UK Immigration Briefing: Sponsorship Rules for Employers

Welcome to the U.K. Immigration Briefing with Antonio Lam, the Director of U.K. Immigration at Envoy Global. In this post, Lam offers his insights on the latest updates to the U.K. digital immigration system. 

UK Expands Restrictions on Recouping Sponsor Fees Across Work Visa Routes 

The United Kingdom (U.K.) implemented new regulations concerning employer sponsorship fees, specifically aiming to enhance protections for sponsored foreign national workers across key visa categories. These changes, which took effect on 9 April 2025, introduce stricter guidelines for businesses hiring foreign talent under the Skilled Worker and Senior or Specialist Worker routes.  

Key U.K. Immigration Policy Updates 

Employers can no longer pass sponsorship costs onto employees in a way that reduces their salary below the required income threshold. This restriction is often referred to as clawback clauses, which previously allowed companies to recoup expenses from sponsored workers in certain circumstances. This includes barring employers from reclaiming expenses such as the Immigration Skills Charge, Certificate of Sponsorship (CoS) fees and legal or immigration advice fees tied to sponsorship.  

Additionally, any payments made by the worker to the sponsoring employer, such as repayments of loans, deductions from salary or investments, must be factored into any salary assessments. This ensures that workers are not indirectly funding their own sponsorship, closing a loophole that previously allowed businesses to offset costs through employee contributions. 

These restrictions apply retroactively to Skilled Worker CoS assigned after 31 December 2024 and extend to other visa categories from 9 April 2025 onward. 

However, employers may still deduct specific immigration-related expenses—such as visa application fees and the Immigration Health Surcharge (IHS)—from workers’ salaries. Notably, from 9 April 2025, these deductions will contribute toward minimum salary calculations for Skilled Worker visas. 

Why These Changes Matter 

The updated guidance aims to ensure greater fairness in visa sponsorship practices while reinforcing minimum salary requirements for foreign workers. Employers must now factor these restrictions into workforce planning and recruitment budgets. 

Insight for Employers Provided by Antonio Lam, Envoy Global’s Director of UK Immigration: 

Employers with clawback clauses in their global mobility programme, especially those sponsoring workers from 31 December 2024, must ensure compliance with the new regulations to avoid potential violations of the new rules.  

A look at how costs should be distributed at the starting point of sponsorship should be considered prior to agreeing any claw back agreement with the employee.  

The change in guidance, and most certainly, the continual changes, is not a surprise. The U.K. government has recently published a white paper proposing further measures in enhancing compliance and restrictions on employing foreign nationals.  

For sponsored workers, these changes provide greater financial protections, ensuring employers can no longer pass sponsorship-related costs onto them. 

However, the long-term effects remain uncertain. For instance, these changes may impact hiring strategies or reduce sponsorship offers due to hiring costs for organizations.  

Employees may now see fewer clawback agreements in place prior to the start of their employment, but the support given by an employer (i.e., prepayment of Immigration Skills Charge, dependents’ support, etc.) may be lessened to ensure that employers are not exposed financially and risk being non-compliant.  

What’s Next for UK Businesses? 

As immigration policies continue to evolve, employers must stay ahead of these changes to remain compliant and effectively attract global talent in an increasingly regulated environment. However, navigating these complexities can be challenging, which is where Envoy Global comes in. 

Our team of international immigration experts understands the shifting landscape and provides businesses with the guidance they need to adapt, retain top talent and deploy teams worldwide. With industry-leading experience and tailored solutions, we help organizations stay compliant while achieving their workforce goals in a constantly changing immigration environment. 

Reach out to us to learn more about our U.K. immigration services.