IMPACT – HIGH

What is the change? Ireland and the U.K. have confirmed that the U.K.-Ireland Common Travel Area will remain, regardless of the outcome of the U.K. Parliament’s Brexit negotiations.

What does the change mean? The CTA will continue to allow Irish and British nationals to travel, live and work in the U.K. and Ireland in the case of a no-deal Brexit. 

  • Date of Memorandum of Understanding: May 8.
  • Who is impacted: British and Irish nationals working and living in the U.K. and Ireland. British and Irish nationals travelling to and from U.K. and Ireland.
  • Impact on business: The deal is good news for companies as the above-mentioned employees will be able to reside, work and study as they currently do under the CTA.

Background: The CTA provides reciprocal rights to Irish citizens and U.K. citizens to travel, study, work and reside in each other’s country on the basis of their passport and without further immigration processing, such as work or residence permit procedures. The memorandum of understanding signed last week noted that the “CTA and associated reciprocal rights and privileges existed long before either Ireland or the UK were members of the European Union” and that “the privileges which Irish and British citizens enjoy (under the CTA) are separate from, and therefore not dependent on, EU citizenship or EU membership.”

Analysis & Comments: The memorandum affirms that Irish and U.K. nationals will continue to enjoy the privileges they have under the CTA, regardless of the Brexit outcome, and ensures that companies will be able to continue employing the affected nationals as before Brexit.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – HIGH

The Migration Advisory Committee (MAC) has released its report and recommendations on the Shortage Occupation List.

The report recommends a substantial expansion of the SOL to include a broader range of jobs in health, information technology and STEM fields. The recommendations would expand the SOL from 1% of total jobs (180,000 workers) which it currently covers, to about 9% of all jobs (around 2.5 million workers).

The SOL is the list of skilled jobs for which local workers are deemed to be in shortage and for which employers may hire non-EEA workers without labor market testing and without being subject to the numerical cap on Tier 2 (General) visas if the category is oversubscribed. Non-EEA workers filling jobs on the SOL also pay lower visa fees and are not required to meet the salary threshold of £35,800 for permanent residency (settlement) after five years.

The MAC makes the following recommendations:

  • As soon as possible, the U.K.-wide SOL should be expanded to include numerous additional job titles, particularly in science, medicine and IT. Among the additions, all jobs in the following occupational categories should be added:
    • Programmers and software developers
    • IT business analysts, architects and systems designers
    • Web design and development professionals
    • Civil, mechanical, electrical or electronical engineers
    • Design and development engineers
    • Production and process engineers
    • Medical practitioners
    • Veterinarians
    • Quality control and planning engineers
    • Architects

The complete list of recommended SOL jobs is available in the MAC’s full report.

  • Scotland, Northern Ireland and Wales would benefit from the recommended expansion of the U.K.-wide SOL rather than adding job titles to their individual SOLs. To address labor shortages in remote communities, a pilot program could encourage long-term immigration into these areas.
  • When the details of the future U.K. immigration system (post-Brexit) are clearer, the role of the SOL should be studied to determine whether it is still needed or if there are new ways to give preferential treatment to shortage occupations, such as a faster path to permanent residency. The SOL should be studied because the government has already agreed to adopt the MAC’s earlier recommendations to abolish the Resident Labour Market Test and the cap on Tier 2 (General) visas—two of the main advantages of the SOL that would no longer exist under the new immigration system.

Background: On June 14, 2018, the government commissioned the MAC to undertake a full review of the SOL and issue a report with recommendations by spring 2019. The MAC launched a Call for Evidence on Nov. 9, 2018 and accepted comments for nine weeks, as well as conducting stakeholder events. The committee received approximately 600 responses.

The MAC is an independent group of economists that conducts analysis and makes recommendations to the U.K. government on immigration policy. Its policy recommendations are not binding on the government, but are highly influential and often adopted.

Analysis & Comments: The MAC’s recommended expansion of the Shortage Occupation List would be a welcome development to ease the labor shortages currently felt by U.K. companies. In particular, the MAC found that the jobs most in shortage are programmers and software development professionals, and the shortage of these workers affects not only the digital sector but businesses in sectors across the board.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – MEDIUM

What is the change? The United Kingdom has expanded access to eGates to nationals of Australia, Canada, Japan, New Zealand, Singapore, South Korea and the United States.

What does the change mean? Nationals of these seven countries will be able to use automated self-service gates at 15 international airports in the U.K. and two Eurostar terminals in Brussels and Paris. They will also not be required to fill out a landing card when entering the U.K.

