United Kingdom: Mobility – 2024 Highlights and 2025 Outlook

Prior to the General Election, the previous Conservative administration introduced a number of changes to the UK immigration system, with the overall aim of reducing the level of net migration into the United Kingdom. The most significant of these was raising the minimum salary level which must be paid to overseas nationals that UK employers wish to sponsor to work in the UK. Early indications are that these changes are having the desired effect, meaning that, although the new Labour Government has also pledged to reduce net migration, it is unlikely to make any major policy changes unless net migration begins to rise again, or there is evidence that current immigration policy is shown to impede UK economic growth. Instead, the government is focusing on the continued digitisation of the UK immigration system and the rollout of the Electronic Travel Authorisation process, which will continue into 2025.

2024: HIGHLIGHTS

• On 4 April 2024, new Immigration Rules came into force, affecting employers who sponsor workers under the “Skilled Worker” or “Global Business Mobility: Senior or Specialist Worker” routes.
  
  Among the main changes to the Skilled Worker route was an increase of the minimum salary threshold from £26,200 to £38,700 per year. In addition, the minimum occupation-related going-rate salaries were raised, which are now calculated by reference to the 50th percentile (median) of all wage earners in a particular occupation, rather than the 25th percentile. This means that those being sponsored under the Skilled Worker route must now be paid an annual salary of at least £38,700, or the bottom 50% of all those working in the relevant occupation, whichever is higher. On a positive note, the supplementary employment provisions were liberalised, meaning that Skilled Workers are now permitted to undertake supplementary employment in any occupation eligible under the Skilled Worker route.
  
  The main change for the Senior or Specialist Worker route is that the minimum salary threshold was increased from £45,800 to £48,500 per year. The UK Government opted to continue to calculate the minimum occupation-related going-rate salaries with reference to the 25th percentile, while maintaining the High Earner threshold at £73,900.

• Keeping with its continuing digitisation of the UK immigration system, the UK Government stopped issuing Biometric Residence Permits (BRPs)—credit card-sized identity documents which hold a migrant’s biographic data, biometric information, and details of their UK immigration status—to those who submitted their UK immigration applications after 31 October.
  
  Upon approval of an immigration application submitted after this date, the individual will be issued with digital immigration permission, known as an eVisa.
  
  Anyone whose current immigration permission expires after the end of 2024, and who currently holds a BRP, must register for a UK Visas and Immigration (UKVI) account to access their eVisa. Even after they have been issued with an eVisa, BRP holders must continue to carry their BRPs with them when they travel overseas, to ensure re-entry to the United Kingdom up to the date that their BRPs expire. In addition, although current BRP holders would, technically, no longer need to carry any physical immigration documents with them after 1 January 2025, we advise individuals to continue to carry their BRPs, and to always have access to their UKVI approval e-mails when they travel overseas, in case they are asked to prove their UK immigration status when they return to the UK.

• The United Kingdom launched its Electronic Travel Authorisation (ETA) scheme in October 2023. An ETA is a digital permission to travel to the United Kingdom. Initially only available to Qatari nationals, the program was expanded in February 2024 to include nationals of Bahrain, Kuwait, Oman, United Arab Emirates, Saudi Arabia, and Jordan. ETA is for those who are coming to the United Kingdom for up to six months for the purposes of tourism, visiting family and friends, business, or short-term study. ETA does not grant immigration permission to enter the United Kingdom, and is not a guarantee of entry. Individuals who obtain an ETA will still need to see a Border Force officer when they arrive in the United Kingdom, who should then grant them entry as a visitor, provided the individual meets the relevant requirements.

2025: OUTLOOK

• Beginning 8 January 2025, all non-Europeans will require an ETA to travel to the UK, unless they already hold UK immigration permission. Non-Europeans may start applying for an ETA from 24 November 2024, and—provided the application is approved—it will remain valid for two years. The requirement to hold an ETA will extend to European nationals, with the exception of Irish nationals, from 2 April 2025. European nationals may apply for ETAs from 5 March 2025.
• The UK Government is in the process of updating the Sponsorship Management System (SMS), the online portal through which companies can manage their sponsor licences and issue Certificates of Sponsorship (essentially electronic work permits) to overseas workers they wish to sponsor for work in the United Kingdom. The current SMS has been in place since 2008, when the UK Government first introduced the Points Based System. The aim is to make the SMS more intuitive and easier for sponsor licence holders to meet their immigration compliance duties and responsibilities.
  
  The UK Government has already started rolling out the new SMS to those who hold licences under the Temporary Worker routes, and plans to implement it for the remaining categories—including the Skilled Worker and Senior or Specialist Worker routes—by the end of 2025.

Although we do not expect any major immigration policy changes in 2025, the UK Government’s continued digitisation of the UK immigration system is likely to create challenges for employers, business travellers, and those who hold long-term immigration permission to remain in the United Kingdom. Although the experience of those who have already applied for ETAs has been positive, it remains to be seen how robust the system is once rolled out to more nationalities. Although the process to obtain eVisas has been smooth for the vast majority of BRP holders, we have seen instances where the details set out on the eVisa are incorrect, or where individuals are unable to access their eVisas. Although the Home Office has been efficient in rectifying these issues so far, it will be interesting to see if this continues to be the case when it has to deal with the inevitable rush of UKVI account registrations towards the end of the year.

The long-overdue update of the SMS is a positive one, and it is hoped that it will deliver benefits to those who sponsor migrants by making it easier for them to meet their immigration compliance duties and responsibilities.

With the UK Government under increasing pressure to reduce net migration—which is currently running at the highest level since records began—we are seeing increasing scrutiny of applications, as well as an upturn in Home Office immigration compliance activity, which we expect to continue into 2025.

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