In our April 2026 update, we considered the Government's significant Statement of Changes to the Immigration Rules and the emerging position on earned settlement. Since then, the pace of reform has continued, albeit with fewer headline announcements than many expected.
These reforms expand compliance obligations beyond traditional employment relationships and may require organisations to revisit their workforce engagement models, contractual arrangements and onboarding procedures. A further Statement of Changes has also been published by the Government, but ongoing uncertainty around the implementation of earned settlement reforms remains.
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