  • Implementation time frame: Immediate and ongoing. The change was implemented Monday
  • Processes affected: Entry into the U.K. at 15 U.K. airports and two Eurostar terminals.
  • Who is affected: Nationals of Australia, Canada, Japan, New Zealand, Singapore, South Korea and the United States. The eGates remain available to EU/EEA nationals and Registered Traveller Service members. Travelers must be at least 12 years old and have a biometric passport to use eGates. Travelers who need a stamp in their passport must get their passport stamped by a Border Force officer upon arrival in the U.K.
  • Additional information: Travelers from Australia, Canada, Japan, New Zealand, Singapore, South Korea and the United States will no longer require a stamp in their passport unless they are (1) coming for short-term study, (2) have a Tier 5 Creative and Sporting certificate of sponsorship, (3) are traveling to carry out permitted paid activities or (4) are a family member of an EEA national seeking to join them in the U.K. Additional information is available here.

Analysis & Comments: Monday’s expansion of access to eGates marks the first time the self-serve terminals will be available to non-EU/EEA nationals. Nationals of Australia, Canada, Japan, New Zealand, Singapore, South Korea and the United States will enjoy easier entry procedures when traveling to the U.K.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – MEDIUM

Biometric enrollment services are currently suspended for U.K. visa applicants at USCIS Application Support Centers.

Key points:

  • VFS Global, U.K. Visa and Immigration’s official visa application processing partner, posted a message to its website that says that visa applicants with ASC appointments should check for updates here before traveling to an ASC for any scheduled appointments.
  • Applicants who miss an appointment because of the suspension will be permitted to complete biometrics enrollment at an ASC on a walk-in basis once services are restored.
  • Normal U.K. visa services are available at 10 U.S. VFS Premium Application Centres, though additional charges will apply at these locations.

Analysis & Comment: Little information is available about what caused the suspension, but the statement on VFS Global’s site says said officials are working “to restore service as soon as possible.” Depending on the urgency of travel plans, applicants may wish to complete biometrics enrollment for an additional charge at one of the VFS application centers. Those affected are encouraged to contact their immigration provider to discuss their best options.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – HIGH

What is the Brexit news? The Swiss Federal Council has approved a bilateral Swiss-U.K. agreement that will administer the status of U.K. nationals in Switzerland and Swiss nationals in the U.K.

What does the news mean? The effective date of the agreement depends on the outcome of negotiations between the EU and the U.K.

  • If a deal is reached, the Swiss-U.K. agreement will enter into force after the transition period ends on Dec. 31, 2020.
  • If no deal is reached, the Swiss-U.K. agreement will enter into force on March 30, 2019.

Key points of the Swiss-U.K. agreement:

  • Work authorization. U.K. nationals registered in Switzerland and Swiss nationals registered in the U.K. before the Swiss-U.K. agreement goes into force, as well as their dependents, will preserve their status under the EU-Swiss Agreement on the Free Movement of Persons (FMOPA).The agreement also covers cross-border workers in both countries, such as G-permit holders working in Switzerland.
  • Permanent residence. U.K. nationals already residing in Switzerland and Swiss nationals already residing in the U.K. will remain eligible for permanent residence after five years of legal residence, as under current rules.
  • Post-Brexit arrivals. Dependents of U.K. and Swiss nationals already residing in their respective host country who arrive after the Swiss-U.K. agreement goes into effect will also fall under the scope of the FMOPA. U.K. and Swiss nationals who arrive in their respective host country after the effective date will require work authorization possibly involving labor market testing and a residence permit. In Switzerland, the entry and exit of U.K. nationals and their family members will be regulated by the Schengen rules.

Background: While many EU member states are currently establishing unilateral measures to protect U.K. citizens’ rights under a no-deal Brexit, Switzerland must take a bilateral approach to its Brexit planning, as the country’s immigration regime does not fully fall under EU mobility regulations. Switzerland is not part of the EU but is a member of Schengen, a peculiarity which distinguishes Switzerland’s immigration regime from that of its European neighbors.

Switzerland has established various bilateral agreements that support free movement to and from the country. Currently, relations between the U.K. and Switzerland are governed by FMOPA. After Brexit, the U.K. will no longer be an EU member and the agreement will not cover U.K. citizens.

