On 1 July 2025, the UK Government enacted substantial amendments to the possible Immigration Rules changes under Statement of Changes HC 997. These reforms reflect a strategic tightening of economic migration criteria, aimed at reducing overall migration numbers while recalibrating the Skilled Worker route to favour high-wage and high-skill occupations.

These changes are consistent with the government’s ongoing migration reform agenda, following the 2024 MAC (Migration Advisory Committee) recommendations. The new rules directly affect both individual applicants and UK-based sponsor licence holders. Understanding their legal and practical implications is crucial for compliance and forward planning.

At Axis Solicitors, we’re seeing first-hand how these changes are impacting our clients across sectors—from care homes and SMEs to multinational tech firms. In this comprehensive blog, we break down the major provisions of HC 997 and what they mean for those navigating the UK immigration system today.

Skilled Worker Route – Raised Salary and Skill Thresholds

The Skilled Worker route has undergone pivotal reforms under the UK immigration changes introduced by HC 997. These updates, effective from 22 July 2025, reflect a decisive move to tighten eligibility, reduce net migration, and prioritise higher-skilled, higher-paid workers.

Elevated Salary Thresholds Across All Bands

Under the new rules, salary requirements have increased substantially:

• Band A roles (e.g. engineers, IT professionals): Raised from £38,700 to £41,700
• Bands B & G (e.g. business analysts, mid-level professionals): Increased from £26,100 to £28,200

Only the first 48 hours per week will count towards meeting salary thresholds, eliminating the ability to inflate earnings through excessive overtime. This aligns with Home Office efforts to ensure fair pay standards and close loopholes.

Shift to RQF Level 6 and Above

A major shift in eligibility is the requirement for all roles to meet RQF Level 6 or higher, equivalent to degree-level skill. Previously eligible RQF Level 3–5 roles—such as care workers, retail supervisors, or warehouse shift leaders—no longer qualify unless they fall within temporary shortage or transitional categories.

This update significantly narrows the Skilled Worker route to a more selective group of applicants and sectors.

Supplementary Employment Expanded for Legacy Workers

Workers granted Skilled Worker visas before 22 July 2025 may now engage in supplementary employment in a broader list of eligible occupations. This offers some added flexibility, but only if their status remains continuous and compliant.

Temporary Shortage Occupation List – Major Revisions and Removals

One of the more controversial aspects of the UK immigration changes introduced through HC 997 is the near-dismantling of the Temporary Shortage Occupation List (TSOL). This list, previously designed to ease visa conditions for sectors facing acute labour shortages, has been drastically narrowed.

Purpose of the TSOL (Before HC 997)

Before July 2025, the TSOL allowed employers to recruit workers at a 20% lower salary threshold and reduced visa fees for designated shortage roles. This was particularly vital for sectors like:

• Social care
• Construction
• Hospitality
• Agriculture
• Engineering

Many SMEs and care providers relied heavily on the TSOL to remain operational while recruiting internationally.

Post-HC 997 Revisions – What Changed?

The new rules have:

• Removed almost all low-skilled and mid-skilled roles from the TSOL
• Retained only a minimal number of RQF level 6+ roles, mainly in STEM and niche technical fields
• Abolished the 20% salary discount—all roles must now meet the full Skilled Worker threshold

This reform effectively strips the TSOL of its original purpose. The government has justified this move by stating that shortage roles should not be a “backdoor” to permanent migration and that employers must invest in UK-based recruitment and training.

Who Is Most Affected?

The impact is sharpest in the care sector, which had relied heavily on the TSOL to recruit care workers from overseas. Under HC 997:

• Care workers (SOC code 6145) are no longer eligible under TSOL, unless sponsored under specific transitional pathways (e.g. Health and Care Worker route)
• Roles such as chefs, bricklayers, and welders, previously recognised under TSOL, are now excluded unless meeting full salary and skill thresholds
• Hospitality and retail sectors lose nearly all access to sponsorship unless they pivot to higher-paid managerial roles

The Migration Advisory Committee (MAC) had recommended many of these cuts, asserting that reliance on migrant labour was unsustainable. However, employers across sectors argue that the transition has been too abrupt and lacking in support mechanisms.

