Looking ahead to 2026 – Business immigration horizon scanner

As we wrap up 2025, we've put together a short summary of the key business immigration changes expected in 2026 to help you prepare and look ahead.  With major reforms to the Indefinite Leave to Remain (ILR) system, increased English language requirements for new skilled workers and a new Temporary Shortage List due to be released this time next year, this article outlines the changes on the horizon which could influence workforce planning in 2026 and beyond.

January

8^th January 2026 – the English language requirement will be raised from CEFR level B1 (strong GCSE standard) to B2 (closer to an A-Level standard) for all new applications under the Skilled Worker, Scale-Up and High Potential Individual (HPI) routes. This will affect new applications for their first grant under these routes submitted on or after 8^th January. Those already in these routes can extend under the old requirements.

23^rd January 2026 – In the wake of the Government's announced proposals to overhaul the current Indefinite Leave to Remain (ILR) regime with a new "earned settlement, the Justice and Home Affairs Committee have launched an inquiry into settlement, citizenship and integration and has published a Call for Evidence.

Key areas of focus for the inquiry will include: the complexity and cost of applying for ILR and British citizenship, experiences of applicants and barriers in the current system, review of the "Life in the UK" test to potentially inform how the Government "refreshes" the test, the impact of the English language requirements for those coming to the UK on integration, and the consequences of becoming a British citizen compared to remaining on Indefinite Leave to Remain.

The Committee is particularly keen to hear from those with experience of the process and the deadline for written submissions in response to the call for evidence is 23^rd January 2026 and further information can be found here: Call for Evidence - Committees - UK Parliament. 

February

2^nd February 2026 – closing date for the Migration Advisory Committee's (MAC) call for evidence about the occupations which should be added to the Temporary Shortage List (TSL). The MAC will only review evidence in relation to the occupations it identified during its first stage review as being potentially crucial to the delivery of Industrial Strategy or building critical infrastructure. Annex A of the MAC's first stage report sets out the 2020 occupation codes and which of them progressed to stage 2. Here is the link to submit online responses before the closing date: https://www.gov.uk/government/calls-for-evidence/temporary-shortage-list-review-stage-2

12^th February 2026 – closing date for the public consultation on the new "Earned Settlement" model. Currently, someone who holds a Skilled Worker visa must complete five years in the UK to qualify for Indefinite Leave to Remain (ILR), or permanent residence. The Government is consulting on changing this to a ten-year path, and in some cases, it may be even longer. Employers, sponsors and individuals are strongly encouraged to engage with this consultation on how the proposed 10-year performance-based route for ILR will impact the economy and workforce.   

25^th February 2026 – The UK's Electronic Travel Authorisation (ETA) scheme will be strictly enforced, by carriers, before boarding from 25^th February 2026. This means that all visitors from currently visa-exempt countries (i.e. US, Canada and EU nations) must have an approved ETA to travel to the UK from this date. Business visitors will need to apply online for an ETA, pay £16 and once approved, it will last for 2 years or until the applicant's passport expires, whichever is sooner.  Applicants can then travel to the UK as many times as they want while their ETA is approved.

April

Spring – The new Earned Settlement model is due to come into effect for future ILR applications and those already on the path to ILR.

July

July 2026 – end of the MAC's second stage review of the Temporary Shortage List. The MAC's stage 2 report will ultimately detail the occupations that the MAC recommends to the Home Secretary for inclusion on the revised TSL.

December

Last quarter of 2026 – The European Travel Information and Authorisation System (ETIAS) is due to become operational in the last quarter of 2026. The ETIAS is an entry requirement for visa-exempt nationals travelling to 30 European countries, which travellers will need to apply for in advance and will cost EUR 20. The ETIAS is linked to a traveller's passports and is valid for up to three years or until the passport expires. With a valid ETIAS, travellers can enter the territory of European countries as often as they want for short-term stays (normally up to 90 days in any 180-day period).

31^st December 2026 - The Temporary Shortage List is due to have its current roles removed on 31^st December 2026, with the ongoing roles being confirmed once the Migration Advisory Committee has concluded stage two of its review.

Dates to be confirmed

Expansion of the illegal working regime – Section 48 of the Border Security, Asylum and Immigration Act 2025 received Royal Assent on 2 December 2025. This new legislation significantly extends the scope of right to work regime and expands liability for an illegal working civil penalty. Under this new regime, workers (gig-economy, zero hours etc.), self-employed contractors and service providers matched through online job matching platforms will be caught. The public consultation on these changes to right to work checks closed on 10 December 2025. We must now await the date this will come into effect, but we can expect the launch of revised right to work guidance and a public awareness campaign for businesses.

Looking into 2027

1 January 2027 – The Graduate route is due to shorten its length from 2 years to 18 months for most students applying for a graduate visa to remain in the UK. This will reduce the timeline for employers to assess potential before offering sponsorship.

If you need business immigration advice or wish to discuss any of these upcoming changes, please contact our immigration team using the details below.