Analysis & Comments: The agreement, if ratified by both countries, will provide some certainty to employers as well as to U.K. and Swiss nationals residing in each other’s country. While some post-Brexit and post-transition procedures remain unclear, it is likely that employees will be able to continue working and residing in their respective host country based on their current status. Employers should ensure that sufficient preparation is afforded to those nationals who will require work and residence permit in a post-Brexit scenario.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – HIGH

The U.K. government has now confirmed that in the event of a “no deal” Brexit:

  • EU nationals will be able to travel to and enter the U.K. using a biometric passport or ID card on the same terms as they currently do, including using e-gates, during a transition period until Dec. 31, 2020.
  • To achieve a frictionless border, EU nationals passing a security check will automatically be given three months’ “leave to enter” the U.K. at no cost. (Multiple entries would also be possible, as is currently the case with visitors from visa-waived countries such as the United States).
  • Non-EEA family members will need to apply for a family permit prior to travel to the U.K., as they currently do.
  • EU nationals wishing to remain in the U.K. for more than three months must apply for a new type of permit—European Temporary Leave to Remain, or ETLR—and will be required to pay a (currently undetermined) fee.
  • ETLR will be a temporary, non-extendable visa that has no skill level or salary requirement and is available for 36 months only. Time spent in this status will not count toward an application for indefinite leave to remain.
  • The ETLR application must be made online, and migrants will be asked to prove their identity with a passport or ID card and declare any criminal convictions. Serious and persistent offenders or threats to national security may be refused.
  • EU nationals due to remain in the U.K. for more than three years will need to apply for a further visa once the U.K.’s new skills-based immigration system is launched on Jan. 1, 2021.
  • Not all EU nationals who hold ETLR will necessarily qualify under the new system, as employer sponsorship, minimum salary and skills levels will apply.
  • Those EU nationals already living in the U.K. as of March 29, 2019 will have until Dec. 31, 2020 to apply under the EU Settlement Scheme for “settled status.”
  • Employers will not be asked to distinguish whether EU nationals were resident before or after Brexit. There will be no significant changes to the right-to-work regime, meaning that EU nationals’ right to work will continue to be based on their passport or national identity card alone. Employers will only need to check new EU employees’ status starting Jan. 1, 2021 once the new skills-based system is launched, and will not need to check existing employees retrospectively.

In the alternative, in the event that the Withdrawal Agreement (“the deal”) is ratified:

  • EU nationals will be able to travel to and enter the U.K. using a biometric passport or ID card on the same terms as they currently do during a transitional period until at least Dec. 31, 2020.
  • EU nationals arriving in the U.K. after Jan. 1, 2021 must apply for a visa prior to travel under the U.K.’s new skills-based immigration system (details of which should be confirmed by December 2019).
  • EU nationals living in the U.K. as of Dec. 31, 2020 will have until June 30, 2021 to apply under the EU Settlement Scheme for “settled status” or “pre-settled status.”

It is important to note that in any scenario, Irish nationals will continue to have the right to enter and live in the U.K. under the Common Travel Area arrangements which pre-date the European Union, and will not need to apply under either the EU Settlement Scheme or for European Temporary Leave to Remain. Moreover, the rules for EU nationals will be applied equally to nationals of EEA countries (Norway, Iceland and Liechtenstein) and to Switzerland.

Analysis & Comments: Employers have known for weeks that, whether or not there is a deal, the EU Settlement Scheme will protect EEA nationals living in the U.K. prior to March 30, 2019. However, the position for new assignees arriving in the U.K. post-Brexit has been unclear until now. Employers are only now in a position to conduct thorough no-deal planning that takes into account the position for both current and future employees from the EU, EEA and Switzerland. This latest announcement confirms that new migrants, while allowed entry to the U.K. on the same terms and at no cost, will have to obtain a temporary visa with a fee in order to stay beyond three months. If they are staying more than three years, they would then need to follow with an application under the U.K.’s new single immigration system once it is launched. Employers must therefore factor in increased costs and process requirements for EU, EEA and Swiss nationals in the short term should “no deal” prevail, and amend recruitment strategies accordingly.

In the event of no deal, employers will for the first time have two sets of Europeans in their workforce: those with residency rights (which may or may not be registered under EU Settlement Scheme) and those with temporary permission to live and work in the U.K., the ETLR permit holders. However, the fact that right-to-work checks will continue to be based on passports, ID cards, and biometric residence cards alone means that employers should not have to adapt right-to-work checks at short notice.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

What is the change? The U.K. government has announced plans to scrap all fees for EU nationals and their family members applying to register their residence in the U.K. under the EU Settlement Scheme. Registration under the scheme will now be free.

