On this page
- Right to Work Rules Expand From 1 October 2026
- Major Changes to the Sponsorship Management System
- Sponsor Compliance and Reporting Duties
- Increased Scrutiny of Skilled Worker Salary Compliance
- Higher English Language Requirement for Skilled Workers
- September 2026 Statement of Changes: What Is Coming Next?
- Key Takeaways
- Frequently Asked Questions
UK immigration rules have changed throughout 2026, affecting right to work checks, sponsor licences, Skilled Worker compliance and English language requirements. On 3 September 2026, the Home Office published Statement of Changes HC 584, with most changes taking effect on 8 October 2026. Employers and sponsors should review their compliance processes now. The changes also affect visitors, students and several other visa routes. This article explains the key UK immigration changes for late 2026 and what employers and sponsors need to do.
Right to Work Rules Expand From 1 October 2026
Section 48 of the Border Security, Asylum and Immigration Act 2025 amends the Immigration, Asylum and Nationality Act 2006 and expands the illegal working rules. From 1 October 2026, the rules will apply not only to employees, but also to certain workers, individual subcontractors and people who find work through some online matching platforms.
The Home Office updated its draft employer guidance on 11 September 2026. From 1 October 2026, the guidance will explain how the expanded Right to Work Scheme applies to new working arrangements, including:
- who may be responsible across a contracting chain; and
- when workers can use substitutes.
Businesses should not assume right to work rules do not apply just because someone is not a traditional employee.
Major Changes to the Sponsorship Management System
The Home Office updated its sponsor guidance on 28 August 2026. The changes affect how sponsors manage their licences through the Sponsorship Management System (SMS).
The Home Office has also introduced a process for dealing with inactive SMS accounts. An account may be treated as inactive where it has not been accessed for 12 months or more, and sponsors who fail to keep active Level 1 Users in place could ultimately put their sponsor licence at risk.
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Sponsor Compliance and Reporting Duties
If the Home Office reasonably suspects that a sponsor is failing to comply with its duties, possible action includes:
- reducing the sponsor’s Certificate of Sponsorship allocation;
- downgrading the licence;
- suspending it; or
- ultimately revoking it.
From 1 October 2026, the sponsor guidance confirms that right to work checks will also apply to some worker contracts, individual subcontractors and certain online matching services.
Increased Scrutiny of Skilled Worker Salary Compliance
Updated Skilled Worker guidance confirms that the Home Office can check whether sponsors are paying workers the salary stated on their Certificate of Sponsorship. The Home Office can check this through HMRC data and sponsor compliance checks.
Payroll compliance is especially important when workers have:
- sponsored workers have variable hours;
- salary deductions;
- periods of unpaid leave; or
- irregular working patterns.
Higher English Language Requirement for Skilled Workers
Since 8 January 2026, most first-time Skilled Worker applicants must show B2 English in reading, writing, speaking and listening. Existing Skilled Workers can still use the B1 standard for qualifying extension or update applications.
From 26 March 2027, most Skilled Worker applicants applying for settlement must meet the higher B2 English standard, unless an exemption applies.
September 2026 Statement of Changes: What Is Coming Next?
On 3 September 2026, the Home Office laid Statement of Changes HC 584 before Parliament.
The changes take effect on:
- 8 October 2026: most amendments;
- 29 October 2026: T2 Minister of Religion and Religious Worker changes;
- 30 November 2026: Student maintenance changes; and
- 9 December 2026: EUSS biometric residence permit change.
“Most businesses still think right to work checks are only about their own payroll. That assumption stops working in October, once liability can reach up the chain to a business that has never met the person doing the work. The safest move now is mapping who actually supplies your labour, not just who invoices you.”
Skilled Workers Recognised as Victims of Modern Slavery
The Home Office has introduced more flexible work rights for some Skilled Workers who are victims of modern slavery.
From 8 October 2026, the Home Office may allow eligible Skilled Workers to take any type of work after they receive a positive Conclusive Grounds decision through the National Referral Mechanism. This includes self-employment and voluntary work.
Visitor Route: Overseas Training Becomes More Flexible
The Visitor Rules allow employees of overseas businesses to come to the UK for work-related training. Currently, they can only do this if the training is not available in their home country.
From 8 October 2026, that restriction will be removed. This means overseas employees can come to the UK for genuine work-related training without proving it is unavailable at home. Overall, this should make it easier for overseas businesses to send staff to the UK for training.
