UK
Immigration – labour and migration
Impact date: 22 July 2025 (majority of provisions) On 1 July 2025, the Government announced a statement of changes to the Skilled Worker and other work routes. These changes implement the first phase of reforms to work visas which were initially set out in the Immigration White Paper, “Restoring Control over the Immigration System”, published in May 2025.
From 22 July 2025, salary changes will take effect, increasing the UKVI minimum threshold for:
- New hires from £38,700 to £41,700
- For those extending or changing employment in Skilled Worker from £29,000 to £31,300
- Global Mobility Route from £48,500 to £52,500
The SOC Going Rate thresholds are also increasing for both new and current Skilled Workers. There is also an increase to the required skill level for Skilled Worker visas from RQF Level 3 (approximately A-Level) to RQF Level 6 (approximately graduate level), meaning only graduate positions are now eligible for sponsorship (unless the role is on one of the two new interim shortage occupation lists). The Social Care Worker visa route will be closed to overseas recruitment meaning sponsors will not be able to sponsor migrants in SOC 6135 Care Workers and Home Carers and SOC 6136 Senior Care Workers after 22 July 2025. In-country switching into these codes will remain possible until 22 July 2028, if certain conditions are met.
Employer implications/action needed Employers should review and amend their approach, including:
- Salary reviews: Undertake an immediate review of salaries of those on the Graduate Route and Skilled Worker route to identify any employee whose salary will fall below the new minimum thresholds
- SOC code reviews: Review any commonly used SOC codes to identify if specific areas will be impacted by the uplifted skill threshold
- Review recruitment pipeline: Any planned new hires will need to satisfy these new Skill and Salary requirements and all offers should be considered to check the new requirements are met
- CoS allocation requests: If employers intend on early sponsorship they should have sufficient CoS available and if needed request an increase as soon as possible
- Updating policy documents and training: HR and Global Mobility teams should ensure they are up to date with the changes and aware of the new applicable skill and salary thresholds. Template offer letters and immigration policies should be updated to reflect any rule changes regarding dependents and training should be given to those in HR and global mobility
Employer risk Employers should prepare for higher recruitment costs and tighter regulations on sponsorship.
Economic Crime and Corporate Transparency Act 2023
Impact date: 1 September 2025 Legislation has introduced a new offence under which large employers may be criminally liable where an employee, among others, commits a fraud intending to benefit the employer (or, in some circumstances, to benefit a client) and it did not have reasonable fraud prevention procedures in place. The aim of the legislation is to encourage more employers to implement or improve prevention procedures, including a shift in corporate culture to help prevent fraud.
The employer will have a defense if it has reasonable procedures in place to prevent fraud, or if it can demonstrate to the satisfaction of a court that it was not reasonable in all the circumstances to expect the organization to have any prevention procedures in place.
Employer implications/action needed Employers should familiarize themselves with the Home Office guidance, which sets out procedures that employers can put in place to prevent employees from committing fraud offences. Employers should refer to the guidance when developing or updating their fraud prevention policies and procedures. For example, conducting risk assessments, providing training and reviewing the effectiveness of whistleblowing procedures, among other steps.
Employer risk Organizations can be held criminally liable if an associated person (such as an employee, agent, or subsidiary) commits fraud intended to benefit the organization, and the organization did not have reasonable fraud prevention procedures in place. A court will take adherence to the Home Office guidance into account when considering liability. Employers should therefore ensure adherence to the guidance to mitigate risk.
Confidentiality clauses - Victims and Prisoners Act 2024
Impact date: 1 October 2025 The Victims and Prisoners Act 2024 will make any confidentiality clause (often referred to as an NDA) signed on or after 1 October 2025 void if it seeks to prevent a victim (or a person who reasonably believes they are a victim) from making certain disclosures of information to specified groups/persons for specified purposes, as set out within the Act. This includes for example disclosures to victim support services, or a victim’s close family, for the purposes of obtaining support in relation to the relevant conduct.
Employer implications/action needed Employers will need to review the wording of any confidentiality clauses, including within template settlement agreements, to assess whether updates are required. Employers should also consider training line managers and HR teams involved in settlement agreement negotiations to ensure that appropriate NDAs are used, depending on the circumstances. It should be noted that the Government is also introducing further limits on the use of NDAs in the Employment Rights Bill.
Employer risk N/A
Links Read our article here: Victims and Prisoners Act 2024 - Changes to NDAs from 1 October 2025 in England and Wales
Tax liabilities for workers supplied through umbrella companies
Impact date: 6 April 2026 Umbrella companies are employment intermediaries that employ workers on behalf of recruitment agencies and end clients. HMRC is concerned that some umbrella companies are facilitating tax non-compliance, including avoidance and fraud. It believes that making those who can control labor supply chains legally responsible for ensuring that PAYE/NIC is properly accounted for will improve compliance.
To that end, draft legislation has been published which makes recruitment agencies or end clients responsible, in certain circumstances, for PAYE and National Insurance payments arising from workers supplied via umbrella companies.
