On 1 July 2025, the Home Office published HC 997, a Statement of Changes to the Immigration Rules, which comes into force on 22 July 2025. These amendments affect Skilled Worker and related routes, introduce a Temporary Shortage List (TSL), tighten dependant rights, and update settlement pathways for children. We have distilled the key questions with answers to help employers, sponsors, and applicants handle the new landscape.

1. Temporary Shortage List (TSL)

Q1. What is the Temporary Shortage List (TSL), and how long will it run?
The TSL is a time-limited list of occupations at RQF 3–5, deemed vital to the UK’s modern industrial strategy. It replaces the Immigration Salary List for sub‑RQF 6 roles and runs until 31 December 2026, after which all those occupations will be removed unless the MAC advises otherwise.

Q2. Which occupations are on the TSL, and how can I check if mine is included or removed?
The Explanatory Memorandum at paragraph 5.1 lists the initial professions, e.g. logistics managers, certain technical and care roles. The list can be found here; employers must check regularly for additions/removals.

Q3. What RQF level must a role meet to appear on the TSL?
Only RQF 3–5 occupations may be added to the TSL. All RQF 6+ roles remain on the main Skilled Occupations List (Tables 1–3).

Q4. Can TSL-sponsored workers bring dependants?
No. From 22 July 2025, any Certificate of Sponsorship (CoS) for an RQF 3–5 role, whether via the expanded Immigration Salary List or TSL, bars dependants, except children born in the UK or where the sponsor holds sole parental responsibility.

Q5. Are there any salary or fee discounts for TSL roles?
No. Unlike the old Immigration Salary List, the TSL provides no discounted salary or Immigration Skills Charge (ISC) concessions. All TSL roles must meet the full Skilled Worker salary thresholds.

Q6. Can an employer move a current TSL worker to another TSL role without a new CoS?
No. Any material change of occupation, even within the TSL, requires a new CoS and fresh visa application.

2. Switching Between Routes

Q7. How do I switch from a TSL role into a standard Skilled Worker occupation?
To switch:

- Obtain a CoS for your new RQF 6+ role.

- Demonstrate you meet the higher salary threshold (see Q12).

- Apply in country (or from overseas); there is no additional “cooling off” beyond standard eligibility checks.

Q8. Can someone on a Student or Graduate route switchdirectly into a TSL role?
Yes. Provided the applicant holds a valid CoS for a TSL occupation and meets all Skilled Worker requirements: salary, English language, and maintenance funds.

3. Minimum Salary Requirements

Q9. What is the general “going rate” test versus the £41,700 minimum threshold?
Applicants must meet whichever is higher of:

- The general minimum salary of £41,700 per year, or

- The occupation-specific “going rate” in Appendix Skilled Occupations (Table 1 for RQF 6+).

Q10. How do the PhD and new‑entrant rates interact with the standard threshold?
From 22 July 2025

- PhD relevant roles: minimum £37,500

- STEM PhD / new entrants: minimum £33,400

In each case, you must still meet the higher of this discounted rate or your occupation’s going rate.

Q11. What counts towards “salary” for threshold purposes?
Only guaranteed pay qualifies: basic annual salary pro-rated, plus any mandatory allowances specified in the CoS. Discretionary bonuses, overtime, or commission are excluded unless contractually guaranteed.

Q12. How should fluctuating pay, zero‑hours contracts, or part‑year work be treated?
The Home Office expects stable earnings. For zero‑hours: average your earnings over 12 months to show you meet the threshold. Part-year contracts mustbe pro‑rated to a full-year equivalent; any sick leave should be demonstrably paid at no less than the NMW.

4. Transitional Arrangements

Q13. Which applications can still use a CoS issued before 22 July 2025?
Any Skilled Worker (or other CoS-based) application made (i.e. submitted) before 22 July 2025, 15:00 BST will be decided underthe old rules, even if the Home Office decision falls later.

Q14. What happens if I start my application before butthe decision comes after the cut‑off?
It remains under the pre-change rules. Only applications submitted (not decided) on/after 22 July 2025 must meet the new thresholds.

Q15. Are there grandfathering provisions for existing lower‑RQF occupations?
Yes. Workers already in the Skilled Worker route (or with a successful CoS) in RQF 3–5 roles may renew, change employment or take supplementary work in those roles. These arrangements are temporary and under review.

