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Written evidence by Work Rights Centre (SCI413)

ABOUT WORK RIGHTS CENTRE

Work Rights Centre is a registered charity dedicated to supporting migrants and disadvantaged Britons to access employment justice and improve their social mobility. We do this by providing free and confidential advice in the areas of employment, immigration, and employability, and by mobilising frontline intelligence to address the systemic causes of migrants’ inequality. The charity was founded in 2016. Ever since, we have advised over 6,000 people, helped recover over £650,000 in unpaid wages and fees, and supported hundreds more to make job applications and secure their immigration status.

Summary

The Work Rights Centre fundamentally rejects the government's earned settlement proposals. We argue that the stated policy objectives (social cohesion and contribution) are already being achieved under the current system, while the proposed changes will undermine integration, increase poverty, and fuel exploitation. We are particularly concerned that the lack of an Impact Assessment, which renders this consultation procedurally flawed.

The government justifies these reforms by claiming migration is too high and contribution too low. However, evidence shows:

●       Migration is already falling, and is projected to fall further, due to a recent series of policy restrictions that have increased minimum salary thresholds, limited the roles eligible for sponsorship, and reduced migrants’ abilities to bring dependants.

●       Integration is happening. The vast majority of migrants already speak English well, and are employed, including in sectors that struggle with labour shortages.

●       Migrant’s fiscal contribution is positive. Migrants on the Skilled Worker visa, including in medium-skill roles make a net positive contribution to public finances. Care workers fill vital labour shortages that enable broader economic activity.

The government proposes doubling the baseline settlement period from 5 to 10 years, with even longer waits (15–20 years) for refugees and lower-paid workers like care staff. This "earned settlement" model penalises the most vulnerable while offering accelerated routes only to the highest earners. We identify four major areas of harm:

●       Increased Exploitation. Extending the time migrants are tied to employers on temporary visas drastically increases the risk of labour exploitation and modern slavery, as workers lose bargaining power and the ability to leave abusive employers.

●       Poverty and Destitution. Prolonged exclusion from public funds (NRPF) and the high costs of repeated visa renewals will push thousands of working families into poverty. This increases the risk of homelessness and shifts costs to local authorities.

●       Barriers to Integration. Academic evidence confirms that delaying permanent residence hinders social and economic integration. By creating a class of "perpetual temporary" residents, the government fosters social isolation rather than cohesion.

●       Fiscal and economic harm. The proposals risk damaging public finances by pushing migrants into the underground economy, shifting welfare costs to local authorities, and making British businesses less competitive. A 10–15 year route to settlement would make the UK an international outlier, far stricter than Germany, France, Canada, and Australia, which typically offer settlement after 3–5 years.

In conclusion, the government's proposals risk creating a permanent underclass of temporary residents who are socially excluded and legally precarious. They also undermine the government’s broader policy objectives to grow the economy, reduce child poverty and halve Violence Against Women and Girls, and are likely to disadvantage protected groups and thus become subject to legal challenges. We urge the Committee to reject these changes and demand the immediate publication of a full Impact Assessment.

Recent developments in Government policy on settlement and citizenship

Question 1. What is the policy intention behind the proposals on settlement and citizenship, and will the proposed changes have the intended effect? What are the terms and conditions of settlement in the UK?

Summary of policy intention and likely outcomes

1. In the opening of the consultation document, Home Secretary Shabana Mahmood lays out the two primary objectives of the proposals on settlement and citizenship.[1]

2. The first objective is to improve social cohesion, which she argues has been undermined by high levels of migration under the previous Conservative government, particularly under the Health and Care Worker visa. The second objective is to ensure that migrants contribute and integrate in the UK. This, she argues, requires moving away from the current model, where settlement is described as near ‘automatic’, to a new model where settlement is a privilege that must be ‘earned’.

3. We are deeply concerned by the Home Secretary’s proposals, and the disconnect between their stated aims, and likely outcomes. The best available evidence suggests that the government’s stated aims of social cohesion and positive contribution are already being achieved: immigration to the UK has already been decreasing and is projected to decrease further; migrants already speak English and are employed at a level that enables them to integrate; and the majority are already either net fiscal contributors to the UK, or are employed in shortage occupations that make a critical contribution to the UK economy and public services.

4. Worryingly, while the government’s policy proposals do little to further their stated aims, they are likely to have a series of harmful unintended consequences - on migrant communities, who face a higher risk of labour exploitation, poverty, and becoming visa overstayers; the Home Office, which faces more complex applications and litigation; and public finances, which are likely to take a hit as more people are forced to move into the underground economy. This submission looks in more detail at (i) what the government is proposing, (ii) why the stated policy aims are already being achieved, and (iii) the harm derived from the unintended consequences of these proposals.

What the government is proposing

5. To achieve its objectives of reducing migration and increasing contribution, the government is proposing to:

●     increase English language requirements from B1, the current level, to B2;

●     impose a new requirement for migrants to earn above a certain threshold  (£12,500/year subject to consultation) for 3-5 years before settlement; and

●     double the baseline qualifying period to settlement for most people* from the current 5 years to 10 years, while simultaneously introducing a set of criteria that would reduce - or radically increase - a person’s journey to settlement on a case-by-case basis.

6. Under this ‘time adjusted’ settlement model, the new standard 10 year baseline to settlement would be:

●     shorter for high earners; highly proficient English speakers (at C1 or above), family members of British citizens, BN(O) visa holders, people on the Global Talent and Innovator Founder visas, migrants employed in certain public service occupations, and vulnerable groups (which remain to be defined); who are seen as having contributed more, or having a closer connection to the UK; and

●     significantly longer for applicants who have been in receipt of public funds at any point during their stay in the UK (who face an additional 5 to 10 year wait), and for applicants who arrived in the UK illegally, on a visit visa, or who overstayed (and who face an additional 20 years). They are effectively penalised for appearing to contribute less. 

