Written evidence submitted by Care England’s (RTS5785)
Care England, a registered charity, is the largest and most diverse representative body for independent adult social care providers in England. Our members run and manage over 3,000 care services, amongst them single care homes, small local groups, national providers, and not-for-profit voluntary organisations, as well as private associations. They provide over 110,000 beds and a variety of services for older people, and working-age adults with long-term conditions, learning disabilities and mental health needs.
This submission represents the views of Care England and its members, using evidence submitted from its members. We have conducted a roundtable to find qualitative data from them. This evidence was taken prior to the announcement made by the Home Secretary, The Rt Hon. Shabana Mahmood MP, on the 20th November 2025, which means that care workers will have to wait for 15 years to qualify for ILR. From the evidence collected from our members, the changes that Mahmood announced will only exacerbate the pressures felt by many providers. We have gathered some evidence post this announcement.
On the changes to ILR following the 20th November announcement Professor Martin Green OBE, Chief Executive of Care England, said:
“Placing care workers on a 15-year settlement route is a grave injustice to the very people who keep our care system standing. These are the people who care for our parents, our partners, our children; who bring reassurance in moments of deep uncertainty and dignity on the hardest days. To tell them they must wait a decade and a half before they can build any sense of security in this country is indefensible.
And what makes this worse is that the decision sends a chilling message that the contribution of care workers is valued less than the contribution of others. It is wrong, it is short-sighted, and it reveals a disturbing disconnect from the reality of the workforce crisis the Government claims it wants to solve.
These reforms will not address that crisis. They will intensify it. They will push away the dedicated people we rely on most at the very moment the country needs them. Care workers deserve dignity, respect and a fair route to security, not a 15-year barrier and a message that their work somehow matters less.”
Care England is calling on the Government to take immediate action to prevent further destabilisation of the workforce:
1. Reclassify adult social care within the migration model: Remove care workers from the longest settlement route and recognise them as an essential part of the public service workforce.
2. Introduce immediate transitional protections for existing staff: Ensure current international recruits are not left in uncertainty or subjected to retrospective barriers to remaining in the UK.
3. Deliver a fully funded workforce plan for adult social care: The Government already has a ready-made roadmap. The Skills for Care Workforce Strategy, co-produced with the sector, sets out the steps required to build a strong domestic workforce. It must now be put into action and properly funded.
Even extending the qualifying period for Indefinite Leave to Remain (ILR) from five to ten years and introducing a points-based “earned settlement” regime was described repeatedly by our members as an immediate, material and sector-specific shock to workforce planning in social care. A provider reported that around 10% of their workforce is international and that doubling the qualifying period would add roughly £1.5 million to their sponsorship bill, a cost many organisations said they could not absorb indefinitely.
More broadly, participants warned of a cascade of operational effects: employers will face a choice between absorbing higher costs, operating two-tier pay and conditions, or withdrawing sponsorship and international recruitment altogether, thereby reducing labour supply with a vacancy rate currently at 131,000 and increasing pressure on domestic recruitment channels that are currently insufficiently developed. Several providers noted that the Home Office, DfE and DWP are not working in a cross-departmental way on workforce planning, which amplifies uncertainty for providers who must make long-term staffing and training commitments today without clear sight of future settlement rules. It was also noted that a further example of poor interdepartmental coordination is the positioning of the Fair Pay Agreement as a key solution to recruitment and retention challenges within the sector, despite its implementation after the recent immigration changes. With the relevant visa pathway now closed, this represents a “cart before the horse” situation. As a result, several providers have been forced to significantly revise their strategic approach with minimal support from either the government or local authorities.
A second practical effect is on progression pathways: the removal of senior and management Standard Occupational Classification (SOC) codes in 2025 prevents visa holders in social care from being promoted above certain grades (for example to deputy manager or manager) while on sponsored visas; providers described this as demotivating and as directly blocking career development, and leading to migrants feeling undervalued, despite their enormous contributions. This means they must wait 10 years to progress in their career.
Several providers produced employer testimony and sector impact estimates. Several providers reported that when previous restrictions were introduced, there was a “massive reduction in applicants” for care visas; several participants characterised the government’s impact assessment as flawed, citing divergence between the government’s assumptions and the Health Foundation and Skills for Care. The impact on the volume of Health and Care visas granted, due to Care and Senior Care worker occupations being removed, is estimated to be an annual reduction of approximately 7,000 main applicants (with a range of 6,000 to 8,000 main applicants), according to the Home Office. This baseline is derived from Home Office internal
management information covering the 12-month period March 2024 to February 2025. It is assumed to have no impact on dependants, as Care Workers and Senior Care Workers have not been able to bring dependants since the Spring 2024 Immigration Rules changes. Skills for Care highlighted 8,000 recruited in the last quarter, so this is in direct conflict with the Home Office.
