Key Spring 2026 UK immigration changes include new duties for employers with sponsor licences

23 April 2026

It’s Spring: time for Snowdrops, Bluebells, bare legs and a swathe of immigration changes for personnel teams to grapple with.

We will first cover changes affecting sponsoring employers. As in recent years, these Spring immigration changes mainly affect employers with licences to sponsor migrant workers, but unlike the last couple of years there are no major curbs on who can be sponsored.

Avoiding enforcement action by UK Visas and Immigration

The backdrop to these changes is a ramping up of enforcement action. The number of UK employers losing sponsor licences tripled at the end of 2025 to 3,100 – the highest since records began. More than 1,500 employers were stripped of their sponsor licence between October and December, up from 541 in the previous three months.

UK Visas and Immigration (UKVI) enforcement has recently focused more on certain sectors such as construction, social care, hospitality and retail. Common issues include underpayment, poor record-keeping and worker exploitation.

UKVI increasingly relies on data-sharing across government systems (including HMRC, PAYE and Companies House) to identify compliance concerns, rather than traditional site visits. As a result, minor breaches, particularly around reporting duties and salary compliance can have serious implications. Errors in pay calculations, such as allowances, deductions or working hours, can be a key trigger for enforcement action. It is essential to ensure compliance, record-keeping and reporting are all accurate, up to date and proactively managed to minimise risk.

Please let us know if you would like us to organise some training on the new measures outlined below or an audit to ensure that your practices are fully complaint with the most up to date sponsor guidance and Immigration Rules.

Scope of right to work expanded for sponsors

An expanded right to work regime is set to come into force following the Border Security, Asylum and Immigration Act 2025. Right to work checks and the large financial penalties they provide protection from are to be broadened from pertaining to employees to encompass employment “and other working arrangements”.  The UK Government’s consultation on the “other working arrangements” that the new right to work code should govern ended in December, with no timeline yet for implementation. We expect all employers will have to comply with a new code later this year when the relevant provisions of the legislation are likely to commence.

In the meantime, the government has updated its guidance for sponsors who are now the first employers to have to adopt an expanded right to work check regime. Employers with a sponsor licence must now check the right to work of any worker they wish to employ or sponsor, including workers who are not a direct employee, whether sponsored or not. As well as employees, this now includes any worker they “directly engage”. What’s more, elsewhere the guidance says that the government can now revoke a business’s sponsor licence where a sponsor is “employing or engaging” a worker (whether sponsored or not) who does not have the right to work, or is working in breach of the conditions of their permission.

We have written to the Home Office for more clarity on this wording. The new sponsorship guidance suggests sponsors should now check the status of all self-employed, zero-hour and directly engaged contractors to protect against the loss of their licence to sponsor workers, but it remains ambiguous.

This is a major change for sponsors. Most will not have been carrying out right to work checks on self-employed workers and will be unaware of their status as it has not been a requirement. Sponsors may want to take legal advice on how best to protect themselves in the light of this new guidance and audit their right to work processes accordingly.

Pay periods to meet salary thresholds for sponsored Skilled Workers

The Immigration Rules on payment of Skilled Workers were also updated this month. To allow UKVI to intervene faster against sponsors suspected of underpaying staff on Skilled Worker visas without needing to make the comparison against a full year of averaged salary receipts, from 8 April 2026 Skilled Worker salary requirements have been changed so that they must now be consistently paid the correct salary within specific pay periods.

Skilled Workers must now be paid the required salary or above for sponsorship in monthly or less frequent pay periods, or as otherwise specified in their contract. Salary must meet the going rate for the occupation code each hour worked during each pay period and the average salary must meet the required minimum amount across any three-month period for monthly or less frequent pay periods, or in any 12-week period in more frequent pay periods (rather than over a year as was previously the case).

If the amount sponsored Skilled Workers are paid differs between pay periods, there are new rules regarding how UKVI will determine salary across a longer working pattern and also how UKVI will consider situations where a person repays their employer for certain immigration costs.

