The changes outlined in the Home Officeโs recent communication on the HC 997 arrangements represent some of the most significant shifts in immigration policy in years.
The immediate implementation has left thousands of employers scrambling to understand how these changes will affect their operations, existing employees, and future recruitment plans.
This guide breaks down the three major changes employers must understand immediately: the RQF 6 requirement restricting skilled worker visas to degree-level jobs only, the complete closure of care worker visa applications, and the introduction of the restrictive Temporary Shortage List.
RQF 6 Requirements: Degree-Level Jobs Only
One of the most significant of the UK 2025 immigration changes is the raising of the skill threshold to RQF 6, meaning only degree-level jobs now qualify for skilled worker visas. This change has eliminated approximately 180 occupations from eligibility.
What’s excluded: The RQF 6 requirement has removed vital roles, including hospitality managers, retail supervisors, many technical positions, and specialised roles that previously qualified at RQF 3-5 levels. If your business relies on overseas recruitment for management trainee positions, technical specialists, or sector-specific roles that don’t require degrees, you may find yourself directly affected by these immigration changes.
Timeline and protections: July 22, 2025, became the hard implementation date, but transitional arrangements exist for current employees. Workers extending their leave from overseas can benefit from these protections, but only if sponsors properly document the transitional arrangements in their Certificate of Sponsorship applications.
Immediate actions required:
- Audit all your sponsored employees to identify those in roles below RQF 6.ย
- Ensure you’re making use of the transitional arrangement protections for existing staff.ย
- Begin planning alternative visa routes for affected roles or pivot to domestic recruitment strategies. The window for reactive planning has closed – proactive adaptation is now essential.
We’re seeing genuine panic among those who didn’t anticipate this speed of implementation. Businesses that delayed workforce planning are now facing immediate crises. Our strategic advice is clear: review your entire workforce now, not when individual visas approach expiry dates.
The End of the Care Worker Visa
Among all 2025 immigration changes, none has created more immediate disruption than the complete closure of care worker visa applications under SOC codes 6135/6136. This represents a seismic shift for an industry that has become heavily dependent on overseas recruitment.
What’s happened: From July 22, 2025, all new care worker visa applications are rejected outright. Outstanding applications submitted before this date were also rejected unless already assigned.
Tann Law’s Emergency Guidance: This creates a crisis for many care providers. However, panic responses often make situations worse. Our guidance focuses on three priorities:
- Retain existing overseas care workers through proper visa extensions and compliance.ย
- Pivot immediately to domestic recruitment with competitive packages.
- Ensure absolute compliance with remaining transitional arrangements to avoid sponsor license issues.
The increased Home Office scrutiny that typically follows major policy changes means care providers must be especially careful about compliance with existing obligations while adapting their workforce strategies.
New Temporary Shortage List
The Temporary Shortage List (TSL) introduced alongside these UK immigration changes offers far less relief than many employers hoped.
Key differences from the old system: Unlike the previous Immigration Salary List, the TSL provides no salary discounts or reduced visa application fees. Its scope is dramatically more limited, focusing only on roles deemed critical to infrastructure or national priorities. The time-limited nature means even approved occupations may be removed as domestic workforce capacity develops.
Tann Law’s Assessment: The TSL is not a replacement for the previous system; it’s far more restrictive. Businesses banking on TSL inclusion for their key roles may be disappointed. We advise clients not to rely on future TSL additions when planning workforce strategies. Instead, focus on domestic workforce development and alternative visa routes where appropriate.
The government’s clear message through these immigration changes is that overseas recruitment should be exceptional, not routine. Expect very selective and temporary additions to the TSL, with strict workforce strategy requirements for accessing even these limited options.
Industry-Specific Impact and Strategic Response
Different sectors face varying levels of disruption from these new regulations.
Healthcare and Care: Beyond the visa closure crisis, the broader healthcare sector faces challenges with many support roles now excluded from skilled worker routes. Businesses must focus on retention packages for existing overseas staff and domestic recruitment campaigns to build future workforces.
Hospitality and Retail: Many management and supervisory roles that previously qualified for skilled worker visas are now excluded by the RQF 6 requirement. These sectors should focus on management trainee programs for domestic candidates and career progression pathways that justify degree-level requirements for key roles.
Manufacturing and Technology: Technical roles require careful review against RQF 6 standards. Some may qualify for TSL inclusion, but this shouldn’t be assumed. Investment in skills development and apprenticeship programs becomes crucial for long-term sustainability under these immigration changes.
Future-proofing strategies: Build robust domestic recruitment pipelines now, before competition intensifies. Invest in employee development programs that create clear career progression paths. Most importantly, prepare for additional restrictions as the government continues implementing its migration reduction strategy.
Future Developments
These UK immigration changes may represent the beginning, not the end, of significant policy shifts affecting overseas recruitment.
Further restrictions are highly likely in the coming months as the government pursues its net migration reduction targets. The enhanced focus on domestic workforce development suggests additional support for apprenticeships and skills programs, potentially coupled with further restrictions on overseas recruitment.
Businesses should prepare to implement regular compliance audits as standard practice, not just crisis responses, and develop proactive workforce planning that anticipates policy changes rather than reacting to them.
Most critically, businesses should seek to establish relationships with professional immigration support before crises emerge. Reactive legal advice is invariably more expensive and less effective than regularly working alongside a trusted legal professional.
Taking Decisive Action
The UK immigration changes under HC 997 represent fundamental shifts requiring immediate, comprehensive responses from affected employers.
Professional guidance has become essential for the successful navigation of these complex new requirements. The interconnected nature of immigration law means that mistakes in one area can cascade into serious compliance issues affecting your entire sponsor license. Early action protects both business continuity and employee welfare during this period of significant change.
Contact Tann Law’s immigration specialists today for confidential, practical guidance tailored to your specific business circumstances.
Our corporate immigration team understands the urgent challenges created by these changes. We’re ready to help you protect your business operations, support your existing employees, and develop sustainable workforce strategies.
Are you prepared to safeguard your business from these changes?
Contact our team today. Your quick action today determines your competitive position tomorrow.
This article provides general guidance on HC 997. For advice specific to your business circumstances, contact our corporate immigration specialists.