Closure of the Immigration Salary List: What This Means for Migrant-Sponsored Healthcare Workers

LONDON Oct 6: The Home Office has confirmed that the Immigration Salary List (ISL) will close on 31 December 2026. This change will have a significant impact on some migrant healthcare workers who are currently sponsored in roles below degree level.

The impact will depend mainly on the skill level of the worker’s role and the date their first Certificate of Sponsorship (CoS) was assigned.

For healthcare workers, this is particularly relevant to roles such as healthcare support workers aligned to nursing auxiliary and assistant roles (SOC 6131), pharmaceutical technicians (SOC 3212), and some laboratory technician roles (SOC 3111).

What does this mean for migrant healthcare workers? Key Points

The relevant date is when the Certificate of Sponsorship (CoS) was assigned.
Transitional arrangements apply to workers first sponsored in RQF level 3-5 roles before 22 July 2025.
Workers first sponsored in RQF level 3-5 roles on or after 22 July 2025 will no longer be able to extend their visa or change employment in those roles once the ISL closes.
When the ISL closes on 31 December 2026, it will no longer be possible to assign a new Certificate of Sponsorship for roles that currently rely on ISL eligibly.
Settlement remains available under the current £25,000 salary threshold, or any future updated equivalent.
The position remains subject to future changes to the immigration rules, including proposals on earned settlement.
No additional Home Office guidance has been published at this time.

What this means for NHS employers
Staff first sponsored in affected RQF level 3-5 roles before 22 July 2025 remain covered by transitional arrangements.
Staff first sponsored in these roles on or after 22 July 2025 will not be able to extend their visa or change employment in those roles after 31 December 2026.
New applications and in-country switches into roles that currently rely on ISL eligibility will no longer be possible when the ISL closes on 31 December 2026, although visa applications can still be submitted after this date where a valid CoS was assigned before the closure date.
Settlement remains available under the current rules.
Employers may wish to identify affected staff and consider the potential impact as part of their workforce and sponsorship planning.

How the rules apply
The position depends on both the skill level of the role and when the individual was first assigned their Certificate of Sponsorship (CoS). The relevant date is when the CoS was assigned, rather than when the visa application was submitted or granted.

If the worker was first sponsored before 22 July 2025
Workers first sponsored in RQF levels 3-5 roles before 22 July 2025 are covered by transitional arrangements. They can continue to apply for:
extensions
changes of employment
settlement.

Applications can continue to be made using the £25,000 salary threshold, or any updated equivalent threshold if this changes in the future.

If the worker was first sponsored on or after 22 July 2025
For workers first sponsored in RQF levels 3-5 on or after 22 July 2025, the position is different.

These individuals:
can continue to apply for settlement using the £25,000 salary threshold, or any updated equivalent threshold
can extend their permission or change employment while the ISL remains in place until 31 December 2026
will no longer be able to apply for extensions or changes of employment in RQF level 3-5 roles once the ISL closes. To remain on the route, they would need to move into a role at RQF level 6 or above.

Workers sponsored in RQF level 6 roles
Workers sponsored in RQF level 6 roles on the ISL can continue to apply for:
extensions
changes of employment
settlement.
This applies regardless of when they were first sponsored and continues to be assessed against the £25,000 salary threshold, or any future updated equivalent threshold.

Considerations for employers
The information above reflects the current immigration rules only. These arrangements remain subject to any future changes to the immigration rules, including any decisions arising from proposals on earned settlement, which could change the qualifying period and criteria for settlement. This means there is uncertainty for some staff who may need to extend their permission after the Immigration Salary List closes on 31 December 2026. The Home Office has advised that it does not currently have any additional published guidance on this issue. – NHS Employers