Immigration Skills Charge (Amendment) Regulations 2025: implications for UK health and safety compliance and business duties

Immigration Skills Charge (Amendment) Regulations 2025: implications for UK health and safety compliance and how duty holders should respond

What has changed

The Immigration Skills Charge Regulations 2017 have been amended by The Immigration Skills Charge (Amendment) Regulations 2025. The available information confirms that changes were made to the regulatory framework governing the charge payable by employers when sponsoring skilled workers from outside the UK. The exact wording of the amended provisions is not detailed in the notice, but the amendment sits within the policy framework used to administer the ISC for skilled migration.

Who is affected

The changes affect employers that sponsor non-UK workers under skilled routes. This includes HR and payroll teams, recruitment functions, and compliance leads responsible for visa and sponsorship arrangements. It also affects external recruitment agencies and any organisations that employ sponsored workers directly or through contractors.

Why it matters

Changes to the Immigration Skills Charge influence the cost and administration of recruiting and retaining skilled personnel from overseas. In practical terms, organisations may see shifts in upfront charges, timing of payment, or administrative processes surrounding sponsorship. While the update is primarily an immigration matter, it intersects with regulatory compliance and governance expectations for lawful recruitment, worker rights and safe operation of the business.

Key duties for employers

Employers should ensure accurate and timely ISC payments where sponsorship is in place and maintain proper sponsorship records. This includes keeping up to date with any new exemptions, routes or charging arrangements introduced by the amendments and ensuring payroll systems reflect sponsorship costs. Organisations should also review their supplier and contractor onboarding to confirm that any labour supplied via sponsorship complies with the amended rules.

Enforcement and sanctions

Non payment or incorrect administration of the ISC can lead to sanctions, including penalties, withdrawal of sponsorship rights or other administrative actions by UK Visas and Immigration. Regular audits and prompt remediation of any compliance gaps are essential to mitigate risk to business continuity and access to skilled labour.

Steps to achieve compliance

Consider the following actions:

1. Review current sponsorship arrangements and confirm which roles are sponsored and the current ISC obligations.
2. Coordinate with HR, payroll and legal to understand payment timelines and any changes introduced by the amendment.
3. Update internal policies and procedures for ISC administration, including record keeping and reporting to UKVI as required.
4. Train relevant staff on sponsor duties, fee payment processes and how to identify and handle changes in employment status.
5. Assess supplier and contractor onboarding to ensure external workers covered by sponsorship are correctly managed.
6. Consider mapping the ISC requirements to your health and safety governance framework, ensuring governance, risk assessment and competent oversight remain robust, for example through ISO 45001 occupational health and safety management aligned processes.

For practical guidance on integrating regulatory compliance with risk management, organisations may engage with Competent Person support and health and safety risk assessments as part of a broader compliance programme. Partnerships with specialists such as ISO 45001 occupational health and safety management can help embed governance and assurance across the workforce.

Taking timely action now will help maintain regulatory compliance, safeguard access to skilled staff and support safe, compliant operations.

In summary, the Immigration Skills Charge (Amendment) Regulations 2025 alters the landscape of sponsorship costs and administration. Duty holders should revisit policies, update risk controls and ensure competent oversight to demonstrate ongoing regulatory compliance within UK health and safety law frameworks.

Timely planning and proactive implementation are essential to minimise disruption and maintain a compliant, capable workforce.