Employer implications/action needed The inclusion of umbrella companies within contractual chains will no longer act as a shield to potential PAYE/NIC liabilities for affected end clients and agencies. They should audit their labor supply chains to identify the involvement of any umbrella companies and those identified should be risk-assessed. Contracts, warranties and due diligence processes should be reviewed for adequacy. In addition, given other changes in the contingent labor supply chain under the Employment Rights Bill reforms, a holistic review of worker engagement models is also advisable.
Employer risk N/A
Links Read our article here: UK government publishes draft legislation to tackle non-compliance in the umbrella company market
Employment Rights Bill
Impact date: 2025 - 2027
On 10 October 2024, the new Government unveiled the UK Employment Rights Bill* and a supporting document (“Next Steps to Make Work Pay”), the breadth and depth of which is likely to transform employment law and significantly change employer practices. The Bill is currently moving through its final parliamentary stages.
In summary, the Bill includes measures to:
- Require employers to publish an equality action plan on addressing gender equality
- Take 'all' reasonable steps to prevent workplace sexual harassment
- Introduce protection from third party harassment
- Strengthen flexible working rights
- Make paternity and unpaid parental leave day one rights
- Extend bereavement leave
- Extend protection from dismissal during pregnancy, maternity and other leave and upon return
- Reform trade union, industrial action and statutory recognition legislation
- Introduce new zero-hour contract (ZHC) and 'low-hour' contract workers' rights, including for agency workers
- Significantly limit 'fire and re-hire' or ‘fire and replace’
- Introduce day one unfair dismissal rights subject to a probationary period
- Adjust employment tribunal time limits to six months for all claims
- Extend SSP entitlements
- Widen the duty to collectively consult on redundancies and increase employer penalties
- Introduce a Fair Work Agency - a new enforcement body
The Government has published a roadmap detailing an anticipated timetable for consulting on, and implementing, the ERB’s key measures. While some will be implemented in 2025, most will commence in April or October 2026 or 2027.
In addition, new amendments to the ERB soften the impact of the 'fire and rehire' measures while also introducing protection against 'fire and replace' (certain situations where an employee is dismissed and replaced by contract labor). They also extend bereavement leave to include pregnancy loss before 24 weeks and they void any provision in a confidentiality agreement (e.g. NDA) which precludes the worker from making an allegation or disclosure of information relating to relevant harassment or discrimination, or the employer's response to the harassment or discrimination or making of the allegation or disclosure (exceptions will be provided for, but as yet they are unknown).
Employer implications/action needed Employers should prioritize preparations for those measures anticipated to take effect in 2025 and early 2026, including:
- Updating family leave polices to reflect the new day-one rights to paternity and unpaid parental leave
- Budgeting for increased SSP costs from April 2026 and reviewing sickness absence policies and manager training on short-term sickness absence, levels of which may rise as a result of the SSP changes
- Undertaking a pay audit of workforce pay practices (including national minimum wage, SSP and holiday pay) to identify and address any inadvertent issues in advance of the establishment of the FWA (although a transitional period is expected while powers transfer to the FWA)
- Reviewing collective redundancy consultation processes given the planned increase to the maximum protective award period
- Assessing contingency planning for industrial action, including preparing for situations where it will be simpler and quicker for a union to commence industrial action
- Anticipating an increase in TU recognition requests and reviewing engagement strategy, including assessing existing employee relations and identifying and addressing engagement concerns
For longer-term measures, it remains important for employers to risk assess their current practices and plan well in advance given the scale of change.
Employer risk The Employment Tribunal enforcement route will remain, but a new single enforcement body is also expected to take a targeted approach to enforcement. The Government has identified enforcing the minimum wage, including on travel time between multiple working locations, and the treatment of migrant workers, as priorities.
Link For more detail on these changes and anticipated timescales see our tracker: Home - Preparing employers for workplace changes (eversheds-sutherland.com)
Pay gap reporting
Impact date: Awaited Already well established in Great Britain, in Northern Ireland the Employment (NI) Act 2016 provides for a gender pay gap regime to be introduced, as well as ethnicity and disability pay gap reporting. The relevant Regulations have been delayed and are expected later this year at the earliest, which will outline the practical workings of the scheme. There are likely to be some differences with Great Britain, but the methodology as proposed reflects the position in Great Britain regarding gender pay gap reporting, including provisions like mean and median pay, bonuses and information being published in quartiles.
In Great Britain, the Employment Rights Bill (see above) includes a requirement for employers to publish an equality action plan on addressing gender pay gaps. In addition, with a Draft Equality (Race and Disability) Bill (yet to be published, see under Equality change below), it is proposed to mirror the existing legislation relating to equal pay and gender pay reporting to introduce mandatory ethnicity and disability pay gap reporting for employers with 250 employees or more and to enshrine in law the full right to equal pay for ethnic minorities and disabled people.
Employer implications/action needed Employers should continue to monitor developments and ensure that they have the infrastructure in place to comply with updated reporting requirements, once in force.
