15 October 2025

Yesterday, the Home Office published the Statement of Changes in Immigration Rules (HC 1333) alongside the relevant Explanatory Memorandum. A full Impact Assessment has also been published. The Statement, the sixth of the year, introduces a broad package of amendments affecting work-based, visitor, student, economic migration, and family routes. It also includes technical and simplification changes. Implementation is staggered, with effective dates varying by change.

These changes align with the Government’s Immigration White Paper, Restoring Control over the Immigration System, published in May 2025. The Autumn 2025 Immigration Rules Impact Assessment provides additional context, highlighting the rationale behind the reforms and their expected effects on migration routes.

We have separately received confirmation that the Immigration Skills Charge (ISC) will increase by 32% from Tuesday 16 December 2025, with further details to be confirmed.

English language requirement to increase for Skilled Worker, High Potential Individual, and Scale-up routes
The minimum English language requirement for Skilled Worker, High Potential Individual, and Scale-up routes will increase from B1 (intermediate) to B2 (upper intermediate). This change affects the evidence required to demonstrate language competence and raises the standard expected for entry on these skill-based routes. The Impact Assessment notes that the adjustment aims to ensure migrants meet a higher skill threshold and aligns with international language standards. Transitional arrangements will apply, so that individuals already in a route subject to a B1 English language standard will continue to benefit from this lower threshold when they extend their permission, provided they are continuing in the same category.

The change will enter into force from 8 January 2026.

Reduction in permission for new Graduate route applicants from 2027
Non-PhD graduates will be granted a reduced period of leave of 18 months, down from two years, if they apply under the Graduate route on or after 1 January 2027. PhD graduates will continue to benefit from a three-year period of leave. The Impact Assessment explains that this change is intended to align post-study work permissions with broader immigration policy objectives and to manage the scale of post-study work migration.

Whilst the change will be implemented on 11 November 2025, it will only be effective for applications made on or after 1 January 2027. This significant lead time of more than a year, following extensive lobbying from the higher education sector, will allow universities to prepare communications and international student recruitment policies accordingly.

New ‘Part Suitability’ to consolidate refusal and cancellation grounds
All refusal and cancellation grounds previously scattered throughout the Rules have been consolidated into the new Part Suitability. The reorganisation includes criminality, deception, public good and security grounds, applying the same principles across family, private life, and general legal migration routes.

Significantly, Paragraph 39E, which sets out exceptions for individuals who have overstayed their visa or permission, has been moved into Part Suitability under a dedicated section titled ‘Exceptions for overstayers’. Previously, applicants to the Family route who had overstayed past immigration permission benefited from more generous suitability requirements that did not specifically include overstaying.

The definition of ‘permission’ has also been clarified to reflect that it means either permission to enter or permission to stay and includes settlement.

These crucial, albeit technical, changes will be implemented from 11 November 2025.

Transitioning provisions from the Student Route to the Innovator Founder route

Student route work conditions will be amended to allow international students to establish and work for their own business in the UK while still under the Student route, provided they have completed their course and are switching to the Innovator Founder route. This change is intended to encourage entrepreneurial activity among international students. The Impact Assessment indicates that this measure is expected to have a small impact but facilitates greater flexibility for graduates seeking to establish businesses.

The change will enter into force from 25 November 2025.

High Potential Individual route expansion
The High Potential Individual route has been expanded to include a broader range of eligible institutions, doubling the total list. Certain institutions may still be excluded where their inclusion could raise national security or foreign policy concerns. The route will also be capped at 8,000 applications per year.

The updated list of eligible universities has not yet been published, but it is expected to be published on Saturday 1 November 2025, in line with historic publishing dates.

The change will be implemented on Tuesday 4 November 2025.

Global Talent Route – prestigious prizes 

Twenty-seven new prestigious prizes have been added to the Global Talent route qualifying list, while one prize, the Olivier Award for Best Play Author, has been removed. The Impact Assessment highlights these changes as part of a strategy to attract highly skilled talent while maintaining control over overall numbers.