Where a worker is paid the same amount each regular pay period and the total annual amount meets the requirements, this is unlikely to be affected by the new rules.  Examples where this could require changes by sponsors are where the pay amounts or periods are irregular or longer, such as when someone is paid less often than monthly or where pay is weighted differently due to shift working or annual salary being front- or back-loaded in the year (although it is important to note that UKVI does not recognise golden handshakes, parachutes or bonuses as eligible for meeting the salary requirement).  The aim of the rule is to allow UKVI to assess whether a worker is being paid enough more quickly and so they do not need to wait to see if it averages out over a year.

If this applies to any of your sponsored workers, please let us know and we can advise accordingly.

Duty to read sponsor guidance in full

Sponsors are now required to read the sponsor guidance in full including Part 1, 2 and 3, the appendices, the route specific guidance and the glossary, and to remain aware of its contents (i.e. any updates implemented to these documents by UKVI). The relevant guidance documents for Skilled Worker sponsors are included below:

• Workers and Temporary Workers – guidance for sponsors part 1: apply for a licence
• Sponsor a worker: sponsor guidance part 2
• Workers and Temporary Workers: guidance for sponsors part 3: sponsor duties and compliance
• Sponsor a Skilled Worker
• Sponsor guidance appendix A: supporting documents for sponsor applications
• Sponsor guidance appendix B: immigration offences and sponsorship
• Sponsor guidance appendix C: civil penalties and sponsorship
• Sponsor guidance appendix D: keeping records for sponsorship
• Workers and Temporary Workers: guidance for sponsors: glossary

Sponsors with other routes on their licence should make sure to read the route-specific guidance available here.

These documents run to several hundreds of pages, and this is a significant duty to impose on sponsors so we would advise putting the kettle on.

Sponsor guidance changes often and at short notice, so it will be important to remain aware of the contents of these documents and any updates made to them in the future. UKVI expects sponsors’ Level 1 Users to log into the Sponsor Management System at least once a month to review the message board. This should detail the updates sponsors should be aware of and we recommend this check is diarised monthly.

Making workers aware of employment rights

Sponsors have a responsibility to comply with wider UK law, including UK employment law. The guidance has now been updated to specifically require sponsors to ensure their workers understand their employment rights. This includes but is not limited to:

• entitlement to National Minimum Wage
• compliance with Working Time Regulations
• pension auto-enrolment and opt-outs
• entitlement to statutory leave and pay
• health and safety
• trade union memberships
• duties under the Equality Act
• how to raise grievances

Sponsors may want to review employment contracts and documents provided to workers to ensure that they are fully informed of their rights.

Overhaul of asylum seekers’ right to work

Asylum seekers who have waited for over a year for their claim to be decided can request permission from the Home Office to work. Up to 26 March 2026 this had to be employment only in occupations on the UK Immigration Salary List. Eligible asylum seekers are now permitted to work in a role that appears on Appendix Skilled Occupations of the UK Immigration Rules as long as it is RQF skill level 6 or above (i.e. degree level in job skill level, not necessarily academic attainment). This means many more roles are open for to them, though only at the skill level of occupations such as programmers, HR managers, teachers, engineers or vets.

As with the previous situation with jobs on the Immigration Salary List, asylum seekers who have permission would not need to be sponsored by employers, who can avoid all the duties that go with that, including paying the going rate.

Mandatory refusals for 12-month custodial sentences, even if suspended

A 12-month or above custodial sentence is now mandatory grounds for refusal of a visa application or renewal, even if the sentence was suspended. This is the case however long ago the sentence was handed down and wherever in the world sentencing took place. There are no transitional provisions so this may affect those who were already granted permission to work in the UK when it comes to renewing their visa or applying for indefinite leave to remain.

There may be exceptions where a conviction abroad is for something that would not be criminalised in the UK – for example – a criminal sentence for homosexuality or membership of a trade union. It’s worth noting that these types of convictions may not state the actual reason for the conviction. So, a conviction for homosexuality may be presented as a conviction for “obscenity and public disorder” or something equally misleading.

