What the Immigration White Paper means for universities
On 12 May 2025, the Government published a white paper, Restoring Control over the Immigration System. The paper sets out a comprehensive plan to reduce net migration through a more restrictive and compliance-focused approach which will have far reaching implications for the higher education sector’s international offering.
While the white paper itself does not change the law, it is clear statement of the government's intentions, the majority of which will not require any legislative changes and can be brought into force with relatively little fanfare or scrutiny through changes to the Immigration Rules or policy guidance. Nevertheless, some of the proposals are to be consulted on before implementation, which gives scope for the sector to make its voice heard in relation to some of the more controversial proposals.
Pressure on International Student Recruitment
Prior to the publication of the white paper there was speculation that Graduate visa holders could be restricted to working in roles above a particular skill level, or at a minimum skill level. Those rumoured changes have not made their way into the white paper, but instead the government plans to reduce standard length of duration of a Graduate visa from two years to 18 months. This change may result in students considering their overseas study options to decide against the UK in favour of countries which continue to offer longer post-study options.
The Government also says that it will explore the imposition of a levy on income universities receive from international students. Although details are sparse, the aim appears to be to redistribute funding within the sector. However, the inevitable consequence of this will be that universities which choose to pass this levy on to international students in the form of higher tuition fees will see demand drop, while those which feel unable or unwilling to pass on that cost will have reduced incentive to grow international recruitment.
The white paper also confirms that the Basic Compliance Assessment (BCA) thresholds relating to visa refusals, course enrolment and course completion, which Student Sponsors must meet on an annual basis, will be strengthened. The Government's technical annex, which accompanies the white paper, says that data from BCAs in 2023/24 suggests that 22 universities (out of approximately 190 on the register of student sponsors), which were responsible for sponsoring approximately 49,000 students, would not have met at least one of the stricter criteria.
To prepare for this change, universities should:
- Review their BCA thresholds from recent years to determine whether they may exceed or be close to the new thresholds
- Review their approach to recruitment of students from countries where visa refusal rates are generally higher, which may involve more detailed due diligence
- Consider the interventions they have in place for non-compliant students to improve enrolment and course completion rates
In addition to the above, all sponsors who use agents for recruiting overseas students will need to sign up to the British Council's Agent Quality Framework.
Greater barriers to recruitment of international academic staff
The white paper proposes reforms to work-based immigration that will make it more difficult, and expensive, to recruit international staff. These include:
- Raising the salary threshold for Skilled Worker visas, which could make it harder to sponsor early-career academics, research assistants and technical specialists
- Increasing the Immigration Skills Charge by 32% - while the Skills Charge does not apply to most academic roles, it will mean that sponsoring non-academic staff will become significantly more expensive
- Increasing the qualifying period for indefinite leave to remain (settlement) in work routes from five to ten years, which is likely to act as a deterrent in many cases
- Stricter English language requirements, including the introduction of an English language requirement for partners of people coming to the UK on work visas
One bit of positive news in the white paper is that the government will look at ways of making it easier to come to the UK under the Global Talent and High Potential Individual routes.
What universities should do now
We do not have any dates for the timing of these changes and the extent to which some changes will apply will not be known until the full details are published. In the meantime, we recommend that universities:
- Assess their exposure to risk in relation to restrictions on international student and staff recruitment, by identifying programmes and staff cohorts most affected by the proposals
- Strengthen their compliance infrastructure, particularly around the Basic Compliance Assessment metrics and ensuring that they are audit-ready
- Engage early in consultations and sector-wide lobbying efforts: policies like the proposed levy and changes the settlement rules are not yet final and sector engagement may influence their shape