications for these codes must be ‘for permission to stay’. In addition, for these codes, one of the following criteria must be met:

  1. ‘(i) The applicant must have been legally working for the sponsor in one of these SOC 2020 occupation codes for at least the three months ending on the date the certificate of sponsorship was issued by the sponsor to the applicant; and (ii) the date of the application must be before 22 July 2028’. This reflects a transitional period for switching from other routes until 22 July 2028 and the transitional provisions will be kept under review, according to the Explanatory Memorandum at paragraph 5.14. Occupation codes 6135 and 6136 are included on the Immigration Salary List until the same date, namely 22 July 2028.
  1. ‘the applicant must have permission as a Skilled Worker, sponsored in either of these SOC 2020 occupations codes (or the SOC 2010 occupation codes “6145 Care workers  and home carers” or “6146 Senior care workers”) (except that where paragraph 39E  applies, that period of overstaying will be disregarded).’ 

Given the above changes, the current care recruitment requirements (regarding first recruiting from the pool of Skilled Workers seeking new sponsorship) contained in SW 6.1B and SW 6.1C are being removed. ILPA’s members reported problems with the operation of those requirements in practice.  

Due to concerns of the occupation code ‘6131 Nursing auxiliaries and assistants’ being misused in light of these changes, a clarification on the code will be added in the relevant tables to confirm it ‘only applies to roles in environments where registered nurse roles also exist.’

  1. Other notable changes

Additional changes include:

  • Part 9 of the Immigration Rules, paragraph 9.30.1 currently states that an individual in specific routes, including the Skilled Worker route, ‘who has been absent from work without pay, or on reduced pay, for more than 4 weeks during any calendar year may have their permission cancelled’, unless the absence is for certain permitted reasons. The Statement of Changes adds neonatal care to the list of permitted reasons.
  • As above, the tables for roles below RQF level 6 have been added to the eligible occupations for Immigration Rules Appendix Temporary Work – Government Authorised Exchange, which is reflected in the definition of the scheme in the introduction to the Immigration Rules, alongside additional changes to that definition:

““Government Authorised Exchange Scheme” means a scheme under the Government Authorised Exchange route which is endorsed by a Government Department in support of Government objectives, and provides temporary supernumerary work in an occupation which appears in Tables 1, 1a, 2, 2aa, 3 or 3a of Appendix Skilled Occupations.”

At paragraphs 5.26 – 5.27 of the Explanatory Memorandum, it is stated that minor changes have been made to align drafting across the Immigration Rules and minor drafting changes to correct paragraph references and minor drafting errors.