Immigration update – March 2025 

Increases in Home Office immigration fees (effective 9 April 2025) 

On 19 March 2025 the Home Office announced a number of immigration and nationality fee increases, which will take effect from 9 April 2025. 

Businesses will be especially concerned by the 120% fee increase of a CoS – a cost that cannot be passed on to employees. 

Key fee changes for businesses applying for sponsorship licenses and employee visas: 

 
(*Discounted fees apply if the role is on the Immigration Salary List.) 

 
Practical tip: businesses considering obtaining a sponsorship licence, or with employees needing a UK work visa, may wish to accelerate the process to submit applications before 9 April 2025 and benefit from the current lower rates. 

Changes to Skilled Worker Route for care workers (effective 9 April 2025) 

Recent increased media and government scrutiny of the care sector, with a focus on worker exploitation, has driven a number of amendments to the Skilled Worker – Health and Care worker visa sub-category.  

1. Imposition of a sector specific Resident Labour Market Test for care workers and senior care workers 

Care providers must now demonstrate efforts to recruit UK-based care workers (including displaced workers) before hiring from overseas. 

Sponsors will be required to provide confirmation that they have attempted to recruit for their vacancy from the pool of workers in the UK who are seeking employment and that no suitable workers were identified which is why they are now considering sponsoring someone from overseas or another visa route.  

This change will only apply to care sector jobs based in England. Those based in Scotland, Wales and Northern Ireland will not be impacted. 

Individuals who are already on a Health and Care visa working within these occupations and individuals switching from other immigration routes who have been legally working for their sponsor for at least 3 months are also unaffected when this change comes into effect on 9 April 2025. 

The proposed change will see employers having to obtain a confirmation from a regional partnership that there are no suitable workers already available.  

The mechanism for obtaining this certification has not yet been published, so affected employers will need to keep a close eye on upcoming Home Office announcements. 

2. Rise in minimum salary  

The minimum hourly rate required to be eligible for visa sponsorship will increase: 

• Hourly rate: £12.82 (up from £11.90). 

• Annual salary: £25,000 (up from £23,200). 

This change will ensure that salary is significantly above the UK National Living (also set to increase in April 2025).  

3. Wages and immigration costs  

Any deductions from staff wages for immigration costs (e.g. loans for visa fees) will count against meeting minimum salary requirements. 

This is a significant change and is likely to drive a significant change in employer practices. It remains to be seen how/if clawback agreements for visa costs may be dealt with going forward.  

These changes are likely to require a considerable amount of adapting recruitment and retention policies of companies operating in the health and care sector. It is advisable to start thinking now about how these changes can be incorporated into affected business processes and policies. 

Further policy guidance is expected to be announced in due course to assist sponsors. 

UK Electronic Travel Authorisation update 

The UK Electronic Travel Authorisation (ETA) scheme applies to visitors who do not have to apply for UK visit or transit visa before coming to the UK.  

The scheme requires travellers to apply for security clearance before they set off on their travels. This includes children of any age. It is advisable to apply for the ETA in good time before travel is required.  

The scheme currently applies to all other non-EU countries and, as the final phase of implementation, applications are now open, nationals from EU, EEA, and Switzerland that are arriving in the UK on/after 2 April 2025. 

It has also been announced that from 5 March 2025, British Nationals (Overseas) passport holders are no longer required to obtain an ETA – reversing the previous requirement to obtain one for travel to the UK. 

Tip: Apply early to avoid delays in travel. 

eVisa grace period extended 

Most UK visa holders will be aware that their Biometric Residence Permits (BRPs) or Biometric Residence Cards (BRCs) expired on 31 December 2024. This is usually only the expiry date of the physical card, rather than the expiry date of the immigration permission.  

Travellers should retain their BRPs/BRCs even if they expired on 31 December 2024. 

Expired Biometric Residence Permits (BRPs) and Cards (BRCs) remain valid for travel until 1 June 2025 (assuming the actual permission expires after this date).  

All visa holders should: 

• Set up a UKVI online account. 

• Check their eVisa status displays correctly. 

• Ensure their current passport is registered on the account. 

• Keep expired BRPs/BRCs with their passport when traveling (until 2 June 2025). 

Updated employer guidance on Right to Work (RTW) checks 

The Home Office released new RTW check guidance on 12 February 2025, with several key updates. 

1. Manual RTW checks 
    

• Where manual RTW checks are still permitted (for British and Irish nationals), employers can no longer accept clipped passports, as they are considered cancelled. 

• Birth certificates (short or long) are acceptable when accompanied by official proof of name and National Insurance (NiNo) from a government agency or previous employer. 

2. Contractors 

• RTW checks are generally not required for self-employed individuals. 

• Exceptions: Employers with sponsor licences must conduct checks and keep evidence when sponsoring contractors. 

3. New deadline to create a UKVI account 

Individuals applying from overseas to come to the UK for more than six months are issued with a vignette (sticker) in their passport. This is valid for 90 calendar days to enable them to travel to the UK.  

Following their arrival, they will have 10 calendar days or before their vignette expires (whichever is later) to create a UKVI account to access their eVisa, and to prove they have the right to work in the UK.  

Proving RTW with a vignette 

If employees need to start work for you prior to creating a UKVI account and accessing their eVisa, they will be able to evidence their right to work by producing the vignette in their passport.  