Strategic Implications for Employers

Organisations previously dependent on TSOL roles must now:

• Restructure their recruitment models
• Redefine job descriptions to meet RQF level 6 equivalency
• Consider automation or training programmes to fill gaps domestically

For those who still wish to recruit from abroad, Axis Solicitors recommends exploring routes like:

• Global Talent visa (where applicable)
• Graduate visa for recent international students
• Scale-up Worker visa, subject to employer registration

Each of these routes comes with its own eligibility criteria and compliance duties, which must be understood in full.

Closure of the Afghan Relocations and Assistance Policy (ARAP)

The HC 997 statement of changes marks the formal closure of the ARAP scheme, effective 1 July 2025. This scheme, introduced in 2021, was designed to resettle Afghan nationals who worked alongside UK forces in Afghanistan, particularly those employed by the British Armed Forces, Embassy, or related contractors.

Its closure represents a turning point in the UK’s commitments to refugee protection and post-conflict obligations.

What Was the ARAP Scheme?

ARAP was a flagship relocation and protection initiative established during the final phase of the UK’s withdrawal from Afghanistan. It offered eligible Afghan nationals and their families:

• Indefinite Leave to Remain upon arrival
• Full access to public funds, housing, and employment
• Relocation support funded by the UK government

The programme was regarded as a moral and strategic obligation to those who had served UK interests abroad, often at grave personal risk.

HC 997 – Termination Clauses and Justification

HC 997 announces that no new ARAP applications will be accepted from 1 July 2025. The closure is justified on the basis that:

• The UK has now resettled the “overwhelming majority” of eligible individuals.
• Ongoing humanitarian assistance will now fall under general refugee protection frameworks.
• The government aims to streamline immigration priorities toward economic migration and border control.

Key Legal and Humanitarian Concerns

The end of ARAP has raised several issues among human rights organisations and immigration solicitors:

• There is no formal appeal mechanism for those denied under ARAP before 1 July 2025.
• Thousands of cases remain pending or unprocessed, many of whom are still in high-risk regions.
• The closure appears to conflict with international obligations under the 1951 Refugee Convention and UK’s moral commitments post-intervention.

At Axis Solicitors, we are monitoring legal challenges to the closure, including potential judicial reviews.

For Affected Applicants and Families

Individuals with pending ARAP applications or those seeking family reunification should:

• Seek legal representation immediately
• Retain all communication with the MOD or Home Office as evidence
• Explore parallel protection routes, such as asylum or Article 8 ECHR claims (right to family and private life)

Axis Solicitors is assisting eligible individuals in preparing late protection claims and appeals under human rights grounds, particularly where family reunification is at stake.

New Compliance and Sponsor Licence Obligations

The UK immigration changes introduced via HC 997 have not only revised eligibility criteria for workers, but also tightened the rules for sponsor licence holders. These reforms are aimed at strengthening Home Office oversight, minimising abuse of the sponsorship system, and ensuring that only compliant, credible sponsors are granted access to international labour.

Heightened Scrutiny of Salary Compliance

Under the new regime, salary underpayment or inconsistencies can now result in immediate action against the sponsor, including:

• Suspension of the sponsor licence
• Revocation of previously approved Certificates of Sponsorship (CoS)
• Civil penalties and Home Office audits

Sponsors are expected to fully document how the salary offered meets or exceeds the new thresholds, particularly in transitional or hybrid roles where the job function overlaps multiple SOC codes.

Axis Solicitors has observed increased Home Office auditing activity in this area. Employers must now be able to produce:

• Signed employment contracts
• Payroll records for sponsored workers
• Accurate SOC code justifications
• Evidence of ongoing salary payments matching what was declared in the CoS

Real-Time Reporting Requirements

HC 997 has also shortened the timeframe for reporting changes in circumstances for sponsored workers. Sponsors must now report:

• Changes in work location
• Adjustments to salary
• Changes in job title or responsibilities
• Absences or unpaid leave exceeding 10 working days

These must be reported via the Sponsor Management System (SMS) within 5 working days, a reduction from the previous 10-day window. Failure to comply is now classified as a major breach.

Sponsorship of Transitional Roles – Evidence Burden

Sponsors wishing to hire individuals under transitional exemptions (e.g. social care workers during the sunset period) must now submit:

• Explicit confirmation of the role’s transitional eligibility
• Documented efforts to recruit locally (where applicable)
• Assurance that the worker’s duties will not exceed the limitations of the transitional SOC code

This additional evidence burden increases the cost and complexity of sponsorship, especially for small employers without in-house legal teams.

