On Tuesday evening immigration advisers received a fresh Home Office update to Appendix Skilled Worker and accompanying sponsor guidance, dated 23 June but taking legal effect on 9 April 2027 . The biggest change is a crackdown on employers who attempt to recoup immigration costs from sponsored workers.
![New Appendix Skilled Worker rules tighten salary deduction and fee-repayment bans]()
VisaHQ’s corporate immigration team can help sponsors get ahead of these new requirements. Through its UK portal (https://www.visahq.com/united-kingdom/), the company offers compliance audits, automated reminder tools and on-call specialists to review contracts, salary structures and CoS allocations, ensuring that claw-back prohibitions and salary calculations satisfy Home Office scrutiny.
From the commencement date, sponsors must not deduct or claw back licence fees, Certificate of Sponsorship charges or the Immigration Skills Charge from a worker’s pay, either directly or via loans or investment schemes. Breach could lead to licence suspension or revocation across all sponsored routes, not just Skilled Worker. HR and payroll teams must audit any salary-sacrifice or repayment clauses to ensure compliance. The rules also exclude any money “paid by the applicant to the sponsor” – including investments – from salary calculations used to meet the going-rate threshold, closing a loophole some start-ups had used to top-up wages with equity purchases. Transitional protection is offered to Tier 2 (General) migrants extending with the same sponsor before 1 December 2026, provided allowances are guaranteed and would be paid to settled workers in similar roles . For mobility managers the message is clear: review employment contracts, secondment agreements and claw-back policies now. Budget holders should assume 100 % of sponsorship costs must be employer-funded and cannot be recouped, even if the worker leaves early. Failure to comply risks not only licence action but also civil penalties under the 2025 Border Security, Asylum and Immigration Act. Sponsors should also note the absence of a definition for “related organisation”. Until the Home Office clarifies, best practice is to avoid any arrangement where funds flow from worker to any group entity if those funds could be viewed as subsidising salary.
VisaHQ’s corporate immigration team can help sponsors get ahead of these new requirements. Through its UK portal (https://www.visahq.com/united-kingdom/), the company offers compliance audits, automated reminder tools and on-call specialists to review contracts, salary structures and CoS allocations, ensuring that claw-back prohibitions and salary calculations satisfy Home Office scrutiny.
From the commencement date, sponsors must not deduct or claw back licence fees, Certificate of Sponsorship charges or the Immigration Skills Charge from a worker’s pay, either directly or via loans or investment schemes. Breach could lead to licence suspension or revocation across all sponsored routes, not just Skilled Worker. HR and payroll teams must audit any salary-sacrifice or repayment clauses to ensure compliance. The rules also exclude any money “paid by the applicant to the sponsor” – including investments – from salary calculations used to meet the going-rate threshold, closing a loophole some start-ups had used to top-up wages with equity purchases. Transitional protection is offered to Tier 2 (General) migrants extending with the same sponsor before 1 December 2026, provided allowances are guaranteed and would be paid to settled workers in similar roles . For mobility managers the message is clear: review employment contracts, secondment agreements and claw-back policies now. Budget holders should assume 100 % of sponsorship costs must be employer-funded and cannot be recouped, even if the worker leaves early. Failure to comply risks not only licence action but also civil penalties under the 2025 Border Security, Asylum and Immigration Act. Sponsors should also note the absence of a definition for “related organisation”. Until the Home Office clarifies, best practice is to avoid any arrangement where funds flow from worker to any group entity if those funds could be viewed as subsidising salary.