Employers will need to conduct a manual right to work check on the vignette, which must be valid at the time of the check. However, as this will expire 90 calendar days from issue, employers will have to repeat the check using the online share code service for their statutory excuse against employing an illegal worker to continue.  

If a business employs someone on the basis of the vignette, and the individual is unable to access their eVisa or use the online service when the vignette time expires business can continue to employ them if there is a belief the employee continues to have the right to work. However, once the 90 calendar days have expired, the business will not be protected by a statutory excuse if it transpires that the employee is working illegally. 

4. National Insurance Numbers (NiNo) 

Some individuals are automatically issued a NiNo as part of their immigration application. 

 This currently applies to most migrants and dependants who have been granted permission in the Skilled Worker category, or as a refugee, plus some other specific routes. In such cases, the NiNo should appear on their eVisa profile.  

There is no need for the individual or the employer to make a separate application to the Department for Work and Pensions to obtain one. 

5. Ukrainian Permission Extension scheme 

Ukrainian nationals and their eligible family members (who may be non-Ukrainian nationals) who are currently in the UK under one of the existing Ukraine schemes will be able to apply for a further 18 months to remain in the UK through the bespoke Ukraine Permission Extension (UPE) Scheme. The scheme opened to applicants on 4 February 2025 and provides the same rights and entitlements to access work, benefits, healthcare and education as the existing Ukraine schemes. 

Individuals will be able to submit applications within 28 days of their current permission expiring. Applications will usually receive a decision within eight weeks. If an individual with a pending application is required to prove their right to work, they should access their eVisa and provide their employer with a share code, which they should process like any other right to work check. 

Employer obligations 

Failure to perform required RTW checks or non-compliance with updated guidance can result in: 

• Fines up to £60,000 per illegal worker. 

• Imprisonment for directors in serious cases. 

Stay informed and ensure checks are compliant to maintain statutory protections. 

New visit visa requirements for Trinidad and Tobago nationals 

1. New Visit Visa requirements for Trinidad and Tobago nationals 

Effective 12 March 2025, nationals of Trinidad and Tobago are no longer considered “non-visa nationals”. They must now apply for and be granted a full visit visa before traveling to the UK. Obtaining an ETA alone is not sufficient for UK entry. 

Transition period: 

• Trinidad and Tobago nationals can still enter with only an Electronic Travel Authorisation (ETA) if they can prove: 
  • Travel is booked before 3pm on 12 March 2025. 
  • Arrival is scheduled before 3pm on 23 April 2025 (UK time). 

Important notes: 

• Bookings cannot be amended to meet these requirements. 

• For arrivals after 23 April 2025 (3pm), any ETA issued will be cancelled, and travellers must apply for a visit visa. 

• Anyone who has booked travel for a date after 3pm (UK time) on 23 April 2025 but has not obtained an ETA also needs to apply for a visit visa. 

• Nationals will also require a Direct Airside Transit Visa (DATV) unless exempt. 

Processing times: 

• Standard visit visa processing takes around three weeks (priority services may be available in some countries). 

• Businesses and travellers should factor these timelines into their plans. 

Visit visas are often underestimated regarding how complex the applications are and just how much supporting evidence is required – it is therefore important going forward to factor these new requirements into the timeline for the affected travellers.  

Ukrainian Permission Extension Scheme (UPE) launched 

Launched on 4 February 2025, this scheme allows Ukrainian nationals (and eligible family members) already in the UK to extend their stay by 18 months. 

Applications can be submitted once there are 28 days or less remaining on the current permission but must be submitted before the current permission expires. 

Children born in the UK to a parent with permission under the Ukraine Scheme, who could previously apply for permission under the Ukraine Extension Scheme when that route was available, are instead eligible to apply under the Ukraine Permission Extension Scheme. 

Key benefits: 

• No application fee. 

• Immigration Health Surcharge is waived. 

Limitations: 

• The scheme does not provide a route to settlement. 

Employer action: employers with Ukrainian employees should stay updated to support them and ensure compliance with right to work checks when required. 

Changes to EU Settlement Scheme (EUSS) 

The EUSS has been in place for a number of years to allow EU, EEA and Swiss nationals to make applications to remain in the UK, and for eligible family members to make applications from outside the UK to join their EU/EEA/Swiss national family member. 

Recent Home Office updates clarify that individuals who became EU/EEA/Swiss nationals after 31 December 2020 cannot sponsor EUSS Family Permit applications to bring family members from outside the UK. 

There remains a large amount of confusion about the EUSS, who can and cannot apply, when and how. It is therefore important to ensure that any applications which are made comply with all relevant validity and eligibility requirements. 

Clarification to settlement requirements in various visa routes 

Most work-related visa routes (such as Skilled Worker, Global Talent and Innovator Founder) permit obtaining settlement (also called Indefinite Leave to Remain) after having held a UK visa for five years. There is some opportunity to combine time spent in the UK on different visa categories. However, the requirements to be able to do this are very specific, and only certain visas can be combined. 

The Home Office has clarified that the qualifying period for settlement as the main applicant in these work-related visa categories must consist of time spent as the main applicant and cannot include time spent as a dependant of another main applicant. 

It is important for visa holders to understand fully what changing visa category and/or changing from main applicant to dependant means for their ability to apply for settlement after five years. Doing so without fully appreciating the potential consequences can mean time already spent in the UK may no longer count, requiring more visa applications and more costs before settlement can be obtained.