The evidence is qualitative and operational employers’ experience of sudden falls in applicants, increased sponsorship costs, blocked progression, as well as the emotional impact on international recruits felt by their employers. The Committee should therefore combine this frontline testimony with quantitative modelling (labour supply projections, visa application flows, and fiscal costing) before drawing system-wide conclusions.
Longer pathways will raise direct costs (visa fees, sponsorship costs and legal fees), create greater administrative burdens (monitoring contribution criteria such as volunteering, collating evidence of NI/tax records) and reduce the attractiveness of UK employment to international candidates, particularly higher-skilled professionals for whom alternative destination countries offer clearer or quicker settlement routes. Providers gave the concrete example that one organisation’s additional five years would cost £1.5 million, and for their 10% of staff on sponsored routes, several reported that if the landscape hardens, they will cease offering sponsorship for new recruits.
Employers also highlighted a perverse employment effect: removing managerial SOC codes and restricting progression while staff remain on visas produces wasted investment in training and demotivated employees. One participant explained that a deputy-manager role had been removed from the eligible SOC list, they had been demoted, and this means sponsored colleagues “can’t progress” even after completing training; this creates retention risks and, without alternative support from DfE and DWP, thus undermines apprenticeship, T-level and graduate pipelines that employers are simultaneously trying to build. One provider found a loophole that if the carer was employed/sponsored before 4th April 2024, you can promote them by giving them a new COS with occupational code 1232, which is Residential/Day or Domiciliary Manager. This worked for them and was passed by their solicitor. They described the Home Office rules as a minefield. This shows there is a fault in the rules set by the Home Office, and they must be tightened to be effective. Several providers pointed to competitive effects: employers expect international candidates, particularly higher-skilled workers and those with portable qualifications, to choose labour markets where settlement prospects are clearer, undermining the UK’s ability to recruit globally for professions in health and social care.
A provider raised that they have received their first resignation from a nurse who is leaving to join the NHS on the basis of the rule that an “applicant has been employed in a specified public service occupation for five years, minus five years.”
If this rule applies to NHS employment but not to social care roles, it would mean that nurses and any other roles that exist in both health and social care could secure Leave to Remain after five years by leaving their current employer and moving into the NHS. This was the reason provided
for the resignation they have already received, and they anticipate a number of similar resignations once this becomes widely known.
Given that up to 80% of nurses in the social care sector in the Southeast are from overseas, some with Leave to Remain and some without, they believe this could amount to a major crisis if they are unable to retain overseas staff who receive preferential immigration treatment in the NHS.
They also warned that this could become an immediate problem. Staff may move en masse to the NHS within months of the policy taking effect in order to qualify for five-year Leave to Remain, leaving nursing homes across the sector with significant staffing gaps. Furthermore, they noted that recruitment of overseas nurses would become far more challenging, as any new recruits would face the same incentive to leave for the NHS.
Providers noted that while the new framework aims for “character, integration, contribution and residence,” it is deeply unfair to health and social care staff. Lower-paid and “low-skilled” workers are expected to earn their place in the UK far more than higher earners, despite providing essential frontline services.
Shortened ILR timelines based on salary (e.g., 3- and 5-year routes for higher earners) will systematically disadvantage care staff. Many care and support workers will not meet income thresholds and may face 10–15-year settlement routes, even though they:
This creates a hierarchy where high salaries are valued over hands-on care for older people, individuals with learning disabilities and autism, and those with complex needs, sending the message that essential care work is “worth less” to the immigration system.
Requiring volunteering or an unpaid civic contribution to shorten ILR is insulting. Care workers already:
Expecting additional voluntary work treats their essential contributions as insufficient while rewarding higher-paid roles based solely on salary.
Proposed penalties (adding 5–10 years to ILR) for accessing public funds disproportionately affect lower-paid social care staff, who may experience in-work poverty or temporary financial hardship due to illness, pregnancy, cost-of-living crises, or reduced hours. Punishing legitimate need with extended immigration insecurity is punitive and disproportionate.
The model narrowly defines contribution by income, uninterrupted work, and formal volunteering, ignoring the real-world value of care work. Health and social care staff:
Despite this, the reforms impose the longest, most precarious settlement routes on those with significant societal impact, while higher earners with less impact are rewarded with faster routes. This sends a damaging message that essential care workers are valued less than those who simply earn more, risking recruitment and retention in an already strained sector.
