UK Immigration White Paper 2025: Scottish Government proposals
Paper outlining proposals sent to the UK Government in March 2025 for consideration in the development of the Immigration White Paper which was published on 12 May 2025.
Policy Area / Sector issues relating to the current design of the UK immigration system.
The following section outlines problems that the current structure of the immigration system is contributing to within Scotland, and presents brief, high-level proposals for distinct solutions to each of these problems. The Scottish Government stands ready to further explore and engage on any of the topics outlined.
Immigration and Visa fees
Problem: The UK Government’s revenue raising model for immigration fees results in some of the highest charges internationally, making Scotland less attractive for skilled workers. The Immigration Health Surcharge (IHS) rose from £624 to £1,035 per year in 2024, with a further £41 increase under review, disproportionately impacting essential workers.
Solution: The Home Office should lower visa and immigration fees to a fair level, ensuring they do not act as a barrier to recruitment. The IHS should be scrapped to prevent double payment for healthcare services. Immigration should be based on an analysis of the skills and expertise that our economy needs rather than the ability to pay and in a competitive market for skilled workers it is not in our interests to make the UK a less attractive destination. The Scottish Government consider that fees should be proportionate and based on cost.
Seasonal Agricultural Worker Visa
Problem: The Seasonal Worker visa is the only legal route for migrant workers in the UK’s horticulture sector, but annual visa allocations are set to decrease. Smaller producers may struggle with the costs of automation, risking disruption to Scotland’s agriculture, food, and drink sectors. Solution: The UK Government should ensure the number of visas issued meets seasonal demand and consider financial assistance for automation in the sector.
Health and Social Care Workforce
Problem: Health and Care Worker visa applications fell by 81% between May 2024 and January 2025, following the removal of dependent visas for care workers. Proposed changes to the IHS reimbursement scheme could exclude healthcare support staff, hospital administrators, and other essential non-registered roles. Solution: The Home Office should restore dependent visas for care workers in Scotland to improve recruitment and retention. The Department of Health and Social Care should ensure IHS reimbursement covers all frontline health and care workers, regardless of registration status.
Universities, Higher Education, and Research Sectors
International Student Numbers
Problem: The number of EU students at Scottish universities has dropped by 81% since 2016, from 4,625 to 880, due to Brexit and changes in fee support. Non-EU international student numbers increased to 70,840 in 2022/23, but recent UK immigration restrictions risk making the UK a less attractive destination – the impact of these restrictions has been seen in recent data. The College sector has expressed concern that the study visa does not recognise the changing delivery model for the sector, making it more difficult for them to recruit and retain international students.
Solution: The UK Government should reconsider the ban on dependants for most international students studying in Scotland, in order to maintain Scotland’s appeal as a global education hub. Visa policies should support international students who contribute to Scotland’s economy and research excellence and should align with the delivery model for the sector.
International Graduate Retention
Problem: Scotland faces long-term skills shortages and population challenges. We know that many international graduates want to stay in Scotland, and they have the skills and expertise that employers need. However, there is concern that the recent increase in the Skilled Worker Visa salary threshold makes it difficult for international students to stay in Scotland. There is a risk that individuals will either leave the UK or leave Scotland for London, thus increasing the geographic imbalance within the immigration system.
Solution: The UK Government should enhance post-study work visa opportunities, such as the proposed ‘Scottish Graduate Visa’, to better enable international graduates to stay and contribute to Scotland’s workforce. Our engagement with the sector and with international students suggest that providing individuals with more time to enable them to reach the salary threshold for the Skilled Worker Visa is key to enabling them to stay in Scotland. We have proposed an additional 2-year visa, focused on graduates in Scotland, to bridge the gap between the Graduate Visa and the Skilled Worker Visa. This will enable students to see a pathway to a Skilled Worker Visa, and linking it specifically to a Scottish tax code would ensure that people stayed in Scotland making a positive fiscal contribution to public finances and to our economy. Collaboration between universities, colleges, and employers should be supported to integrate graduates into key sectors facing shortages.
International Research
Problem: Scotland is a world leader in research, with nearly one-third of its research directly supporting the UN’s Sustainable Development Goals. Increasingly restrictive immigration policies risk hindering international collaboration. In 2022/23, 49% of research staff at Scottish universities were non-UK nationals, making them vital to research success.
Solution: The UK Government should ensure visa policies attract and retain top international researchers, supporting Scotland’s position as a leader in global innovation. Immigration rules should facilitate international research partnerships to drive solutions to global challenges.
Research and Innovation
Problem: International researchers struggle to commercialize their work due to limited visa options, with the Innovator Founder visa having a success rate below 30%. Universities, which previously endorsed researchers for visas, can no longer do so, creating further barriers.
Solution: The UK Government should reinstate universities as endorsing bodies for the Innovator Founder visa to support high-growth start-ups.
Cultural Mobility and Touring Artists
Problem: The end of free movement and lack of mobility agreements in the UK-EU Trade and Cooperation Agreement (TCA) are damaging Scotland’s cultural sector. Increased costs, administrative burdens, and legal confusion are preventing creative professionals from touring and collaborating internationally.
Solution: The UK Government should negotiate new mobility arrangements with the EU to allow artists and performers to travel and work freely.
Youth Mobility
Problem: The end of freedom of movement has reduced opportunities for young people to live, work and study in other countries. The Scottish Government has long advocated that better opportunities should be created for young people to enjoy the opportunities offered by mobility, including the opportunities to live, work and study in other countries.
