Business immigration updates for employers | March 2026

March has been a busy month for business immigration updates, with a host of changes implemented plus on the horizon. The changes include a series of amendments under the Statement of Changes, publication of what the increase in visa and sponsorship fees will be from 8 April 2026 and various important updates to the Home Office guidance for sponsors. We've summarised the key changes for businesses and employers to understand and, where necessary, take action to remain compliant.

The key amendments introduced within the Statement of Changes

On 5^th March 2026, the Home Secretary, Shabana Mahmood, released her Statement of Changes in Immigration Rules HC 1691, accompanied by an Explanatory Memorandum, impacting several immigration routes. Our summary focuses only on the key changes that businesses and sponsors need to be aware of, which include:

1. Visa Brake on Skilled Worker Applications from Afghan Nationals

A significant implication is that the UK Government has formally introduced a "visa brake": a fast‑acting mechanism allowing ministers to suspend visa routes for specific nationalities where high asylum claim rates are observed. From 12:01am on 26 March 2026, Skilled Worker visa applications submitted from outside the UK by Afghan nationals will be automatically refused, regardless of whether the individual already holds a valid Certificate of Sponsorship. This restriction is part of a wider set of visa‑brake measures also affecting the Student route for nationals of Afghanistan, Cameroon, Myanmar and Sudan. It is important to acknowledge that this new measure will not affect in-country applications or switching or applications made before 26 March 2026.

The policy is framed as a response to a high proportion of skilled worker visa holders later claiming asylum, with the Home Office signalling ongoing review but no immediate end date.

Source: Visa brake: changes to the UK visa system - GOV.UK

2. Higher English Language Requirement to Level B2 for Settlement

From 26 March 2027, the English language requirement for settlement applications (currently Indefinite Leave to Remain) will be increased from B1 to B2 level on the Common European Framework of Reference for Languages (CEFR). This will apply to applicants on many work routes including the Skilled Worker, Global Talent, Scale Up and Representative of an Overseas Business routes. This change is in line with the 'Earned Settlement' consultation which is currently under review by the Government.

This will mean that visa holders planning to settle in the UK from 26 March 2027, who do not have a UK degree taught ini English or the passport of a majority English language country will need to take a harder English language test to evidence with their ILR application.

3. New salary compliance for Skilled Workers

A major shift in the way that Skilled Workers are expected to be paid to ensure compliance and consistency. The Statement of Changes requires that for Certificates of Sponsorship (CoS) issued on or after 8 April 2026, sponsors must ensure those Skilled Workers receive the required salary in each pay period, which should be at least a monthly frequency or as otherwise specified in the worker's contract, rather than relying on annual salary calculations. This means that sponsors must ensure that both the minimum salary threshold and the applicable hourly going rate must be satisfied within each pay period, rather than waiting until the end of the year to check.

The UK Government has confirmed limited flexibility to average pay over longer periods in certain circumstances. For instance, those sponsored who work irregular hours, and receive uneven pay, must have their salary monitored over any 17-week period to ensure it at least equals to 17/52 of the required annual salary and the sponsor must confirm their working pattern. We interpret this to mean sponsors should add the working pattern to the CoS as a sponsor note.

Sponsors should take action to review their payroll arrangements and make sure they will be compliant for Skilled Workers, regardless of their working pattern, during each pay period. 

4. Global Business Mobility – Service Supplier route and Indian nationals

From 8 April 2026, the GBM – Service Supplier route will be amended to allow certain Indian service suppliers to enter the UK for up to 12 months, under the UK-India trade agreement. These changes are intended to allow the temporary movement of professionals delivering services covered by international trade agreements.

Employers sponsoring overseas workers should review their sponsorship compliance processes and workforce planning to ensure that they are aligned with these new Immigration Rules.

