It is a pivot away from the post-Brexit liberal immigration system that led to record net migration.

For employers who use migrant labour and who recruit from overseas, the impacts of these proposals will vary, depending on the skills level of the roles that are filled. The effect will be to remove eligibility for around 180 lower-skilled occupations, including many in care, hospitality and food services. 

The care industry will arguably be the most significantly impacted sector, as the white paper proposed ending social care visas. Up until a transition period until 2028 visa extensions and in-country switching for those already in the country with working rights will be retained but this will be kept under review.

The advice to employers and recruiters would be to urgently review workforce forecasts and to make arrangements for hires sooner rather than later, and to boost training in the long term.

The newly proposed Temporary Shortage List may offer some respite for industries that are particularly struggling but this will not be a permanent fix as it is time limited. It is also conditional on workforce strategies, including training, pay and domestic recruitment commitments, and restricted to occupations key to UK infrastructure or industrial strategy, so will most likely focus on construction and manufacturing.

One of the key changes that employers who employ overseas workers are expected to make is increased and measurable training in domestic workers. According to some figures, there are nine million people in the UK of working age who are not in work, training or education. 

The government has staked its policy on the prediction that with the right training and working conditions these people can be coaxed back into work. I am not sure it will be that easy. Many labour shortages for lower-skilled roles have been enduring in part because of low wages, but also because domestic workers simply don’t want to do those jobs. I’m sceptical as to whether there is a home-grown army of workers ready to step in, train up and do these hard-to-fill jobs.

We must ensure that this transition is not only enforceable, but economically and socially sustainable. Oversimplified crackdowns that could destabilise key sectors like health will be counterproductive. We need smarter migration, not just smaller numbers.

At the other end of the scale, recruiters and employers in skilled and highly skilled sectors will be largely unaffected by the changes. The new system favours highly educated and highly skilled overseas workers. IT, finance, research and development, engineering and science-based roles will fall within the higher salary and higher education level criteria the white paper proposes.

For all firms my advice would be to review your overseas hiring pipeline, prepare for compliance scrutiny and monitor government guidance, which could change further.

It is also important to understand that not all the measures included in the white paper are currently in effect. It sets out the UK government’s intended direction for immigration reform but does not itself change the law.

Some measures are already underway such as higher salary thresholds, tighter controls on dependents and application of the genuine vacancy test in social care. Further measures such as raising the Skilled Worker visa threshold to RQF 6 and abolishing the Immigration Salary List are scheduled to be implemented during 2025 and into 2026, with full closure of the social care visa route by 2028. This gives employers some breathing space and I anticipate an increase in applications for a range of visas over the coming months.

Many reforms also require consultation with advisory bodies and some will be subject to transitional arrangements.

Some reforms, particularly those related to earned settlement, family migration rules or citizenship, may also require new legislation, and thus a formal vote in Parliament.

Yash Dubal is director at A Y & J Solicitors

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