Key takeaways
Overseas recruitment for care roles closed
New rules mean care providers must now hire locally.
Visa rules tighten for switching workers
Only those already employed can switch to care visas.
Stronger focus needed on local hiring
Providers must invest in domestic talent and retention.
Restricting the pipeline
UK care sector faces new recruitment limits
On 22 July 2025, the UK government closed overseas recruitment for adult social care roles under the Skilled Worker (Health and Care) visa.
Individuals already in the UK can continue to extend or switch within the route until 2028, subject to eligibility. Reforms, outlined in the White Paper Restoring Control over the Immigration System, implemented via the Statement of Changes and now the Immigration Rules carry significant implications for sponsors, particularly those reliant on international care sector recruitment (UK Immigration White Paper 2025: Key Changes for Employers | Hill Dickinson).
A narrowing window for sponsorship
A transition period is now in effect and remains in place until 22 July 2028, allowing for in-country applications to extend their current visa or switch from other visa routes to the Skilled Worker (Health and Care) visa. However, eligibility is restricted to:
Care workers and home carers who currently hold a Health and Care visa sponsored under Standard Occupational Classification (SOC) codes 6135 (6145 pre-April 2024);
Senior care workers who currently hold a Health and Care visa under SOC 6136 (6146 pre-April 2024).
Individuals switching from a different visa route (e.g. Dependant visa, or Graduate visa) to Skilled Worker must now have been legally employed by the Sponsor in the relevant role for at least 3 months (before the Certificate of Sponsorship is assigned) unless an exception applies. Additional documentary evidence is required to be kept on file in line with the care provider’s record keeping obligation.
Salary Threshold - The salary requirements for a Skilled Worker in some healthcare roles remains at £25,000 a year or £12.82 per hour, whichever is higher, rather than the steeper new salary threshold for non-health roles which is now at £41,700 per annum.
After the transition period, SOC 6135 and 6136 will be removed from the Immigration Salary List and the Temporary Shortage List. With the removal of overseas recruitment, care providers will need to rely on the domestic labour market to meet staffing needs and the question remains whether there are sufficient numbers in the UK to meet demands? This shift will place increased pressure on an already stretched workforce, adding to existing staff shortages and limiting providers’ ability to respond to urgent care needs.
Removal of displaced worker pool requirement
Previously, care sponsors were required to prioritise recruitment from the “displaced worker pool”, a list of care workers in the UK who had lost sponsorship due to sponsor licence revocations - a total of 1,494 sponsor licenses were revoked in 2024. This requirement has now been removed.
The removal of this requirement leaves affected care workers more vulnerable. Those who have lost their roles due to licence revocations may struggle to secure a new sponsor in time, and without prioritised access to sponsorship, face an increased risk of being required to leave the UK.
Given their valuable experience and qualifications, many care workers may look to continue their careers in countries where their skills are in high demand – risking a loss of talent from the UK care sector where a provider may have, to date, invested significant time and costs to train them.
Recruitment challenges
These recent changes place additional pressure on the social care labour market, which is already strained by high turnover and persistent vacancies. The potential introduction of a Fair Pay Agreement for social care (a negotiated arrangement between employers and worker representatives, such as unions, setting minimum pay and working conditions) is aimed at improving standards and retention. However, while well-intentioned, such agreements may further stretch already limited budgets, particularly for smaller providers.
Strategic planning required
Sponsors must now take a more proactive approach to workforce planning, including:
Developing contingency plans for recruitment and retention
Investing in domestic workforce development and training
Considering these developments, care providers should urgently review and strengthen their recruitment, training and retention strategies. Building a resilient domestic workforce will be essential to navigating the evolving employment and immigration landscape and ensuring continuity of care in the years ahead.
How can Hill Dickinson help
With the care sector under heightened scrutiny, navigating workforce planning and immigration compliance requires strategic foresight and expert legal support. Our experienced immigration and employment lawyers can provide expert advice and ongoing support to safeguard your workforce strategy and ensure the best outcomes for your business.
Our support includes:
Strategic guidance on complying with Home Office requirements and mitigating risks associated with workforce changes.
Preparation of tailored documentation (e.g. policies, guidance notes, templates) to support providers in decision-making and compliance.
Conduct detailed sponsor licence compliance reviews (remote or on-site) to assess readiness for UKVI/Home Office audits and ensure alignment with current sponsor duties.
Tailored training sessions for HR teams/Managers/Key Personnel on the Health and Care route, compliance with sponsor duties, Home Office requirements and practical tips.
This article was co-authored by Alice Web.
