People Management magazine warns that 2026 is the year "policy turns into paperwork" for companies dependent on overseas talent, as multiple Home Office reforms move from legislation to on-the-ground compliance requirements. From 8 January, Skilled-Worker and High Potential Individual applicants must already prove English at CEFR B2, up from the previous B1 benchmark. In April a new ‘pay-period’ salary test took effect, meaning sponsors must evidence that the going-rate threshold is met in every monthly payslip, not just on an annualised basis— a change that creates audit exposure whenever unpaid leave or variable hours reduce gross pay. The article highlights looming deadlines: the Migration Advisory Committee will deliver recommendations in July on raising the £38,700 general salary threshold and replacing the Shortage Occupation List with a narrower Temporary Shortage List. Interim salary concessions for medium-skilled roles are due to lapse on 31 December 2026, and industry bodies in hospitality, logistics and social care fear recruitment pipelines will dry up if concessions are not renewed. HR directors are therefore advised to map workforce demographics against new salary floors, budget for English-language training, and front-load Certificate-of-Sponsorship assignments before further rises. Legal experts also recommend refreshing right-to-work procedures: once Biometric Residence Permits are fully replaced by e-Visas later this year, employers must move to digital status checks and cannot accept an expired BRP as evidence. In practice the reforms shift much of the administrative burden to sponsors. Where errors are found— for instance a single under-payment— the Home Office now has discretion to revoke the entire sponsor licence rather than issue an action plan. With audit activity up 40 per cent year-on-year, companies that rely on Tier 2 licences obtained pre-pandemic but have not updated HR systems are at particular risk. The article concludes that proactive gap-analysis in Q2 will cost less than last-minute remedial work under a ‘sponsor assurance visit’.
Source: People Management
