The Skilled Worker visa continues to underpin international recruitment for UK employers. The 2025 reforms, however, have made the route more demanding. Salary thresholds are higher, occupational criteria are narrower and UKVI expects sponsors to demonstrate tighter control over their processes. These changes mean sponsorship now needs the same level of oversight as other core business compliance functions.
Employers have to be confident that their recruitment, payroll and reporting systems all align with Home Office Skilled Worker and sponsorship requirements.
This article explains how the updated Skilled Worker framework operates in practice, focusing on eligibility, salary compliance, visa management and long-term planning. The aim is to help employers manage sponsorship accurately, reduce risk and maintain permission to employ overseas staff.
Section A: Skilled Worker Sponsorship in 2025 – Core Employer Duties
The Skilled Worker visa replaced the Tier 2 visa in 2020. While the framework largely remained the same, there were many changes to the eligibility and process requiring (including rules affecting dependants and the application process), and more reforms have taken effect since that have reduced the availability of this route to only high skilled workers with higher pay thresholds.
The Skilled Worker visa remains the UK’s main route for employers to recruit international talent, but the 2025 reforms have reshaped the system. Higher salary thresholds, updated occupational lists and closer Home Office monitoring mean sponsorship now demands precision, structure and integration across HR, legal and payroll operations. Employers that treat sponsorship as a compliance function embedded within business governance can continue hiring overseas talent efficiently while maintaining full regulatory confidence.
All sponsorable occupations are listed in Appendix Skilled Occupations. Each role is tied to a distinct SOC code and Skilled Worker going rate. Employers must offer salaries meeting or exceeding both the role’s going rate and the Skilled Worker visa minimum salary. In July 2025, the Government replaced the shortage occupation list with the immigration salary list and introduced a temporary shortage list. Both lists are now integrated into Appendix Skilled Worker, forming the definitive reference for eligibility checks. Since July 2025, new sponsorships are generally limited to RQF Level 6 (degree-level) jobs unless the role appears on the ISL or TSL. Employers must always confirm eligibility using the latest Appendix Skilled Worker, ISL and TSL before issuing a Certificate of Sponsorship.
Applicants must score 70 points under the Skilled Worker visa points system across sponsorship, skill, salary and English-language requirements. The Skilled Worker English language standard remains CEFR B1, met through an English-taught degree, nationality exemption or approved test. The IELTS for UKVI B1 test requires 4.0 in each element, aligning with the minimum IELTS score for UK work visa benchmark. Employers must verify English evidence before assigning a certificate to avoid refusal risks. Although higher language thresholds have been discussed, no changes are yet in force.
Section B: Managing Employment, Transitions and Compliance Duties
Employers must also understand how fees, dependants and job changes fit into their compliance responsibilities. The difference between Skilled Worker visa and Health Care visa determines which route applies to a role. Both require sponsorship, but the health and care visa offers lower health and care visa fees and faster processing for qualifying roles. Current Skilled Worker visa fees vary depending on job length, occupation and location. Dependants can apply under the Skilled Worker dependant visa and hold full work rights. HR teams should capture dependant data during extensions to maintain accurate employment records.
Sponsorship duties extend for the duration of employment. Any role change or pay variation may require a Skilled Worker change of employment application before the change takes effect. Employers should submit a Skilled Worker visa extension ahead of expiry, confirming the salary still meets applicable thresholds. All changes must be logged through the Skilled Worker change of circumstances process. Since July 2025, care and senior care workers can no longer be newly sponsored under this route, (note there is no separate care worker visa), so employers should consult the most recent update to the Skilled Worker visa for sector-specific guidance.
Many recruits already hold permission to work under another category, and may be able to switch into the Skilled Worker visa, depending on their current permission. The graduate visa to Skilled Worker visa route allows employers to retain post-study hires with minimal disruption. The student to Skilled Worker visa process enables switching after completion of eligible study, while transitional Tier 5 to Tier 2 arrangements remain valid for certain legacy employees. Plan job offers and onboarding around these timelines to preserve continuous lawful residence. Employers must also track secondary employment activity: under Skilled Worker visa additional work rules, employees can take up to 20 hours per week of extra work in an eligible occupation or sector. Medium-skilled supplementary work is only permitted for legacy holders sponsored before July 2025, and any secondary role must be documented to avoid breaches.
