Lack of information surrounding immigration policy change sparks criticism from House of Lords Committee

On 1 July 2025, the Home Office published its Statement of Changes to the Immigration Rules: HC 997 (The “Statement”), which outlines and explains the proposed changes to the Immigration Rules required to achieve government objectives and policy changes stated in government white papers. The Statement introduces two significant policy shifts: tightening the conditions for Skilled Worker visas, and terminating three Afghan Assistance schemes.

However, the House of Lords Secondary Legislation Scrutiny Committee, whose role is to scrutinise and examine the merits of statutory instruments and other types of secondary legislation, has criticised the Home Office for publishing such consequential changes without adequate supporting information or an Impact Assessment.

Notable changes

Skilled Worker visas

A Skilled Worker visa allows UK-based employers to sponsor and bring in workers from overseas. There are certain criteria required for a role to be eligible for sponsorship,which includes the skill level (measured by Regulated Qualifications Framework or “RQF”), salary, and the SOC code.

The main proposed changes to the Skilled Worker visa application are:

• Increasing the minimum skill level for sponsorship from  RQF 3 to RQF 6.
• Introducing routine increases of the salary threshold for Skilled Workers.
• Removing adult social care sector roles from the list of eligible occupations.
• Introducing interim measures while the Immigration Salary List is being replaced with a Temporary Shortage List, providing for time-limited inclusion of roles with recruitment challenges.

These changes were initially announced in the Immigration white paper published on 12 May 2025, and the Home Office argues that implementing these changes will positively contribute towards the achievement of the government’s objectives.

According to the Home Office, increasing the RFQ level will help curb the high number of dependants accompanying visa holders to the UK, while the removal of adult social care role from the list of eligible occupations will help reduce exploitation of workers. The Home Office claims that care worker visas are “widely associated with worker exploitation”, partially due to unscrupulous overseas recruitment agents. Furthermore, it asserts that exploitation is “mainly seen in roles below RFQ level 6”. Notably, the RQF requirement was dropped from level 6 to level 3 in 2020 – coinciding with a rise in the number of concerns raised about exploitation of overseas workers.

Afghan Assistance schemes

Following the Taliban’s return to power in 2021, the UK began offering several resettlement schemes to Afghans who had supported the UK government in Afghanistan in various capacities, be that by working in “exposed or meaningful roles”, or by promoting values such as democracy, women’s rights, freedom of speech and the rule of law.

The main proposed changes to the Afghans assistance schemes:

• Closure of the Afghans Relocations and Assistance Policy (ARAP).
• Closure of the Afghan Citizen Resettlement Scheme (ACRS).
• Closure of the Afghan Response Route (ARR).

The government argues that these schemes were “never intended to operate indefinitely”.

Criticism from House of Lords Committee

Throughout the report, the Committee challenged the basis of the policy changes, repeatedly highlighting the lack of sufficient analysis or data to justify such changes.

A major concern voiced by the Committee is the absence of an Impact Assessment. The Home Office stated in response that changes to the Skilled Worker visa will have an indirect impact on organisations’ ability to recruit, which the Committee has since disagreed with, arguing that the potential impact is likely to be significant, especially considering the wide range of sectors affected. The lack of an Impact Assessment, however, meant that it was not possible for the Committee to appropriately scruitinise the policies.

The Home Office has since agreed to publish an Impact Assessment as soon as possible, and admitted that failure to produce one beforehand should not become common practice. It cited “some complexities in finalising the relevant information” for the delay, which led the Committee to express further concerns that the measures may have been formed before the consequences were fully understood, and that a throrough investigation may provide results that undermine the rationale for the changes.

The Committee has provided the Home Office with an deadline of 1^st September – the day Parliament returns form summer recess – to provide a full Impact Assessment to analyse the likely consequences of the new immigration policies.

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