7. Notably, two groups are singled out for starting with an even longer baseline, that far exceeds the proposed new standard 10 years:

●     refugees face starting with a 20 year baseline - meaning that a person who entered the UK on a visitor visa and was subsequently granted asylum could wait as many as 40 years;

●     care workers and migrants on Skilled Worker visas employed in medium-skilled roles (below RQF Level 6), face starting with a 15 year baseline. 

8. It is important to note that in addition to reconfiguring routes to settlement, the consultation also raises the question of what rights are provided as a result. Specifically, it proposes that benefits should not be available to those who have settled status, and asks whether they should instead be reserved for those who have achieved British citizenship. 

9. Crucially, the Home Secretary proposes to apply these changes to everyone who has not already received indefinite leave to remain (ILR). This would mean that those who are due to reach settlement in the coming months and years would be subject to the new requirements, as soon as the immigration rules have changed.

10. The only groups who remain out of scope of this consultation and planned reforms are people who can qualify for settled status under the EU Settlement Scheme (EUSS), those eligible under the Windrush Schemes, children in care and care leavers.

The stated policy aims are already being achieved

11. We are deeply concerned by the Home Secretary’s proposals, and the disconnect between their stated aims, and likely outcomes. The evidence suggests that the government’s stated aims of social cohesion and positive contribution are already being achieved in several ways.

Immigration has been decreasing, and is projected to decrease further.

12. Due to successive restrictions in immigration policy, both work immigration[2] and family-based immigration[3] have been decreasing over the last two years. This has contributed to a significant reduction in net migration to the UK, from 944,000 in the year ending March 2023, to 204,000 in the year ending June 2025.[4]

13. The number is projected to decrease yet further.[5] In July 2025, the Home Office banned overseas recruitment of care workers and many medium-skilled workers on the Skilled Worker route. This was followed by an increase in recruitment costs for businesses following a December 2025 rise in the Immigration Skills Charge (ISC). Finally, on 8 January 2026 the Home Office introduced a B2 English language requirement (A-level equivalent) for the Skilled Worker route, a significantly higher threshold than the previous B1 requirement.

14. The Home Office suspended the refugee family reunion route on 4 September 2025. And for both family and private life applications, the Home Office instituted more stringent suitability requirements from November 2025 - all with the cumulative effect of reducing immigration.

Migrants already speak English and work at a level that supports integration.

15. Home Office research on the Skilled Worker route found that most visa holders (86%) feel they are already integrating well into UK life.[6] The assertion is not surprising, given that main applicants were subject to evidence of knowledge of English at B1, and employment is the basis on which one maintains the right to remain in the UK. Indeed, 82% of Skilled Worker visa holders also reported knowing English ‘very well’. This is broadly consistent with Migration Observatory analysis of Census 2021 data for all immigrants in England and Wales, which showed that an overwhelming majority of adult migrants spoke English ‘well’ or ‘very well.’[7]

16. Furthermore, migrants improve their knowledge of English over time. The Migration Advisory Committee’s annual report highlights this by citing Census 2021 and Understanding Society data. The latter reveals that “most migrants who reported difficulty speaking English at the first survey reported improvement 7-10 years later.”[8] In this context, introducing a stringent B2 English eligibility criterion for ILR applications would be disproportionate and unnecessary.

17. The notion that migrants are not already contributing enough is also erroneous. Most migrants are required to have a job offer from a Home Office approved employer, before they can qualify for a work visa. Where they are permitted to bring a dependant partner, the evidence suggests that 71% of Skilled Worker route dependants were in work, while just 8% were neither working, nor looking for work.[9] Analysis of immigrants who arrived in the UK to join a family member also finds strong labour market participation in this cohort.[10] For those with 10 or more years’ residence, the employment rate for women is only 8pp lower than for their UK-born counterparts, while for men the difference is just 2pp. Moreover, after 10 or more years’ residence, the differential in annual earnings between the migrant and UK-born cohorts was very minor. Overall, the implication that migrants are insufficiently integrating or leading separate lives is not borne by the evidence.

Most migrants on a Skilled Worker visa already make a net positive fiscal contribution

18. Most migrants coming to the UK after Brexit have done so on the Skilled Worker visa, a route that requires applicants to have a job offer with a Home Office approved employer, and meets strict salary and skill requirements. The consultation document cites figures from the Office for Budget Responsibility’s 2024 report, but the more recent Migration Advisory Committee’s report on lifetime fiscal impacts of Skilled Workers finds that:[11]

●     Migrant workers on the main Skilled Worker visa are projected to have a substantially positive lifetime fiscal contribution of £689,000 each.

●     Even the lowest decile of earners on the main Skilled Worker visa route is projected to have a net positive fiscal impact over their lifetimes.

●     Care workers, the lowest earners on the Health and Care Worker visa (a subset of the Skilled Worker visa), are expected to have a net positive or neutral fiscal impact for the majority of their lives, but a net negative impact overall due to the low level of wages in the sector. However, the analysis does not account for career progression and associated increases in salaries, and fails to consider the impact of the government’s plan to institute a Fair Pay Agreement under the Employment Rights Act in England,[12] which would further increase salaries in the care sector. Perhaps more importantly, migrant care workers make a critical positive contribution to the sector, and to recipients of care, which is not captured in fiscal analysis. As Peter Prinsley MP remarked in an oral evidence session of the Commons Home Affairs Committee: “There is a sort of political mood that immigration is terrible and something must be done to reduce it. I do not think that we are sufficiently clear with the public about the trade-offs. A trade-off that occurs to me is that your elderly relatives might have nobody to look after them. I think that is a story that we ought to be able to tell.”[13]

Care workers plug a significant labour gap

19. By the government’s own logic, contribution to the UK should not be measured in fiscal impact alone, but is also a multi-layered social phenomenon. This is where care workers, one of the groups singled out for a draconian increase in the baseline wait (to 15 years), stand out for being most unjustly penalised.

