April 2026 UK Immigration Changes: New Salary Rules and Sponsor Compliance Requirements

A series of UK immigration changes took effect during March and April 2026, introducing new salary assessment requirements for Skilled Worker sponsors, updated sponsor guidance, higher immigration fees and changes to certain Global Business Mobility routes.

For employers holding a sponsor licence, the most significant development is how the Home Office assesses whether sponsored workers are receiving the salary required under the Immigration Rules.

The changes make it particularly important for HR, payroll and immigration teams to work together. A salary that appears compliant in an employment contract or Certificate of Sponsorship (CoS) may not necessarily satisfy the requirements when actual payments and working hours are examined.

This article explains the changes and the practical steps employers should consider.

1. New Skilled Worker Salary Assessment Rules from 8 April 2026

From 8 April 2026, new provisions in Appendix Skilled Worker introduce more specific requirements for assessing sponsored workers' salaries across pay periods.

The changes are intended to provide a clearer basis for identifying underpayments without waiting until a full year's salary has been paid. For sponsors, this means that recording an appropriate annual salary on a CoS is not enough. Actual salary payments must also satisfy the relevant requirements.

How Do the New Pay Period Rules Work?

The rules establish different assessment periods depending on how frequently the worker is paid.

Monthly payroll

Where a worker is paid monthly, or less frequently, the salary paid over any three-month period must generally equal at least one quarter of the required annual salary.

For example, where the required annual salary is £52,000, the worker must receive at least £13,000 over the relevant three-month period.

Weekly or fortnightly payroll

Where a worker is paid more frequently than monthly, the salary over any 12-week period must generally equal at least 12/52 of the required annual salary.

For a required annual salary of £52,000, this equates to £12,000 over 12 weeks.

Irregular working patterns

Where a sponsored worker has a regular working pattern involving different hours each week, resulting in uneven pay, a 17-week assessment period may apply.

The sponsor must confirm the working pattern, and the salary over the relevant 17-week period must meet the prescribed proportion of the required annual salary.

The Hourly Going Rate Still Matters

There is an additional requirement that employers must not overlook.

The salary paid in each pay period must also equal or exceed the applicable occupational going rate for every hour worked during that period.

This means that satisfying the three-month or 12-week annual salary calculation does not automatically establish compliance.

Employers need to assess both requirements.

Does One Month of Lower Pay Mean a Breach?

Not necessarily.

The rules allow salary to be assessed across the relevant period, rather than requiring the same amount to be paid in every individual month. However, the employer must still satisfy the hourly going-rate requirement and any other applicable conditions.

There are also specific provisions addressing certain deductions and irregular working arrangements. Sponsors should therefore avoid assuming that a lower payment can simply be compensated for later without considering the circumstances.

2. Why Payroll Records Are Becoming More Important

The Home Office already uses compliance checks and information obtained from HMRC to assess whether sponsors are paying workers correctly.

The April changes provide a more defined framework for examining actual salary payments.

This creates particular risks where:

• Employees work variable hours.
• Salary changes are implemented partway through a payroll period.
• Payroll records do not clearly distinguish basic salary from other payments.
• Workers experience temporary reductions in pay.
• Contracts, CoS records and actual working arrangements do not match.
• Employers rely on annual salary figures without examining payments during the relevant periods.

A sponsor may believe it is paying the correct annual salary while its payroll records reveal a different position.

What Should Employers Do?

Employers should review whether their existing payroll systems can demonstrate compliance with both the annual salary requirements and the applicable hourly going rates.

A practical review should compare the salary recorded on the CoS, employment contracts, payslips, payroll information, working hours and any relevant changes reported to the Home Office.

Where inconsistencies exist, employers should establish why they arose and whether corrective action or reporting is required.

A payroll review is now an important part of sponsor licence compliance.

3. Do the New Salary Rules Apply to Existing Sponsored Workers?

The April 2026 changes include transitional arrangements for applications supported by a CoS assigned before 8 April 2026.

Employers should distinguish between the immigration requirements applicable to an individual's application and their continuing responsibilities as a licensed sponsor. Existing workers remain subject to the salary and employment conditions applicable to their sponsorship, including any relevant transitional provisions.

It would therefore be incorrect to assume that every existing sponsored worker automatically becomes subject to identical new salary requirements. Nevertheless, employers should ensure they can demonstrate that workers are receiving the salary required under their particular sponsorship arrangements.

