The government’s proposed changes to the pathways to Indefinite Leave to Remain (ILR or permanent residence) have been thrown into doubt following political uncertainty within the government. 

It is not currently clear whether the proposed changes will be implemented at all, due to a divide within the government, and there is no set date for the timing of the proposed changes. 

Following the release of the latest net migration figures by the Office for National Statistics on 21 May 2026, there are reports that the Home Secretary is focused on continuing the plan to reduce migration. The ‘Earned Settlement’ reforms are part of her plans, and it appears she is still keen to pursue them. 

In any case:

  • The delay in the introduction of the changes will allow more people to apply for ILR, so please do get in contact with us if you are approaching eligibility for ILR; and
  • There is much less certainty around whether the Labour government of the day will survive. Any changes in the personnel leading the government could result in a shift in immigration policy. 

Updates to sponsor licence guidance

In addition to the updates to the sponsor licence guidance made on 6 March 2026, a further tranche of updates were published on 20 May 2026.

In summary:

  • Prospective and existing sponsors are required to read all relevant parts of the sponsor guidance and keep up to date with changes to it. You can find the relevant parts of the guidance here.
  • Sponsors must conduct right to work checks on any worker you wish to employ or sponsor (including workers who are not your direct employees).
  • Sponsors must ensure that their sponsored workers are aware of their employment rights in the UK. You may want to seek employment law advice on this matter.  

18 months since expiry of last BRPs

Biometric Residence Permits (BRPs) were phased out in late 2024 and the UK immigration system has now become (almost) fully digital. So we’re now approaching 18 months since the last expiry date of BRPs.

This creates a potential problem – when people make visa applications within the UK, they either submit through their UKVI account or attend a biometrics appointment. The UKVI account process allows for a fully digital process, with no need to attend an in-person appointment. 

But for the UKVI account process, you need an ID document that the Home Office verify with a chip – they can only do that with EU passports and BRPs that expired within the last 18 months. Here’s where the issue lies. All BRPs expired before or on 31 December 2024, so at the end of June 2026, we will hit 18 months since the last BRP expired. 

The Home Office are yet to tell us what this will mean for the UKVI account process. If no alternative option is provided for people with BRPs, there will be a significant increase in demand for biometric appointments, which could lead to delays in securing an appointment.

We are hoping for news on this in the coming month and will update clients accordingly.