UK-wide: An Immigration: High Net Worth Individuals Overview

The State of UK Immigration – In Brief

The UK immigration landscape continues to evolve at a pace. With new Labour leadership taking the reins, immigration advisers and clients must prepare for further changes, including to long-established policy.

In February 2026, the government closed its landmark consultation on changes to settlement, or Indefinite Leave to Remain (ILR), which could represent some of the biggest changes to UK immigration law in decades. It remains to be seen how far the new leadership will go in implementing the proposals, with changes expected from Autumn 2026.

In business immigration, the government has introduced tighter compliance rules and is applying greater scrutiny to sponsors. From 1 October 2026, right-to-work obligations will also expand across the UK.

Further to the closure of the Tier 1 (Investor) route in 2022, there remains a gap for HNW individuals wishing to invest in the UK. However, the case for a reformed investor visa may now be on the policy agenda, following feedback from stakeholders and public policy groups. Any reformed route must deliver tangible economic benefits and contain robust due diligence measures to guard against abuse. This firm supported the Institute for Public Policy Research’s report into the case for a new British Business Investment visa, published in July 2026.

The Visa Landscape for HNW Individuals

Since the Tier 1 (Investor) route closed to new applicants in February 2022, the UK has had no dedicated route for HNW individuals to obtain residence in exchange for capital.

Two distinct proposals for a replacement have emerged during 2026. The first is a government-led proposal, reported in May 2026, for a narrower, invite-only investor route requiring a minimum GBP5 million investment into priority sectors and offering a three-year path to settlement.

The second is the Institute for Public Policy Research’s British Business Investment Visa (BBIV), published on 9 July 2026, which proposes a GBP5 million investment through a vehicle managed by the British Business Bank, no fast-track to settlement or citizenship, a dedicated Home Office financial and security-vetting unit, and a ban on applications from high-risk jurisdictions.

The proposals are not yet reflected in the Immigration Rules and the timing and final shape of any new route remain unconfirmed. In the meantime, there is a gap for HNW investors who wish to make significant UK capital investments but do not fit within employment-based, innovation or exceptional talent frameworks. This creates a barrier for individuals who could contribute substantially to the UK economy.

Despite this, the government has moved to widen the UK’s appeal to overseas talent. This year saw the announcement of the Sovereign AI Fund in April 2026, where the government indicated that start-ups backed by Sovereign AI will benefit from super-priority visa decisions within one working day, as well as access to up to ten visas for research and development talent “cost free”.

The Global Talent visa has also been expanded with a new endorsement pathway for design professionals since 1 July 2026. The government has separately announced a further expansion, whereby more than 100 UK research and development businesses will be able to more easily access exceptional overseas researchers. These changes reflect a wider effort to make the UK more competitive for globally mobile talent, even as the earned settlement and sponsor compliance reforms tighten the system for other cohorts.

A broader question remains whether existing visa categories need greater reform to attract a wider pool of talent. The Migration Advisory Committee is reviewing how well the current system attracts top talent to the UK, and is due to publish a report this winter.

Earned Settlement Proposals

The government has proposed some of the most major changes to settlement seen in many years, under its “earned settlement” consultation. In summary, the proposals would double the standard timeline to settlement from five to ten years, abolish the existing ten-year long residence route and impose new requirements for dependants, among other changes.

Entrenched into the proposals are streamlined pathways for high-earners and top talent, who may qualify for a three-year timeline to settlement.

The consultation closed in February 2026 and received over 200,000 responses, extremely high for a government consultation of this kind. There has also been backlash from stakeholders and MPs, particularly around the proposed retrospective effect, the impact on vulnerable people, carers and children, and the potential effect on the UK’s ability to attract global talent. The government is yet to formally respond. However, the Home Secretary has indicated that changes are due from Autumn 2026, with further announcements expected shortly.

Increased Scrutiny for Businesses Hiring Overseas Talent

In recent years, the Home Office has supercharged sponsor licence enforcement, revoking 1,545 Skilled Worker sponsor licences in the first quarter of 2026 alone. It is increasingly relying on HMRC data-sharing to identify salary discrepancies without an audit, has introduced measures to make revocation easier, and has created more stringent rules for sponsoring businesses.

Sponsors must now ensure all sponsored workers are made aware of their UK employment rights and retain evidence. They must be ready to demonstrate how a sponsored role fits within the business and that the Certificate of Sponsorship accurately reflects the work performed. The revocation ground for artificial salary inflation has been extended across the immigration process, not just settlement. Crucially, the Home Office may now take enforcement action where it reasonably suspects a breach has occurred or may occur. Licences may also be revoked for unintentional breaches.

Right to work (RTW) obligations are also expanding from 1 October 2026. RTW checks currently apply to traditional employee–employer relationships. However, from 1 October 2026, the definition of “employer” for RTW purposes will require businesses to carry out checks not only for direct employees, but also for workers engaged under a worker’s contract, as individual sub-contractors, and through an online matching service. Civil penalties can reach up to GBP60,000, with reductions available where the employer has voluntarily reported suspected illegal working, co-operated with the Home Office and can demonstrate effective RTW checking practices. In the most serious cases, criminal liability may also arise.

From 26 March 2027, Skilled Worker ILR applicants will be required to meet a higher level of English. The settlement English language requirement will increase from CEFR level B1 to B2, reflecting a tightening across several immigration routes.

Digitalisation: eVisas Are Now the Default

The Home Office’s digitalisation agenda continues. By the end of 2025, Biometric Residence Permits had generally ceased to be accepted as evidence of status, and from 2026, UK immigration status is held digitally as an eVisa on a UKVI account, with no physical card issued for new grants.

From 25 February 2026, most visa nationals applying for a visitor visa began receiving an eVisa only, in place of a physical vignette sticker, and the Home Office intends to stop issuing all physical visa vignette stickers by the end of 2026.

The Electronic Travel Authorisation scheme came fully into force from 25 February 2026, meaning that visitors to the UK can no longer travel without first obtaining pre-authorisation.

Immigration and Asylum Bill

The Immigration and Asylum Bill was introduced in the Commons on 30 June 2026. It is wide reaching and covers modern slavery as well as immigration and asylum. One of its most-discussed aspects is the creation of the Independent Immigration Appeals Authority (IIAA). Instead of judges, appeals would be decided by IIAA adjudicators, who would not require legal experience. The Bill would also amend existing legislation on how Article 8 rights should be interpreted in appeals. It aims to tighten the rules so fewer migrants obtain UK residence rights in future. It would also introduce a new legal status for refugees and change the laws on preventing modern slavery and supporting victims.

Conclusion

As ever with immigration, the landscape ahead is one of rapid change and competing initiatives. On one hand, the government is looking to increase compliance burdens for businesses and make it harder, and more drawn out, for many individuals to obtain settlement in the UK, making the UK an outlier compared with other developed economies. On the other hand, the government is seeking to broaden the UK’s appeal to top talent, and it remains to be seen whether it can run these competing objectives in tandem. Advisers and clients should treat the current position as highly fluid: none of the investor visa proposals are reflected in the Immigration Rules, the earned settlement response is pending, and further Statements of Changes are expected before the Autumn 2026 and March 2027 implementation dates take effect. Clients with existing applications, or those considering a move to the UK, should seek up-to-date advice at the earliest opportunity.