20. The social care sector is grappling with significant recruitment and retention challenges. Data from the England adult social care sector shows that as of December 2025, the vacancy rate stood as high as 6.4%, while for care worker roles it was at 7.7%[14] - far higher than the national average of 2.3% in November 2025.[15] The numbers of posts filled by British citizens in the sector fell by 60,000 (5%) between March 2022 and March 2025,[16] and the government’s long-awaited reforms to the sector are not expected to take place before 2028.[17] In this context, migrant workers plug a significant labour gap. A robust labour force of carers, in turn, can support unpaid family carers to return to work (consequently reducing their reliance on welfare),[18] and reduce discharges and emergency admissions in the NHS by ensuring that at-risk individuals are cared for in a controlled external setting.[19] Penalising migrant care workers with a longer route to settlement is not only ignoring these important contributions. It also undermines the care sector as a whole.

21. We also note the Home Secretary’s assertion that “fraud, as any constituency Member of Parliament can tell you, was rife”. She notes that an attempt to fill between 6,000 and 40,000 jobs resulted in 616,000 arrivals between 2022 and 2024, and uses this to justify introducing a higher 15-year baseline route to settlement for care workers. This is a profound misreading of the data, and a disturbing conflation of victim and perpetrator of abuse.

22. The number of visas cited, 616,000, represents the number of Health and Care Worker entry clearance visas awarded overall in the period 2022-2024, including care workers, but also nurses, doctors and other medical professionals and their dependants.[20] Only 157,000 visas (a quarter of the figure cited by the Home Secretary), were awarded to main applicants for roles in Caring Personal Services.[21] While the Home Office does not publish data on the number of dependants associated with care workers, it previously reported that in the year ending September 2023, approximately 120,000 dependants were associated with the 101,000 visas issued to main applicants.[22] Assuming this ratio - which fails to take into consideration a ban on dependants that came into effect 11 March 2024 - just 187,000 visas would have been issued to dependants in 2022-2024. In total, the number of visas issued to care workers and their dependants is significantly lower than 616,000 quoted in the government’s paper.

23. Similarly, Skills for Care data from March 2025 puts the number of vacancies in England’s adult social care sector at 111,000, most of which were for direct care roles - lower than the peak of 152,000 in March and still significantly higher than the 6,000-40,000 figure cited by the Home Secretary.[23] Data from Skills for Care only covers the England adult social care sector, so the number of vacancies is higher, once those in (i) children’s social care, (ii) private care sector, and (iii) devolved nations are added. The figures cited by the government are simply incorrect.

24. The implication that migrant care workers were responsible for visa fraud is also worrying. While it is true that many migrant care workers fell victim to recruitment scams, and were never allowed to take up the jobs they were promised, the government’s proposals gloss over the fact that these scams were enabled by the Home Office’s own failure to ascertain the credentials of employers entrusted with sponsorship.

25. Having initially awarded licences with little scrutiny (the number of employers with a licence to sponsor doubled in just two years, from 6,100 in Q1 of 2022, to 13,800 in Q4 2023[24]), the Home Office subsequently increased enforcement action.[25] Between July 2022 and December 2024, the government revoked more than 470 sponsor licenses in the care sector,  displacing 39,000 sponsored workers in the process.[26]

26. Regrettably, these proposals do nothing to compensate these migrant care workers - who, in our experience, came in good faith, made life-changing investments for the opportunity to work in the UK, but were tricked by rogue employers, left indebted, and prevented from working by a system that insists on tying them to another sponsor. These proposals just punish them, and all other care workers (including those who were and are still employed in the adult social care sector), by putting settlement and the prospect of security it entails further out of reach.

Why the settlement proposals are likely to have adverse impacts

27. While the government’s policy proposals do little to further their stated aims, we are deeply concerned by the unintended consequences they are likely to have on migrant exploitation, poverty, integration and fiscal costs.

Labour exploitation - the risk of extending sponsorship ties

28. Many of the migrants on an extended track to ILR would be Skilled Worker visa holders, particularly those in occupations below RQF Level 6 (e.g. care workers), whose baseline qualifying period is proposed to be 15 years.[27] This would tie them to their sponsoring employer for an extended period of time, grossly increasing the likelihood of exploitation.  A vast amount of literature, including by the Work Rights Centre, journalists, government bodies, and parliamentary committees, has found that sponsorship carries the increased risk of labour exploitation (see our response to Question 2). Employers can use the prospect of visa curtailment to pressure migrant workers into working longer hours, for insufficient pay, or in conditions that breach labour laws and contractual arrangements. Similarly, sponsored workers are often reluctant to report cases of labour non-compliance, knowing that doing so can lead to visa curtailment - and that changing sponsors is both practically difficult and expensive. By putting settlement further out of reach, the government will extend the time that migrants spend on employer-sponsored visas, exacerbating the risks inherent in sponsorship.

Poverty - by increasing visa costs and extending NRPF

29. Extending the qualifying period to ILR effectively means that many people will have to make more visa renewal applications before they can settle in the UK. This comes with significant costs, including visa application fees (payable for the main applicant and any dependants) and the Immigration Health Surcharge (IHS) - a fee for NHS services payable upfront by most migrants, for every year they intend to spend in the UK.

30. To take just one example, as of 19 January 2026, a family of three (one parent as the main applicant, with their partner and one child) looking to renew their Skilled Worker visas for another three years, would be looking to pay as much as £13,791 upfront (£8,538 for the IHS and £5,253 in visa fees). For the Home Office, this is an extremely lucrative model. The National Audit Office reports that in 2023-2024 the Home Office raised an estimated £437.9 million in visa fees on the Skilled Worker route, while application processing costs were just £109 million.[28] For migrant families however, this is an expense that can wipe out savings - and, given how most visa routes come with an NRPF condition, throw migrant families into poverty. 

