
The Home Office has quietly published a 110-page consultation document outlining the most radical overhaul of permanent residence rules since the points-based system was introduced 17 years ago. Branded “earned settlement”, the blueprint would replace the largely automatic five-year qualifying period for Indefinite Leave to Remain (ILR) with a baseline of ten years, modifiable up or down according to a migrant’s ‘character, integration, contribution and residence’.
Under the draft matrix, high earners paying UK tax on at least £125,140 for three consecutive years could fast-track to ILR in as little as three years, whereas visa-holders with minor rule breaches—or periods claiming public funds—could face waits of up to 30 years. A higher B2 English-language requirement and a mandatory Life in the UK test would apply to all economic migrants.
The consultation, open until 12 February 2026, explicitly states it will apply retrospectively, meaning the roughly 900,000 people already on work and study routes that lead to settlement will have their clocks reset unless they qualify under the limited transitional arrangements. That prospect is triggering particular concern in sectors such as social care and hospitality, which rely on lower-paid roles that are unlikely to meet the new economic-contribution thresholds.
For employers, the immediate action points are to audit sponsored staff approaching the five-year mark, model salary uplifts that might accelerate settlement under the new rules, and decide whether to bring forward ILR applications before the new regime goes live—potentially as early as April 2026. With net migration projected to fall by 90,000 per year under the plan, in-house mobility teams should also review long-term workforce strategies and consider alternative immigration categories such as the Global Talent route.
Although some aspects—such as tougher criminality checks—enjoy cross-party support, business groups led by the CBI and techUK have warned that retrospective changes could damage investor confidence. The Home Office has indicated it is open to “targeted refinements” based on consultation feedback, making corporate submissions vital in the coming weeks.
Under the draft matrix, high earners paying UK tax on at least £125,140 for three consecutive years could fast-track to ILR in as little as three years, whereas visa-holders with minor rule breaches—or periods claiming public funds—could face waits of up to 30 years. A higher B2 English-language requirement and a mandatory Life in the UK test would apply to all economic migrants.
The consultation, open until 12 February 2026, explicitly states it will apply retrospectively, meaning the roughly 900,000 people already on work and study routes that lead to settlement will have their clocks reset unless they qualify under the limited transitional arrangements. That prospect is triggering particular concern in sectors such as social care and hospitality, which rely on lower-paid roles that are unlikely to meet the new economic-contribution thresholds.
For employers, the immediate action points are to audit sponsored staff approaching the five-year mark, model salary uplifts that might accelerate settlement under the new rules, and decide whether to bring forward ILR applications before the new regime goes live—potentially as early as April 2026. With net migration projected to fall by 90,000 per year under the plan, in-house mobility teams should also review long-term workforce strategies and consider alternative immigration categories such as the Global Talent route.
Although some aspects—such as tougher criminality checks—enjoy cross-party support, business groups led by the CBI and techUK have warned that retrospective changes could damage investor confidence. The Home Office has indicated it is open to “targeted refinements” based on consultation feedback, making corporate submissions vital in the coming weeks.







