The Home Office has stated the Immigration Salary List (ISL) would close on 31 December 2026. This adjustment will have a substantial impact on those migrant healthcare workers sponsored in professions below degree level.
The effect will rely largely on the skill level of the worker’s job and the date of their first Certificate of Sponsorship (CoS).
This is particularly applicable for healthcare professionals in jobs such as healthcare support workers matched to nursing auxiliary and assistant roles (SOC 6131), pharmaceutical technicians (SOC 3212) and some laboratory technician roles (SOC 3111).
So what does this mean for migrant health workers?
Highlights:
The relevant date is the date of allocation of the Certificate of Sponsorship (CoS).
For workers first sponsored in RQF level 3-5 roles before 22 July 2025 there are transitional provisions.
After the closure of the ISL, workers sponsored in RQF level 3-5 roles on or after 22 July 2025 won’t be allowed to extend their visa or change employment in such roles.
On 31 December 2026 the ISL will close and it will no longer be allowed to award a new Certificate of Sponsorship to roles that are currently eligible under ISL.
Settlement is still possible with the present £25,000 salary threshold or future updated equivalent.
The post will be susceptible to future modifications in the immigration regulations, including proposals on earned settlement.
To far, no further guidance has been issued by the Home Office.
Implications for employers of NHS
Staff sponsored into affected RQF level 3-5 posts before 22 July 2025 continue to be covered under transitional provisions.
Staff sponsored on or after 22 July 2025 for these roles will not be eligible to extend their visa or move to employment in these roles after 31 December 2026.
The ISL will close on 31 December 2026. After this date, new applications and in-country swaps into roles that currently depend on ISL eligibility will not be accepted. However, visa applications can be made after this date where a valid CoS was assigned before the closure date.
Settlement is still available under present rules.
Employers may want to identify the staff affected and assess the possible effect as part of their workforce and sponsorship planning.
How the regulations work
This would depend on the skill level of the role and when the individual first got their Certificate of Sponsorship (CoS). The important date is the date the CoS was issued, not the date the visa application was made or granted.
If the worker was sponsored before 22 July 2025
Workers first sponsored in posts at RQF levels 3-5 before 22 July 2025 will be subject to transitional measures. They are still eligible to apply for:
- extensions
- changes of job
- settlement.
Applications can be made under the £25,000 salary threshold or any amended equivalent threshold in the future if this changes.
if the worker was sponsored for the first time on or after 22 July 2025
Things are different for workers first sponsored in RQF levels 3-5 on or after 22 July 2025.
These people:
- can continue to apply for settlement on the basis of the £25,000 salary level, or any updated equivalent threshold
- can extend their permission or change employment while the ISL remains in effect until 31 December 2026
Applications for extension or change of employment in RQF level 3-5 roles will not be possible once the ISL ends. To keep on the route they would need to move into a position at RQF level 6 or above.
Sponsored workers in RQF level 6 roles
Workers sponsored in RQF level 6 jobs on the ISL can still apply for:
- adjustments to prolongation of employment
- settlement.
This applies regardless of when they were first sponsored and will continue to be tested against the £25,000 salary criteria or any updated equivalent threshold in the future.
Employer considerations
The information above is only current immigration rules. Any future modifications to the immigration laws, including judgements emerging from suggestions on earned settlement that could affect the qualifying term and conditions for settlement, remain subject to these procedures. This implies there is ambiguity for some staff who may need to renew their permission when the Immigration Salary List concludes on 31 December 2026. No other official guidance is currently available from the Home Office on the matter. – NHS Employers