5. Care Sector

Q16. Which care occupations lose overseas entry‑clearance eligibility on 22 July 2025?
SOC 6135 (Care workers and home carers) and SOC 6136 (Senior care workers) are removed from the main list for entry clearance.

Q17. Can existing in-country care workers extend or switch after 2025?
Yes. If they hold a CoS issued before 22 July 2025 and have worked atleast 3 continuous months for that sponsor, they may extend or switch in‑country until 22 July 2028.

Q18. What proof of 3 months’ employment is required for care‑sector extensions?
Payslips (covering the 3 months immediately before CoS issuance), P60, a letter from HR confirming continuous employment, and, if needed, National Insurance records.

6. Dependant Restrictions

Q19. From 22 July 2025, who can no longer sponsor dependants?
Primary applicants in TSL or any RQF 3–5 role (including care workers) cannot add dependants. Those already on leave with dependants remain unaffected.

Q20. Are any dependants exempt from these new restrictions?
Yes. Dependant children born in the UK (where the sponsor has sole parental responsibility) may apply separately under the child rules.

Q21. Who counts as a “dependant”?
Spouse, civil partner, unmarried partner (2 years’ relationship), any under-18 child (or up to 24 if in full-time education), plus “adult” dependants in exceptional circumstances (requiring financial dependancy evidence).

7. Private‑Life & Child Settlement Routes

Q22. What is the new 5-year private‑life route for children, and who qualifies?
Children (including those on the 7-year concession) with 5 years’ lawful UK residence and strong ties (school, GP registration, community involvement) may apply under the 5-year Private Life route, down from the usual 10-year requirement.

Q23. How does evidence differ between the 5‑ and 10-year Private Life routes?
For 5 years: focus on child-specific ties; school reports,tutoring records, letters from youth organisations, GP/paediatrician letters.

For 10 years: full visa history plus broader private‑life factors (family connections, property, long-term relationships).

Q24. Can adults with exceptional private‑life ties stil luse the 5-year route?
No. The 5-year path is child-only. Adults must meet the 10-year route unless they qualify as “new entrants” in other routes.

8. Global Business Mobility (GBM) & Other Work Routes

Q26. What salary and skill changes apply to GBM Senior/Specialist and Graduate Trainee?
From 22 July 2025:

• GBM Senior/Specialist: salary rises from £48,500 → £52,500
• GBM Graduate Trainee: from £25,410 → £27,300 gov.uk

Q27. Are there any changes to the Health & CareWorker visa?
No. All existing concessions (20% IHS discount, ISC exemption) remain unchanged under HC 997.

Q28. Does the Graduate or Student route change under HC 997?
No. HC 997 focuses solely on Skilled Worker, GBM and ARAP changes. Student and Graduate categories remainas per HC 836 (24 June 2025).

9. Sponsor Duties & Compliance

Q29. What new record-keeping or reporting duties dosponsors face?
Sponsors must:

• Update HR/payroll systems for new salary thresholds
• Track CoS expiries to Dec 2026 (TSL/ISL) and Jul 2028 (care‑sector transitions)
• Report any non-compliance (e.g. underpayment, illegal working) to UKVI within 10  working days.

Q30. What new grounds for licence suspension orrevocation have been added?
Employing someone below the new thresholds (e.g. <£41,700) or in an ineligible occupation (e.g. care worker post‑July 2025) may now trigger immediate licence suspension or revocation.

10. Afghan Relocations and Assistance Policy (ARAP)

Q31. When did ARAP close to new principal applications?
ARAP closed at 15:00 BST, 1 July 2025. Applicants must have submitted their MOD eligibility application between 1 April 2021 and the deadline to qualify.

Q32. Can family members still apply under ARAP afterclosure?
Yes. Those family members of principals whose eligibility applications were submitted before the 1 July deadline may continue to apply.

GigaLegal Solicitors is here to help you interpret and implement these changes. For bespoke 5-star-rated advice from our expert Immigration solicitors, application checklists, or representation, please get in touch.

Disclaimer: UK immigration rules are subject to frequent updates. For the most current information, always refer to official GOV.UK publications, Home Office guidance, and your legal adviser.

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