Right to Work scheme changes 2025: what employers need to know

SECTION GUIDE

The UK Government’s white paper Restoring Control Over the Immigration System and the latest consultation to extend the Right to Work scheme to wider working arrangements signal some of the most significant shifts to employer immigration responsibilities in over a decade. While these proposals are still under consultation, they indicate a decisive move towards tighter controls, higher compliance expectations and greater scrutiny for all employers – particularly SMEs.

For sectors reliant on international talent such as care, hospitality, logistics and engineering, the proposals represent a considerable departure from the current system. This article explores the key changes, the new RTW consultation, their impact on employers, and the practical steps businesses can take now.

Understanding the current immigration and right to work landscape

Under today’s system, employers must complete a compliant Right to Work check before any employee begins work. Those recruiting internationally through the Skilled Worker route must also hold a sponsor licence, meet salary and skill thresholds, maintain detailed records and fulfil ongoing reporting duties.

The system is often criticised as expensive and administratively heavy, but it has provided a reliable route for employers to recruit talent where the domestic labour market falls short. The recent proposals, however, suggest a fundamental shift in both access to overseas talent and employer compliance requirements.

Right to Work scheme changes 2025impact hr ident

Key proposed changes to immigration rules

  • Increasing sponsorship costs

    Sponsoring a Skilled Worker already costs employers up to £1,400 per employee, with total fees exceeding £10,000 if dependants are included. Further increases are likely, creating financial pressure for SMEs and lower-wage sectors.

  • Higher skills thresholds

    The minimum qualification requirement would rise from A-level to degree level, removing around 180 eligible occupations from the Skilled Worker list. Practical, experience-based roles are likely to be disproportionately affected.

  • Stricter English language requirements

    The Government proposes raising English language standards for sponsored workers. Employers may need to support existing international employees to meet the new level.

  • A longer route to settlement

    The settlement (Indefinite Leave to Remain) period may increase from five years to ten, requiring more visa renewals and compliance checks, impacting long-term workforce planning.

  • Replacement of the Immigration Salary List

    The current list will be replaced, and employers will need to demonstrate active domestic recruitment before hiring internationally – although how this evidence will be assessed remains unclear.

  • Sharp rise in minimum salary thresholds

    The minimum salary for Skilled Worker visas is set to rise from £26,200 to £38,700, creating a major challenge for care, logistics, retail, hospitality and other sectors where wages sit close to National Minimum Wage levels.

  • Increased compliance and enforcement

    More frequent Home Office audits, stricter documentation checks and greater penalties for unintentional administrative failings are expected.

Right to Work scheme changes 2025

The new development: Extending the Right to Work scheme

In November 2025, the Government launched a consultation proposing the expansion of the Right to Work scheme to a wider range of working arrangements. This could mean the employer’s legal obligation to check working status will apply far beyond employees.

What the consultation proposes

  • Right to Work checks for contractors, freelancers and self-employed individuals working on behalf of a business.
  • Equal civil penalties for illegal working across all worker types.
  • New statutory record-keeping and reporting duties for non-employee labour.
  • Possible digital-only identity verification for certain contractor categories.
  • A review of the “reasonable excuse” defence, potentially making it harder for employers to demonstrate genuine mistakes.

This marks a substantial shift, as RTW checks have historically centred on employees rather than contractors.

  • How these changes impact employers

    The combined effect of the immigration reforms and the potential RTW extension is significant:

    Reduced access to global talent

    • Higher salary thresholds and degree-level requirements will shrink the eligible overseas talent pool and raise recruitment costs.

    Increased administrative burden

    • Employers may need new onboarding processes, audit trails, contractor policies and digital systems.

    More compliance risk

    • Penalties for illegal working may apply not only to employees but also to contractors, freelancers and self-employed workers engaged indirectly.

    Workforce and resource pressures

    • Lower-wage sectors may struggle to recruit, while international staff may experience uncertainty around settlement and visa renewals.

    Diversity and inclusion impacts

    • A reduced pipeline of international talent may affect workforce diversity and organisational EDI ambitions.
  • What employers should do now

    Although these changes are still proposals, early preparation is essential. Employers should:

    Audit the workforce

    • Identify all employees, contractors and agency workers with visa requirements or RTW documentation.

    Strengthen onboarding and compliance systems

    • Introduce digital RTW tracking, renewal alerts and consistent recording practices for both employees and contractors.

    Budget for increased costs

    • Plan for higher sponsorship fees, rising salary thresholds and additional resource costs linked to compliance.

    Upskill and develop domestic talent

    • Invest in internal development programmes to reduce reliance on sponsored workers.

    Review contractor agreements

    • Ensure contracts clearly outline responsibility for RTW checks and specify documentation requirements.

    Support existing sponsored staff

    • Provide communication, reassurance and English language support where needed.

    Build stronger domestic recruitment strategies

    • Engage local training providers, colleges and job centres to widen the talent pipeline.

Your Questions Answered

Everything you need to know about the Right to Work scheme

  • What is the Right to Work scheme and why is it changing?Reveal

    It governs the checks employers must complete to ensure individuals have permission to work in the UK. The Government proposes extending these duties to contractors and freelancers to reduce illegal working.

  • Will employers need to check the RTW status of contractors and self-employed individuals?Reveal

    Possibly yes. The consultation proposes extending RTW checks to anyone carrying out work for a business, including contractors, freelancers and some agency workers.

  • What are the penalties for failing to complete RTW checks correctly?Reveal

    Civil penalties can reach up to £60,000 per illegal worker, and these could be applied to contractor engagements if the scheme is extended.

  • How will Skilled Worker visa changes affect employers?Reveal

    The salary threshold rise to £38,700, alongside higher skills and English requirements, will drastically reduce the number of eligible overseas workers and increase costs.

  • Will current visa holders be impacted?Reveal

    If settlement rises to ten years, existing visa holders will face more renewals and compliance checks. The Home Office has not confirmed transitional protections.

  • How should SMEs prepare now?Reveal

    Strengthen RTW processes, review contractor arrangements, budget for increased costs, upskill domestic staff and improve internal workforce planning.

  • When will the new rules take effect?Reveal

    There is no confirmed date. Changes are expected in 2026 following consultation outcomes.

Make an enquiry

Let’s talk

Start making your impact.

Whether you need day-to-day HR support, ad-hoc support or a long-term partner, we’re here to help.

Get in touch for a free initial chat — no pressure, just practical advice from people who get it.

0330 2369866
hello@impacthr.co.uk

Leicester: 6 St. Georges Way, 3rd Floor, St. George’s House, Leicester LE1 1QZ
London: 167 City Road, London EC1V 1AW
Leeds: Building 3, City West Business Park, Gelderd Rd, Holbeck, Leeds LS12 6LN
Essex: Halford House, 2 Coval Lane, Chelmsford, England, CM1 1TD

You may also like Explore more content to keep you informed and up to date with the latest HR resources