Several members have expressed deep concern that the proposals within the consultation will create a serious and immediate risk of losing large numbers of international staff from social care to the NHS. They note that the consultation is framed in a way that positions social care as “low-skilled and low-wage”, with care workers placed on a 15-year qualifying period for settlement, while NHS workers are described as providing “vital services” and therefore viewed more favourably. This disparity reinforces the long-standing perception of social care as a “second-class” public service.
They highlighted that the proposals allow the 15-year settlement period to be reduced by five years for people working in certain public service occupations. However, this accelerated pathway is intended only for roles at RQF Level 6 and above, and is envisaged for professions such as medicine and teaching, not social care. As a result, nurses and other RQF6+ staff currently working in social care would be incentivised to leave and join the NHS, where they could access a significantly faster route to settlement. They also warn that the NHS is likely to lobby for the RQF threshold to be lowered, which could extend this incentive to care assistants and other lower-skilled roles, substantially worsening the problem.
They believe that this dynamic would create a powerful pull factor, leading to a mass exodus of both nurses and potentially care workers into the NHS. The concern is not long-term drift but rapid movement within months, as the proposals appear to apply retrospectively to all existing staff who have not yet secured leave to remain. This would leave providers with no opportunity to replace staff in a labour market already characterised by acute shortages.
Providers stress that these risks are amplified by the consultation’s negative framing of social care, the disparity with how NHS roles are described, and the lack of recognition of social care’s contribution to the wider health and care system. They caution that recruitment of international nurses into social care will also become far more difficult, as new recruits will know they can secure earlier settlement by moving to the NHS after arrival.
To mitigate these risks, the member recommends:
1. that social care roles should be explicitly included within the five-year reduction linked to service in a vital public service;
2. that the RQF Level 6 threshold must be maintained to prevent a widened pathway that would accelerate the loss of lower-skilled staff; and
3. that government must recognise that social care delivers essential public value equivalent to the NHS.
They also note that although the ideal outcome would be for all social care staff to receive the five-year reduction, this is unlikely given how the consultation portrays the sector. Therefore,
securing the reduction for social care’s RQF6+ roles represents, in their view, the most realistic and vital minimum requirement to prevent destabilisation of the workforce.
We have also attached at the end of this various anonymised copies of case studies from our members detailing the delays experienced by UKVI on sponsorship. If the government plans to triple the ILR waiting time for a care worker, this issue will only be further exacerbated. Please see the end for these studies.
Providers identified immediate financial, benefit-access and psychosocial harms for international workers. Financially, families face higher immigration and legal costs during an extended qualifying period, and the employer evidence implies increased risk of downward pressure on pay or careers.
On benefits and services, participants emphasised extended eligibility uncertainty: ILR is often the point at which certain rights stabilise, and lengthening the wait creates prolonged insecurity. Several providers described high levels of anxiety among sponsored staff about family stability, children’s schooling and future housing, all predictable consequences of prolonged insecure status.
The personal and social impacts were described in stark terms: multiple providers warned of a growing “two-tier” society in which long-term contributors who pay tax and NI nonetheless face precarious residence, constrained progression and new bureaucratic hurdles, for example, mandatory or evidenced volunteering. Many providers underlined that any requirement for recorded volunteering disproportionately disadvantages those already working long shifts, single parents and carers, and it raises safeguarding and modern-slavery concerns, for example, unpaid shifts. If the government pushes the volunteering through, and volunteering in a care setting meets the criteria, there needs to be a reimbursement pool for those administrative costs, or there must be a way to reclaim those costs, safeguarding issues were raised. Participants therefore argued that paid work in social care already represents a significant social contribution and should be credited accordingly and thus be exempt from extra volunteering hours.
Contrary to the government’s stated objective that contribution-based measures will promote integration, the roundtable judgement was that longer and more bureaucratic routes risk weakening social cohesion. Participants argued that mandating extra volunteering or community-engagement activities of people who are already delivering vital public services will be experienced as punitive, will add unpaid labour to already low-paid roles, and will erode trust. Several speakers emphasised that social care work itself produces tangible social value, companionship for older and disabled people, continuity of community support, and that this paid contribution should count decisively towards any integration metric.
Roundtable evidence also highlighted a behavioural risk: if the rules are perceived as unfair or opaque, migrants may withdraw from civic participation rather than deepen it, particularly where bureaucratic verification is onerous or carries risk. For example, the inability to evidence hours or having to obtain DBS checks for minor volunteering roles, particularly in schools and care homes. Due to safeguarding risks and administrative burden, they raised that they did not want prospective ILR applicants to do their volunteering hours in care homes. The Committee should therefore treat integration outcomes requested by the Home Office as conditional on perceived fairness and recognition of paid social value, such as social care work.
