UK Immigration Update: Guidance released for employers in advance of new immigration system

Last Updated on February 23, 2023

Key Points

  • The government has issued guidance for a new immigration system starting December 1, 2020
  • The guidance follows the Statement of Changes in Immigration Rules released in October 2020
  • The guidance clarifies employer reporting requirements, extends COVID-19 electronic filing processes, and converts existing Sponsorship Licenses
  • EEA and non-EEA applications will be accepted through the new program
  • Irish nationals are exempt from the program requirements


The Government of the United Kingdom has issued guidance for employers in advance of the new immigration system that starts on December 1, 2020. The guidance follows the Statement of Changes in Immigration Rules announced in October 2020.

What are the Changes?

The new guidance provides details for employers on the new system, including updated employer reporting requirements, extending electronic filing processes introduced during the COVID-19 pandemic, and converting existing sponsorship licenses under the new system.

The most recent guidance clarifies sponsorship license conversions. On December 1, existing Tier 2 and Tier 5 sponsors will have their licenses and outstanding Certificates of Sponsorship or Restricted Certificates of Sponsorship converted automatically through the new system. Unassigned Tier 2 General or Tier 2 Intra-Company Transfer Certificates of Sponsorship (CoS) will be converted to Skilled Worker and Intra-Company Transfer (CoS). Sponsors with suspended licenses will have their licenses updated once they are reinstated.

Employer reporting requirements will change under the new system. In December, all salary changes must be reported, even if they are part of an employee’s annual review cycle. More company-level changes must be reported as well, including corporate restructurings. Changes to employers’ key personnel will be automatically updated, provided the employer has been licensed since 2009.

Compliance requirements are also outlined in the new system. Beginning next week, the Government of the UK will focus on UK sponsors that are using CoS licenses to fill vacancies for employment.

Who is Affected?

The new program applies to both EEA and non-EEA nationals.

What Should Employers and Applicants Know?

Applications for non-EEA nationals may be submitted starting on December 1, while applications for EEA nationals can be submitted starting on January 1, 2021. Applications should be submitted electronically. Irish nationals will be unaffected by the system changes. They do not need a visa or prior authorization to work in the UK.

Content in this publication is not intended as legal advice, nor should it be relied on as such. For additional information on the issues discussed, consult an Envoy-affiliated attorney or another qualified professional.