Where an employee's salary or working hours have changed, the employer should consider whether the change is permitted and whether it needs to be reported through the Sponsor Management System (SMS).

4. Sponsor Guidance: Greater Emphasis on Understanding Your Duties

The Home Office also updated sponsor guidance during March and April 2026. One important message is that employers cannot treat the sponsor guidance as something to consult only when assigning a CoS or responding to a Home Office enquiry.

Licensed sponsors are expected to understand and comply with the relevant guidance throughout the life of their licence. This includes the main sponsor guidance, applicable appendices and route-specific requirements.

What Does This Mean for Authorising Officers and HR Teams?

The Authorising Officer has overall responsibility for the organisation's sponsorship arrangements. However, effective compliance also depends on the people responsible for recruitment, payroll, record-keeping and SMS administration.

Employers should consider whether their personnel understand:

• Which changes must be reported to the Home Office.
• What records must be retained for sponsored workers.
• How salaries and working hours are assessed.
• How sponsored worker absences are monitored.
• What happens when a worker changes role or employment conditions.
• How to identify and escalate potential compliance problems.

Maintaining records of training, guidance reviews and internal communications is a sensible way of demonstrating that these responsibilities are being taken seriously.

It is not sufficient simply to have written policies if those policies are not followed in practice.

5. Sponsored Workers' Employment Rights and Welfare

Sponsor guidance also places emphasis on employers' responsibilities towards the workers they sponsor.

Sponsors must comply with applicable employment law and ensure that sponsored workers understand their employment rights.

These responsibilities include matters such as:

• National Minimum Wage requirements.
• Working time and rest periods.
• Statutory leave and pay.
• Workplace health and safety.
• Pension arrangements.
• Equality and protection from discrimination.
• Access to grievance procedures.

Employers should review how this information is communicated during onboarding and throughout employment. Employment contracts, staff handbooks, written guidance and training may all form part of an appropriate approach.

The important consideration is whether workers genuinely understand their rights and whether the employer can demonstrate that suitable arrangements are in place.

6. Right to Work Checks and Digital Immigration Status

The continuing transition towards digital immigration status is changing how employers verify permission to work in the UK.

An increasing number of visa holders now access their immigration status through a UKVI account and provide employers with a share code for an online right to work check.

Employers should ensure that staff responsible for these checks understand the correct Home Office procedures.

Right to Work Checks Are Not the Same as Sponsor Compliance Checks

There are two related but distinct responsibilities.

First, employers must carry out appropriate right to work checks to establish whether individuals have permission to undertake the employment in question.

Second, licensed sponsors have additional obligations to verify and retain evidence of the immigration status of the workers they sponsor.

Employers should not assume that a copy of an eVisa screenshot or a share code supplied by an employee is, by itself, sufficient evidence that a compliant check has been completed. The prescribed checking procedure must be followed and the appropriate evidence retained.

Businesses should also ensure that their processes distinguish between employees, sponsored workers and other working arrangements, applying the requirements relevant at the time.

7. Immigration Fees Increase from 8 April 2026

The Home Office has also increased a wide range of immigration and nationality application fees.

Examples include:

• Skilled Worker visa, outside the UK, up to three years: £769 to £819.
• Skilled Worker visa, outside the UK, over three years: £1,519 to £1,618.
• Small sponsor licence application: £574 to £611.
• Large sponsor licence application: £1,579 to £1,682.
• Indefinite leave to remain: £3,029 to £3,226.
• Electronic Travel Authorisation: £16 to £20.

These increases follow other changes to sponsorship costs, including higher CoS fees in April 2025 and an increase to the Immigration Skills Charge in December 2025.

For employers recruiting internationally, the cumulative effect can be substantial.

Our separate article on UK immigration fee increases from 8 April 2026 provides a detailed comparison of the new charges.

8. Global Business Mobility Changes

The March and April 2026 rule changes also introduce greater flexibility within certain Global Business Mobility (GBM) routes.

Secondment Worker: Overseas Employment Requirement Reduced

From 8 April 2026, the overseas employment requirement for the Secondment Worker route is reduced from 12 months to six months.

The route allows eligible overseas workers to undertake assignments in the UK connected with qualifying high-value contracts or investments. The reduced qualifying period may help international businesses deploy employees who have not yet completed a full year of overseas employment.

Other eligibility conditions continue to apply, including the requirements relating to the qualifying contract or investment.