Section C: Salary, Settlement and Long-Term Workforce Planning
Salary validation remains central to UKVI compliance. The SOC codes with salary framework outlines benchmark pay for each occupation. Sponsors must align job duties and pay with the relevant Skilled Worker going rate and keep audit trails, including offer letters, payslips and job descriptions. The new entrant Skilled Worker visa allows lower pay for early-career employees under 26 or within two years of graduation. Employers should schedule pay reviews before a Skilled Worker visa extension to confirm that all workers meet the standard rate when reapplying or seeking settlement.
After five years of sponsorship, employees may apply for settlement under the Skilled Worker visa to ILR route. Transitional Tier 2 to ILR requirements continue to apply to legacy cohorts. Under the UK ILR rules for Skilled Worker visa, applicants must show continued qualifying employment and pay at or above the required threshold. The proposed ten-year earned settlement model remains under consultation. Employers should identify staff approaching ILR eligibility early, build salary progression into retention strategies and plan workforce succession around settlement milestones.
Ongoing compliance is the cornerstone of long-term sponsorship. Employers must align HR and payroll systems with official Skilled Worker guidance and incorporate each update Skilled Worker visa change into policy promptly. Even administrative oversights can lead to licence downgrades or suspension. Quarterly audits of right-to-work checks, salary records and CoS data help maintain accuracy. Employers that embed sponsorship management into HR governance will stay audit-ready, protect their licence and continue attracting international talent with confidence.
Section D: Penalties and Enforcement
UKVI applies strict enforcement where sponsors fail to meet their duties. Licence downgrades, suspensions and civil penalties can follow even minor administrative errors if they reveal systemic weaknesses. A downgrade restricts the ability to assign new Certificates of Sponsorship until an action plan is completed, while more serious breaches can lead to a revoked licence. Employers should review reporting and payroll data regularly to prevent enforcement action and maintain full confidence in their compliance systems.
1. Licence downgrades and suspensions
Where compliance concerns are identified, UKVI may downgrade the sponsor’s licence from an A-rating to a B-rating. During this period, the sponsor cannot assign new Certificates of Sponsorship and must complete a UKVI action plan to address the issues. If the plan is not completed or further breaches occur, the licence may be suspended pending investigation. Suspension pauses all sponsorship activity and can delay new hires. Maintaining accurate records and prompt reporting helps avoid these outcomes.
2. Licence revocation
In cases of serious or repeated breaches, UKVI can issue a sponsor licence revoked notice. Revocation immediately ends all existing sponsored employment, and workers’ visas are normally curtailed within sixty days. This can cause significant business disruption, particularly where sponsored staff hold key roles. Employers must wait for a cooling-off period before reapplying and must demonstrate that the underlying compliance failings have been resolved. Prevention through regular audits and early risk detection is always more effective than recovery after revocation.
3. Civil and criminal penalties
Non-compliance that results in illegal working can lead to civil penalties of up to £45,000 per worker for a first breach and £60,000 for repeat offences. Deliberate or negligent conduct may trigger criminal prosecution, which carries unlimited fines or imprisonment for responsible individuals. Reputational damage can also affect future recruitment and contract bids. Employers should ensure right-to-work checks and payroll data are accurate and up to date to minimise exposure.
4. Reducing enforcement risk
Regular internal audits are the most effective safeguard against penalties. Employers should test reporting workflows, review Appendix D documentation and cross-check payroll and CoS data each quarter. Where potential issues are identified, voluntary disclosure to UKVI can mitigate sanctions by demonstrating transparency and good faith. By maintaining disciplined internal oversight and clear communication channels, sponsors can minimise enforcement risk and protect their licence for the long term.
Author
Gill Laing is a qualified Legal Researcher & Analyst with niche specialisms in Law, Tax, Human Resources, Immigration & Employment Law.
Gill is a Multiple Business Owner and the Managing Director of Prof Services - a Marketing Agency for the Professional Services Sector.