Equality changes
Impact date: Awaited The Government has consulted on mandatory ethnicity and disability pay gap reporting, stating its aim of using a similar reporting framework for ethnicity and disability to that already in place for gender pay gap reporting. Together with a call for evidence, the consultation will inform the Draft Equality (Race and Disability) Bill which is expected to be published in 2025. The call for evidence addresses a range of equality topics, including: equal pay rights for ethnic minority and disabled people; ensuring that outsourcing of services cannot be used to avoid paying equal pay; improving enforcement; improving pay transparency; steps to prevent workplace harassment; strengthening protections against combined discrimination; socio-economic duty; and public sector equality duty.
Employer implications/action needed The Equality (Race and Disability) Act is anticipated to be finalized in 2026 and there is likely to be an implementation transition period to allow employers to get ready for the change, for example, there may be a period during which it is voluntary for employers to comply. However, employers should not wait to take steps until the law is implemented, reflecting the unique challenges associated with collecting and analyzing ethnicity and disability data. Employers with 250 or more employees should be acting to ensure that they have the infrastructure in place to be able to report on affected pay practices and workforce numbers.
Employer risk N/A
Links N/A
The “Good Jobs” Employment Rights Bill (Northern Ireland)
Impact date: There is no definitive timeline at present, but we expect to see the Bill introduced in 2026 and the legislation passed before the mandate of the current NI Assembly expires in 2027. On 28 April 2025 the Minister for the Economy provided an update on the proposals for the “Good Jobs” Employment Rights Bill. It was confirmed that the key areas of focus will include amendments and/or new rights, entitlements and obligations in relation to (a) zero hours contracts (b) fire and rehire (c) agency workers (d) tips (e) holiday pay (f) trade unions and industrial action, and (g) family related rights, including paternity leave, carer’s leave, neonatal leave and flexible working.
Employer implications/action needed The Minister for the Economy described this as the “biggest upgrade in workers’ rights since the Good Friday Agreement [in 1998]”.
Any employer with a presence in Northern Ireland should monitor developments closely and prepare for the introduction of the legislation as it develops. The changes are likely to be significant.
Employer risk While some of the proposed reforms will make Northern Ireland more closely aligned to Great Britain (for example, regarding flexible working and family rights), others will create further divergence and this will pose an additional risk to multi-jurisdictional employers, in addition to those already present. The differences/risks will be even more pronounced as Labour’s proposals will not apply in Northern Ireland.
Report published following consultation on changes to race relations legislation (Northern Ireland)
Impact date: With the consultation complete, the legislative process will commence. The Executive Office has published a Response Report following the completion of a consultation in relation to amending the Race Relations (Northern Ireland) Order 1997. Amendments to the legislation are likely to follow and proposals include in relation to taken place by the Executive Office following a review of the Race Relations (NI) Order 1997. Legislative developments are anticipated, including making victimization claims more straightforward and widening the definition of racial harassment.
Employer implications/action needed Employers with a presence in NI should monitor developments, particularly following the publication of any draft legislation.
Employer risk N/A
Link N/A
Safe leave for victims of domestic abuse (Northern Ireland)
Impact date: Awaited The Domestic Abuse (Safe Leave) Act 2022 makes provision for an entitlement to paid safe leave for victims of domestic abuse in Northern Ireland. Regulations are awaited that will set out the details of how safe leave will work.
Employer implications/action needed While the exact details are awaited, we know from the framework that this will be a ‘day one right’ (i.e. no length of service will be required) and that it will provide for leave relating to domestic abuse, such as for the individual to obtain legal advice and find alternative accommodation, with their employment terms protected in the meantime.
Employer risk N/A
Link N/A
Paid miscarriage leave (Northern Ireland)
Impact date: There is a longstop date of 6 April 2026 by which paid miscarriage leave must be introduced in Northern Ireland, but it could be earlier than that. In March 2022 Northern Ireland introduced parental bereavement leave and pay equivalent to the entitlement in Great Britain. In time the Northern Irish law will also introduce paid miscarriage leave. In Great Britain, the Government has also indicated its support for leave for pre-24 week pregnancy loss, however it is currently unclear whether such leave would be paid or unpaid.
Employer implications/action needed Employers should follow developments and amend their policies and practices to accommodate miscarriage leave, once in force.
Employer risk N/A
Link N/A
Equality Commission for Northern Ireland Submission into Gaps in Equality Legislation (Northern Ireland)
Impact date: There will be no immediate reform of this area, but it is likely in the future. In September 2024 the Equality Commission for Northern Ireland (ECNI) filed a submission to the Committee for the Executive Office Inquiry into gaps in NI equality legislation. ECNI’s submission highlighted “clear and persistent weaknesses in equality law” in NI (where the Equality Act 2010 does not apply), including disparities between the equality protection offered by different equality laws and “increasing shortfall” when compared to other jurisdictions, including Great Britain and the Republic of Ireland. Recommendations have been made in reform, including in age discrimination (access to goods facilities and services), race, disability (including the lack of discrimination arising from disability, which does not apply here) and in respect of sex, gender reassignment, pregnancy, as well as religious belief and political opinion.
Employer implications/action needed NI employers should continue to review developments in this area and, in the meantime, ensure that they are aware of the differences in legislation/approach in NI compared to other jurisdictions.
Employer risk N/A
Link ECNI Submission
*Applies to England, Wales and Scotland only.
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