Participants found few unambiguous positive comparators within the discussion. Japan was cited as an example where restrictive immigration policy, combined with rapid population ageing, has produced acute shortages in the care sector; providers used this to illustrate the risk of tightening settlement without coherent domestic workforce alternatives. Providers were sceptical of simple foreign analogues and recommended that the UK pilot any contribution-based design while monitoring labour market and integration outcomes formally.
Participants proposed practical design features to make an “earned settlement” regime coherent with labour market realities:
Certificate of Sponsorship (CoS) with occupational code 1232 for staff employed/sponsored before 4 April 2024, which took legal advice and was accepted by a solicitor; this demonstrates the urgent need for explicit Home Office guidance on transitional promotions and re-coding to avoid ad-hoc legal risk.
Providers recommended a composite, transparent metric that places primacy on objective fiscal measures while allowing verified social contributions to augment the score. A practicable scoring framework would include:
1. Fiscal/economic contribution — continuous years of paid employment in the UK, NI contributions and PAYE tax records, cumulative earnings thresholds, and documented progression (promotions, professional qualifications completed while working). These are straightforward to audit and minimise discretion.
2. Sectoral social value — explicit recognition that paid roles delivering social value (registered nurse, care worker, domiciliary care manager) count towards community contribution; in other words, paid care work should automatically score highly under social contribution, so workers are not required to duplicate effort through unpaid volunteering.
3. Community and civic engagement — documented volunteering or civic leadership (formal trustee roles, elected local office, sustained recognised volunteering with DBS where required). Providers stressed this element must be narrowly defined, proportionate and not discriminate against those who cannot access volunteering (shift workers, carers, those with childcare responsibilities).
4. Family and settlement ties — long continuous residence, partner/family ties, children in UK schools. Providers indicate strong employer sympathy for recognising household stability as evidence of long-term commitment.
5. Exemptions and mitigating factors — recorded periods of illness, caring responsibilities, or enforced gaps in employment (for example, visa processing delays) should not irreversibly penalise applicants; the system needs objective tolerance bands.
Fiscal/economic contribution should be the largest single component because it is objective and directly relates to public finances, but the metric must allow clear bonus points for verifiable civic leadership and a large automatic credit where paid work produces demonstrable social value (e.g. regulated health or social care). The roundtable emphasised that vague “good citizen” boxes or one-off symbolic volunteering would be inadequate and inequitable.
Providers recommended several exemptions to ensure the system is workable, fair and aligned with labour market needs:
Without a fair, realistic and coherent settlement route, the UK will not retain the international workforce it needs to meet rising demand. These proposals risk accelerating workforce shortages at the very moment the Government aims to reform and professionalise social care through the Fair Pay Agreement. A stable, safe and predictable route to settlement is not simply an immigration issue; it is integral to the sustainability of adult social care and, by extension, the NHS.
For your awareness, I have included below a set of case studies directly from providers so that you can see the real experiences behind the issue of CoS license delays. This is from a recent ask from our membership (November 2025). This is how the system works at the moment, with an ILR qualifying period of 5 years. We assume the Home Office will need to spend more and
have a larger workforce in order to deal with this 3 times over as the ILR qualifying period rises to 15 years.
Provider A
“We have experienced a significant delay in moving 165 workers from our previous sponsor licence to our central licence. The correct process was followed and UKVI advised an 18 week timeframe, but we are now at 21 weeks with no progress. We have written repeatedly and the only response we receive is that they are busy. Our legal representative advises us to wait, but we urgently need these workers transferred so we can manage them appropriately.”
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“We assigned a Certificate of Sponsorship to a worker on 2nd October 2025. On 18 October she received an email stating that the application could not be concluded because
UKVI required more information from us. We have not been contacted for any information. Repeated calls and emails either go unanswered or bounce back. We have been told only to wait. The worker has had no success making contact either.
Any refusals or escalations experienced: None yet
Scale of staff affected: One currently, with two more due to be processed shortly.”
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“I applied for four Certificates of Sponsorship and the volume of information requested was unrealistic. There are 18 week delays. We paid for priority but the request was refused. This affects three senior staff who have since qualified as nurses and one care worker due for
renewal. Between January and March 2026 we need to renew fifteen staff but we do not have the certificates to do so.”
