Business immigration updates for employers | November 2025

Following a busy month of developments in October, November has been a quieter, but more significant, month. The key update this month has been the release of the Home Secretary's proposals to overhaul the current Indefinite Leave to Remain provisions with a new "earned settlement" model, which has been eagerly awaited by both sponsors and migrants since it was first mentioned in Labour's Immigration White Paper in May 2025. 

The public consultation is launched on the new "Earned Settlement" model to replace the Indefinite Leave to Remain conditions for the majority of migrants

On 20 November 2025, the Home Secretary outlined the proposed change to double the permanent settlement qualifying period (also known as Indefinite Leave to Remain) for most migrants from 5 to 10 years. This has been driven by an intention to control the UK settlement system through various adjustments (both upwards and downwards) to the 10-year path depending on personal circumstances, designed to "reward those who contribute and play by the rules".

Please see our latest article here for the details on these significant proposals and details on how you can respond to the public consultation by the deadline of 12 February 2026.

UK Electronic Travel Authorisation (ETA) to be strictly enforced from February 2026

While the ETA has been rolled out since January 2025, it has not been strictly enforced, to give visitors time to adjust to the new requirements. However, this is set to change as the Home Office has announced that from 25 February 2026, the ETA will be strictly enforced such that everyone travelling to the UK must have digital permission through either an ETA or an eVisa. This will involve carriers checking individuals before they travel.

Visitors from 85 nationalities, including the United States, Canada and France, who do not need a visa will not be able to legally travel to the UK without an ETA. However, those who are exempt from immigration control or those who require a visa, will not require an ETA. The UK government strongly advises dual British citizens to make sure they have a valid British passport or certificate of entitlement, to avoid problems like being denied boarding when travelling to the UK from 25 February 2026.

Those requiring ETAs can apply through the official UK ETA app. While most individuals currently receive a decision automatically in minutes, it is recommended to allow 3 working days to account for a small number that require additional review. In our experience, those applying for an ETA with previous criminal history are coming across delays, and even rejections, so business visitors expectations should be managed in such instances.

Source: No permission, no travel: UK set to enforce ETA scheme - GOV.UK

Updated sponsor guidance confirms several new updates

On 11 November 2025, the Home Office updated several of its sponsorship guides for employers and educators, which includes several new updates relevant to sponsors. The key updates include:  

• The Premium customer service, which provided an enhanced level of support for eligible sponsors, closed on 30 November 2025.

• The trial of the new sponsorship IT system that has been in place for certain sponsors in the Government Authorised Exchange (GAE) scheme has been abandoned and those sponsors will return to using the existing standard processes and Sponsor Management System (SMS).

• While the SMS currently allows two levels of access – 'Level 1' and 'Level 2' users, the Home Office intend to phase out Level 2 users. This reflects the distinction between Level 1 and Level 2 functions being diminished in practical terms. Sponsors do not need to take immediate action as we do not know when this change will become effective, but are advised to plan ahead for this change.

• There is a new clarification on ‘branches’ of sponsors (which includes different offices, UK-based subsidiaries and or entities, locations or campuses), so that where a branch is currently unregistered on the licence, a sponsored worker working for the main sponsor/one of its registered branches can move to work for the unregistered branch before it is approved by the Home Office provided certain criteria are met. Please see updated guidance at paragraphs s1.27-s1.32 for those criteria here.

• New clarification that if a worker moves sponsor under TUPE or similar protection, the original sponsor will not receive a refund of any Immigration Skills Charge they have paid.

• In relation to right to work checks and record keeping under Appendix D, this has been updated to confirm that sponsors conducting an online right to work check must use the "Check a job applicant’s right to work: use their share code" online service on GOV.UK, rather than the "Check someone’s immigration status" or "Check a tenant’s right to rent" services. In relation to evidence of entry to the UK, where a worker does not have an entry stamp in their passport, it now details the reporting obligations for offshore workers who arrived in UK waters without first entering the UK landmass.

Source: https://www.gov.uk/government/collections/sponsorship-information-for-employers-and-educators

Expanded Global Universities List for High Potential Individual (HPI) visa route published

On 4 November 2025, the Home Office published the expanded Global Universities Lists for qualifications awarded between 1 November 2020 and 31 October 2026, from 50 to 100 eligible universities.

The HPI visa route enables graduates of top global universities to come to work in the UK for 2 years without a job offer provided certain criteria are met. While the eligible universities have doubled, a new annual cap of 8,000 applications has been introduced. The application year runs between 1 November and 31 October. Applicants will be made aware that the cap has been reached when they apply online. We would encourage all businesses to review the expanded list and ensure that recruitment teams are aware of the HPI visa route, after all this route doesn't require sponsorship, so would be a cost-effective visa option.

Source: High Potential Individual visa: global universities list - GOV.UK

Further extension to the UK-Switzerland Services Mobility Agreement

A further extension to the existing UK-Switzerland Services Mobility Agreement (SMA) has been agreed to cover the next 4 years, to 31 December 2029. The SMA allows:

• UK professionals to travel freely to Switzerland and to work and deliver services without a visa for up to 90 days per year. The agreement also ensures that UK professionals do not face economic interests' tests or be required to secure work permits during these first 90 days of service supply; and

• Swiss professionals to travel to the UK and provide services under contract in several key skilled sectors through the UK's service supplier visa for up to 12 months.

Source: Update on the UK-Switzerland Services Mobility Agreement - GOV.UK

If your require any legal advice on the subject of business immigration, please contact our team.