Introduction
The 2025 immigration reform package introduces significant changes to the Health and Care Visa, particularly impacting care workers and senior care workers (SOC 6135 / 6136). While overseas recruitment for these roles will be largely closed, higher-skilled healthcare professionals continue to benefit from flexible visa pathways. Understanding the nuances of the reforms, including transitional arrangements, skill and salary thresholds, and sponsor registration requirements, is essential for applicants, existing visa holders, and employers across the UK.
Ban on recruiting overseas care workers
From 22 July 2025, entry‑clearance applications from overseas for care workers and senior care workers (SOC 6135 / 6136) will be refused UK-wide. This restriction applies only to new overseas recruits.
For providers in England, the ban interacts with Care Quality Commission (CQC) compliance: only CQC-registered providers can sponsor in-country switching or new roles for existing care workers. In devolved nations (Wales, Scotland, Northern Ireland), equivalent regulators, Care Inspectorate Wales (CIW), Care Inspectorate Scotland, and Regulation and Quality Improvement Authority (RQIA), enforce similar sponsorship requirements, although public guidance currently emphasises implementation in England.
Existing visa holders and transitional arrangements
Existing care workers and senior care workers in the UK can continue in their current roles and extend their visas.
For those seeking to switch employers or roles after 22 July 2025, transitional conditions apply:
- The worker must have been employed by their current sponsor for at least three months.
- The new sponsor must be registered with the relevant regulator (CQC in England; CIW, Care Inspectorate, or RQIA in devolved nations).
- These transitional arrangements end on 22 July 2028, after which care-worker roles will be removed from the Temporary Shortage List (TSL) / Intra-Company Shortage List (ISL)
These conditions ensure continuity for existing workers while gradually phasing out overseas recruitment for these roles.
Recruitment priority for in-country workers
From April 2025, providers in England must prioritise recruitment of workers already resident in England who are eligible for sponsorship before considering overseas candidates. This aligns with CQC compliance requirements and ensures domestic workers have first opportunity to fill vacancies.
Equivalent measures are expected under regulatory frameworks in Wales, Scotland, and Northern Ireland, but implementation may vary according to each nation’s guidance.
Sponsors must be registered with the relevant regulators
Providers that are not registered with the appropriate regulatory body cannot sponsor overseas care workers or senior care workers:
- England: Care Quality Commission (CQC)
- Wales: Care Inspectorate Wales (CIW)
- Scotland: Care Inspectorate
- Northern Ireland: Regulation and Quality Improvement Authority (RQIA)
These rules help maintain professional standards, protect workers from exploitation, and ensure only compliant employers can recruit from abroad.
No dependants for new care workers
Since March 2024, new care workers on the Health and Care Visa cannot bring dependants.
From 22 July 2025, similar dependant restrictions apply to certain medium- and lower-skilled Skilled Worker roles (RQF 3-5). The restriction depends on whether the role remains on the TSL / ISL or qualifies for other exceptions.
Higher-skilled healthcare professionals on national pay scales (e.g., NHS doctors, nurses, allied health professionals) are generally unaffected, provided the Certificate of Sponsorship is correctly issued and the pay scale threshold is met.
New skill and salary thresholds for other visa holders
From 22 July 2025, the general Skilled Worker route increased the minimum skill level to RQF 6 (graduate level) and raised the standard salary threshold to £41,700 or the going rate, whichever is higher.
Health & Care Visa roles on national pay scales: covering most NHS doctors, nurses, and allied health professionals, remain exempt from the £41,700 threshold, typically using £25,000 or the national pay scale, whichever is higher.
Employers must ensure Certificates of Sponsorship reflect the correct pay threshold, as errors may lead to refusals or delays.
continued benefits for healthcare professionals
Despite the reforms, the Health and Care Visa continues to offer key advantages:
- Visa extensions remain accessible and streamlined for eligible healthcare professionals.
- Pathways to settlement are preserved for skilled roles.
- Skilled workers in shortage occupation categories can continue to engage in additional work, supporting staffing flexibility where needed.
Exemption from Immigration Health Surcharge
Applicants for Health and Care roles remain exempt from the Immigration Health Surcharge, including eligible dependants in permitted categories. This exemption remains a significant incentive for high-demand healthcare professionals.
Flexibility for some skilled workers
Visa holders in the Skilled Worker, Health and Skilled Worker, Shortage Occupation categories retain the ability to undertake additional work within visa limits, enabling healthcare professionals to address urgent staffing needs without administrative barriers.
Practical implications for workers and employers
- Care workers and senior care workers: overseas recruitment is heavily restricted. Employers must focus on domestic candidates or retain existing staff. Switching employers is possible only under transitional rules until 22 July 2028.
- Higher-skilled healthcare professionals: pathways for visa extensions, settlement, and additional work remain robust, but employers must comply with salary thresholds and sponsor registration requirements.
Understanding these distinctions is critical for workforce planning and compliance under the new rules.
Conclusion
The 2025 Health and Care Visa reforms represent a major policy shift. Overseas recruitment for care-worker roles is now largely closed, while higher-skilled healthcare professionals continue to benefit from a flexible and advantageous visa route.
Awareness of transitional arrangements, skill and salary thresholds, and sponsor registration requirements is essential for applicants and employers across the UK.
For professional assistance navigating these changes, ensuring compliance, or managing Health and Care Visa applications, contact LawSentis today for expert guidance and support.