On the 5th of March 2026 the UK Home Office released its Statement of Changes HC 1691, setting out key changes to the UK’s immigration framework. Such changes are typically made twice a year, and it was expected that this Statement would confirm the new rules on applications for settlement following the public consultation. It did not, which may mean those changes may not be confirmed until later this year.
The March 2026 Statement did confirm changes across work, study, and travel routes, introducing stricter eligibility criteria in some areas and loosening it in others. This will deliver mixed news for employers and individuals alike.
In this article, Ryan Lenihan and Alex Christen analyse the changes and their implications for employers, employees, students, and applicants.
1. The temporary visa brake
From the 26th of March 2o26 the Home Office will refuse Skilled Worker visa applications from main applicants who are Afghan nationals, as well as refusing Student visa applications from Afghanistan, Cameroon, Myanmar and Sudan. This measure further expands on the stated intents of May 2025’s Immigration White Paper and Asylum Policy Statement; to drive down asylum, where it is preventable.
The visa brake aligns with Government policy to assess the increase in individuals entering the asylum system and to better understand the underlying issues or trends driving their behaviours.
What does this mean for businesses?
The visa brake dictates that sponsors should not assign Certificates of Sponsorship (CoS) to Afghan nationals intending to apply for entry clearance under the Skilled Worker route from the 26th of March 2026 – but should instead keep matters under review, given that the brake is intended to be temporary and may be lifted at any time.
This won’t affect visa extension applications for Afghan nationals already sponsored as Skilled Workers, or those intending to switch into the Skilled Worker route from within the UK. Nor will it affect dependant visa applications from Afghan nationals, where the main applicant is of a different nationality.
It does, however, mean that sponsors should update their internal sponsorship processes to include the new step of checking whether an application for a visa will be accepted or refused based on the applicant’s nationality and when the application is made. And businesses should also be aware that, although the brake is limited to Afghan nationals now, it could easily be extended to other nationalities, making our immigration system increasingly complex for employers to navigate.
2. Additions to the Visa National List
Due to updated risk assessments and border control priorities, nationals from Nicaragua and St Lucia will now be subject to a visit visa requirement, meaning they will need to apply for and obtain a visitor visa prior to entering the UK. Linked to this, Nicaragua and St Lucia will be removed from the list of countries whose nationals are eligible to apply for an Electronic Travel Authorisation (ETA).
This requirement came into effect on the 5th of March 2o26, at 3pm GMT, with a 6-week transition period granted for those who had already obtained ETAs and are due to arrive in the UK before the 16th of April 2026.
What does this mean for international travellers and businesses?
Travel plans for Nicaraguan and St Lucian nationals must be reviewed immediately, and affected individuals should seek guidance on visa application procedures to avoid disruption. Those travelling to the UK will be assessed against the Immigration Rules in advance of arriving in the UK. When an individual is required to make a visitor visa application, their visitor visa may be refused if the application, and reasons for travel, do not meet the requirements. Where the requirements are met, the individual will be issued with a visitor visa at that point.
Businesses in the UK who regularly receive visitors from Nicaragua and St Lucia should now factor in time for those travelling to obtain visitor visas in advance (with standard applications taking around three weeks). We have always recommended that UK businesses provide letters in support of UK in-bound business visits, but well drafted supporting letters will now be even more important for nationals of these countries, to enable successful visitor visas to be obtained.
3. Changes to Skilled Worker routes for prison workers
A new transitional arrangement is being put in place to increase the number of prison workers who can be sponsored – welcome news at a time where the prison service is facing severe recruitment difficulties.
Following the changes made to the Skilled Worker route in July 2025, individuals can generally only be sponsored in the Skilled Worker route if the role is skilled to degree level or equivalent and the corresponding minimum salary level is met. Transitional arrangements were put in place to ensure those already in the Skilled Worker route would not have to meet the higher skill and salary thresholds when extending their visas. However, the July 2025 changes mean that those in ‘lower skilled’ roles are not generally able to switch into the Skilled Worker route.
This change (which will come into effect on the 7th of April 2026) creates an exception specifically for prison workers. The new approach should help certain groups of people, such as those on Graduate visas looking to switch, to be sponsored on Skilled Worker visas, and businesses will be able to take advantage of lower salary and skill thresholds. The change also means that applicants only need to be skilled to Regulated Qualifications Framework (RQF) Level 3, and a minimum salary level of £31,600 must be met, which is significantly lower than the general Skilled Worker salary minimums.
Certificates of Sponsorship can be issued under this new exception, to be used in applications until the 31st of December 2027. However, a visa (and a corresponding CoS) can only be issued for up to 3 years, as opposed to the standard 5 year maximum period for Skilled Worker visas. It is expected that extensions to this initial 3-year period will be possible, provided the initial CoS is assigned before the cut-off date of the 1st of January 2027. Dependents already in the UK can apply to extend their stay under the 3-year prison worker visa exception, but no new dependents can enter the UK under these arrangements.