Service Supplier: New Arrangements for Indian Nationals

From 26 March 2026, changes linked to the UK–India trade agreement expand access to the Service Supplier route for eligible Indian nationals. This creates additional opportunities for businesses operating under qualifying international service contracts.

However, the route is subject to specific requirements, including the nature of the services being provided, the contractual arrangements and the relevant eligibility conditions.

Employers should assess whether the route is appropriate rather than assuming that any service agreement with an Indian business qualifies.

Do Global Business Mobility Visas Lead to Settlement?

The GBM routes do not provide a direct route to settlement.

Employers planning longer-term UK assignments should consider whether a different immigration route may be more appropriate, particularly where the worker may ultimately wish to apply for indefinite leave to remain.

9. Visa Restrictions Affecting Certain Nationalities

From 26 March 2026, the government introduced restrictions affecting certain overseas visa applications.

These include:

• Skilled Worker entry clearance applications by Afghan nationals.
• Student entry clearance applications by nationals of Afghanistan, Cameroon, Myanmar and Sudan.

The restrictions affect relevant applications made from outside the UK and are subject to the detailed provisions of the Immigration Rules.

Employers and education providers recruiting from the affected countries should review their recruitment plans and consider the implications for individual candidates.

10. Further Changes to Settlement and English Language Requirements

The government is also pursuing wider reforms to settlement.

Proposals under the earned settlement model include extending the standard qualifying period for indefinite leave to remain from five years to ten years for many applicants, with opportunities to qualify earlier or later depending on specified circumstances.

At the time of the April 2026 changes, the detailed settlement reforms had not been implemented. The existing settlement requirements therefore continued to apply unless and until the Immigration Rules were amended.

Separately, the government has confirmed an increase in the English language requirement for settlement from B1 to B2, scheduled to take effect in March 2027 for relevant routes.

Employers supporting sponsored workers who are approaching settlement eligibility should consider the potential implications for retention, workforce planning and employee support.

Employer Checklist: What Should You Review?

The April 2026 changes provide an opportunity for employers to examine whether their sponsorship arrangements are working effectively.

Salary and payroll

Review sponsored workers' salary payments, working hours and applicable immigration thresholds. Confirm that payroll records can demonstrate compliance with the relevant requirements.

Sponsor guidance

Ensure the Authorising Officer and relevant HR personnel understand the current guidance and that changes are communicated to those responsible for sponsorship.

Worker rights

Review how sponsored workers are informed of their employment rights and whether appropriate records are retained.

Right to work

Confirm that the correct checks are undertaken and that HR staff understand the digital status verification process.

SMS accuracy

Check that the information recorded on the Sponsor Management System reflects the actual employment arrangements and that reportable changes have been submitted.

Recruitment and immigration budgets

Update cost projections to reflect the increased application fees and other sponsorship costs.

Future immigration planning

Identify employees approaching visa expiry or settlement eligibility and review the options available under the applicable rules.

How Immtell Can Help

The April 2026 changes reinforce the importance of examining how sponsorship works in practice, rather than relying solely on the information recorded when a CoS was assigned.

Immtell supports UK employers with sponsor licence compliance, Skilled Worker applications, salary reviews and preparation for Home Office compliance audits.

Our Managing Director, Gavin Webster, has 23 years' UK immigration experience, including 13 years working for the Home Office.

Our Head of Sponsor Compliance, Ewen McKenzie, is a former Home Office Regional Compliance Manager who also has in-house experience overseeing immigration and sponsor compliance for a major UK care provider.

Together, they bring experience of both Home Office compliance expectations and the operational challenges faced by employers.

Our services include:

• Desktop Salary Reviews: Examining sponsored workers' salaries, payroll evidence and sponsorship records to identify potential compliance issues.
• Mock Home Office audits: Assessing the systems, records and procedures that may be examined during a compliance visit.
• Sponsor compliance support: Helping employers address reporting, record-keeping and sponsorship concerns.
• Skilled Worker and GBM applications: Supporting employers with CoS preparation, visa applications and immigration planning.
• Training: Helping Authorising Officers, HR teams and other key personnel understand their responsibilities.

If your organisation has not reviewed its sponsored worker salary arrangements following the April 2026 changes, this is a sensible place to start.

Contact Immtell to discuss a Desktop Salary Review or wider sponsor compliance support.

Sources: Home Office, Statement of Changes HC 1691; Appendix Skilled Worker; Workers and Temporary Workers sponsor guidance, including the April 2026 Skilled Worker guidance.

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