Digital Right to Work Checks – Enforcement Tightening

The Home Office is also cracking down on employers relying on outdated manual right-to-work checks. HC 997 aligns immigration enforcement with digital verification platforms and introduces fines of up to £60,000 for employers found to have employed illegal workers.

Sponsors must now:

• Use certified digital identity providers (IDSPs) for right-to-work checks
• Maintain up-to-date records in line with revised sponsor duties
• Complete annual internal audits to flag non-compliance risks

Axis Solicitors offers Sponsor Compliance Audits to help employers identify and address risk points before they attract Home Office enforcement.

 

Implications for Existing Visa Holders and Transitional Pathways

One of the most critical concerns following the July 2025 HC 997 reforms is how the changes apply to those already in the UK on a Skilled Worker visa or awaiting decisions. Axis Solicitors has received a surge in enquiries from individuals caught between old and new criteria. This section addresses their position under the revised rules.

Are Current Visa Holders Affected?

Existing Skilled Worker visa holders will not be retrospectively impacted by the new salary or skill thresholds — provided they remain in the same job with the same sponsor. However, the moment a visa holder:

• Changes employer
• Switches job role
• Applies for an extension
• Applies for Indefinite Leave to Remain (ILR)

—they may become subject to the new HC 997 thresholds.

In other words, your visa remains valid, but any future application or change must meet the new, higher standards unless a transitional exception applies.

Transitional Concessions – Who Qualifies?

The Home Office has introduced limited transitional arrangements for applicants who:

• Have a pending CoS assigned before 1 July 2025
• Are already in the UK on a Skilled Worker route and seeking an extension or ILR
• Are applying under a job that was eligible before HC 997 but is no longer listed

These transitional concessions generally expire on 31 July 2026, giving applicants and employers 12 months to adjust or reapply under legacy rules.

Examples of transitional concessions:

• A care worker in the UK on a Skilled Worker visa issued in 2024 may apply for an extension without meeting the new £38,700 threshold.
• An employer with an unused CoS issued before 1 July 2025 may still sponsor under the previous rules, but must act before the CoS expires or the July 2026 cut-off.

Switching Categories – Increased Barriers

Switching from lower-skill visas (e.g. Graduate, Youth Mobility, or Temporary Worker) to the Skilled Worker route is now significantly harder. Previously, roles such as:

• Customer service managers
• Retail supervisors
• Junior chefs

could be used as a stepping stone to permanent migration. Under HC 997, most of these roles no longer qualify, unless they meet the new RQF 6 and salary benchmarks.

This change limits the upward mobility of many temporary workers and graduates, effectively closing the route to settlement for certain categories unless they transition into higher-paid roles.

ILR Eligibility – Salary Implications

Those approaching the five-year ILR threshold under the Skilled Worker route must ensure their salary at the point of ILR application meets the updated threshold. If their salary remains at the old level, they may:

• Be refused ILR
• Be forced to extend their visa under transitional rules (if eligible)
• Consider alternative settlement routes

Axis Solicitors advises all visa holders approaching extension or ILR points to undergo a legal assessment to determine if their position aligns with post-HC 997 requirements.

Key Action Points for Existing Visa Holders:

• Confirm your job’s current SOC code eligibility with updated guidance
• Assess upcoming extensions or job changes and how they interact with HC 997
• Do not delay in acting on transitional protections—they are time-limited
• Consider legal advice for ILR planning, especially if you fall near salary thresholds

Frequently Asked Questions

Here, Axis Solicitors answers the most common and urgent questions from clients, employers, and visa applicants following the UK immigration changes introduced by the HC 997 Immigration Rules on 1 July 2025.

1. What are the most important UK immigration changes in HC 997?

The most critical UK immigration changes in HC 997 include:

• A salary threshold increase for Skilled Worker visas, now set at £41,700
• Raising the skill requirement from RQF level 3 to RQF level 6
• A major reduction of roles on the Temporary Shortage Occupation List
• The closure of the ARAP scheme for Afghan nationals
• Stricter compliance and reporting duties for sponsors

These changes reflect a shift in the UK’s immigration policy towards higher-skilled, higher-paid roles, while significantly limiting access for mid- and low-wage sectors.