31. IPPR, Greater Manchester Immigration Aid Unit and Praxis conducted a survey of 314 people who were subject to the NRP condition on a 10-year route to settlement, which found that a sizable share struggled to meet the costs of utility bills (62%), food (57%) and housing costs (43%).[29] Almost half of respondents (41%) were forced to borrow from friends or family to pay for the costs of their visa application, while three-quarters would not be able to apply for permanent residency even after they have fulfilled all the criteria, because they simply could not afford the fee. There is a risk that by imposing a minimum income requirement, some people will never qualify for settlement (e.g. single parents who are more likely to be women,[30] unpaid carers, or people who struggle with illness and disability).

32. In the worst cases, making visa renewals too costly does not just lead to poverty, but risks pushing some into irregularity. This opens a downward spiral of loss of right to work, rent, or study, where the risk of exploitation is acute, the chances of integration diminish, and the only way out is via complex immigration applications.

Increase in complex case volume for the Home Office

33. We anticipate that putting ILR further out of reach will not only harm migrant families, but also increase the Home Office caseload. First, we anticipate an increase in fee waiver and change of conditions applications, from migrants who will be pushed into poverty or unable to cover hefty visa fees. Second, we anticipate an increase in applications under Appendix Private Life, from migrants (such as children and young people) who will have spent much or all of their lives in the UK, but will be unable to qualify under the main pathway to settlement (due to fees, or the parents’ own inability to meet ILR criteria).

34. This in turn will have wider implications on the legal sector. More applications and complexity will lead to greater demand on an already strained advice sector.

35. Refusals, which will be inevitable in any system, will result in increased work loads of the courts/tribunal. The Immigration and Asylum Chamber tribunals already have significant backlogs and are struggling to process cases.[31] Equally, Home Office data shows that the number of open Human Rights or other complex immigration cases stood at 76,433 in Q3 2025, higher than at any point since records started in Q3 2019.[32]

Fiscal costs of migrants falling into irregular status

36. During an oral evidence session for this enquiry, Professor Gareth Davies argued that there exists a flawed notion that those unable to obtain ILR on a longer route will go back to their countries of origin.[33] We agree with his assessment. Making ILR more difficult to obtain does not necessarily mean that people will leave the UK - many people, such as the care workers the Work Rights Centre has been supporting, will have spent their lives’ savings for a UK work opportunity. It could also mean that they remain, but continue to live in precarious conditions of irregularity, where they risk labour exploitation, eviction, and social exclusion. This carries a real risk of harm to individual migrants and their families. There is also a fiscal cost of irregularity that affects UK public finances more generally - including from lost income tax revenue, and from an increase in councils’ expenditure on supporting families on the NRPF condition.  When migrant families are excluded from public funds, councils generally step in, in compliance with their statutory duties (such as under section 17 of the Children Act 1989).

Human costs of penalising recipients of public funds

37. Migrants can only claim public funds in a limited set of circumstances, where access is desperately needed, and by making a complex change of conditions application to the Home Office.[34] The application is subject to a high evidential threshold and must be made on the basis of a limited set of reasons (e.g. where there is a risk to the welfare of a child; or for Skilled Workers, where there are “particularly compelling circumstances which justify giving access to public funds”).

38. Under the government’s proposals, the qualifying period will be extended by 5 years for applicants who had received public funds for less than 12 months on the route to settlement, and by 10 years where they had received public funds for more than 12 months. This is an extraordinarily punitive measure that makes little sense.

39. Quarterly migration transparency data published by the Home Office indicates that between Q1 2023 and Q3 2025, a total of 9,541 applications were submitted, corresponding to an average of just 867 applications per quarter.[35] Grants were even lower - the average application acceptance rate between Q2 2024 and Q1 2025 was just 55%. While the number of people who are given access to public funds is very small, these decisions save significant costs from local authorities. The NRPF Network reports that “in the financial year 2024–25, 91 councils in England, Scotland and Wales collectively spent £94 million” on supporting NRPF households.[36]

40. There is limited evidence to suggest that access to public funds for households with children or vulnerable individuals has long-term negative fiscal or economic consequences. On the contrary, Social Cost Benefit Analysis done by the London School of Economics found that lifting the NRPF condition to avoid households falling into poverty would result in a net gain of £872 million over ten years.[37] Much of this gain comes from lifting children out of poverty (which has significant implications for their future prospects), enabling access to better-quality housing (with associated savings for the NHS), access to childcare (improving employment outcomes), and relief from problem debt (which has profound implications on productivity). We also note that change of conditions applications are disproportionately likely to be submitted by women, who made up 62% of applicants in the first three quarters of 2025.[38] Therefore, penalising recipients of public funds is likely to have a stronger, negative impact on female migrants, who are generally more likely to be single parents and unpaid carers.

41. In our frontline experience, migrants on the Skilled Worker visa have only been granted public funds after severe exploitation and retaliation by their visa sponsor - such as in cases of modern slavery, where the sponsor not only pressured migrants to work in precarious conditions, but also made them homeless. Both we[39] and others, such as the Public Accounts Committee,[40] have argued that exploitation on this route was enabled by insufficient structural safeguards and the government’s slow response to the issue.

42. It is therefore unconscionable for the government to penalise migrant families for decisions made by Home Office officials - and to dissuade migrant families from making change of conditions applications in the future. Punishing exploited workers who need to claim public funds following exploitation would be particularly unjust, given the failings of government immigration policy in safeguarding them (see our reports)[41].

Limiting access to public funds for migrants with ILR.

43. Another proposal the Home Secretary is consulting on is retaining the NRPF condition even upon receiving ILR. This is a stark departure from the present rules, that could cause real harm to migrant families.

