CIOs and tech leaders should heed the UK’s latest immigration reforms

CIOs should heed recent changes to UK immigration law, argue Boodle Hatfield’s Rhona Findlay and Zoe Jacob. (Photo: Artens / Shutterstock)

The Government’s white paper “Restoring Control over the Immigration System,” published in May 2025, has big implications for the tech sector. Published as part of its wider push to lower net migration to the UK, the first tranche of associated legal reforms came into force on 22 July. The flagship change is that the minimum skills threshold for sponsored occupations has been raised to degree level, otherwise known as RQF Level 6+. Occupations at the RQF 3 to 5 level will remain eligible for sponsorship for new applicants if they appear on either the expanded Immigration Salary List, or the new interim Temporary Shortage List. 

Sponsorship of roles on these lists will be subject to different conditions compared to RQF 6+. Significantly, new workers sponsored on either list at RQF levels 3 to 5 will be unable to bring dependents with them to the UK. Workers sponsored at an RQF level 6 or above will still be able to bring dependents. The Home Office has also stated that the Immigration Salary List will be ‘phased out’ and the entries on the Temporary Shortage List are ‘time-limited and conditional.’ This uncertainty will, combined with the restriction on bringing dependents, make these roles less attractive to foreign talent.

For the tech sector, the above changes to UK immigration law may not immediately ring alarm bells, the general assumption being that most roles in the industry comfortably meet the RQF Level 6 minimum skills threshold. Engineering or analyst roles certainly fall above the relevant threshold. This analysis, however, ignores the roles which fall below the new minimum skills threshold for sponsorship, which are critical to the tech sector – particularly those within customer services and sales. 

The reality is that, although the White Paper refers to “support for strategic industries,” and recognises the crucial role the tech industry plays in economic growth, by proposing increased access to high-talent routes, it fails to acknowledge that the tech industry also recruits essential migrant workers in roles that fall below “RQF Level 6.”

UK immigration implications for tech firms

With this in mind, we recommend all tech companies undertake an internal audit of their current sponsored workers, as well as their talent pipeline, to assess their vulnerability in the context of the 22 July changes. This audit must be undertaken in the context of recent tech sector layoffs as, if a company were to lay off sponsored workers now, then, in the future, decided to rehire a migrant worker in a similar role, there are two key concerns. Firstly, if the migrant worker’s role is below RQF level 6, it may be much harder to recruit a migrant worker in the role in the future. Secondly, sponsorship of new migrant workers is set to become significantly more expensive as the Home Office has recently commissioned the Migration Advisory Committee to undertake a review of salary thresholds and substantial increases are expected. 

In addition to an audit of their sponsored workforce, it is vitally important that Authorising Officers and HR teams stay on top of the changes to the Skilled Worker route, including updates to the compliance regime. There are an ever-increasing number of compliance visits by the Home Office to Skilled Worker sponsors. If a company is ill-prepared for inspection, there is a real risk of revocation of the sponsor licence – which could be catastrophic, both to the company and individual alike.

Zoe Jacob is a partner and head of immigration at Boodle Hatfield LLP. Rhona Findlay is an immigration associate at the same firm.

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