Business immigration updates for employers | June 2026

June has seen a number of practical updates for employers and sponsors, particularly around the continued move to digital immigration status and new Government support for high-growth businesses seeking to recruit international talent or expand into the UK.

Sponsor guidance changes and adjusted right to work processes remain fast-moving areas, so employers should continue to monitor Home Office guidance carefully and ensure internal processes are kept under review.

Expired BRPs can be used for certain purposes until the end of 2026/24 months from expiry

The Home Office has updated its guidance on expired Biometric Residence Permits (“BRPs”). All BRPs have now expired and have been replaced by eVisas. However, an expired BRP can now be used for certain limited purposes for up to 24 months after the expiry date printed on the card, or until 31 December 2026, whichever is earlier. This replaces the previous 18-month position, which would in many cases have ended on 30 June 2026.

This extension is helpful for individuals who still need to create their UK Visas and Immigration (“UKVI”) account, obtain access to their eVisa, or make a further in-country application where the identity process permits use of an expired BRP. The current guidance states that an expired BRP can be used to sign in to view an eVisa and get a share code, create a UKVI account to access an eVisa, and apply to extend permission to stay in the UK.

However, the extension is limited. It does not extend a person’s underlying immigration permission, and expired BRPs should not be relied on for travel to the UK. Individuals should ensure that they have access to their eVisa and that their current passport is linked to their UKVI account before travelling.

Practical steps for employers

• Employers should continue encouraging any employees who have not yet done so to create a UKVI account and access their eVisa. This is particularly important for sponsored workers, employees with indefinite leave to remain previously evidenced by a BRP, and anyone who may need to travel internationally or prove their status for work purposes.

• Employers should also avoid assuming that an expired BRP means an employee’s immigration permission has expired. The BRP was evidence of status, not the status itself. Right to work checks should continue to be carried out using the correct online checking process where required.

New visa fee reimbursement scheme for Scale Ups

The Government has launched the Visa Fees Reimbursement Scheme for Scale Ups, a targeted funding scheme designed to support eligible high-growth businesses in recruiting international talent. The scheme applies to UK-based scale-ups operating in the Clean Energy, Life Sciences and Digital and Technologies sectors.

Eligible businesses can claim reimbursement of visa application fees for qualifying hires and their dependents under the Skilled Worker, Global Talent and Scale-up routes. Businesses can claim up to £25,000 per year, capped at £5,000 per international hire and their dependants. The scheme opened on 9 June 2026 and is due to close on 1 March 2027, with funding allocated on a first-come, first-served basis. To apply for the funding, businesses must register and submit their application through the Grants Hub portal which can be found here: Visa Fees Reimbursement Scheme for Scale Ups - GOV-UK Find a grant.

To qualify, a business must broadly be a UK-based scale-up satisfying the average annualised growth definition, operate in one of the eligible priority sectors, hold a valid sponsor licence, have an established UK presence, recruit through an eligible visa route, pass DBT due diligence and assurance checks, and hold a UK bank account to receive reimbursement.

The scheme is likely to be relevant to a relatively narrow group of employers, but for eligible sponsors, it may help reduce some of the visa fee burden associated with international recruitment.

Practical steps for employers

• Eligible businesses should consider planned international recruitment and whether any recent or upcoming hires may fall within the scheme. Given funding is limited and allocated on a first-come, first-served basis, employers who may qualify should consider applying promptly.

• Employers should also remember that the scheme does not remove the wider costs and compliance obligations associated with sponsorship. Sponsor licence duties, right to work checks, salary requirements and record-keeping obligations remain unchanged.

Fast-track referral process for UK Expansion Worker sponsor licence

The Office for Investment (“OfI”) is offering a fast-track referral process for certain overseas businesses applying for a UK Expansion Worker sponsor licence. Where accepted, this may reduce Home Office processing times to around 10 working days, compared with the standard processing time of up to 8 weeks.

