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The UK immigration system is changing again. On 3 September 2026, the Home Office published a new Statement of Changes to the Immigration Rules. Most of the changes covered in this guide take effect on 8 October 2026.
For employers, HR teams and sponsor licence holders, this is not simply another policy update to file away. Some of the changes affect how employers should interpret a worker's immigration status, how pending applications may interact with permission to work, and what overseas visitors may lawfully do while they are in the UK.
Read the official Statement of Changes on GOV.UK
The main date UK employers, HR teams and sponsor licence holders need to have on their radar.
What is changing on 8 October?
The Statement of Changes is wider than the four areas below, but these are among the changes most relevant to organisations managing international workers, overseas employees and immigration related workforce processes.
1. More flexibility for Skilled Workers recognised as victims of modern slavery
A Skilled Worker is normally granted permission to work in a particular sponsored role, although the Immigration Rules already allow some limited additional work in certain circumstances.
From 8 October, a specific additional protection is available for some people who have been identified as victims of modern slavery.
Where a Skilled Worker has been referred into the National Referral Mechanism and receives a positive Conclusive Grounds decision during their most recent period of permission, their employment conditions may be amended so that they can undertake other work for the remainder of that permission.
This can include employment, self employment and voluntary work. Work as a professional sportsperson, including as a sports coach, remains excluded.
What does this mean for employers?
Do not determine someone's current permission to work solely from an old Certificate of Sponsorship, visa record or assumption about the normal Skilled Worker conditions.
The employer still needs to establish the person's current Right to Work and any restrictions that apply to them through the appropriate Home Office checking process.
An applicant presents as a Skilled Worker but explains that their immigration conditions have changed following a modern slavery decision. The hiring team should not simply reject the application because the proposed employer is not the organisation originally listed on the worker's sponsorship record.
Instead, the organisation should establish the person's current Right to Work and the conditions attached to it.
Check the worker's current immigration status through the appropriate Home Office process.
Keep the required evidence of the check and record when it was completed.
Where permission is time limited, track the correct follow up date and any change in status.
2. Fee waiver requests and section 3C leave are being tightened
This part of the update is more technical, but it matters because immigration permission does not always end simply because the expiry date shown on an older visa has passed.
Section 3C of the Immigration Act 1971 can extend a person's existing leave where a valid in time application has been made and remains undecided.
The new rules clarify how the date of an immigration application is calculated where that application follows a fee waiver request.
To rely on the date of the fee waiver request in the circumstances set out in the Rules, the later application must be for the same immigration route specified in the fee waiver request.
Where the relevant application is submitted after the fee waiver decision, it must generally be submitted within 10 working days of receiving that decision for the fee waiver request date to be treated as the application date under the amended provision.
The changes also confirm that varying an application does not start an entirely new period for biometric enrolment.
Why does this matter to HR?
A worker may tell you that they have submitted an immigration application and are waiting for a decision. That can be relevant to their continuing permission to work, but HR should not make assumptions about the legal effect of the application.
The correct evidence should be obtained through the applicable Right to Work process or, where necessary, the Home Office Employer Checking Service.
Employers should have a reliable way to keep track of:
- Current immigration permission and expiry dates
- Pending immigration applications reported by workers
- Right to Work check dates
- Required follow up checks
- Evidence obtained through Home Office checking services
- Changes that could affect an individual's permission to work
The important distinction is between knowing that an application exists and establishing that the individual continues to have the required permission to work.
3. The Immigration Rules are preparing for the return of Erasmus+
The UK is due to participate in Erasmus+ again from 2027. The September Statement of Changes begins adapting the immigration system so that eligible Erasmus+ participants can undertake relevant education, training and mobility activities in the UK.
The updated rules cover training, study, job shadowing, certain sports activities and different sponsored arrangements. The immigration route still matters.
Under the Visitor rules, qualifying Erasmus+ participants will be able to undertake a number of specified activities where the relevant requirements are met.
These include:
- Providing or receiving certain training at a UK organisation or educational institution
- Taking part in qualifying courses
- Job shadowing through participative observation
- Certain coaching or training assignments at UK sports organisations
- Specified Erasmus+ traineeships under the conditions set out in the Rules
An important detail about traineeships
The Visitor route provision allowing an Erasmus+ traineeship of up to 30 days applies to a visitor who is aged 18 or under.