44. In absolute terms, limiting access to public funds for migrants with ILR would have minimal impact on the public coffers. Data gathered by the Department of Work and Pensions in June 2025 confirmed that of the 7.9 million people on Universal Credit in June 2025, the vast majority of claims (83.6%) were made up of British nationals, Irish nationals and people with right of abode in the UK that do not need an immigration status to claim Universal Credit.[42] Only 2.7% of people on Universal Credit were in the Indefinite Leave to Remain (ILR) category, and 32% of these were already in employment. Notably, while the proportion of claimants with ILR has increased slightly (by 0.5pp) since June 2024, this increase is slower than that of the British, Irish and right of abode category (1.1pp).

45. By contrast, instituting more stringent welfare policies for migrants may have significant, unintended negative effects, according to the literature. Following a 40% cut in welfare transfers for refugees in Denmark in 2002, households’ disposable incomes were reduced, and this had profound implications for their integration outcomes.[43] This included increased adult crime and reduced education attainment among children in school at the time of the reform. At the same time, any employment gains were largely short-term and concentrated in areas of high labour demand.

Costs of possible litigation

46. Aside from the human and fiscal costs outlined earlier, there are glaring ways in which the changes would disproportionately and negatively impact individuals with protected characteristics under the Equality Act 2010, and this could lead to further litigation costs. Zoe Bantleman, Legal Director of the Immigration Law Practitioners’ Association (ILPA), warned that the proposed changes create “perversities” in the system, including by creating different entitlements for family members of British nationals (who would face a 5 year wait), and family members of non-British residents settled in the UK (who would face longer waits).[44] The mandatory requirement to have earned a minimum salary for 3-5 years before applying for ILR may also disadvantage people with disabilities. The harsher proposals for a 15-year baseline for care workers is almost certain to disadvantage women, who make up the majority of the workforce. Without a full equalities impact assessment, the current formulation of the proposals carries a significant risk of litigation, with an associated cost for the government.

Impact on businesses

47. Finally, it is deeply worrying that the government has not published an impact assessment of how these changes will impact businesses and the economy.

48. Extending the qualifying period for ILR would mean that businesses would incur additional long-term staffing costs for every Skilled Worker they want to retain. Currently, businesses are required to pay an Immigration Skills Charge (of £480/year/worker for small and charitable employers, and £1,320/year/worker for large employers). Delaying settlement would require employers to keep paying the IS Charge for years.

49. The retroactive nature of the changes may also damage business trust in the predictability of government policy, with potential impacts on recruitment and investment. These immigration changes are being introduced in a climate of serious policy uncertainty, higher than in all but one Parliament in the last 30 years.[45]

50. Any impacts are likely to be felt more acutely in industries with significant shares of hard-to-fill vacancies, where businesses cannot easily recruit domestically. They are also more likely to be felt in industries, where countries with less restrictive immigration regimes (see our response to Question 1 within “Historical and International Context”) would be seen as alternative or preferential destinations by workers. This risks putting such industries at a competitive disadvantage, with potential repercussions for industry-level labour shortages, as well as regional and national economies.

Question 2. Is it preferable to have a system whereby it is hard to get a visa but easier to get permanent status, or easy to get a visa but harder to get permanent status?

51. Our view is that the changes proposed by the government are not addressed by this question. Currently, it is both hard to get a visa, and hard to obtain ILR. We urge the committee to consider the risks outlined in our response to Question 1.

Question 4. What are the implications of having many long-term residents on temporary visas without access to ILR and/or citizenship?

52. It is important to note from the onset that the government has failed to publish an Impact Assessment or an Equality Impact Assessment (EIA) alongside the consultation. The consultation document merely states on page 10 that these assessments will only be published “in due course”.

53. This omission undermines the validity of the consultation process. Respondents are effectively asked to evaluate a radical set of policy proposals with limited and, at times, erroneous information (such as on the number of care workers, or the rate of vacancies in the care sector). Crucially, without an impact assessment it is not clear if the government’s intentions are aligned with other strategic priorities - including to spur growth, achieve higher housebuilding targets, prevent child poverty and tackle Violence Against Women and Girls.

54. In our response to Question 1, we outlined how putting settlement further out of reach can lead to poverty for the most vulnerable households, who face years of exclusion from public funds, and significantly increase the risk of labour exploitation. We would like to draw the committee’s attention to the vast amount of evidence on labour exploitation, and highlight the further risk that delaying access to ILR hinders migrants’ social and economic integration.

Increased risk of exploitation

55. The relationship between sponsorship and exploitation has been robustly evidenced, including in reports by the Work Rights Centre[46] and other third sector organisations (Citizens Advice[47], the Modern Slavery Policy and Evidence Centre[48], Unseen[49]), Unison,[50] media reports (including by the Bureau of Investigative Journalism,[51] BBC,[52] the Guardian,[53] and the Financial Times[54]), parliamentary committees, and the National Audit Office.

56. In its July 2025 report,[55] the Public Accounts Committee drew an explicit connection between the sponsorship system and migrant workers’ exploitation in the UK, noting not only that the Skilled Worker route “makes migrant workers vulnerable to exploitation”, but also that the Home Office had failed to protect workers in this system - including by failing to safeguard workers affected by sponsor licence revocations (particularly in the care sector), and by adopting an unconvincing approach to preventing modern slavery more generally. Similarly, on 17 March 2025, the NAO report[56] on the Home Office’s management of the SW route found that much of the Home Office’s decision-making was made with poor understanding of how the route operates. It was also slow to address non-compliance on the route and had limited data on the scale of exploitation.

57. We are very concerned that by tying migrant workers to employers for years, the government is creating an exploitable, immobile workforce. It is important to observe that while the Home Office has increased sponsor due diligence and compliance activities in response, and immigration policy has restricted the types of roles that can be sponsored, the design of the system remains unchanged. Employers continue to hold the power to have workers’ visas curtailed, and workers continue to face the risk that reporting unscrupulous employers will lead to them losing their status in the UK. The government’s settlement changes do nothing to address those risks - on the contrary, they extend them for years.

Lower prospects of integration

58. We are also concerned that by adopting a policy model that puts migrant workers on temporary status for years, the government is inadvertently hindering their ability to integrate. There is ample evidence to that effect.

