How Employers Are Preparing for the New Temporary Shortage List?

Employers Are Preparing for the New Temporary Shortage List by reassessing how they manage their workforce and long-term recruitment needs. Across the UK, businesses are taking a closer look at the way they recruit, train, and retain staff to remain resilient in a shifting labour market. For many, this means reviewing job roles, updating sponsor licences, and aligning job descriptions more carefully with immigration requirements. Others are turning attention to domestic recruitment and upskilling, ensuring that existing employees can grow into positions that may be harder to fill from overseas. The changes are prompting employers to balance short-term staffing needs with longer-term strategies that strengthen their workforce for the future.

What is the Temporary Shortage List?

The Temporary Shortage List (TSL) is part of the UK government’s updates to the Skilled Worker visa system. It was published on 22 July 2025 and sets out jobs at skill levels RQF 3–5 (below degree level) that are in genuine shortage. Employers can sponsor overseas workers in these roles, but only under specific rules.

The TSL sits alongside the Immigration Salary List (ISL), which covers higher-skilled jobs (degree level and above, RQF 6+). Both lists will stay in place until 31 December 2026, when the Migration Advisory Committee (MAC) will review them and decide which roles should remain on a permanent shortage list.

Key points to note:

• Employers must use the correct SOC 2020 job codes. Only roles listed in the official Appendix Skilled Worker and matched to the TSL are eligible.
• The salary threshold is higher. Jobs below degree level must pay at least £23,200, or meet 100% of the official “going rate” for that role, whichever is higher.
• Workers in these roles generally cannot bring dependents with them under the TSL rules.

The Regulatory Shift: Why It Matters?

Why are these changes significant for employers?

1. Skill threshold rise: The Skilled Worker visa route now requires most new roles to be RQF Level 6 (degree level). Only roles on the Temporary Shortage List can be at RQF 3–5. This means many roles that were previously eligible will no longer be, unless included in the TSL.
2. No salary discounts: Under the TSL, the previous percentage salary discounts available under older schemes are not generally in use. Employers must pay at least the full going rate for the role.
3. Time-limited access: The list is temporary, with a sunset date of 31 December 2026. Occupations may be removed earlier if conditions change, or if there is non-compliance by employers or sectors. Employers must plan for potential delisting.
4. Focus on domestic workforce and training: The government expects employers in sectors using the TSL to invest in domestic recruitment, training, and retention. Workforce strategy plays a central role in whether occupations are maintained on the list after the MAC reviews.

What Employers Need to Do?

With these changes in effect, employers across sectors are making preparations to adapt. Here are some of the main steps businesses are taking in employer shortage list preparation.

1. Audit existing sponsored roles & job descriptions

• Review all roles currently sponsored under the Skilled Worker route to determine whether they are still eligible under the new rules. This means checking if they fall under RQF 6+ or are on the TSL for RQ 3–5 roles.
• Re-examine job descriptions to ensure that the duties, qualifications, and responsibilities clearly align with the SOC code associated with the TSL listing. Inaccuracies or mismatches can lead to compliance issues.
• Update contracts and documentation to reflect changes in required qualifications, working hours, and salary (pro rata if part-time) to meet the going rate requirements.

2. Review Sponsor Licence status and compliance

• Ensure that your organisation has a valid Skilled Worker sponsor licence. If not, apply early. If you already hold one, verify all compliance obligations are being met: record-keeping, reporting changes in job duties or salaries, right-to-work checks.
• Update internal HR and immigration teams on the new rules and ensure that they are trained in how to use the proper occupation codes and calculate salary requirements.
• Document all decisions made, particularly where roles are retained under TSL, to have evidence should there be Home Office audits.

3. Workforce Planning: Domestic Recruitment & Upskilling

• Invest in local training and apprenticeship schemes to reduce dependency on overseas workers, especially for roles that are on the Temporary Shortage List.
• Collaborate with colleges, universities, or training providers to ensure that skills relevant to TSL roles are being taught domestically.
• Retention strategies are more important when recruiting: ensure that your workplace offers competitive pay, progression, and stability to keep employees long-term.

4. Financial Planning and Budgeting

• Factor in higher salary costs — since the role must meet the going rate without previous discounts for many roles.
• Budget for Certificate of Sponsorship (CoS) costs, Immigration Skills Charge (if applicable), visa application fees, and any legal or advisory costs.
• Plan for possible changes if a TSL role is removed from the list: have contingency plans such as domestic recruitment, automation, or role redesign.

5. Communication & Internal Policy Updates

• HR departments should inform managers, department heads, and recruitment teams about the changes so all job adverts, skill expectations, and hiring practices are in line with the TSL and Skilled Worker rules.
• Update job adverts to include the correct SOC code, required qualifications, salary terms, and any TSL-specific requirements.
• If relying on overseas recruitment, ensure that team members understand the limitations, e.g. no dependants for many TSL roles.

6. Monitor Government Updates

• Keep track of MAC reviews to see which occupations stay or are removed.
• Watch for changes in salary thresholds, going rates, or rules related to dependents or settlement eligibility.
• Be alert to adjustments in the Temporary Shortage List itself: roles may be added or removed.

Challenges Businesses Are Facing

In preparing for the TSL, many employers are encountering obstacles:

• Role eligibility uncertainty: Some roles that were previously eligible are now excluded, meaning firms must decide whether to restructure or drop certain job functions.
• Finding domestic talent: Training and recruiting from the local workforce takes more time and effort, especially in sectors with historically low uptake.
• Cost pressures: Higher salary obligations and visa-related costs are putting strain on smaller employers.
• Compliance risk: Mistakes in SOC codes, misalignment of job description vs actual duties, or inadequate documentation may lead to licence revocations or fines.

Sectors Most Affected & Examples

Some sectors are particularly affected by the TSL rules:

• Technicians in various fields (engineering, IT support, electronics) are heavily represented on the Temporary Shortage List. Employers in manufacturing, tech, and engineering are already redesigning their recruitment strategies.
• Logistics and operations management roles are included; businesses in transport, warehousing, and distribution are adjusting.
• Creative & design sectors have some roles under the TSL (e.g. designers, translators) and are assessing whether overseas recruitment remains viable or how to build domestic pipelines.

What Employers Should Plan for Moving Forward?

• Develop contingency workforce strategies so that if a role is removed from the TSL, the business can transition to domestic hiring or reassign tasks.
• Engage in long-term skills development, including apprenticeships and reskilling programmes in sectors where labour shortages persist.
• Build partnerships with training providers and local authorities to anticipate future roles likely to be affected.
• Keep immigration-related processes and record-keeping sharp to avoid delays or rejections in sponsoring workers.

Conclusion!

The Temporary Shortage List isn’t just a policy update — it’s a signal for employers to rethink how they approach recruitment and compliance. Those who stay ahead will find themselves better placed to manage workforce needs and reduce risk.

As the new rules bed in, the real advantage will belong to businesses that adapt early and keep their processes sharp. For more insights and practical updates on navigating Skilled Worker rules, follow Skilled Worker Mag.