To be eligible, businesses must be receiving ongoing support from the OfI, operate in one of the Government’s priority Industrial Strategy sectors and meet at least one specified investment or growth criterion. These include having received at least £1 million in venture capital or institutional investment, committing at least £2 million in capital investment for UK expansion, or participating in a government-recognised high-growth programme. This is likely to be relevant to a relatively narrow cohort of overseas businesses, so we don't anticipate this offering to be that impactful. particularly given the eligibility criteria and the historically limited use of the UK Expansion Worker route,

Applicant organisations will also need to pass due diligence checks and provide credible UK expansion plans, including set-up costs, monthly operating cost forecasts and revenue projections. Complex cases may still be subject to standard timelines.

Practical steps for businesses

• Overseas businesses considering UK expansion should assess early whether the UK Expansion Worker route is appropriate and whether they may be eligible for OfI support.

• Businesses should ensure that their UK expansion plans, entity structure, projected costs and supporting evidence are robust before submission.

Digital ID and right to work checks: Home Affairs Committee criticises policy development

The House of Commons Home Affairs Committee has published a report criticising the Government’s approach to digital ID policy development. The Committee found that the initial September 2025 announcement, which proposed mandatory digital ID for right to work checks, was made before proper consultation and detailed policy work had taken place. The Government has since moved away from mandatory digital ID as originally announced, but still intends to make digital right to work checks mandatory.

This follows last month’s update on the Home Office’s reversal of the April 2026 expansion of right to work check obligations for sponsors. While that earlier change reduced the immediate compliance burden on sponsors, the Committee’s report shows that wider reform of right to work checks remains firmly on the policy agenda.

The Committee noted that mandatory digital right to work checks would be a significant operational change for both employers and individuals. It recommended clearer cost and benefit estimates, a detailed implementation roadmap, better engagement with employers and the public, stronger privacy safeguards, and protection against “function creep” - where a digital ID system introduced for one purpose, such as right to work checks, is gradually expanded into other areas without proper scrutiny, clear legal limits or public consent. For employers, this reinforces the need for any future digital right to work regime to be supported by clear guidance, safeguards and accessible alternatives for individuals who may struggle with digital systems.

Practical steps for employers

• Employers should continue to monitor developments on digital right to work checks. Although mandatory digital checking is not yet in force, businesses may wish to review existing right to work processes, assess how much of their checking is already digital, and identify any categories of workers who may face practical barriers to digital-only processes.

• Employers should continue to ensure that right to work checks are carried out consistently and in line with current Home Office guidance, whilst keeping systems and processes under review ahead of anticipated further changes to the right to work regime.

Student sponsor updates

The Home Office has updated its Student sponsor compliance guidance, with the revised guidance applying from 1 June 2026. The update replaces the legacy Basic Compliance Assessment (“BCA”) framework with a new framework, including revised core requirement thresholds, a new Red-Amber-Green (“RAG”) rating system, accompanying compliance actions and transitional arrangements.

The BCA framework is used by UKVI to assess whether student sponsors are continuing to meet key compliance standards. The updated guidance is therefore important for education providers and student sponsors because it changes how compliance performance will be measured and categorised. The introduction of RAG ratings should give sponsors a clearer indication of compliance risk, but may also increase the need for early internal escalation where metrics begin to deteriorate.

The updated guidance also includes changes to how certain outcomes are treated when calculating BCA metrics, including clarification on refusal rate calculations and how withdrawn sponsorship before a visa decision is considered. Sponsors should therefore ensure that teams responsible for CAS allocation, student monitoring, compliance reporting and visa oversight understand the revised framework.

Practical steps for student sponsors

• Student sponsors should review the updated guidance and ensure that internal teams responsible for sponsor compliance understand any changes to BCA metrics, RAG ratings and related compliance actions.
• Where student sponsorship sits alongside worker sponsorship within the same organisation, sponsors should ensure that responsibility for each licence type is clearly allocated and that compliance records are maintained separately and accurately.
• Sponsors should also consider whether existing monitoring processes, escalation routes and reporting lines remain sufficient under the revised framework.