These changes are due to be implemented on 11 November 2025.

Seasonal Worker route
The maximum period for which seasonal workers may stay in the UK has been reduced from 12 months to six months within any rolling 10-month period. This change limits repeated stays throughout the year.

These changes are due to be implemented on 11 November 2025.

Visitor visa requirements for Botswana nationals
Botswana nationals previously did not require a Visitor visa for short visits and could use the Electronic Travel Authorization (ETA) scheme where eligible. From 14 October 2025 at 15:00 BST, Botswana nationals must now apply for a visit visa. Botswana has also been removed from the ETA eligibility list.

A transitional period allows anyone who booked travel and obtained an ETA before this date to travel until 25 November 2025. This change responds to security concerns and aims to align Botswana’s requirements with those of other countries with similar risk profiles. The Impact Assessment notes that this measure is expected to affect a small number of travellers.

These changes have been immediately implemented.

Recognition of Palestine
Following the Government’s recognition of the State of Palestine, Palestine has been added to the visa national list. Palestinian passport holders will need to obtain a visa to visit the UK. This change standardises the treatment of Palestinian travel documents with other nationalities and clarifies operational procedures.

This change is due to be implemented on 11 November 2025.

German school group travel
Schoolchildren under 19 years old who are part of accredited German school groups can now visit the UK using their national ID cards, rather than passports, with no visa or ETA. Travel must be as a group and led by a teacher. The policy is intended to encourage educational visits and foster partnerships, similar to a measure introduced for French school groups in December 2023.

This change is due to be implemented on 11 November 2025.

Ukraine Permission Extension Scheme concessions
Protections for child applicants under the Ukraine Permission Extension Scheme have been strengthened, aligning their permission with that of legal guardians. This change prevents children from being left without status and supports safeguarding vulnerable groups.

This change is due to be implemented on 11 November 2025.

Child Student Accommodation and Student maintenance requirements
Clarifications have been made regarding the definition of nominated guardian for Child Students and the circumstances in which a guardian may be appointed.

Maintenance requirements for Student route applicants have been updated to align with home student loan levels for the 2025/2026 academic year, including adjustments related to accommodation cost offsets.

These changes are due to be implemented on 11 November 2025.

EU Settlement Scheme updates
Minor updates clarify the grounds under which pre-settled status may be curtailed or cancelled and specify eligibility conditions more precisely. The changes also align in-country curtailment grounds with those that apply before arrival, enhancing clarity for applicants and caseworkers.

These changes are due to be implemented on 11 November 2025.

Changes to Continuous Residence rules
Adjustments have been made to continuous residence provisions, including additions for Tier 1 (Entrepreneur) and Tier 1 (Investor) categories and corrections to break rules. These amendments provide more explicit guidance on qualifying periods for residence across various visa routes, including those being phased out or transitioned.

These changes are due to be implemented on 11 November 2025.

Other technical and drafting amendments
Several minor technical changes improve consistency in terminology and cross-referencing across the Immigration Rules. These include repealing obsolete rules, updating paragraph references (particularly with the replacement of Part 9 by Part Suitability) and revising occupation tables to reflect earlier updates made in July 2025. These amendments aim to make the Rules easier to interpret, reduce ambiguity and ensure smoother application processing.

HC 1333 and the Immigration White Paper
When considered in conjunction with the July 2025 Rules and the Immigration White Paper, this Statement of Changes represents a significant phase in the Government’s ongoing reform programme. The changes require careful consideration for compliance, eligibility and route planning.

With implementation dates staggered from October 2025 through to January 2027, legal practitioners and employers must monitor the changes closely to ensure that applications are prepared in line with the new Rules and to maximise the benefits of the available pathways.

Get in touch
Please contact enquiries@lauradevine.com or your assigned LDI lawyer if you would like further assistance to prepare for these upcoming changes and subscribe to our mailing list to receive the latest updates and implementation timelines.