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“We had ten workers whose 3 year visas expired in October 2025. We applied for renewals in July, but the certificates were not granted in time. Fortunately we had also applied for
certificates in our annual allocation, which arrived in October and allowed us to renew the visas. Further certificates were approved in November. The information requirements are extreme. We are often asked to submit contracts for every sponsored worker even when applying for a single certificate. This causes long delays due to the volume of documentation. It feels as though the system is being slowed down intentionally.”
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“We have sent more than 150 emails to the priority inbox since thirty one October 2025 without receiving a response. We are awaiting decisions for 27 workers whose visas expire between now and July 2026. This has created considerable stress for our team. Several staff have resigned
because they believe they will not get a certificate in time. One worker is leaving her family to move to another region where an employer has been able to offer her a certificate.”
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“We have around 9% of our workforce on sponsorship. Our main issues are as follows. First, updates are posted on the Sponsor Management System without email alerts, which
means important information can be missed. Second, renewed visas are taking longer to arrive.
Third, displaced workers experience very long delays. One worker has been waiting for an outcome since August 2025 and cannot work until a decision is made. Fourth, the business
helpline rarely gives clear answers. Finally, the 70.73% pay increase for sponsored care workers
introduced in April 2025 has made it unaffordable to continue employing some staff on sponsorship.”
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“There has been a marked decline in the speed of responses since the summer. A change request was submitted in August to correct our licence details but remains outstanding. We
have been repeatedly informed it can take up to eighteen weeks. We are unable to sponsor new staff while this is unresolved. We have received some Certificates of Sponsorship for existing employees, but the overall pace of decision making is deteriorating.”
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“We are preparing to submit certificates for the winter period. We have been told we may already be too late. There is a belief among some providers that the delays are financially motivated because Further Leave to Remain applications generate income for UKVI.”
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“We are experiencing extreme delays with Certificates of Sponsorship being granted.”
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“We are sponsoring an employee who is switching from a dependant visa to a Skilled Worker visa. The application has been in progress for more than two months and the worker is very anxious.”
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“We applied every day for four months to retain sponsorship for our registered manager. The application was eventually rejected. We have sponsored the manager elsewhere but have lost our allocations and cannot appeal. We are at risk of significant displacement because UKVI is not issuing certificates.”
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“We are experiencing delays when transferring staff from a student visa to a Skilled Worker visa, even when we have submitted all the required information.”
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“We continue to receive displaced workers who want to work with us, but we are granted no undefined certificates. We were advised to wait for our annual allocation. When it arrived, we received only one certificate for a named worker whose visa expires soon. All other requests
were refused. We are told UKVI wants named individuals, but we cannot predict in advance who will come forward. This results in false hope for applicants. Many believe the delays are
intended to ensure workers become undocumented so they can be counted in enforcement statistics. It is a very distressing situation.”
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“We have seen this pattern before. In 2015 and 2016 the Home Office revoked licences for flimsy reasons. Although these decisions were often overturned at Judicial Review, the delays meant employers could not keep their workers. The same thing appears to be happening again.”
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“We have three small care homes and nine visa renewals due next year. We have had no update on our request for additional certificates. The system feels opaque and difficult to navigate. We receive messages encouraging us to recruit displaced workers, but the delays make this impossible.”
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“We have around thirty staff whose visas expire in 2026. We only used three certificates last
year, so we expect to receive a very small allocation for the coming year and will need to request an immediate increase to avoid losing staff.”
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“We requested fifty additional Certificates of Sponsorship in August to support renewals due before March 2026. UKVI requested extensive documentation which we provided. We have not received an update despite repeated attempts to contact them. We have begun requesting certificates through the priority service every morning but without success. Our local MP is now
supporting us. If we do not receive the certificates, 38 staff across several roles will be affected. We have already begun dismissal processes for those most at risk.”
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“This situation is causing significant anxiety for colleagues who have been with us for three years. Recruitment is difficult and we cannot replace these workers easily. Our local MP has
been supportive and has contacted UKVI, but the Home Office has not yet issued a decision. We have tried to use the Business Priority Service at a cost of £750 per certificate, but we have not received a response.”
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“We were due our annual allocation on 23 November but it did not arrive. When we checked the
system, our correctly submitted request had been removed without any notification. The system now shows our next allocation date as November 2026 which is clearly an error. We have resubmitted the request, but if UKVI takes the full eighteen weeks, we will not receive it in time to renew the visas of staff whose permission to stay expires in January and March 2026. This
places the continuity of our service at serious risk, especially as we have recently opened a complex care unit that cannot operate without these staff. We urgently need this matter escalated.”
Dec 2025