Date set for commencement of new student, graduate and work immigration rules

New immigration rules were published today affecting a wide range of immigration routes. Most of the changes had already been announced in the earlier immigration white paper but there are a few surprises included in what is formally known as Statement of Changes HC 1333. If you are glutton for punishment, you can also take a look at the written statement in Parliament and the charming press release.

The full statement weighs in at 111 pages. This is my best stab at a brief summary of what’s going on…

Introduction of a visit visa requirement for nationals of Botswana

With immediate effect at 3pm today, 14 October 2025, but with some transitional protections. We’ve put out a separate short post explaining briefly what that means in practice.

Recognition of Palestine: changes to the visa national list

Palestine has also been added to the visa national list, with effect from 11 November 2025, meaning Palestinians too must apply for a visa before attempting to travel to the UK.

German school groups travel

Taking effect on 11 November, German students under the age of 19 can come to the UK without an advance permission (an ETA or visa) when they are travelling as part of a school party of five or more. It also allows EU, EEA, and Swiss nationals aged 19 and under who are studying at the school to travel on a national identity card rather than passport.

Introduction of dependants for Stateless people

Appendix Statelessness is amended so that a partner or child of a stateless person may apply for entry clearance or permission to stay under Appendix Statelessness from 11 November 2025 where they formed part of the family unit before a stateless person was granted permission to stay. Those applying as a dependant on this route will need to meet the relevant partner or child requirements.

Alternatively, where the partner or child of a Stateless Person are not themselves stateless and formed part of the family unit after a stateless person was granted permission, they may now apply to come to or stay in the UK under the family provisions in Appendix FM.

Immigration Skills Charge increasing by 32%

This isn’t actually in the statement of changes because a different legal mechanism is used, but it is part of the same package of measures.

The Immigration Skills Charge is levied directly on employers and is a fee per year of a worker’s employment with temporary leave. It was previously set at £1,000 per year in 2017 and will increase to £1,320 per year. There’s no date specified but we are told the “Parliamentary process to increase the charge will begin later this week.”

It is worth noting that many employers also pay the visa application and/or immigration health surcharge for employees they recruit from abroad as well as an annual fee for a sponsor licence and, quite often, a lot in compliance and legal costs to navigate the whole nightmare. Recruiting from abroad ain’t cheap.

Changes to English language requirements for economic migration routes

The English language requirement for the Skilled Worker, High Potential Individual and Scale-up routes is increased from B1 Level to B2 Level (as defined under the Common European Framework for Reference for Languages (CEFR)).

The new requirements will apply to those seeking an initial grant of leave in a relevant route following the implementation of these provisions on 8 January 2026. Those who have already obtained a permission where they were required to show a B1 level, will continue to be subject to a B1 level requirement where they are seeking an extension on the same route.

High Potential Individual: targeted and capped expansion of eligibility

Targeted and capped expansion, you say? How does that work? Well, the government is doubling the number of universities whose graduates can use the route but also capping the number of places that are available in this route at 8,000 per year. The High Potential Individual visa route is aimed at attracting graduates from top universities worldwide, as we explain in our, er, explainer.

The press release goes on to say:

The number of people coming to the UK through the HPI route is expected to double from 2,000 to 4,000, giving graduates from the world’s best universities the chance to base their careers in the UK.

So the cap of 8,000 is not expected to be reached. That begs the question of why have such a cap, then. Presumably it is to guard against an unexpected very large increase in applications.

Global Talent Route

The Global Talent Route is also getting some love, with the gateway list of eligible prizes to be expanded along with some changes helpful to architects. Architect applicants will be allowed to provide evidence of their achievements as a named member of a group or contributor, as well for their work as an individual, and provide evidence of significantly contributing to being shortlisted or nominated for an international architectural award.

There’s more to come in 2026, apparently:

The government aims to double the number of highly skilled people coming to the UK on our high skilled routes, including the best researchers, designers, and creatives working in film and TV to ensure continued competitiveness in growth sectors. Further changes, including to the Global Talent route, will be made in 2026.

Duration of stay under the Graduate route reduced to 18 months

The Graduate route currently allows eligible graduates who have successfully completed a UK bachelor’s degree, master’s degree, or other relevant qualification to remain in the UK for two years, and PhD graduates for three years.

This is being reduced to 18 months will apply to applications submitted on or after 1 January 2027, with PhD graduates continuing to receive three years of leave.

Students to transition to the Innovator Founder route

A small tweak but a welcome one for those who benefit. With effect from 25 November 2025, a student will be permitted to be self employed, for example to establish a business, where they have completed their course and are switching to the Innovator Founder route. This is how it used to work for those switching into the old Start-up route.

The financial requirements for student visas will be increased for the 2025-2026 academic year, unsurprisingly.

Part 9: Grounds for Refusal replaced with Part Suitability

Argh.

What we used to call the ‘general grounds for refusal’ are being replaced with new, consolidated, universal suitability requirements. The separate Appendix FM suitability rules are being scrapped and rolled into the new general ones. The change takes effect on 11 November 2025.

In principle this is probably a helpful change because the negative nature of the refusal grounds made them pretty confusing to explain to new lawyers, which is never a good sign. Applications which looked like they would succeed would actual fail because of a non-cross-referenced override situated elsewhere in the rules and thereby effectively hidden. But this change is going to take us existing lawyers a while to get our heads around as the old Part 9 goes back to time immemorial. Or, to be more precise, 1994. I have not had time to review and analyse the new text and compare it to the old version to see if there are any substantive changes.

There are also a LOT of technical consequential changes because there were a lot of references to the old general grounds and various old suitability requirements as well.

Appendix Temporary Work – Seasonal Worker

Seasonal workers will be able to spend no more than six months working in the UK during any rolling 10-month period, rather than any rolling 12-month period under the previous rules. There’s also a 4 month cooling off period before a person who was previously working as a seasonal worker may re-enter in the same category. The new rules apply for applications made on or after 11 November 2025.

Ukraine Permission Extension Scheme

A slight tweak to allow a child’s leave to be aligned with a legal guardian as well as with parents along with some other changes which sound minor from the explanatory statement but might well need some closer scrutiny.