Erasmus+ also interacts with the Student, Child Student and Government Authorised Exchange routes. Organisations should therefore identify the correct route for the activity rather than treating every Erasmus+ placement as a standard Visitor arrangement.
Organisations hosting Erasmus+ participants through the Visitor route will not generally need to sponsor those visitors simply because they are carrying out one of the permitted Erasmus+ activities.
That is different from the Student route and Government Authorised Exchange arrangements, where sponsorship requirements can still apply.
4. Overseas employees will have more flexibility to receive UK training
There is also a practical change for international businesses that bring employees from overseas operations into the UK for training.
Under the previous Visitor rules, an overseas employee could receive training from a UK based company in certain circumstances, but one condition was that the relevant work practices and techniques were not available in the employee's home country.
That wording is being removed.
The change makes it easier for genuine overseas employees to receive qualifying training in the UK without having to demonstrate that equivalent training is unavailable at home.
A multinational company wants an employee from an overseas office to visit its UK operation to receive internal training on company systems and working practices.
The fact that comparable training might also be available in the employee's home country will no longer, by itself, prevent that training from falling within this particular permitted activity.
This does not turn the Visitor route into a general work route. Employers still need to establish that the actual activities being carried out in the UK are permitted for a visitor.
Other Visitor changes also include provision for artists, entertainers and musicians to attend rehearsals, and updated rules for certain entertainment staff supporting permitted activities.
What should employers review before 8 October 2026?
Most businesses will not need to rebuild their immigration processes from scratch. What they do need is confidence that the information behind each immigration decision is current, traceable and easy to retrieve.
Right to Work checks remain central
One theme runs through several of these changes: employers need to establish a worker's current immigration status rather than relying on assumptions based on an old document or previous immigration position.
Right to Work checks remain an important part of this process.
Annaizu supports employers with digital Right to Work checks and workforce record management, helping teams keep the check, evidence and employee information connected.
Explore Annaizu Right to Work checks
Immigration compliance works better when the information is connected
A visa record in one system, a Right to Work check somewhere else and sponsor information sitting in another folder creates unnecessary risk for HR teams.
Annaizu combines workforce compliance technology with immigration support so employers can manage employee records, sponsorship processes, Right to Work evidence and immigration tasks in a more connected way.
Annaizu Immigration Services can support organisations with sponsor licence matters, Sponsor Management System tasks, changes of circumstances, Certificate of Sponsorship queries, compliance preparation, mock audits and other immigration and sponsorship matters within the scope of the service.
Annaizu also provides access to an IAA registered Level 1 Immigration Adviser for eligible straightforward matters within the permitted scope of Level 1 advice.
Frequently asked questions
When do the September 2026 Immigration Rule changes take effect?
Most of the changes discussed in this guide take effect on 8 October 2026. The Statement of Changes also contains measures with later implementation dates, including 29 October, 30 November and 9 December 2026.
Can a Skilled Worker recognised as a victim of modern slavery work for another employer?
In qualifying circumstances, a Skilled Worker who has received a positive Conclusive Grounds decision can have their employment conditions amended so that other work is permitted for the remainder of their existing permission. The exact immigration conditions should still be verified.
Does a pending immigration application automatically mean an employee can continue working?
Employers should not make that assumption. Section 3C can extend existing immigration permission in qualifying circumstances, but the employer should establish the individual's continuing Right to Work using the appropriate Home Office process.
Can any Erasmus+ visitor undertake a 30 day traineeship?
No. The specific Visitor rule allowing an Erasmus+ traineeship for up to 30 days applies to visitors aged 18 or under and is subject to the other requirements in the Immigration Rules.
Do organisations need to sponsor every Erasmus+ participant?
No. Some qualifying Erasmus+ activity can take place under the Visitor route without organisational sponsorship. Other arrangements can fall under the Student, Child Student or Government Authorised Exchange routes, where different sponsorship requirements apply.
Do the new Visitor rules allow overseas employees to work normally in the UK?
No. The Visitor route continues to restrict work. The changes expand or amend specific permitted activities, including certain training, but they do not convert the Visitor route into a general work visa.
This article provides general information and is not a substitute for immigration advice on an individual case. Immigration rules and Home Office guidance can change. Employers should check the current GOV.UK rules and obtain regulated advice where appropriate.
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