Changes and updates – what do employers/sponsors and employees need to know?

Below we outline some key changes affecting sponsorship rules, salary changes, and travel to the UK, and provide some indication of recent policy developments for individuals, employers, and sponsors to ensure continuing compliance and help with strategic workforce planning.

Electronic Travel Authorisation (ETAs) – EEA Nationals

• Since October 2023, the UK Government has started to roll out Electronic Travel Authorisation (ETA) – this is not a visa, but issues digital permission to travel to the UK. The ETA is part of the UK Government’s plan to digitise its borders at airports, in order to speed up journeys and ensure a seamless travel experience. Since its introduction, over 1.1 million ETAs have been granted.
• As of 2 April 2025, all EEA nationals travelling to the UK for up to 6 months for short-term study, tourism, visiting family and friends, or business need to apply for an ETA.
• An ETA is required for each individual who is travelling to the UK, including children.
• A decision is normally made within three working days and sent by email. An ETA is valid for two years or until an individual’s passport expires, whichever is sooner, and can be used to enter the UK multiple times on the passport registered with the ETA. If an individual’s ETA application is rejected, the Home Office will provide a reason and the affected individual will instead need to apply for a visa (entry clearance or pre-entry authorisation) if they wish to seek permission to travel to the UK.

Obtaining an ETA is a simple process – you can apply via the UK ETA App downloadable from Google Play or the Apple App store. The app will require you to:

• Scan and upload the bio page of your current passport (this needs to be a scan of the original passport, not a photocopy)
  • Register your email and take a picture of yourself for online verification
  • Answer simple questions regarding your name, date of birth, nationality and complete other formalities
  • Pay the ETA cost of £10

ETIAS – the European Travel and Authorisation System (ETIAS)

ETIAS, a system similar to the ETA, will be a requirement for non-EU nationals from visa-exempt countries for short-term stays in the Schengen Area – again, it is not a visa, but non-EU nationals will need to obtain this travel authorisation for travel to the EU of up to 90 days in any one 180 day period.

However, implementation has been delayed and is not set to start until Q3 2026. 

When implemented, it will be a requirement for all non EU nationals to obtain ETIAS authorisation if they are travelling to Europe for tourism, business (ensure the activity to be undertaken does not require a work visa before any travel is undertaken), health or medical treatment, or who are transiting en-route to a third country destination.

Minimum Salary Requirements

• From 9 April 2025, the minimum salary threshold for Skilled Workers has increased from £23,200 to £25,000 per year. This adjustment reflects the Home Office’s aim to align sponsored worker salaries with current UK workforce earnings, based on data from the Office for National Statistics (ONS), and to ensure compliance with the increased National Living Wage (effective from 1 April 2025).
• These new salary rules particularly impact applicants on discounted salary routes, such as those on Health and Care Worker visas, or Skilled Workers who entered the UK on this route before April 2024 and qualify for discounts (i.e new entrants or those holding relevant PhDs).
• Additionally, the Home Office has clarified that any financial contributions made by the worker to their sponsor (like deductions, loans, or investments) must be excluded from the salary used to assess compliance with the minimum salary threshold. Voluntary salary sacrifices (such as for childcare/nursery fees) are still permitted and can count toward the threshold. (See below for more information on Recouping fees and Sponsor Duties).
• Sponsors must now ensure that Skilled Workers are paid at least £25,000 per year (or the higher going rate) from 9 April 2025.
• Failure to meet updated salary rules, even unintentionally, could put a sponsor’s license at risk of being suspended or revoked. Hence, regular internal audits and policy reviews are recommended.

Minimum Wage Requirements

• From 1 April 2025, the national minimum wage rates have increased, meaning that eligible full-time workers may receive a pay rise worth an extra £1,400 per year.
  • The National Living Wage for those aged 21 and over will rise from £11.44 per hour to £12.21 per hour.
  • The National Minimum Wage for 18- to 20-year-olds rises from £8.60 to £10.00 per hour.
  • The apprenticeship rate, and for 16- to 17-year-olds, rises from £6.40 per hour to £7.55 per hour.
• This increase is in line with the Home Office’s efforts to reflect the cost of living under Labour’s Plan to Make Work Pay. Sponsors must verify that all employees (and especially those on apprenticeship schemes or under 21) are being paid at or above the new minimum rates. The new National Living Wage (£12.21/hour) reinforces the updated Skilled Worker salary floor (£25,000/year), so sponsors need to ensure compliance in both areas.

Recouping fees & Sponsor Duties

• The Home Office has released guidance that expressly lists the non-refundable sponsorship fees that a sponsor has responsibility to pay.
• This includes:
  • The application fee for a sponsor licence (either the small or large fee dependant on the size or status of the organisation)
  • In some cases, the fee for applying to add routes to your licence
  • Fee for each Certificate of Sponsorship you assign
  • If you are sponsoring a Skilled Worker or a Senior or Specialist Worker, you will normally need to pay an Immigration Skills Charge for each worker you sponsor, unless an exemption applies
  • Any additional premium services after your licence has been granted

• On 1 January 2025, the Home Office introduced further amendments to its guidance that explicitly prohibits employers from passing certain sponsorship costs onto workers. Specifically, a Skilled Worker sponsor that has assigned a Certificate of Sponsorship to a Skilled Worker on or after 31 December 2024 is not allowed to recoup or attempt to recoup any part of the CoS fee and Immigrations Skills Charge (where applicable) from a worker that is being sponsored. The Skilled Worker sponsor licence fee and any associated administrative costs also cannot be recouped from a worker.

• The Home Office has outlined the importance of compliance with this on the sponsor, stating that failure to comply could lead to revocation of the sponsor licence, which in turn would not allow a sponsor to re-apply for a licence for 12 months. The sponsor will also have to address reasons as to why the licence was revoked previously.

• The Home Office have also introduced increasingly tight restrictions on employers who attempt to shift ‘business’ or ‘immigration-related’ expenses onto migrant workers, making it clear that the minimum salary for Skilled Worker sponsorship must be calculated after any such deductions are made. For instance, if an employer covers the cost of a visa or the Immigration Health Surcharge and then recoups the money through salary deductions, those repayments will no longer count toward meeting the required minimum salary for sponsorship purposes.

• Sponsors should ensure they are aware of, and have complied with, these changes, as they may affect an employer’s ability to meet the going rate for a migrant employee or the minimum salary threshold – and failure to comply with these requirements could prevent a non-UK employee from taking up employment in the UK.

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