How UK businesses can prepare for sponsoring migrant workers in the financial year 2025-26

As we enter the financial year 2025-26, UK businesses that sponsor migrant workers must be prepared for a changing immigration landscape. Recent changes to the Immigration Rules, implemented in April 2025, bring important considerations for employers who rely on overseas talent to meet their workforce needs.

We understand that navigating immigration compliance can be complex and time sensitive. Below, we outline the key updates and offer practical guidance to help your business remain compliant, competitive, and well-prepared for the year ahead.

Key immigration changes from April 2025

Minimum salary threshold

One of the most significant updates is the increase to the minimum salary threshold for certain employees, such as Care Workers, roles on the Immigration Salary List and new entrants under the Skilled Worker route. The general salary floor has risen from £23,000 to £25,000 per year. So, be sure to account for this increase when calculating your recruitment budget for this upcoming financial year.

Payments to employers

Another change concerns payments made by employees to their employers (usually, in the form of investments or loans). These payments will be subtracted from the employee’s salary when determining whether they meet the salary threshold, unless the payment is not related to business costs, immigration costs or investment, but is rather a genuine benefit for employees, such as a salary sacrifice arrangement. This change is intended to prevent abuse of the system, specifically where applicants previously contributed funds towards their own salaries via investments in their sponsor’s business.

New Entrants

Additionally, the rules around “new entrants” — typically younger workers or recent graduates — have been clarified. While new entrants still benefit from a reduced salary threshold, this now stands at £30,960 per year. Previously, applicants could receive a salary reduction when they were training towards a recognised professional qualification; however, there was no restriction on where the qualification could be obtained. The UK government has now introduced stricter requirements, and the salary reduction only applies to UK-based professional development qualifications. This requirement further emphasises the importance of providing genuine training pathways for developing talent, rather than using the designation to simply reduce salary costs.

Employers must review their current sponsorship strategies to ensure they align with these revised criteria, particularly when budgeting for international recruitment.

Strengthening sponsor licence compliance

Beyond salary requirements, the Home Office continues to place increased emphasis on sponsor compliance. For licence holders, the responsibility extends well beyond issuing Certificates of Sponsorship (CoS). Ensuring full adherence to immigration obligations is essential to avoiding penalties or potential revocation of your sponsor licence.

Here are some proactive steps businesses need take:

1. Conduct comprehensive right-to-work checks
   • Before any employment commences, employers must verify an individual’s right to work in the UK.
   • This includes:
     • Using the Home Office’s online checking tools
     • Maintaining clear and dated records of checks
     • Scheduling follow-up checks for employees with time-limited permissions
     • Failure to carry out these checks correctly can lead to civil penalties and reputational damage.
2. Maintain robust record-keeping practices
   • Documentation lies at the heart of immigration compliance.
   • Employers should:
     • Retain copies of key documents, such as passports, visas or biometric residence permitsTrack visa expiry dates and renewals
     • Maintain records of absences, job roles, salaries, and work locations
   • Consistency and accuracy in record-keeping are essential, particularly in preparation for potential audits by the UK Visas and Immigration (UKVI).
3. Train your HR and recruitment teams
   • Your HR and recruitment departments are your first line of defence in compliance.
   • Equip them with regular training so they understand:
     • What constitutes a valid right-to-work check
     • The implications of non-compliance
     • How to document decisions and maintain internal records
     • A well-informed team can drastically reduce the risk of accidental breaches.

Preparing for digital compliance checks

The Home Office increasingly conducts digital compliance reviews, often with limited notice. To prepare:

• Audit your HR systems: Ensure that your recruitment, onboarding and ongoing employee monitoring systems are aligned with sponsor duties.
• Review all CoS records: Justify each certificate with clear documentation of the role, salary and necessity.
• Document everything: From interview notes to contract updates and internal training records.

Strategic planning for international recruitment

With immigration becoming increasingly policy-driven and scrutinised, businesses should approach international recruitment strategically. This means forecasting workforce needs, budgeting appropriately for sponsorship costs, and ensuring that any recruitment aligns with genuine business requirements.

By preparing early and aligning your internal processes with the latest immigration rules, your business can avoid disruption, manage risk, and continue to benefit from global talent.

At Gherson, we are ready to assist employers with all aspects of UK immigration compliance—from sponsor licence applications to ongoing audits and legal advice. Please get in touch with our Business Immigration team to ensure your operations remain compliant and your international recruitment strategy is future proof.

Updated: 16 April 2025

How Gherson can assist

Gherson’s Immigration Team are highly experienced in advising on UK visa matters. If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail, or, alternatively, follow us on X, Facebook, Instagram, or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2025

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