What does this mean for students and businesses?
This change should help address staff shortages in the prison sector and expand the recruitment pool to international graduates already living in the UK. It also provides international students with an opportunity to stay in the UK for longer. For businesses, it provides an easier and cheaper recruitment option to sponsor international graduates in the prison sector.
We believe there is also scope for the Home Office to extend the same rule to other roles and sectors in the future, providing some level of hope following the extreme impact of the July 2025 changes to many people and companies. However, it does also add another layer to the already incredibly complex framework for considering which roles are eligible for Skilled Worker visas.
4. Change to pay periods for Skilled Workers
The Statement of Changes has introduced a new salary requirement in relation to pay periods. A sponsored worker must now be consistently paid the required salary (as stated on their Certificate of Sponsorship) for each pay period, instead of relying on annual salary calculations, unless a reduction to their salary comes under a variation already permitted under the Immigration Rules. Salary payments must meet the required hourly and annual rates, and ensure salary paid over the specific periods matches with the required annual salary threshold that the job’s Standard Occupational Classification (SOC) code requires.
The following stipulations now apply:
- If the worker is paid at a frequency of monthly or less, the salary paid over a 3-month period must be at least equal to a quarter of the required annual salary.
- If the worker is paid more frequently, the salary paid to the worker over any 12-week period must be at least equal to 12/52 of the required annual salary.
- If the worker is sponsored to work a pattern where the regular hours are not the same each week, the sponsor must confirm the working pattern and the salary over any 17-week period must be at least 17/52 of the required annual salary.
- If the worker is sponsored in a role where the sponsor cannot guarantee at least the 17/52 required annual salary over a 17-week period, because the nature of the job means that hours fluctuate, the sponsor must confirm this.
These changes have been introduced so that the Home Office can identify concerns that a sponsor is underpaying a sponsored employee faster than waiting for a full year of salary to be paid. This aligns with the initiative to support sponsored worker welfare.
What does this mean for businesses and individuals?
Businesses who are sponsors will be notified by the Home Office when they view underpayment as a concern, and will give the sponsor an opportunity to explain or remedy the issue at an early opportunity. Therefore, it is of the utmost importance for Authorising Officers to be carefully monitoring payrolls and ensuring they are compliant with the new Home Office requirements. For individuals, it means they will not be significantly impacted by underpayment, where this occurs, before the Home Office notifies sponsors or takes compliance action.
5. Changes to Global Business Mobility
The Statement also laid out changes to the Global Business Mobility (GBM). They specify that the UK’s entry and temporary stay commitments taken in the Comprehensive Economic and Trade Agreement agreed between the UK and India will be implemented once that agreement enters into force. These commitments give service suppliers up to 12 months leave at a time, where they are in the contractual Service Supplier and Independent categories covered by the commitment.
In addition, the qualifying overseas employment period under the Secondment Worker route has been reduced from 12 to 6 months. The GBM Secondment Worker route allows overseas employers with a high-value contract or investment with a UK organisation (worth at least £50 million) to temporarily send their workers to the UK, where the worker has been employed for a minimum period. This change will take effect from the 8th of April 2026.
What does this mean for businesses?
The changes related to service suppliers give businesses faster access to specialised skills and an opportunity for collaboration with an international partner. It will also help deliver large or complex service contracts. The reduction in the qualifying period will provide greater flexibility for businesses to deploy staff more quickly and will hopefully attract more high-value contracts to the UK. At the same time, retaining a qualifying period maintains an element of integrity to the system by ensuring employees coming to the UK via this route are genuinely employed.
6. Changes to identity requirements
Applicants who must attend the Visa and Citizenship Application Service (VCAS) every time they make an immigration application will now be able to have their identity reused. This means that, where a person’s identity was previously assured to a satisfactory standard (e.g. granted entry clearance or further immigration permission), the applicant does not need to re-establish their identity via a satisfactory identification document, such as by providing an in-date passport. Instead, the applicant can reuse their identity by uploading a ‘live’ facial image using the Generic Identity Document Verification (GIDV) app, which will compare the ‘live’ image with one captured under controlled conditions and stored on the Immigration and Asylum Biometric System (IABS).
The conditions will apply to those who have previously enrolled their biometrics under controlled conditions, such as at a VCAS centre, and are making a new immigration application.
What does this mean for individuals and businesses?
Individuals applying for UK visas or immigration extensions will find the process faster and more convenient. It will also utilise less Home Office resources. For businesses, the increased digitalisation of immigration applications will speed up hiring timelines as visa processes become more efficient. It will hopefully lead to reduced administrative delays, and lower costs and disruption for employers.
7. Changes to English language requirements for settlement applications
From the 26th of March 2027 the English language requirements for those seeking to apply for settlement will be raised from B1 level to B2 level for a number of immigration routes. This aligns the English language requirement with the Skilled Worker Visa, where the level was raised from B1 to B2 on the 8th of January 2026 for new applicants.