59. According to the Migration Observatory analysis of the government’s proposed changes to settlement, “there is evidence that longer periods of time without the rights that come with permanent status and citizenship may somewhat hinder social and economic integration.”[57] Several academic studies support this point.

●     In a study of highly skilled temporary workers in the United States,  Lowell and Avato find that initial visa status limit later earnings growth - notably by reducing migrant workers’ bargaining power, and limiting their professional mobility.[58]

●     Research from Denmark found that the employment rate of refugees affected by a restricted path to permanent residency in 2007, decreased by 30%, “while their average language proficiency remained largely unchanged.”[59]

●     In their analysis of Danish refugee policies adopted over the course of four decades, Dustmann et al. find that policies “that regulate access to welfare benefits or use permanence of residence to incentivise skill investment, while beneficial for some, create disadvantages for others.”[60] Notably, policies that aim to promote integration by tightening eligibility for permanent residence or citizenship only achieve their intended effect if the bar for obtaining permanence is not set too high. Once settlement becomes too difficult, more severe requirements can lead to lower labour market performance.

●     Analysis of immigrants in Swiss cantons found that access to citizenship “strongly improved long-term social integration,” and that “integration returns to naturalisation are larger for more marginalized immigrant groups.”[61] Looking across several European countries, Gathmann and Garbers find that “faster access to citizenship increases take-up and improves the economic, educational, political[62] and social integration of immigrants.”[63]

60. Experts who gave evidence to parliamentary committees echoed the observation that putting settlement out of reach limits integration:

●     Dr. Madeleine Sumption, noted before the Home Affairs Select Committee: “The trade-off that Brian mentioned [the trade-off between having fewer settled migrants and having poorer migrant households] is an integration trade-off. In the short run, if you make it harder for people to get settlement and you restrict their access to benefits, you get that short-run financial benefit. In the longer term, there is a surprising amount of evidence from other countries that having access to a permanent status and then going on to citizenship is beneficial for both economic and social integration. People earn more when they move on to citizenship. That is not necessarily what you would expect, but there are quite a lot of studies that show it. There is a risk of undermining integration by making people wait longer.”[64]

●     Professor Alan Manning, noted in oral evidence before the Justice and Home Affairs Committee: "We have studies where Governments have imposed unrealistic conditions on, for example, getting permanent residence and people then just give up. But we have other studies where they have put more realistic conditions in place and that has induced people to behave in ways that involve better economic and social integration."[65]

●     Professor Ricky van Oers, noted in oral evidence before the Justice and Home Affairs Committee: “Three important drivers for integration are: security of residence and protection against expulsion; equal treatment comparable to other citizens in crucial domains such as education, the employment market and housing; and family reunification. States that create these three measures create a climate in which integration can successfully take place. If these conditions are not present—notably, security of residence and protection against expulsion—it is difficult for a new group to integrate, and any measure taken to promote integration will fail because the basic conditions are not present in those cases.”[66]

Integration risks for care workers

61. We echo these concerns. For the past couple of years, employability advisers at the Work Rights Centre have been inundated with enquiries from migrant care workers on employer-sponsored visas, who were looking to change employers - having fallen victim to recruitment scams, or having experienced exploitation by their visa sponsor.

62. Even with professional advice, supporting them to change sponsors has proven significantly more difficult than supporting service users who had the unrestricted right to work. The pressure to find another sponsor, and make and pay for another visa application before they could take up a full-time position, was a significant barrier to employment. Anecdotally, we have also found that many employers were put off by the numerous immigration policy changes (notably the recent increases in minimum salary requirements and restrictions on the roles eligible for sponsorship), and were reluctant to make the significant upfront cost of sponsorship. The majority were able to find casual employment, and work the additional 20h/week permitted by the Home Office, but struggled to find full-time work with a new sponsor.

63. The government’s only public-facing attempt to rematch care workers ‘displaced’ by sponsor licence revocation into new sponsored roles was largely unsuccessful. Our report on this programme found the same business and worker-side challenges to securing employment that we observed in our casework.[67] FOI data obtained by the Work Rights Centre shows that as of 31 July 2025, a total of 30,170 care workers were ‘displaced’, but only 1,825 (6.1%) were successfully rematched with a new sponsor via the programme by 31 August 2025.[68]

64. These prolonged periods of involuntary unemployment and under-employment pushed many care workers into financial precarity, damaged their mental health, and dampened their confidence - limiting their ability to integrate.

Question 5. Are public attitudes and concerns related to immigration and citizenship being addressed? What are the wider issues that the Government is considering in making these changes?

65. The public’s attitudes towards migration are complex. On the surface, asked for their views on immigration as a whole, a sizable share of respondents to public attitudes surveys express negative views. We seem to be in a moment when, for a significant share of the population, immigration will always appear too high and out of control - regardless of the actual numbers of migrants coming to the UK, their contribution to the UK, or indeed the policy changes adopted by successive governments.

66. But basing settlement policy decisions on topline survey data alone would be a dangerous oversimplification. Firstly, there are serious limitations to public attitudes surveys on migration as a whole. The public perception of migration is markedly different from the reality of migration, and we know that immigration can evoke very different things for different respondents. Secondly, asked for their views on specific groups of migrants, rather than immigration as a whole, the public’s views are significantly more nuanced, and more welcoming, with studies showing non-negative attitudes towards most forms of work migration.

67. We are concerned that the government’s settlement proposals are narrowly responding to these topline polling figures, ignoring these nuances and limitations.

68. For the avoidance of doubt, we are not suggesting that a different, more granular, interpretation of public attitudes would justify the government’s punitive settlement proposals. We reject the settlement proposals for the numerous negative impacts they will have (detailed in our responses to questions 1 and 4). Our aim with this response is simply to show that the government’s proposals also fail to address public concerns - and in the case of migrant workers, go contrary to what the public desire.

