UK Immigration White Paper - Part 1: Skill level threshold and temporary shortage list

On 12 May 2025, the Home Office published its latest white paper, Restoring Control Over the Immigration System, outlining a series of proposed reforms to the UK’s immigration framework. While some of the proposals seek to improve structure and responsiveness within the system, others raise important questions around consistency, long-term planning, and the broader, problematic narrative surrounding immigration.

This article, the first in a two-week series from Irwin Mitchell’s immigration team, focuses on two proposals in particular: the increase in the required skill level for Skilled Worker roles and the abolition of the Immigration Salary List (“ISL”). Both are significant changes which warrant close scrutiny in terms of their policy implications and practical impact.

Raising the Skill Level Threshold

One of the central proposals is to raise the job skill level requirement for the Skilled Worker route from RQF Level 3 (A-level equivalent) to RQF Level 6 (degree level) for new applicants. This effectively rolls back the significant liberalisation introduced by the previous government who reduced the job skill level to RQF Level 3 in 2020. Those changes were primarily introduced to broaden access to the Skilled Worker route to deal with projected labour market needs following Brexit.

The white paper frames this shift back as a means to reduce net migration. However, it does not fully address why an approach previously adjusted in response to critical labour shortages is now being revisited, nor how the new proposal differs in execution or intended outcome from prior attempts. This raises questions about the underlying evidence base and the feasibility of striking a balance between reducing migration and maintaining a functioning workforce in vital industries such as health and social care, logistics, and construction.

The white paper also states that RQF Level 6 jobs may also be reviewed over time to consider whether there is an overreliance on overseas workers and whether such jobs should remain on the Skilled Worker route. 

Additionally, there remains a lack of clarity on a key point: does the new threshold require the job to be at RQF Level 6, or must the applicant themselves hold a degree qualification? This distinction is fundamental, and greater specificity will be needed to ensure employers and applicants understand the practical implications.

Abolishing the Immigration Salary List

A second major proposal is the removal of the ISL, which was introduced less than a year ago to replace the Shortage Occupation List (“SOL”). The ISL aimed to provide a more data-driven mechanism for identifying roles eligible for salary concessions, with the intention of creating a more responsive and transparent system.

The decision to abolish the ISL so soon after its introduction, and to replace it with a newly proposed Temporary Shortage List (“TSL”), may create a perception of instability within the immigration framework. While the Home Office states that the new list will be underpinned by Migration Advisory Committee recommendations, the lack of detail regarding the transition, as well as the short-lived nature of its predecessor, may cause concern for both employers and visa applicants who seek consistency and clarity in immigration policy.

A stable immigration system requires not only well-calibrated rules, but also a sense of reliability. Frequent changes in approach and terminology, particularly over a short period, can erode confidence and create uncertainty for those seeking to live, work, or invest in the UK.

Looking Beyond the Policy

While much of the focus will understandably be on the substance of the proposed reforms, the tone of the white paper also merits attention. Migration is presented, in several instances, as a source of pressure - on services, housing, and wages - rather than as a valuable contributor to national prosperity, innovation, and social diversity.

This framing has been echoed in broader political discourse. Prime Minister Starmer’s recent remarks warning against the UK becoming “an island of strangers” risk reinforcing a sense of division and constructing a narrative in which migrants are seen as outsiders, rather than integral members of society. Language of this nature, particularly when coupled with policy reform, can influence public perception in ways that contribute to stigma and social exclusion.

Although it is appropriate for the government to assess and update immigration policy in line with public interest and economic needs, there is a risk that the wider narrative becomes reductive. It is important to ensure that reforms do not inadvertently stigmatise migrants or oversimplify the complex drivers of societal challenges.

Final Thoughts

The proposals outlined in the white paper are not yet law and will be subject to further legislative processes and consultation. In the meantime, it is crucial for stakeholders - employers, migrants, legal advisers, and policymakers alike - to engage critically with both the content and context of these suggested changes.

At their best, immigration reforms can offer clarity, fairness, and responsiveness to genuine needs. However, for these goals to be achieved, policy must be guided by consistency, transparency, and a recognition of the valuable role that migration continues to play in the UK’s economic and social fabric.