The requirements will apply to those already on a pathway to settlement in the UK in the applicable routes, while the Skilled Worker and Scale Up routes are accordingly amended to apply the new language requirement at settlement stage (so that those who were already in the Skilled Worker route for example, before the 8th of January 2026, only need to meet the higher English language requirement at the time they come to apply to settle in the UK, providing they are eligible for settlement before the 26th of March 2027).
What does this mean for businesses?
This shift is designed to further ensure that migrants possess a higher level of fluency in English across a variety of immigration routes, to enable better integration into the UK workforce and society. However, it also presents challenges for employers, particularly in sectors that previously relied on B1 level applicants. Recruitment strategies will need to be revised to accommodate the new threshold, and additional support may be required to help candidates meet the higher standard.
It will be important for sponsors and individuals to be aware of these new requirements well in advance of an intended visa application, so that applicants are prepared to prove their English language skills to the new, higher level. As the date for the implementation of the English language requirement is the 26th of March 2027, it gives those already on the path to settlement an opportunity to take the necessary steps to meet the requirement.
8. Global Talent visa changes
Changes are also being made to expand the Global Talent route, with the addition of a new design pathway, to cover design roles that were not previously catered for. Applicants seeking endorsement in the design field must demonstrate:
- recognition as exceptional talent or exceptional promise,
- professional engagement producing internationally recognised design work, and
- a record of professional activity within the previous 5 years.
Evidence requirements may include international awards, media recognition or exhibitions, publications, or professional appearances.
Furthermore, the requirements of the appointments fast-track option for designers are being simplified from the 1st of July 2026, with the aim of clarifying which talented individuals, in eligible academic or research positions, can access the pathway. Currently, individuals must pass a peer review to be offered their eligible appointment. Therefore, the new appointments pathway acts as a proxy for the full peer review endorsement pathway, allowing applicants to qualify with fewer evidential requirements.
All PhD roles in an approved UK Higher Education Institution or research institute will be covered under this change, where the role has a responsibility for academic, research, or innovation leadership and development, or their role has a primary function of research and innovation.
What does this mean for businesses?
This will make it easier for top design talent to use the Global Talent visa, making it easier to recruit and retain talented individuals. For those with eligible research positions, the changes will simplify the requirements, as these have previously caused some confusion in the sector; applicants who were eligible for the fast-track route were often applying through the full peer review pathway; a longer, more involved process.
9. Changes to Right to Work for asylum seekers
While, as a general rule, asylum seekers are not allowed to work, some can apply for permission to work if they have been waiting 12 months or more for an initial decision (or for a decision on further submissions) and the delay is not their fault. Asylum seekers who are given permission to work, can currently only accept jobs where the role is listed on the Immigration Salary List (or Shortage Occupation List, depending on when they became eligible to work).
Under changes to the system laid out in the Statement, access to jobs for asylum seekers will now only be available to roles listed as capable of sponsorship at RQF Level 6 from the 26th of March 2026. This aligns the rules with those of the Skilled Worker visa and the focus on routes being available to higher skilled occupations.
What does this mean for businesses and individuals?
While this opens up roles that were previously not accessible to asylum seekers, in reality this change will make it harder for individuals to access work, as they may not have recognised qualifications at the level necessary to satisfy the higher skill level criteria. So, even after 12 months, individuals may still be unable to work.
For businesses, certain industries who may have hired asylum seekers with permission to work may see a tighter labour supply in lower-skill sectors. Businesses will need to remain compliant by undertaking Right to Work checks in accordance with Home Office guidance, but also by taking particular care as to which roles can and cannot be offered to asylum seekers, as employing anyone in an ineligible role will be viewed as illegal working.
While we have not covered this in any detail in our note, the March 2026 changes made other significant updates to the immigration rules for refugees and asylum seekers, including reduced visas of up to 30 months in length (not the current 5 years).
Strategic implications for employers and individuals
These changes together introduce a further level of complexity in workforce planning, compliance, and visa management. Therefore, employers should take proactive steps to adapt. These could include:
- Strategic workforce planning – assess how changes to visa durations, skill thresholds, and eligibility criteria affect recruitment pipelines.
- Sponsorship licence management – ensure compliance with stricter standards, including record-keeping, reporting duties, and audit readiness.
- Visa application support – help employees navigate higher English language requirements and new documentation standards.
- Policy monitoring and risk mitigation – stay informed on legislative developments and assess exposure to immigration risks.
Government policies are designed to prioritise high-skilled migration, faster workforce and societal integration, and tighten eligibility criteria while reducing the UK’s so-called draw for asylum seekers. While the changes aim to enhance the quality and control of migration, they also present new challenges for applicants and sponsors.
Employers, employees, students and applicants must act swiftly to understand the implications, adjust timelines, and seek expert guidance to ensure compliance and continuity in recruitment and retention strategies.
How can we help?
For further information about issues raised in this article, please contact a member of our Business Immigration team.
