The UK Government has published a statement (A Fairer Pathway to Settlement)1 and an accompanying consultation outlining proposals for the settlement (Indefinite Leave to Remain) framework and formally opening the consultation period.2 Central to the proposed reforms is the introduction of an “earned settlement” model.
WHY THIS MATTERS
As was first indicated in the White Paper “Restoring Control over the Immigration System,” published on 12 May 2025,3 the UK Government is proposing the introduction of an “earned settlement” model, which recognises the value of long-term contribution to the UK. The standard qualifying period is proposed to increase to a minimum of 10 years, though accelerated routes may be available for those meeting certain conditions.
Key Highlights
Four Core Pillars
The new proposed “time adjustment” model is built on four core pillars:
- Character: Applicants must meet strict standards on conduct and criminality, with no settlement for those with a criminal record.
- Integration: Demonstrating meaningful engagement with British society will be essential.
- Contribution: Economic participation and measurable contributions to the UK economy will be rewarded, potentially allowing for faster settlement.
- Residence: Lawful, continuous residence is required but will not be sufficient on its own.
Proposed Settlement Timelines (unless discounts apply)
- 10 years: Standard qualifying period for most economic migrants including the Skilled Worker route
- 15 years: Roles below RQF6 level (e.g. Health & Care roles) or those who have been in receipt of public funds for less than 12 months
- 20 years: Individuals in receipt of public funds for more than 12 months
- Up to 30 years: Individuals who originally entered the UK illegally, when the applicant originally entered as a visitor or overstayed for 6 months or more
Note: Only the factor that causes the largest increase to the baseline qualifying period would be applied and this will take precedence over any reduction.
Proposed Expedited Timelines to Settlement (based on reductions available)
- Three years (offering a seven-year discount): Includes those earning a taxable income of £125,140 for three years immediately prior to applying for settlement, Global Talent and Innovator Founder visa holders.
- Five years (offering a five-year discount): Includes those earning a taxable income of £50,270 for three years immediately prior to applying for settlement and specified public service workers.
- Other discounts proposed, which would be taken off the 10-year baseline:
- Higher level of English language (level C1 of CEFR) – One year discount
- Working in the community (volunteering, etc.) – discount range between three to five years
- Higher level of English language (level C1 of CEFR) – One year discount
Note: Only the factor that causes the largest reduction to the baseline qualifying period would be applied.
Dependents
- Dependent partners envisaged to have their own qualifying period towards settlement based on their individual circumstances under the proposals.
- Proposals to allow dependent children to have an option to apply at the same time as parents during a specific window of time, but for there to also be a point at which they can transition to a pathway under which they can progress to settlement in their own right.
Transitional Arrangements
The government’s intention is that applicants who have not yet secured settlement status at the time of implementation would be subject to the new model, however this is subject to consultation (any transitional arrangements will be set out following the consultation, which is open until 12 February 2026).
Not subject to the consultation
- Settlement status under the EU Settlement Scheme (EUSS)
- Grants of settlement related to the Windrush Scheme
- Those who hold visas under the British Nationals Overseas (BNO) route or as the partner, child, or parent of a British citizen will remain on the five-year route to settlement (five-year discount to the new baseline is proposed, which is not subject to consultation)
KPMG INSIGHTS
Considerations for Employers
- Conduct a Workforce Audit: Consider identifying employees on routes to settlement potentially affected by the proposals and assessing their eligibility under the proposed new model. Consider frontloading settlement applications when possible for these to be approved prior to changes taking effect.
- Strategic Workforce Planning & Policy Review: Consider assessing the impact on workforce planning, particularly for roles with salaries near the minimum general/SOC code thresholds as well as considering the potential impact of the proposed discount thresholds based on salary. In particular, assessing impact in parts of your business with high reliance on international talent may be advised. Consider the implications for recruitment, retention, and succession planning as well as any required policy reviews.
- Employee Communication & Support: Consider communication strategies for employees regarding the proposed changes as well as any support that may be provided.
- Cost and Operational Impact Assessment: Consider conducting a thorough cost analysis of the proposed framework, including potential increases in sponsorship duration and associated fees. Factor in the increased compliance burden of retaining evidence for longer sponsorship periods.
- Mitigating Uncertainty: Consider acknowledging the inherent uncertainty in future immigration policy and its impact on talent acquisition and retention, as well as developing contingency plans and flexible strategies to adapt to potential changes.
- Participate in the Consultation: You may wish to consider engaging with the consultations to provide feedback on the impact of these proposed changes on businesses and the UK's ability to attract global talent to represent your views as a business.
- Seek Professional Advice: Consider contacting your KPMG advisory team for guidance on specific cases or strategic workforce planning and cost assessments.
What’s Next?
KPMG in the United Kingdom recognises that these proposed changes represent a significant shift in the UK’s immigration landscape. At this point, no changes have been made and no date for implementation has been announced, although the government has indicated it is aiming to begin implementing the changes beginning April 2026.
If individuals and/or their programme managers have any questions or concerns about the scope of the policy update, its application and potential impacts, and appropriate next steps, they should consult with their qualified immigration professional or a member of the Immigration team with KPMG in the United Kingdom (see the Contacts section).
FOOTNOTES:
1 “A Fairer Pathway to Settlement” (November 2025).
2 “Migration: Settlement Pathway” (20 November 2025).
3 “Restoring control over the immigration system: white paper” (published 12 May 2025).
Contacts
Disclaimer
* Please note the KPMG International member firm in the United States does not provide immigration or labour law services. However, KPMG Law LLP in Canada can assist clients with U.S. immigration matters.
The information contained in this newsletter was submitted by the KPMG International member firm in the United Kingdom.
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