The UK’s immigration system and visa regime continue to change with announcements from government on an almost weekly basis. Anne-Marie Campion, ISE’s Insights Manager, explains what members need to know.
With the UK facing an increasingly regulated sponsorship environment, ISE ran a webinar with Paragon law, offering practical guidance to ensure compliance, maintain competitiveness, and plan for 2026 and beyond.
The session provided an essential update for employers, universities, and HR professionals on the evolving immigration and visa landscape affecting international students and graduates.
The current landscape is complex, and all employers are urged to seek advice from their own legal teams and advisors, but here is a summary from the detailed examination by Thal and Kirin at Paragon Law of the position as known in October 2025.
How can employers ensure they are compliant with discrimination legislation?
Employers must not exclude candidates requiring sponsorship nor can the cost of sponsorship be a reason not to hire – all decisions on whether to progress an applicant must be made on merit and not on immigrations status.
However, there will be legitimate circumstances when an employer can decide to reject an applicant requiring sponsorship. These would include:
- National Security reasons.
- If the applicant is hired on the graduate route (PSW) visa but the graduate programme extends beyond the planned reduced graduate route visa duration of 18 months and the salary level at that point on the graduate programme does not meet the threshold for a skilled worker visa.
- Where the salary level for the substantive role on completion of a graduate programme is below the threshold for a skilled worker visa.
- For work placements or internships where the programme is specifically run as a pipeline for the graduate programme and either or both points above are relevant.
What must employers do?
Employers must be able to produce evidence to support their decision not to consider applicants requiring sponsorship. For example, data showing that the undergraduate/internship programme is now and has been historically a pipeline for the graduate programme.
They must also ensure Right to Work (RTW) checks occur post-selection, not at application stage.
Seeking advice from HR/legal teams or advisors on the wording of application forms is also essential as the following examples have been deemed to be not permissible:
- “Must have the right to live and work full-time in the UK indefinitely without sponsorship from [the company] OR be able to provide evidence that you can achieve this independently.”
- “Must be able to legally live and work in the UK, without future [company] visa support or sponsorship (student visas or visas obtained on your own are not applicable for the program)”
- “Participants in our Graduate Specialist Programme come from around the world, but we anticipate that candidates will have a valid permanent work permit for the UK. Unfortunately, we cannot accept applicants with post-study visas.”
What are the main changes and what is coming in 2026?
The landscape is changing rapidly, but from what we currently know:
- From July 2025 the confirmed minimum skill level increases have removed round 180 roles from sponsorship eligibility unless listed on the Immigration Salary List (ISL) or Temporary Shortage List (TSL).
- The duration of the graduate route visa, sometimes referred to as ‘post study work visa’, will reduce from 2 years (3 years for PhD students) to 18 months.
- The qualifying period for settlement is under consultation, but a planned extension from 5 to 10 years has been proposed.
- A reclassification of the Standard Occupational Classification (SOC) is proposed potentially excluding some graduate level roles from sponsorship.
- There is a review of the new entrant discount.
- There will be higher English Language requirements for main applicants and dependents.
What action should employers and universities take?
Employers should get on the front foot on the proposals and engage in the consultation process by engaging with the Migration Advisory Committee (MAC); demonstrate the value of the new entrant route; review pay structures and hiring plans; and consider sponsorship and extensions now under the current rules.
Universities should take their opportunities to engage in policy consultations for employers and universities; highlight the long-term economic contributions of international students; and collect and share international graduate success stories.
The UK’s 2025–26 immigration reforms mark a decisive shift toward tighter salary thresholds, stricter eligibility, and a stronger focus on ‘high-skilled’ roles.
Employers and education providers must act now to remain competitive in attracting international talent, particularly as post-study and new entrant pathways narrow.