In rare cases, for some applicants, such as those who aren’t subject to a deportation order, there may be arguments for an exception to be made outside UK Immigration Rules. For instance, if there are very strong Article 8 family life human rights grounds. However, such cases are complex and expensive to run.

Paragraph 13.1.1 of Part 13 of the Immigration Rules, which defines who is liable for deportation on the basis of a sentence-threshold conviction, which applies to anyone with a custodial sentence of 12 months or longer has been amended to include anyone with a suspended sentence of the same duration, provided they are convicted on or after 22 March 2026.

Higher English language requirements

The English language requirement for settlement (indefinite leave to remain) in most categories under the Immigration Rules is being increased from CERF B1 to B2. These changes take effect on 26 March 2026. However, the amendments contain transitional provisions which mean that these changes will only affect settlement applications lodged on or after 26 March 2027.

The English language level was recently raised from B1 to B2 for applications made for Skilled Worker, Scale-up Worker and High Potential Individual visas from 8 January 2026 onwards. This includes new applications from those already in the UK and switching into the above work visa routes from other immigration options.

Path to settlement for refugees: shorter grants and active review

Refugees who successfully claim asylum on or after 2 March 2026 will now be granted 30 months of permission instead of five years. This applies to both grants of asylum and Humanitarian Protection. Claims or further submissions lodged before this date will still be eligible for five years. Unaccompanied asylum children are also not affected by these changes.

The changes also introduce “active review” to the Rules, meaning that when the Home Office is considering an application for further leave or settlement/ILR, it will examine whether it is now safe for the applicant to return home.

There are also changes codifying the process of lodging further submissions within the Rules, which takes effect on 8 April 2026. There is also a provision added to allow the Home Office to disclose the fact that an asylum claim had been made where “there is a public interest in doing so”.

Youth Mobility Scheme quotas

Allocated quotas for places on the Youth Mobility Scheme (including the India Young Professionals Scheme) have either stayed the same or slightly increased this month. These are reciprocal cultural exchange agreements that the UK has with several countries which allow people aged 18 to 30 from eligible countries to live and work in the UK without the need for sponsorship for up to two years (though for some nationalities this is now up to three years and up to the age of 35), and in return, for young Brits to live and work in the participating countries. Applicants from Hong Kong, Taiwan and India must first be selected in a ballot.

The quota for each relevant country has been updated for 2026 as follows:

• Andorra – 100 places
• Australia – 38,500 places
• Canada – 10,000 places
• Hong Kong – 1,000 places
• Iceland – 1,000 places
• India – 3,000 places
• Japan – 6,000 places
• Monaco – 1,000 places
• New Zealand – 8,000 places
• Republic of Korea – 5,000 places
• San Marino – 1,000 places
• Taiwan – 1,000 places
• Uruguay – 500 places

Following initial agreements between the UK and the EU in May 2025, negotiations continue on a similar “Youth Experience Scheme” for 18-30 year olds, intended to allow working, studying, and travelling for a limited time, perhaps up to as much as four years. Sticking points in the negotiation include caps on these visas, the cost of the visa applications and the UK’s Immigration Health Surcharge and EU students being charged international student fees in British universities.

Data-led EU Settled Status conversion and curtailment

Since 2025, the Home Office has automatically converted some people with pre-settled status to full settled status without needing a new application, if automated checks are able to establish that they meet the relevant requirements. Where automated checks are not able to confirm this to the required standard, the Home Office has instead been granting five-year extensions of pre-settled status.

On 9 April 2026, the Home Office introduced improvements to the automated system to increase the number of people automatically granted settled status. The system now checks for 30 months of tax and benefit payments in the last 60 months to confirm the continuous UK residence requirement. Some pre-settled status holders cannot be automatically converted to settled status and will still need to apply in the usual way.