Source: Statement of changes to the Immigration Rules: HC 1691, 5 March 2026 - GOV.UK

Updated Home Office Sponsor Guidance

On 6^th March 2026, the Home Office published updated versions of each of the three principal Worker and Temporary Worker Sponsor Guidance documents, along with an updated Appendix D (record keeping) and the Sponsor a Skilled Worker guidance. The changes include the Home Office noting the requirement for both prospective and existing sponsors to read all parts of the sponsor guidance and keep up with changes to ensure compliance with sponsorship duties. We've detailed the key changes and the implications for sponsors below:

• Newly defined term "eligible role" – across the guidance documents, the requirement for a job role to be a "genuine vacancy" or "genuine employment" to be eligible for sponsorship has been replaced with a newly defined term "eligible role". For a job role to be an "eligible role" it must exist or be reasonably anticipated, meet all the requirements of the route the worker is being sponsored on (including skill level, hours and salary thresholds), comply with wider employment laws (such as the National Minimum Wage/National Living Wage and the Working Time Regulations), and be "appropriate to the business or organisation in light of its business model, business plan and scale". This final requirement provides the Home Office with a new discretion and proportionality grounds to refuse to allocate a Certificate of Sponsorship (CoS) where, for example, it does not consider the sponsor would be capable of paying the proposed salary.

• Job details – the guidance includes new paragraphs emphasising the importance of ensuring the job description on a worker’s CoS accurately reflects the role they will be doing. If the worker's role changes after they have been granted permission, and that change does not require a change of employment application, the sponsor must notify the Home Office within 10 working days of the date from which the change in duties is effective. The guidance stresses that where a sponsor fails to report such a change and this is identified as part of a Home Office compliance check, it could cost a sponsor their licence.  

• "Reasonable suspicion" – the updated guidance clarifies that the burden of proof in sponsor licence decisions is that the Home Office can take action in the event of "reasonable suspicion" that the sponsor has not complied with sponsor guidance or is likely to not-comply with sponsor guidance in the future. This seemingly broadens the circumstances the Home Office may refuse a prospective sponsor's application for a sponsorship licence or revoke a sponsor's licence. This is emphasised by the addition to the guidance document that a sponsor licence creates no property or enforceable right for the sponsor, clarification that membership of the sponsorship scheme is voluntary, and that the granting of a licence is at the discretion of the Home Office. Such additions emphasise the Home Office's discretion in respect of sponsorship licences and the minimal recourse for prospective sponsors in the event of a refusal of a sponsorship licence, or revocation of a sponsor licence.

• Worker's rights and welfare – the guidance now includes explicit reference to sponsors' responsibility to ensure worker's rights and welfare, which extends to ensuring that workers understand their employment rights. Further, the guidance provides that sponsors must have processes in place and records retained to demonstrate that this information has been provided to sponsored employees or workers (e.g. contracts, training logs etc.). This duty applies to all employees and workers you currently sponsor, so looking back and ensuring personnel records are up to date is key, or ensuring training is provided and recorded.

• Right to work checks – the guidance clarifies that the requirement to check a sponsored worker’s right to work extends to any worker engaged by the sponsor, including those who are not the sponsor's direct employee. This applies even if the worker is, or appears to be, a British citizen or other settled worker. This seems to be in line with the new right to work laws coming in for all employers, but the Home Office is implementing this duty in advance to sponsors prior to the wider roll out.

It had been anticipated that further guidance would be included on when and how employers are permitted to ‘claw back’ some immigration costs in circumstances where a sponsored worker leaves their employment early, but there were no more changes made on this aspect in the new guidance.

We would encourage all Key Personnel on a sponsorship licence to read the relevant parts of the sponsor guidance, appendices and glossaries for the routes you sponsor or are considering applying for and to remain aware of any changes. Sponsors may consider identifying a specific individual who will be responsible for reviewing the relevant guidance and tracking those changes.