Solution: The UK Government should respond positively to the Commission’s initiative and seek to secure an agreement which will provide enhanced opportunities for young people. There is strong public support for a UK/EU youth mobility visa agreement.
Family Visas
Problem: The current rules on the family visa both in relation to the narrow definition of family and the financial thresholds are preventing those entitled to live in Scotland from having their family members living with them. This results either in family separation or individuals not being able to live in Scotland.
Solution: The UK Government should review their definition of immediate family to bring it into line with the entitlement to bring family members to the UK for those with Settled Status through the EU Settlement Scheme. Scottish Government has produced detailed evidence of the impact of the current financial threshold for the family visa in Scotland which we have submitted to the Migration Advisory Committee.
Address Exploitation and Abuse in the Immigration System
Problem: Certain routes within the current immigration system place migrants at risk of exploitation.
Solution: The Scottish Government is clear that migration policy should support fair work, protect workers’ rights, pay and access to employment and prevent exploitation and abuse. Making an individual’s right to stay in the UK entirely dependent on their employer creates a distorted power dynamic. The UK Government should review the Seasonal Worker and Health and Care Visa routes to consider whether there are sufficient safeguards in place to protect individuals from exploitation and abuse. Individuals should be provided with clear information about their rights both before and after arrival in the UK.
Home Office data sharing with Devolved Governments
In engagement with the Home Office, the topic of immigration data is regularly raised, but there have been limited improvements in the willingness of the Home Office to share this data.
Better access to Scotland-specific immigration data would enable the Scottish Government to better understand and respond to the immigration landscape within Scotland.
Data sharing / Scotland’s Migration Service
Scotland’s Migration Service supports people to move to and settle in Scotland. It also supports Scotland-based employers and inward investors to use the immigration system in order to hire international workers and grow their businesses. The Service therefore contributes to efforts to grow the Scottish economy, maximise our existing talent pool, and attract more individuals to Scotland to address skills shortages and demographic challenges.
Scotland-specific immigration data would greatly assist the Scotland’s Migration Service team in promoting the service to target user groups and assessing the Service’s efficacy. This would help to drive best value for public money, to the benefit of the UK as a whole.
Specifically, the Scotland’s Migration Service team would benefit from access to data in relation to:
- How many people with a home address in Scotland applied for a new visa or an extension (broken down by visa type).
- How many visas (new visas and extensions) were granted to people with a home address in Scotland (broken down by visa type).
- The number of Scotland-based organisations which applied for a sponsor licence (broken down into the different sponsor licence types).
- The number of Scotland-based organisations which hold a sponsor licence (there is a register available at Register of licensed sponsors: workers - GOV.UK (www.gov.uk) but it’s not easy to filter by location).
Immigration system feedback from Scotland’s Migration Service Delivery Partners
The service is delivered by two operational delivery partners: Citizens Advice Scotland and a law firm called Seraphus. These partners have shared the following feedback with Scottish Government, based on the experience of service users:
Seraphus
The UK lacks a visa route for self-employed workers. This is compounded by broader challenges Scottish employers face, particularly the high salary thresholds associated with the Skilled Worker visa, which is not reflective of average wages employers can offer and different economic conditions that exist in Scotland.
Employers, particularly smaller and medium businesses and those in rural areas, often find it difficult to meet sponsorship requirements or justify the costs and administrative challenges involved. This presents a structural disadvantage for Scotland employers in attracting and retaining international talent.
Solution: Introduce greater regional flexibility in the immigration system to support Scottish businesses, and also help address demographic challenges and skill shortages, particularly in sectors and regions that do not align with London-centric wage expectations. This could include:
- Exploring a dedicated visa route for self-employed or freelance workers;
- Revisiting and adapting the former Start-up or Innovator visa routes to better serve regional economies; and
- Introducing regionally adjusted salary thresholds that reflect local economic realities, ensuring that employers in Scotland and other parts of the UK are not unfairly excluded from accessing international talent.
Citizens Advice Scotland
Problem: Many employers are unwilling to sponsor international workers due to high costs and administrative obligations. The 60-day visa curtailment period is too short, which does not give skilled individuals enough time to secure new employment. This results in them leaving the UK, taking their valuable skills and experience elsewhere.
Solution: The Home Office should extend visa curtailment periods. It should adjust salary thresholds and sponsorship fees to make it easier for businesses to hire international workers.
Right to work
Problem: The safe and legal routes available for people to seek safety in the UK are insufficient. This only supports the business model of human traffickers who exploit people forced to flee their homes due to war or persecution. For those who can claim asylum, slow decision making and harsh restrictions on individual’s ability to earn while they are await a decision on their future hampers their ability to rebuild their lives and contribute their skills to the economy.
Solution: The Home Office should increase the availability of safe and legal routes like the Displaced Talent Mobility pilot, or visa routes like the British Nationals Overseas visa which give people the opportunity to use their skills and contribute to the economy while recognising the need for additional support as a result of their circumstances. There should also be flexibility within the system to allow those who need protection to have the ability to use their skills and rebuild their life here. This should include meaningful engagement and consideration of the proposals by the Scottish Government and other stakeholders in the UK on providing Asylum seekers the right to work and increasing access to available safe and legal routes. The Asylum process should not risk pushing people into destitution as a result of restrictive conditions.
Contact
Email: migration@gov.scot