The newly expanded automated checks mean that more data allows the Home Office to build a greater view of a person’s residence history in the UK and so, from 9 April 2026, may also lead to curtailment where they have ceased to meet the continuous residence requirement.  Other factors that can lead to curtailment include deception, misrepresentation and fraud as well as public good and conduct tests.

From 9 April 2026, the Home Office will begin removing pre-settled status from individuals who have clearly ceased to maintain continuous residence in the UK. This will not be a fully automated process as there will be a test of proportionality, the Home Office taking into account factors such as someone’s age, vulnerabilities, state of health, ties to the UK, time spent here and integration.

The Home Office will follow a multi-stage process before cancelling pre-settled status due to broken residence:

1. Checks against tax and benefit data to verify a person’s continuous residence in the UK, as well as reviewing any evidence of criminal conduct – where the Home Office can establish eligibility for settled status, the person’s digital status will be converted automatically to settled status.
2. Checks using Home Office travel data to help determine which pre-settled status holders have not maintained continuous residence in the UK.
3. Individuals will be contacted using registered email and telephone details to be asked to provide evidence of their UK residence or reasons for their absence.
4. Status will be curtailed if it is proportionate to do so.

Those who have been outside the UK for the longest will be reviewed first, starting with those who have been outside the UK for the last five years. There will be a right to appeal the decision to cancel pre-settled status.

April 2026 UK immigration fee rises

The Home Office has confirmed new immigration, nationality and passport fee increases from 8 April 2026, with most charges rising by 6-7%.

You can find the full immigration and nationality application fee rises here. Some key examples are:

• Visitor visa (up to six months):  £135 (up from £127)
• Electronic Travel Authorisation (ETA): £20 (up from £16)
• Student visa: £558 (up from £524)
• Skilled Worker visa (up to three years): £943 (up from £885)
• Spouses, partners and children applying for family visas: £2,064 (up from £1,938)
• Indefinite Leave to Remain (Settlement): £3,226 (up from £3,029)
• Naturalisation (Citizenship): £1,709 (up from £1,605)

Other important Spring 2026 immigration changes

Global Talent visa

A new endorsement pathway is set to open on 1 July for Global Talent visas for the design industry. An endorsement body is yet to be announced. Fast-track pathways have been simplified for academics and researchers endorsed by the British Academy, the Royal Academy of Engineering and the Royal Society for PhD-level roles in approved UK higher education or research institutions.

Global Business Mobility – Service Supplier

From March 2026, as per the UK and India’s trade negotiations, there will be an annual allocation of 1,800 spots for Indian nationals for the job roles of traditional chef, classical musician or yoga instructor, running from 1 January to 31 December of each year. The maximum single assignment period will be the difference between the period the applicant has already spent in the UK since their last grant of permission as a Service Supplier, and 12 months (i.e. 12 months at a time).

Global Business Mobility – Secondment worker

From 8 April 2026, applicants applying in this route will need to have worked outside the UK for their overseas employer for a cumulative period of at least six months (down from 12 months) before entering the route.

Seasonal Workers

Applicants for a Seasonal Worker visa must not have been in the UK as a Seasonal Worker in the four months before applying. From this month, the relevant date used as a reference to calculate the period of time spent in the UK will now be the start date, as stated on the Certificate of Sponsorship, instead of the date of the visa application.

Ukraine Scheme extension

The Ukraine Permission Extension scheme has been updated to permit eligible people already in the UK on Ukraine schemes to extend their permission for a further 24 months. Applicants may now apply within 90 days before their permission is due to expire.

Visa brakes

Afghan nationals may no longer lodge Skilled Worker applications from abroad, when applying as a main applicant. Afghan nationals, as well as those of Cameroon, Myanmar and Sudan no longer qualify for entry on a Student visa. How long this temporary “visa brake” is set to last is unknown.

If you have any concerns regarding how the above changes may impact you or your organisation or you would like us to provide training on adhering to sponsorship duties, right to work compliance and/or a compliance health check, please feel free to contact us.

Photograph of UK Parliament by Ming Jun Tan / Unsplash