Rise in visa fees from 8 April 2026

From 8 April 2026, many visa and sponsorship fees will rise by 6 – 7%. The key increases for sponsors to note are: 

• Electronic Travel Authorisation (ETA) fee will increase from £16 to £20;
• Skilled Worker visa fee and Global Business Mobility visa fee for Senior or Specialist Workers for applicants outside the UK for sponsorship for three years or less will both increase from £769 to £819, over three years from £1,519 to £1,618 (no exemptions);
• Skilled Worker visa fee and Global Business Mobility visa fee for Senior or Specialist Workers for applicants inside the UK for sponsorship for three years or less will both increase from £885 to £943, over three years from £1,751 to £1,865 (no exemptions);
• For small employers considering applying for a sponsorship licence, under the Worker and Temporary Worker routes, the fee increases from £574 to £611;
• For medium/large employers considering applying for a sponsorship licence, under the Worker and Temporary Worker routes, the fee increases from £1,579 to £1,682; and
• Indefinite Leave to Remain – main applicant and dependants from £3,029 to £3,226.

Fees which are staying the same include Certificate of Sponsorship fees across all sponsored routes, priority and premium service fees.

Source: Home Office immigration and nationality fees, 8 April 2026 - GOV.UK

Visitor visa applicants issued eVisas and travel documents added to UKVI accounts

The UK continues its move towards a fully digital immigration system:

• From 25 February 2026, most successful applicants for a UK visit visa will now receive only an eVisa, with no physical vignette or sticker issued. The eVisa links digitally to the traveller’s passport and is accessible via a UKVI account. This should make it much easier for business visitors. Carriers verify permission through Advance Passenger Information feeds rather than inspecting physical documents.
  
  Existing physical immigration documents can be updated to an eVisa without any effect to the individual's immigration status, or conditions of permission to enter or stay in the UK.
  
• From 11 March 2026, Home Office travel documents will automatically be linked to an individual's UKVI account to enable travel documents to be viewed alongside eVisas. When an individual receives a new travel document, it will appear in their UKVI account within 2 working days of the decision.

However, the Home Office has issued its guidance to confirm that individuals should continue to carry their Home Office travel documents with them when they travel, as physical Home Office travel documents will continue to be provided to individuals when they apply.  

Source: Updates on the move to eVisas - GOV.UK

Migration Advisory Committee ("MAC") launches self‑commissioned review on talent attraction

MAC has launched its own independent, self‑commissioned review to evaluate how the UK’s immigration system can better attract global talent.

Announced on 27 February 2026, the review focuses on the effectiveness of talent‑focused routes such as the Global Talent, Innovator Founder, and Skilled Worker visas. The study will examine how well the routes interact, the economic contributions of highly skilled migrants, and whether current definitions and endorsement models remain fit for purpose.

The MAC aims to complete the review by winter 2026, aligning its recommendations with longer‑term economic and labour‑market objectives.

Source: Letter to the Home Secretary on MAC's review into talent routes

Electronic Travel Authorisation ("ETA") for dual british nationals

Recent ETA enforcement changes have created new compliance requirements for dual British nationals, as they cannot obtain an ETA and must travel to the UK using a valid UK passport or Certificate of Entitlement. Previously, they have been able to travel on a passport of their other nationality, as long as that nationality is not on the UK's visa national list.

Temporary Carrier Discretion & Emergency Documents

The Government has confirmed that where an individual has none of the above documentation available, temporary guidance permits carriers to use discretion to board travellers who present an expired UK passport issued in 1989 or later, and a valid passport from non-visa national third country (provided the biographic details match). However, carriers may still refuse boarding. As such, individuals without acceptable documents should apply for an emergency travel document, though this is limited to those who previously held a UK passport unless the urgent travel meets the exceptional circumstances criteria.

Dual British Nationals with EU Settlement Scheme Status (EUSS)

The Government has updated its guidance for British dual nationals with EUSS status to confirm that EUSS status holders can travel using their other nationality passport or identity card (where they are an EU, other EEA or Swiss national) providing that document is linked correctly to their UKVI account.

Source: Written statements - Written questions, answers and statements - UK Parliament ; Dual citizenship - GOV.UK ;

In summary, the changes above typically demonstrate a tightening of the overall sponsorship framework and signal the government's approach to business immigration that treats sponsorship as a privilege, which sponsors must continuously justify through meticulous compliance and alignment with the Home Office's broader objectives.

Please get in touch with our business immigration team on the contact details below if you require further advice on the changes, sponsorship licences or sponsor duties more generally.