UK Immigration Law Report 2025: Key Changes and Proposals
Introduction
UK immigration law is undergoing significant change in 2025. In September 2025, the UK Government announced a range of proposals at conferences and in official statements from a proposed “contribution requirement” for Settlement/Indefinite Leave to Remain (‘ILR’) to a planned Digital ID scheme for right-to-work checks.
The UK Government has confirmed that the new settlement rules will not apply to individuals who already hold EU Settled Status or ILR. The proposed changes are therefore intended to affect mainly future applicants. At present it is not confirmed whether those already in the UK but not yet settled (i.e. on a route to ILR) will be exempt, transitional protections are customary but must be confirmed in legislation or Statements of Changes.
This legal report provides an expert legal opinion on the announcements: what has been said, the legal implications, and how UK immigration law is evolving.
UK Government Immigration Announcements (2025): Summary
1. Indefinite Leave to Remain (ILR): Proposed “Contribution” Test
A new contribution-based settlement model is proposed, requiring ILR applicants to demonstrate contribution (through earnings/NICs, volunteering and no benefit dependency although ‘No Recourse to Public Funds’ restriction is applied automatically to nearly all UK immigration routes), alongside higher English language standards and criminality checks.
Increasing the standard 5-years qualifying period of residence for ILR to 10-years qualifying period of residence.
The UK Government has confirmed that the new settlement rules will not apply to those who already hold ILR.
The scope of transitional protections for those on the path to ILR remains unclear and will depend on legislative drafting.
2. Skilled Worker Route: Changes Already in Force (22 July 2025)
From 22 July 2025, the skill threshold was raised to RQF Level 6 (degree level) for most roles.
Salary and going-rate thresholds were increased, and several roles removed from the shortage occupation list.
These changes are in force and apply to all new Skilled Worker applications.
3. Family Visa Financial Requirement: £29,000 (Operative)
The minimum income requirement (MIR) for spouse/partner visas has been set at £29,000 since 11 April 2024.
Further planned increases (to £34,500 and £38,700) have been paused pending a review by the Migration Advisory Committee (MAC) which has been concluded and published in June 2025.
For now, the operative threshold remains £29,000.
4. Graduate & Student Routes: Under Review
The Graduate route (allowing international students to remain for 2–3 years post-study) remains available.
A review is ongoing, but no changes have been legislated.
5. Digital ID (“BritCard”): Modernising Right to Work Checks
The UK Government announced a forthcoming mandatory Digital ID scheme for right-to-work checks.
This proposal raises data protection and privacy concerns under UK GDPR and Article 8 ECHR.
Legal Opinion
ILR Contribution Test:
The proposed “contribution test” introduces serious questions of legal certainty. Without precise definitions of “contribution” or “benefit dependency,” the test risks vagueness and potential judicial review. Currently, nearly all UK immigration routes already carry a “No Recourse to Public Funds” restriction prohibiting the applying for public benefits in the UK.
Compatibility with Article 8 ECHR is also a concern, restrictions on settlement rights must be proportionate when balanced against private and family life. Courts will scrutinise whether the public interest justifies stricter settlement thresholds.
The UK Government’s assurance that those who already hold ILR will be unaffected is welcomed and reduces some retroactivity concerns. However, individuals already lawfully residing on a route to ILR remain at risk unless transitional provisions are published and legislated through a Statement of Changes.
Skilled Worker Route:
The July 2025 Skilled Worker changes are in full effect. By raising both skills and salary thresholds, the UK Government has materially restricted the pipeline of eligible sponsored workers. This has disproportionate implications for the health, care and hospitality sectors, where shortages remain acute.
From a legal perspective, the changes are validly made under the Immigration Rules. The risk however lies in compliance, sponsors must meet the new thresholds or risk sponsorship licence action.
Family Visa Minimum Income Requirement (‘MIR’):
The £29,000 MIR remains binding, while higher thresholds are paused. Legal precedent (MM (Lebanon) v SSHD [2017] UKSC 10)) shows that very high income thresholds risk infringing family life rights unless supported by strong justification. Any future rise must be evidence-based and proportionate to survive challenge.
Graduate Route:
Although contested, the Graduate route remains in force. Any attempt to curtail it without proper consultation or transparency would risk administrative law challenges on grounds of procedural fairness.
Digital ID:
A mandatory Digital ID scheme raises significant privacy, proportionality and inclusion concerns. Legal challenges could arise under both UK GDPR (data minimisation, retention, rights of access) and Article 8 ECHR. The UK Government will need robust legislative safeguards to defend such a scheme against litigation.
Migrants Already in the UK but Not Yet Settled:
The exemption announced by the UK Government only covers individuals who already hold ILR/Settled Status. Those currently in the UK but still on the path to ILR (e.g. on Skilled Worker or family visas) may be affected by the new rules when they eventually apply for settlement. Though unlikely, transitional protections has not yet been confirmed but are anticipated based on previous practice precedent.
The Home Office often provides transitional protections in immigration changes, but the scope, eligibility and duration of such protections are not yet confirmed. This lack of clarity is a major legal risk and could lead to judicial review if the rules unfairly exclude migrants who have built legitimate expectations under existing pathways.
Key Takeaways
UK Immigration Law 2025 is shifting towards a stricter, contribution-focused settlement model.
ILR Contribution Test: Proposed, but unclear for those already on a route to settlement.
Skilled Worker changes: In effect since July 2025, raising skills and salary thresholds.
Family Visa MIR: Set at £29,000; higher increases paused pending MAC review.
Graduate Route: Under review but still available.
Digital ID: Announced, not yet legislated, raises significant legal and privacy issues.
At Noble Rose Immigration Service, our Regulated UK Immigration Law Firm, we provide clear, strategic legal advice and representation on navigating these changes.
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