Immigration

Right to work obligations are expanding from 1 October 2026

From 1 October 2026, right to work (RTW) obligations will be expanded to go beyond the traditional employer-employee relationship. The definition of "employer" for RTW purposes will require businesses to carry out RTW checks not just for direct employees, but also for workers engaged:

under a worker's contract (including casual and zero-hours arrangements);
as individual sub-contractors; and
through an online matching service (i.e. platforms that keep a register of service providers and match them with clients or customers for a fee or commission).

Businesses with complex supply chains, and those that rely on non-employee workers and subcontractors are likely to be particularly exposed.

We recommend taking the following steps as soon as possible before 1 October 2026:

Map your workforce and supply chains: identify which workers and arrangements will fall within the new rules.
Review and consider updating your contracts: ensure agreements with suppliers, sub-contractors and agencies include the necessary provisions to satisfy the prescribed requirements.
Review your RTW processes and record-keeping: ensure checks cover all in-scope workers, are carried out correctly, and that records are retained as evidence of compliance.
Training: ensure HR teams and those responsible for engaging workers understand the new requirements and how to identify which arrangements are in scope and who RTW checks should be completed for.
Seek legal advice: The new provisions are detailed and complex and legal advice should be sought on how they apply to you and your business.

Other key immigration changes

Earlier this year, the Home Office consulted on proposals to significantly transform the requirements for ILR. The key proposals are:

Doubling the standard timeline to ILR from five to 10 years (which can be extended or reduced depending on individual circumstances).
Introducing new expedited pathways to ILR for high-earners and top talent.
Effectively abolishing the 10-year long residence route to ILR.
Introducing requirements for certain dependants to meet strict financial criteria. This could have unforeseen knock-on implications for children's ability to qualify for ILR.

Many MPs and stakeholders have spoken out against various aspects of the proposals. It remains to be seen how the new Labour leadership will interact with the proposals and the extent to which they will be brought into force. It is currently expected that any changes will come into force from the autumn, though the detail remains to be seen.

Other key immigration changes

English language requirement: From 8 January 2026, the minimum English language requirement for Skilled Worker, High Potential Individual, and Scale-up visas has risen from B1 to B2 level. This change applies to new applicants, rather than existing visa holders. From 26 March 2027, the B2 standard will also apply to settlement (ILR) applications.
Graduate visa: From 1 January 2027, the standard duration of the Graduate visa will be reduced to 18 months. Applications submitted before this date should continue to receive two years of leave. PhD graduates will remain eligible for three years of leave.
Salary compliance: From 8 April 2026, the Home Office assesses Skilled Worker salary compliance on a per-pay-period basis (which would ordinarily be monthly pay) rather than by reference to annual salary alone. Sponsors should review their payroll arrangements to ensure each pay period meets the required threshold.