Key points

These updates involve changes relating to:

• Botswana visit visa requirements.
• Recognition of Palestine.
• German school groups travel.
• English language requirements.
• High Potential Individual - targeted and capped expansion of eligibility.
• Duration of stay under the Graduate route.
• Students transition to Innovator Founder route.
• Immigration Skills Charge increase.
• Global Talent Route expansion.

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Introduction of Visit Visa Requirement for Botswana Nationals

Due to the high number of asylum claims by Botswana nationals, they will now require a visa to visit the UK.  

• Botswana is being removed from ETA eligibility.
• Visitors will be screened before arrival, and refused entry if they don’t meet UK rules.
• Visa status of Botswana will be reviewed over time, based on asylum trends.
• Transition period until 25 November 2025 for those with confirmed travel before the announcement to travel without a visa.
• ETA applications close on 14 October 2025.
• Changing travel dates to within the transition window will not avoid visa requirement. The aim of this is to prevent disruption and allow enough time to apply for a visa.
• Botswana nationals will also need a Direct Airside Transit Visa (DATV) unless exempt.

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Recognition of Palestine: Visa National List

• UK has formally recognised Palestine as a state, as of September 2025.
• Palestine has now been added to the Visa National List, meaning nationals will need a visa to visit the UK.
• This continues existing practice in that Palestinians already needed a visa.
• This ensures visitors are assessed before arriving for security reasons.
• Palestinian nationals will also require a DATV unless exempt.

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German School Groups Travel

• Changes now allow students aged 19 and under from German schools to visit without a visa or ETA, if in a group of 5+.
• Students can use a national ID card instead of a passport.
• This mirrors the existing UK-France agreement.

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English Language requirements 

• For Skilled Worker, High Potential Individual, and Scale-up routes, the English language requirement has been raised from level B1 to B2 (CEFR).
• Applies from 8 January 2026 for new applicants.
• Existing permission holders can continue with level B1 for extensions.

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High Potential Individual route expansion

• Doubles the number of eligible universities (with exclusions for security/foreign policy).
• Annual cap introduced of 8,000 applications.

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Graduate Route: Duration reduced

• To encourage the transition into graduate-level jobs, the graduate route stay has been reduced to 18 months from 2 years for those who have successfully completed a UK bachelor’s degree, master’s degree, or other relevant qualification.
• PhD graduates will still get 3 years stay.
• This change applies from 1 January 2027.

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Students moving to Innovator Founder route

• Students completing their course can now start/establish a business via Innovator Founder route.
• Replaces the now-closed Start-up route.

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Part 9: Grounds for Refusal replaced by Part Suitability

• Part 9 has been replaced by a new section called Part Suitability, which serves as the central reference point for all suitability-related refusal and cancellation grounds. 
• This aligns with the terminology already used in simplified immigration routes, where applicants are assessed against “suitability requirements” rather than “grounds for refusal”.
• Paragraph 39E (overstaying exceptions) moved into Part Suitability. This clarifies the term “permission” and updates references across the rules and follows the Law Commission recommendations for simplification.

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Amendments to Appendix FM, Appendix Private Life, Appendix Adult Dependant Relative and Appendix Settlement Family Life to apply Part Suitability

• Family and private life routes now follow the same suitability rules as other routes (see above), rather than using their own suitability requirements which have resulted in a more lenient suitability criteria to be applied.

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Immigration Skills Charge increase

• The levy paid by employers per year of a sponsored worker’s employment has been increased from £1,000 to £1,320.
• No set date to take effect but stated to take place in late 2025.

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Seasonal Worker rules changed

• Seasonal workers are now limited to 6 months work in any 10-month period.
• This replaces the previous 12-month rolling rule.

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Ukraine Permission Extension Scheme (UPE) updates

• UPE allows Ukrainians to extend stay in UK due to war.
• Children’s permission now can align with legal guardian’s status.
• Adult (parent/guardian) must be in the UK.
• Applications can be refused if a child was born in the UK but has never lived in the UK.
• Minor updates are being implemented to clarify nationality, relationship, and validity rules.

