New Rules for Skilled Worker Sponsorship – Care Sector Focus

The Government confirmed its intention to reduce net migration and tighten Right to Work enforcement in its May 2025 Immigration White Paper. Major reforms to the sponsorship regime swiftly followed in July 2025, alongside stricter Sponsor Licence compliance scrutiny, increased documentation checks, and sector-specific compliance reviews. With over 136,000 Sponsor Licence holders in the UK, over 85% of which are in the Skilled Worker category, these reforms are going to be felt widely by UK employers. In particular, the care sector now has to deal with the most significant change in its staffing strategies in several years: the complete closure of sponsorship for frontline care staff.

New Sponsorship Rules

The main changes introduced from 22 July 2025 include:

• Minimum salary thresholds were increased across all sponsorship types. The salary required for a standard Skilled Worker was increased to £41,700 (up from £38,700) and significant uplifts to going rate (SOC Code) salaries. For care workers, the minimum salary increased to £25,000 per annum.

• Increasing the skills threshold: only roles at RQF Level 6 (graduate level) or above are now eligible for full Skilled Worker sponsorship. Roughly 180 job types were removed from the list of eligible occupations.

• Jobs at skill levels RQF 3-5 (from A Level) can only be sponsored if the job is listed on either the Immigration Salary List (ISL) (aka the former Shortage Occupation List) or the new Temporary Shortage List (TSL).

• The TSL is time limited to December 2026. Whilst sponsorship can be issued beyond that date, if the job is removed from the TSL the worker will not be able to extend in the same role after that date. The Migration Advisory Committee is reviewing the current TSL in preparation for 2026 changes.

• Those being sponsored on the TSL cannot have dependants, even if they are switching from Graduate into Skilled Worker and already have dependants with them.

• Transitional provisions apply to existing sponsored workers depending on when a Certificate of Sponsorship (CoS) was first assigned, with two key dates to be aware of: April 2024 and July 2025. If a worker was first sponsored prior to either of these dates, the rules in place at that time will continue to apply.

• Adult social care workers (SOC Codes 6135/6136, at RQF Level 2), can only be sponsored as a Health & Care worker if they are already in the UK. New overseas care workers can no longer be sponsored, and all remaining sponsored care workers can only extend or change employer until 22 July 2028.

• Other healthcare roles removed from general Skilled Worker sponsorship include 6131 Nursing auxiliaries and assistants, 6132 Ambulance staff (excluding paramedics) and 6133 Dental nurses.

Impact on Care Providers

For a sector that has heavily relied on international workers since the introduction of the Health & Care Worker visa in 2022, this will have a significant effect on future-proofing the workforce of care homes. Hundreds of thousands of care workers have been sponsored since 2022, many arriving during a national workforce crisis. Now, this talent pipeline has been effectively closed. As a result:

• Providers must plan workforce strategies beyond 2028 without sponsored recruits for core roles.

• Overseas workers already here face limited mobility and uncertainty for their ongoing residence, as well as future settlement.

• Recruitment gaps may widen unless alternative staffing and retention measures are implemented.

The Government’s Fair Pay Agreement (FPA) for adult social care, expected by July 2028, intends to attract more resident workers into the sector, forming a framework for improved minimum pay and working conditions, and additional protections through a representative national employer-worker body. It remains to be seen whether the current funding level of £500m will be sufficient to achieve the stated aims or to fill gaps in staffing which previously the international worker was filling.

Sponsor Licence Compliance Is Now a Business-Critical Priority

At the same time, Sponsor Licence compliance audits have increased sharply and the Home Office is suspending and revoking record numbers of care providers’ Licences. Considered a high-risk sector by the Home Office, care providers now face:

• Higher likelihood of Home Office audits

• Risk of Sponsor Licence suspension or revocation

• Stricter Right to Work checks and enforcement

With the consequences of losing a Sponsor Licence so significant to the ability of a care home to continue operating, forward-thinking providers are getting proactive. They are adopting audit-ready HR systems, investing in training, and treating immigration due diligence as seriously as financial audits, particularly during mergers, acquisitions and restructuring. Where the value of the business is closely related to its workforce, the risk of losing that workforce must be minimised.

Building a Future Workforce Without Sponsored Care Workers

The UK care sector stands at a turning point. Providers can no longer rely on international recruitment for core roles. A sustainable response requires a strategic shift, focusing on:

• Workforce planning beyond 2028

• Investment in domestic talent pipelines

• Apprenticeship programmes and local recruitment partnerships

• Stronger career progression routes for care staff

• Collaboration with legal advisors to ensure workforce compliance

Businesses that adapt early will be better placed to protect service continuity and build a more resilient care workforce which can continue to meet the growing needs of an ageing UK population.