We take a look at the key developments of 2022, give some tips for sponsor licence compliance moving forward and take a look at what to expect in 2023.

LOOKING BACK: Round Up of Key Changes for Employers in 2022

  • Ukrainian nationals: In response to the war in Ukraine the Home Office introduced visa schemes for Ukrainian nationals – for those fleeing Ukraine and also for Ukrainian nationals already in the UK: see details in our update here.
  • New business visa categories: In April 2022, substantive changes were made to the Immigration Rules, introducing a raft of new visa categories, including the Global Business Mobility (replacing the Intra-Company Transfer route), Scale Up and High Potential Individual routes. In our update we considered each of these new routes in detail. 
  • Reporting requirements: In November 2022, the Home Office published new guidance which introduced helpful flexibility to start dates and a relaxation of rules around salary reduction and absence notifications for sponsored workers. See our full update here.


The New Year is a great opportunity to pause to consider your sponsor licence compliance duties for the year ahead - HR teams could consider:

  • Annual renewal of CoS: Check and diarise when your annual allocation of undefined certificates of sponsorship needs to be renewed.
  • Licence renewal: Check when your licence is due to expire (licences are subject to renewal every four years).
  • Recruitment needs: Consider whether you may need to recruit migrant workers this year and factor in the time/ costs of sponsorship.
  • Key Personnel: Check that all the key personnel on your sponsor licence are still in their roles and available to maintain sponsor compliance duties. 
  • Visa expiry dates: Check when your sponsored migrants' visas are due to expire and diarise renewal processes.
  • Sponsored migrants' details: Ask migrants to confirm their contact details and consider any upcoming changes that may need reporting.
  • Corporate changes: Upcoming changes to company address, ownership, TUPE transfers and other corporate changes may all need reporting.

LOOKING FORWARDS: Expected changes in 2023:

  • ISC Waiver: From 1 January 2023, there are exemptions to the Immigration Skills Charge where workers in the Global Business Mobility Senior or Specialist Worker routes are assigned to the UK for up to 3 years from a linked EU business.  
  • Technology improvements and digitalisation of visas: the Home Office has confirmed the following:
    • During 2023 and 2024, physical BRP cards will be phased out and e-visas are being introduced.  
    • In early 2023, visa application forms will be pre-populated to include job role details automatically.
    • In late 2023, the sponsor management system will be improved so that licence changes such as adding users will be managed by sponsors.
  • Electronic Travel Authorisation (ETA) will be required for non-visa national visitors from 2023. The applications for ETAs have not yet opened but further information is available here.
  • The Home Secretary, Suella Braverman, outlined her desire to cut net migration in her speech at the Conversative Party Conference 2022. However, we are yet to see how this will manifest and the impact this might have on employers.  It has been reported in the media that she plans to increase the minimum income threshold for British citizens applying for a family visa for a spouse or children and the minimum salary threshold for workers filling jobs on the shortage occupation list.  The report also suggests she plans to reduce the number of foreign students by restricting access to the graduate visa and making it harder for foreign students to bring dependants with them by raising the income threshold. There has been no formal announcement on these proposals yet.
Sarah Harrop

Sarah Harrop

Partner, Employment & Immigration

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Isobel Pickard

Isobel Pickard

Managing Associate, Employment & Immigration

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