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Appendix Global Talent Updates

• This update has expanded the list of eligibility criteria for applicants e.g. architects are now allowed to submit evidence of their achievements both as individual professionals and as members or contributors within a group.
• Applicants can now include proof of their significant contributions that have led to being shortlisted or nominated for prestigious international architectural awards.

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EU Settlement Scheme (EUSS) changes

• The EUSS allows EU, EEA, and Swiss citizens, and their family members, who were living in the UK before 31 December 2020, to secure the right to continue living in the UK.
• Changes clarify that holders of pre-settled status can now be granted settled status if they have spent at least 30 months in the UK within the last 60 months.
• This helps people who may not have applied for settled status yet but have met the required residence period.
• The grounds for cancelling pre-settled status at the border (before entry) have been aligned with in-country curtailment rules. i.e. the Home Office can cancel status if the person never met the original eligibility requirements.

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Child Student route safeguarding changes

• Clarifies that a nominated guardian is someone who cares for a child student for less than 28 continuous days.
• Expanded to include term-time guardianship.
• Rules about living with someone with a criminal record now only apply to adults.
• Living arrangement rules clarified (e.g., boarding students living with parent caring for younger sibling).
• Guardianship organisations must name a UK-settled contact if guardian details aren’t known at application.
• Letters of undertaking must list all adults living with a nominated guardian.

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Student route maintenance requirement – Annual uplift

• The financial requirement for Student visa applicants has been increased for the 2025/2026 academic year.
• This update ensures alignment with UK home student maintenance loans, which are reviewed annually.
• Students must now show higher levels of funds to cover living costs (up to 9 months).
• The accommodation offset i.e. the amount students can deduct from their required funds if they’ve prepaid for housing, has also been adjusted upwards.
• These changes ensure students can support themselves without relying on public funds and reflect rising living costs in the UK.

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Continuous Residence rule updates

• Tier 1 (Entrepreneur) and Tier 1 (Investor) are being added to the list of provisions to which Appendix Continuous Residence applies.
• The rule concerning the breaking of continuous residence is also being corrected.

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What does this mean for employers?

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Increased costs

• The Immigration Skills Charge (ISC) is rising by 32% will increase the overall cost of sponsoring Skilled Workers, especially for businesses sponsoring multiple employees or dealing with visa renewals and role changes.

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Hiring Strategy Adjustments

• The English language requirement for Skilled Worker, High Potential Individual, and Scale-Up routes increases from B1 to B2 (from 8 January 2026). Existing workers on B1 will not be affected if extending.
• Graduate Visa stay reduced to 18 months (from 1 January 2027), meaning employers will have less time to transition graduates to longer-term routes like Skilled Worker.
• The High Potential Individual (HPI) visa now includes double the number of eligible global institutions (from 50 to 100), expanding the pool of high-calibre international graduates. However, the annual cap of 8,000 visas will apply.

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Talent Pipeline Management

• Employers will need to plan earlier and more carefully for visa transitions, especially from Graduate to Skilled Worker, given the shorter timelines and higher costs.
• Early engagement with candidates and robust right-to-work checks will be more critical.

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Travel & Visitor Impacts

• From today, Botswana nationals require a visit visa to enter the UK.
• From 11 November 2025, Palestinian nationals will also require a visit visa.
• Employers should review any plans involving international visitors, clients, or partners from these countries.

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We will continue to monitor these changes and provide further information once available.

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Contact and Disclaimer

Should you have any questions regarding the above information, or require assistance with your immigration or global mobility matters, please don’t hesitate to contact our legal team at Hudson McKenzie. You can reach us by email at londoninfo@hudsonmckenzie.com or by telephone at +44 (0) 20 3318 5794.

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For office locations, please visit our Our Offices page.

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The information provided in this blog is for general guidance only and does not constitute legal advice.