Erasmus+ Returns to the Immigration Rules
HC 584 introduces a number of immigration changes to support the UK’s participation in Erasmus+ from 2027. This includes new permitted activities under the:
- visitor route; and
- changes to the Student, Child Student and Government Authorised Exchange routes.
In some cases, organisations hosting Erasmus+ visitors will not need to sponsor them.
Changes to the T2 Minister of Religion Route
From 29 October 2026, the T2 Minister of Religion rules will change for members of religious orders. The changes will remove the overall limit on how long a person can stay on this route. Each period of permission will usually last up to three years.
New financial rules will also apply to applicants who are not entitled to the National Minimum Wage. An A-rated sponsor must confirm that it will provide their living costs and accommodation during their stay.
Student Maintenance Requirements Increase
From 30 November 2026, Student visa applicants will need to show more money for living costs.
Students must show:
- £1,570 per month if studying in London, up from £1,529; and
- £1,203 per month if studying outside London, up from £1,171.
These amounts usually apply for up to nine months.
Students and education providers should make sure applications lodged on or after 30 November 2026 meet the new requirements.
EU Settlement Scheme Changes
From 8 October 2026, HC 584 will make several changes to the EU Settlement Scheme (EUSS).
The changes set a new deadline for some joining family members. They also protect some people with pre-settled status if their family circumstances change, and removing their status would be disproportionate.
From 9 December 2026, applicants can no longer use a biometric residence permit (BRP) to prove their identity and nationality for an EUSS application.
Victim of Domestic Abuse Route Extended to Adult Dependent Children
From 8 October 2026, some adult children may be able to apply for settlement under the Victim of Domestic Abuse route in their own right. This applies where their relationship with a parent, or their parent’s partner, has permanently broken down because of domestic abuse.
Eligible adult children who previously held dependant status may now be able to apply under the domestic abuse route in their own right.
Hong Kong BN(O): Settlement for Children
HC 584 also changes the settlement rules under the Hong Kong BN(O) route. From 8 October 2026, dependent children under 18 will no longer need to complete the usual five-year qualifying period before applying for settlement. Eligible children can settle with their parents if they meet the other requirements.
Suitability: Frustrating Immigration Controls
From 8 October 2026, the Immigration Rules will treat certain actions intended to frustrate immigration controls as a previous breach of immigration law.
For example, this can include:
- failing to report to the Home Office when required;
- absconding from immigration bail or custody;
- using a false identity; or
- failing to cooperate with the removal process.
The Home Office can now consider this past conduct when reviewing an applicant’s immigration history and deciding whether to refuse their application.
Key Takeaways
Employers should review their immigration compliance processes now. In particular, they should:
- prepare for the Right to Work changes from 1 October 2026;
- review workforce and contractor arrangements;
- check who has access to the Sponsorship Management System;
- keep reporting processes up to date;
- monitor Skilled Worker salaries;
- review the Visitor changes if staff travel to the UK for training; and
- check when each HC 584 change takes effect.
Sponsor licence compliance should form part of normal HR processes, including Right to Work checks, SMS management, salary monitoring, record-keeping and reporting.
LegalVision provides ongoing legal support for businesses through our fixed-fee legal membership. Our experienced immigration lawyers help businesses manage contracts, employment law, disputes, intellectual property, and more, with unlimited access to specialist lawyers for a fixed monthly fee. To learn more about LegalVision’s legal membership, call 0808 196 8584 or visit our membership page.
Frequently Asked Questions
Who does the expanded right to work scheme cover from 1 October 2026?
From 1 October 2026, the scheme extends beyond employees to certain workers, individual subcontractors and people who find work through online matching platforms. More than one business in a contracting chain can face a civil penalty if the required right to work checks are missing.
What happens to existing Level 2 Users on the Sponsorship Management System?
Sponsors can no longer appoint new Level 2 Users from 9 September 2026. Existing Level 2 Users need an upgrade to Level 1, where eligible, or deactivation by 8 March 2027. Sponsors who leave inactive or ineligible users in place risk their sponsor licence.
When does the higher English language requirement apply to Skilled Workers?
Most first time Skilled Worker applicants must already show B2 English across reading, writing, speaking and listening, since 8 January 2026. Existing Skilled Workers can still rely on the lower B1 standard for a qualifying extension or update, but settlement applicants face the B2 standard from 26 March 2027.
When do the changes in Statement of Changes HC 584 take effect?
Most HC 584 amendments take effect on 8 October 2026. T2 Minister of Religion and Religious Worker changes follow on 29 October 2026, Student maintenance changes on 30 November 2026, and the EUSS biometric residence permit change on 9 December 2026.
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