Broad attitudes to migration

69. On the surface, public attitudes to migration are generally skeptical. Polling by YouGov from 4-5 January 2026 found that 23% of respondents thought that tackling immigration should be the government’s biggest priority, more even than those who thought cost of living should be the top priority (16%) and those who prioritised the economy (10%).[69] Tackling immigration was particularly significant for Reform voters (56% of whom made it their number one priority) and Conservative votes (37%), and was the second most important issue for Labour voters (14%), with Liberal Democrats (9%) ranking it as their fourth priority. Polling by Ipsos yields similar findings, with immigration chosen as the most important issue by 21% of respondents, albeit lower than the cost of living (29%).[70]

70. This sentiment appears to be driven at least partly by some of the public’s discontent with perceived levels of immigration. The latest surveying by British Future finds that 57% of Britons would like to see immigration reduced, with the share of those wanting it to be reduced by a lot growing from 25% in January 2022 to 41% in November 2025.[71] Not dissimilarly, Ipsos polling from April 2025 found that 67% of Britons believe immigration levels were too high,[72] and YouGov polling from 5 January 2026 found that 70% of Britons find immigration to be too high in the last 10 years.[73]

71. In this context, the public appears to have limited confidence in the Labour Party to handle asylum and immigration. Separate polling by YouGov has found that as of 12 January 2026 fewer than 10% of respondents believed Labour would be best at this, less than half the share when Labour was elected in July 2024 (26%).[74] Similarly, the latest polling by More in Common finds that 74% of Britons have little or no confidence in Labour’s ability to manage these matters.[75]

72. This immigration debate is, to an extent, intertwined with social cohesion. Research by More in Common finds that in December 2025, 47% of Britons believed that society is at least somewhat divided between immigrants and non-immigrants, with the figures relatively high irrespective of voting intention.[76] The same study finds that 64% of Britons believe the country is somewhat or very divided, the highest figure since polling started.

The case for nuance

73. In many ways, the government’s settlement proposals speak directly to these topline concerns. In her opening statement, the Home Secretary presents the proposals as a means of tackling high levels of migration, building community cohesion, and asserting more government control of migration. But while this engages with one aspect of public opinion on migration as an issue (general, undefined, presented as a broad homogenous concept), it misses both the many biases that can characterise survey results, and the many nuances that characterise public perceptions of migrants as people. This is what we turn to next.

Biases and limitations in data related to attitudes to migration as a whole

74. Public opinion on immigration as a whole is easily biased by recent political and media discourse. For example, a report by British Future from November 2025 finds that hardening political discourse on migration, and reliance on one-dimensional social media for news, are two key drivers of a hardening of opinion on migration - with increased shares of both strong proponents, and opponents, of immigration in the population.[77] Simply put, it could be that more people feel that migration is too high, because more public figures make the same argument.

75. The public’s perception of migration is also often far removed from the reality of migration. Polling by More in Common found that despite net migration to the UK falling by more than two thirds in the year ending June 2025, 67% of respondents believed it had actually increased.[78] This is consistent with analysis by British Future, which found that when posed with net migration statistics demonstrating a reduction between 2023 and 2024, 21% of respondents refused to believe the figures.[79] YouGov polling goes further to suggest that as of December 2025, nearly half (43%) of surveyed Britons did not understand what ‘net migration’ means.[80] Finally, separate YouGov polling from November 2025 found that nearly one third (32%) of Britons erroneously believed that many more immigrants were in the UK illegally than legally, and just 19% thought many more were in the UK legally than illegally.[81]

Nuances in data related to migration in specific contexts

76. It is also apparent that the public has more nuanced views of immigration and immigrants than topline figures suggest. A Migration Observatory study found that when people are asked questions about immigrations, respondents are most likely to think of asylum seekers (62%), and least likely to think of students (29%), even though students represent one of the largest group of immigrants coming to the UK, while asylum seekers are one of the smallest.[82] Broad questions about migration policy might, in fact, be informed by much narrower views on particular types of migration. For example, More in Common polling found that 79% of respondents wanted the government to focus its immigration policy on small boat crossings, as opposed to 10% who selected restricting net legal migration overall.[83]

77. Studies that prompt respondents to express views on particular groups of migrants, or think of migration in context, also reveal more nuanced attitudes. British Future found that a plurality of respondents wanted increased immigration for doctors (47%), nurses (47%) and care home workers (39%).[84] This chimes with YouGov polling which suggests Britons are willing to accept greater work migration into healthcare, if it ensures the sector is fully staffed.[85] Similar findings applied for other occupations. For instance, British Future highlighted that at least 50% of respondents wanted increased or constant immigration into practically all roles covered, excluding bankers but including construction labourers, engineers, and restaurant and catering staff.[86] Notably, some of these roles are below graduate level, and are not considered ‘high-skilled’ under the RQF framework. YouGov polling also found that Britons overwhelmingly do not think negatively of work migrants filling in skills gaps, or coming to work as skilled tradespeople.[87] In fact, the survey finds that Britons want to prioritise “getting enough workers in areas with skills shortages”, as opposed to restricting immigration as a whole.

Conclusion

78. The settlement proposals pose significant risks to migrant communities, as detailed in our earlier responses. They also pose a risk to the economy. This is why we urge the committee to reject them. In addition, we have shown here that they are also not reflective of the public’s actual views and wishes on immigration.

79. The settlement proposals place care workers and other middle-skilled workers on the Skilled Worker route onto an extended, 15-year track to settlement, even though the public welcome work migration in all roles, high and low skilled.

80. The proposals reward the highest earners, and penalise those in lower-paid roles, even though the public broadly welcomes migration that fills skills gaps. It should be added that British Future found bankers to be the only selected profession where less than half of respondents wanted to increase or retain or increase levels of immigration. In fact, respondents aligning with Reform UK overwhelmingly (52%) expressed a desire to reduce immigration for bankers, a figure much higher than for care home workers (37%), engineers (29%) or nurses (27%).[88]

Question 6. What are the implications of the proposed changes on the devolved nations of the UK and on the Common Travel Area?

