Business immigration updates for employers | March 2025

In the constantly evolving world of immigration, we have highlighted below the main updates and developments for employers that have been released this month:

Extension to BRP deadline

At the end of February, the Government announced that holders of biometric residence permits (BRPs) and biometric residence cards (BRCs) which expired on 31 December 2024 can continue to use them for international travel until 1 June 2025, provided that they still hold valid immigration status.

The original deadline of 31 December 2024 was previously extended to 31 March 2025 and has now been further extended to try and make the transition to the new digital system as smooth as possible. However, the Home Office have confirmed that there will be no further extension. At the time of the announcement, it was estimated that around 600,000 BRP holders still needed to create a UKVI account to access their eVisa. We would recommend that individuals, who have already transitioned to the eVisa, continue to carry their expired BRP or BRC when travelling overseas.

Employers should be encouraging their staff with expired BRPs and BRCs to switch to a UKVI account and access their eVisa as soon as possible. This could be via email communication, updated intranet pages, posters, manager conversations, weekly team updates – whichever means works best to get this final message out to your workforce.

ETA applications for EU nationals now open

From 2 April 2025, eligible EU nationals will require an electronic travel authorisation (ETA) to visit the UK. This means that all business or tourist visitors from the list of European countries here, will need an ETA to travel to the UK from this date. Eligible EU nationals can apply for the ETA now through the official UK government website or via the UK ETA app. This is already mandatory for non-European non-visa nationals.

Once granted, an ETA is typically valid for two years or until the holder's passport expires, whichever comes first.

UK employers, who are part of a wider overseas corporate group, should be prepared for the ETA introduction, ensuring any employees from the overseas entities are applying for their ETA in good time, and if individual circumstances give rise to an ETA rejection, legal advice is sought.

Statement of Changes in Immigration Rules

Earlier this month, the Home Office issued a new Statement of Changes detailing several updates to the Immigration Rules, which will come into force at various points between March and August this year. We have outlined several of the key changes for sponsors to be aware of below:

New visa requirement for Trinidad and Tobago nationals

Trinidad and Tobago have been added to the visa national list with immediate effect. This means that instead of applying at the UK border, Trinidad and Tobago nationals must now apply for and obtain a visitor visa prior to travelling to the UK or for any other purpose for less than six months.

However, a transitional period provides that such individuals with travel bookings confirmed prior to 15:00 on 12 March 2025 are exempt from this requirement provided they arrive in the UK no later than 15:00 on 23 April 2025.

Several changes for Skilled Worker visas

• Sponsors recruiting care workers

From 9 April 2025, sponsors wanting to recruit international care workers and senior care-workers with a job location entirely in England, must prioritise recruiting from the existing displaced pool of overseas care workers in the UK before they can sponsor new recruits from overseas. These changes are being made in response to the growing pool of displaced care workers who no longer have sponsorship, because their sponsors have been unable to offer sufficient work and/or have lost their sponsor licences.

To evidence this requirement is met, sponsors must provide confirmation from the relevant regional or sub-regional partnership that they have tried to recruit in this way and confirm that no suitable workers were available from the displaced pool, before relevant entry clearance/leave will be granted.

The changes do not apply to workers in England who were already sponsored in these occupations before the changes take effect (including those changing employers), or those switching from other immigration routes who have been working lawfully as care workers or senior care workers for at least three months. For clarification, where applications for entry clearance or permission to stay for care workers or senior care workers is made using a certificate of sponsorship issued by a sponsor to an applicant on or after 9 April 2025, such applications will be decided without the update above being required. We would expect the numbers of defined CoS for care workers and senior care workers to drop considerably for a period once this change is implemented.

• Increase to the minimum salary threshold for certain visa applicants (includes care workers)

The lowest minimum salary threshold that applies to existing skilled worker visa holders before 4 April 2024 (under the categories for PhD, immigration salary list, new entrant or health and education roles) is being increased from £23,200 per year (or £11.90 per hour) to £25,000 per year (or £12.82 per hour). In addition, the going rates for individual occupations in healthcare and education are also being updated to reflect the latest pay scales.

These higher salary thresholds will apply from 9 April 2025. The additional costs will therefore need to be factored into sponsor's budgets.

• Changes to rules concerning deductions from an applicant's salary

Changes are being made to the rules concerning deductions from an applicant's salary to ensure consistency with how paid allowances for the same purposes are treated, to mitigate against sponsorship costs being passed on to applicants, and to close an unintended loophole whereby applicants could effectively pay towards their own salary through investing in their sponsor's business. We are hoping that the Home Office will provide more clarity on this new provision once the updated guidance is published on 9 April 2025.

• New entrant training salary reduction requirements

A change is being made to confirm that where an applicant is claiming a "new entrant" salary reduction based on training towards a recognised professional qualification, this must be a UK qualification.

More increases to immigration fees

From 9 April 2025, there will be significant increases to certain immigration services and products. Travellers to the UK can expect a 60% increase on ETA fees, up from £10 to £16. Sponsor licence application fees and most visa application fees under the skilled worker and Global Business Mobility routes will rise by 7%. It has also been confirmed, after much speculation, that the cost of assigning a Certificate of Sponsorship ("CoS") will increase by 120%. That means up from £239 to £525 for skilled workers and Global Business Mobility, senior or specialist workers and up from £25 to £55 for temporary workers.

Employers and sponsors should factor in these increases for any future applications. We will no doubt see a surge of sponsors wishing to allocate CoS and encourage applicants to submit their visa applications before 9 April to avoid the fee increases.

Revised timeline for the Entry/Exit System (EES) and European Travel Information and Authorisation System (ETIAS)

The timeline for the implementation of the Entry/Exit System (EES) and the European Travel Information and Authorisation System (ETIAS) has been updated.

The EES is a new automated IT system for registering non-EU nationals travelling for a short stay to one of the 29 European countries. No action will be required from travellers before they start their trip. Registration of the EES will be done every time travellers cross external borders and will replace the manual stamping of passports. The EES is now expected to become operational in October 2025.

Whereas the ETIAS is a new entry requirement for travellers who do not need a visa to enter one of the 29 European countries as well as Cyprus. With ETIAS, visa-free travellers will need to act and apply for travel authorisation before starting their trip. ETIAS is expected to be launched in the last quarter of 2026.

If you have any queries or require advice on these developments. Please contact the immigration team on the contact details below.