2. Do the UK immigration changes apply to current visa holders?

Most UK immigration changes introduced on 1 July 2025 will not apply retrospectively to those already in the UK on a valid Skilled Worker visa. However, if an existing visa holder:

• Changes employer
• Changes job role
• Applies for a visa extension or settlement (ILR)

they may then be subject to the new salary and skill thresholds unless they qualify under transitional exemptions.

3. Which occupations are no longer eligible under the new UK immigration changes?

The HC 997 UK immigration changes have removed a range of occupations previously accepted under the Skilled Worker route. Roles that no longer qualify include:

• Care assistants (except in limited transitional cases)
• Waiters, kitchen assistants, and bar staff
• Retail supervisors and customer service managers
• Junior chefs and hospitality team members

Employers hiring for these roles will now need to explore alternative visa routes or refocus recruitment efforts locally.

4. Can my employer still sponsor me under the old salary rules?

Only under specific transitional provisions. If your Certificate of Sponsorship (CoS) was assigned before 1 July 2025, and your role was eligible under previous criteria, your employer may still sponsor you under the old rules. However:

• The CoS must be used before its expiry date
• Transitional rights end on 31 July 2026
• Evidence of eligibility under the old rules must be provided

Axis Solicitors can assist with verifying whether your role and timing qualify for these exceptions under the new UK immigration changes.

5. What is RQF level 6 and how does it affect Skilled Worker eligibility?

RQF (Regulated Qualifications Framework) level 6 refers to degree-level qualifications. The UK immigration changes now require jobs to meet this level or above to be eligible for sponsorship under the Skilled Worker route.

Jobs that were previously eligible at RQF level 3 (A-level equivalent) have been excluded, unless they fall within transitional categories or specific exemptions like the Health and Care visa.

6. What happens if my employer doesn’t meet the new compliance standards?

Failure to comply with the new sponsorship rules under the UK immigration changes could lead to:

• Suspension or revocation of the employer’s sponsor licence
• Refusal of pending visa applications
• Penalties, audits, or reputational damage

The Home Office now requires evidence of ongoing salary compliance, real-time reporting of job changes, and regular audits of employment records. Axis Solicitors offers full compliance review services to ensure your sponsor meets the revised legal standard.

7. Are there still options for migrants in low-paid roles?

Yes, but they are more limited under the current UK immigration changes. Options may include:

• Graduate visa (for recent UK university graduates)
• Temporary Worker visa (subject to sponsorship and caps)
• Family routes under Appendix FM
• Asylum or human rights claims (in limited cases)

Some workers may also retrain or upskill into eligible higher-skilled roles to meet the new RQF 6 requirement.

8. Can I still apply for Indefinite Leave to Remain under my current job?

Yes—if you meet the ILR requirements, and your salary at the time of application is in line with the thresholds applicable at that point. The UK immigration changes mean:

• Your salary must now typically exceed £41,700 (or the going rate for your occupation)
• You may qualify for transitional ILR rights if your visa was granted before 1 July 2025

It’s crucial to plan well in advance, as last-minute adjustments can lead to visa overstays or refusals.

9. Is the Health and Care Worker visa still available under the new rules?

Yes, but it is narrowed in scope. While the Health and Care Worker visa remains available, only some occupations (e.g. nurses, social workers, paramedics) are still included after the HC 997 reforms. Care assistants and similar roles are no longer universally accepted unless falling within specific transitional concessions.

This area remains fluid, and Axis Solicitors continues to monitor updates that may affect healthcare and social care professionals.

10. What should I do if I’m unsure how the UK immigration changes affect me?

If you are uncertain whether your visa, sponsorship, or eligibility has been affected by the recent UK immigration changes, you should:

• Review your CoS, job code, and salary against the updated rules
• Speak with an experienced immigration solicitor
• Do not rely on outdated advice or employer assumptions
• Act early, especially if approaching a visa expiry or job change

Axis Solicitors offers comprehensive legal consultations, transitional strategy reviews, and full support in adapting to the 2025 UK immigration changes.

Need Expert Guidance on the July 2025 UK Immigration Changes?

The UK immigration changes introduced through HC 997 are far-reaching, complex, and time-sensitive. Whether you’re an individual applicant, employer, or sponsor licence holder, acting without up-to-date legal advice puts your future or your business at risk.

Axis Solicitors is here to help. Contact us today