81. The proposed changes may have a harmful effect on devolved nations, which we identify as being twofold. They could have unintended negative consequences for regional markets reliant on Skilled Workers, and in Northern Ireland they would offer lower family reunification rights to more than a quarter of the population.

82. Devolved nations have different labour markets to England. The National Institute of Economic and Social Research (NIESR) notes that the working populations are more rural,[89] which in turn is driven by the prevalence of key primary (e.g. agriculture) and secondary (e.g. manufacturing) industries. NIESR also highlights that jobs in devolved nations are more likely to be lower-skilled, with just over half of Northern Irish (55%) and Welsh (58%) jobs being in Standard Occupational Codes 1-3 or 5, as opposed to 71% of jobs in London. Therefore, it is possible that these regions were disproportionately reliant on middle-skilled labour available via the Skilled Worker route. We are not aware of any recent, formal assessment on this subject.

83. We do know that between October 2024 and March 2025, more than one in eight (13%) Skilled Worker visas (not including Health and Care Worker visas) were used to fill vacancies in devolved nations.[90] At least some of these roles were in critical primary and secondary industries, with examples being Scottish fishing[91] and farming,[92] which are crucial to local and Scottish economies.[93],[94] The Scottish Government’s proposals, sent to the UK Government for consideration in the development of the immigration white paper, also note the negative impact of reduced work migration on the sustainability of Scottish industry and communities and call for tailored migration policy in this context.[95] Extending the route to settlement for medium-skilled workers in such industries may risk having a disproportionate impact on Scotland and other devolved nations, by increasing the likelihood that workers must leave the UK before becoming eligible for ILR.

84. Devolved nations - in particular Wales and Northern Ireland - also have substantially lower incomes than the Greater South East and East of England regions.[96],[97] The findings stand when using average gross disposable household income (GDHI).[98] In the context of the proposed changes, this means that households in Wales and Northern Ireland on extended routes to ILR are more likely to struggle paying the fees associated with repeated extension of permission to remain (see our response to Question 1). It also means that workers on the Skilled Worker route will be less able to meet the £50,270pa salary threshold required for a five-year reduction to the ILR qualifying period, putting them at a significant disadvantage relative to their counterparts in the southern regions of England. Occupational analysis of Skilled Workers’ salaries by region is yet to be conducted by the Home Office, despite having linked individual records to those held by HMRC.

85. Under the proposals, family members of Irish and other non-British nationals will be subject to a baseline qualifying period for ILR of 10 years, whereas family members of British nationals will be on a 5-year route. The discriminatory nature of this proposal will be felt particularly acutely in Northern Ireland, where more than one quarter of the population holds an Irish, but not a British passport.[99] There may also be significant cross-border movement of Irish nationals into Northern Ireland, owing to the Common Travel Area. Irish households of mixed nationality may feel discriminated against, with (i) lesser family reunification rights than their British counterparts and (ii) lower household cross-border mobility, as ILR under Appendix FM of the Immigration Rules has residence requirements attached.

Historical and International Context

Question 1. How does the UK’s policy on permanent residence and citizenship compare with other countries, particularly those in Europe and the Commonwealth?

86. We analyse the qualifying periods of residence in the UK and other countries. In this respect, permanent residence policy has been broadly comparable between the UK and other countries in Western Europe and the Commonwealth. Should the proposed changes be introduced, the UK would have one of the longest routes to permanent residence. It would put the UK in line with outlier countries, like Jordan, Turkey, Denmark, Japan and Switzerland. We note that Danish and Swiss policy exists in a radically different immigration context, due to EEA citizens’ free movement rights.

87. Information from the Migrant Integration Policy Index (MIPEX) suggests that most Western European and Commonwealth states have residency requirements for settlement that are no longer than five-years.[100] Table 1 summarises the residence requirements for permanent immigration status for selected countries, based on information from MIPEX and government pages on family and work migration routes. Standard family and work migration routes are considered. Information for the UK is based on current immigration rules.

Table 1. Number of years’ residence required to apply for permanent immigration status or citizenship

The Citizenship Process

Question 4. Under the Immigration White Paper’s expansion of the points-based system, what will happen to those who never ‘earn’ enough points to achieve ILR or citizenship?

88. We are extremely concerned that by increasing the baseline and introducing more stringent criteria for settlement, the government’s proposals could create a class of people who are permanently locked in temporary status.

89. This could see thousands of people excluded from public funds for decades, tied to employers with little bargaining power, less able to move jobs, less able to make long-term plans or investments in the UK - on the whole, less able to integrate and to contribute to British society at their full potential.

90. Another extraordinary implication of the government’s proposal is that even after 14 years of living and working lawfully in the UK, a migrant care worker who loses her job (for instance, as a result of sex discrimination, redundancy, or illness), would face the prospect of becoming a visa overstayer. This is not a hypothetical scenario. It is a real risk that could affect hundreds of thousands of migrant workers employed in medium-skilled roles, for whom the Home Secretary proposes a 15 year baseline route.

91. The very notion of decades-long temporary status runs counter to the government’s stated policy objectives of promoting integration. It is also likely to disadvantage migrants in lower-paid roles, women, the sick and disabled, refugees, and all those whom the government penalises with its new ‘time-adjusted’ settlement model.

92. In terms of broader integration, the policy change will create a class of long-term temporary residents who are effectively excluded from the democratic process, by not having the opportunity to naturalise and gain the right to vote in elections. This cohort would potentially include more than one million individuals nationwide, with certain regions and local authorities having significant shares of the resident population being unrepresented in policymaking.

93. Under the guise of rewarding contribution and ending the “automatic” right to settlement, the government is effectively paving the way for further social division. We urge the committee to require an impact assessment of these proposals and resist their implementation.

22 January 2026