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Sponsor guidance updated: Skilled Worker visa holders who are modern-slavery victims freed from tied-sponsor rule

Oct 8, 2026
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Sponsor guidance updated: Skilled Worker visa holders who are modern-slavery victims freed from tied-sponsor rule
UK Visas & Immigration (UKVI) has issued a new edition of its ‘Workers and Temporary Workers—Part 2’ sponsor guidance, effective 8 October 2026. The most significant change is the insertion of paragraphs S8.28–S8.29, creating a special provision for Skilled Worker migrants who have been formally identified as victims of modern slavery. From this date, such workers will be able to change employer without first completing the usual ‘cooling-off’ or new-certificate process, provided certain evidential thresholds are met. Historically, Skilled Workers were effectively tied to their sponsoring employer unless they secured a fresh Certificate of Sponsorship (CoS) and submitted a variation application— a process that could take months and often deterred victims from stepping forward. The update brings the Immigration Rules into line with broader UK anti-exploitation policy and delivers on commitments flagged in Statement of Changes HC 584 last month. For licensed sponsors the change is a double-edged sword. On the one hand, organisations that uncover forced-labour indicators can now help an affected employee exit the abusive environment without fear of breaching immigration conditions. On the other, companies acquiring staff transferred under the new concession will face additional due-diligence duties to verify the worker’s referral status and ensure salary compliance from day one. Failure to follow the revised steps could trigger licence downgrades. Practical implications: Mobility and HR teams should update recruitment checklists and train Level 1 SMS users on the documentary evidence UKVI expects (typically, a ‘positive conclusive grounds’ decision from the Single Competent Authority). Sponsors may also wish to review whistle-blowing channels and modern-slavery statements to reflect the immigration dimension. Because the guidance sits in the public domain, any Skilled Worker—regardless of sector—could now cite the new paragraphs when approaching NGOs or the Home Office. Sponsors that operate in high-risk supply chains (care, agriculture, construction, hospitality) should prepare for potential queries and be ready to provide independent support. Specialists predict a noticeable uptick in change-of-employment applications under the concession over the next 12 months.
Source: GOV.UK – Sponsor guidance Part 2

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