Key points:

  • The EU Settlement Scheme opened to the general public during an expanded pilot phase starting on Jan. 21, 2019.
  • EU nationals with a biometric passport, or family members with a biometric residence card, can now apply to register their residence in the U.K. using an online app (although the scheme will not be fully open for assisted applications until Mar. 30, 2019).
  • The elimination of fees will require a legal change to the immigration rules to go through Parliament over the coming week, and therefore the change will not be effective immediately.
  • Fees paid since the scheme opened on Aug. 28, 2018 will be refunded in due course.
  • Applications made over the coming days may still require payment, but the fee will also be refunded in due course.

As a reminder, under the EU Settlement Scheme:

  • Those with five years of residence or longer in the U.K. will be granted “settled status” and a right to a permanent stay in the U.K.
  • Those with less than five years of residence will receive “pre-settled status” with an option to reregister as “settled” in due course after Brexit.
  • EU Settlement Scheme applications are not mandatory at this stage.
  • By choosing to apply from Jan. 21, EU national applicants will provide valuable insight into the system’s functions and allow adaptions to be made prior to full launch on Mar. 30, 2019.
  • Applicants during this expanded test phase must use the EU Exit: Identity Document Check app, which is part of the integrated online application process, to prove their identity and then National Insurance Number records, or other official documents, to prove residence.

Analysis & Comments: Today’s announcement that the government will scrap fees for registration under the EU Settlement Scheme—£65 for adults and £32.50 for children—should be welcomed by employers and employees. Employers looking to support employees with EU Settlement Scheme applications should be ready for further questions about the scheme, especially regarding payments and refunds, and to amend any Brexit communications in light of this change once it is formally incorporated into the immigration rules.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – MEDIUM

What is the news? Starting Monday, the United Kingdom’s EU Settlement Scheme will open to the public for an expanded test phase for EU nationals in the U.K. to secure their residency rights.

Key points:

  • Starting Jan. 21, all EU nationals, as well as their non-EU citizen family members who hold a valid biometric residence card, will be able to register their citizens’ rights in the U.K. via the EU Settlement Scheme.
  • Under the EU Settlement Scheme:
    • Those with five years or more of residence in the U.K. will be granted “settled status” and a right to a permanent stay in the U.K.
    • Those with less than five years’ residence would receive “pre-settled status” with an option to re-register as “settled” in due course after Brexit.
  • EU Settlement Scheme applications are not mandatory at this stage.
  • By choosing to apply after Jan. 21, EU national applicants will provide valuable insight into the system’s functions and allow changes to be made prior to the full launch on March 30.
  • Applicants during this expanded test phase must use the EU Exit: Identity Document Check app, which is part of the integrated online application process, to prove their identity. They then must show National Insurance Number records or other official documents to prove residence.

Background: The U.K.’s EU Settlement Scheme was put into the U.K. immigration rules in August 2018, and has since been undergoing trials, initially with select universities and National Health Service trusts in northwest England, and then more widely in the NHS, with a full launch not expected until March 30. To date, 15,500 applications have been made, with 12,400 registrations completed, suggesting that the scheme is effective in delivering its aims (although a full report later this month should provide more details).

Analysis & Comments: This announcement means that the EU Settlement Scheme will be available to EU nationals in the U.K. sooner than many employers and employees expected. While registrations are voluntary, this announcement may encourage a surge of applications. In light of this updated timetable, employers looking to support employees with applications should be prepared to address further questions about the scheme in their Brexit communications and events for their employees.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – HIGH

What is the change? The immigration health surcharge required of non-EEA nationals is set to double from £200 to £400 per year (£150 to £300 per year for students and Youth Mobility Scheme applicants).

What does the change mean? Employers, non-EEA nationals and their family members intending to stay in the U.K. for longer than six months should budget for the sharp increase. The surcharge must be paid up front and in full for each individual and for the full term of the visa at the time of application.

  • Implementation time frame: Jan. 8.
  • Visas/permits affected: All visa applications for work, study or joining family for stays longer than six months in the U.K.
  • Business impact: Companies should prepare for the increased costs. Employers who pay the surcharge will not be reimbursed if the employment relationship ends before the full term.

Background: The immigration health surcharge, which was introduced in April 2015, requires non-EEA nationals to contribute to their use of the National Health Service while in the U.K. The surcharge was expanded to include Australia and New Zealand in April 2016 and to the Tier 2 (Intra-Company Transfers) subcategory in April 2017.

A government review found that doubling the surcharge could generate an additional £220 million per year for the NHS, and in early 2018 the government announced plans to implement the increase by the end of the year.

Analysis & Comments: The immigration health surcharge is a significant upfront cost for companies recruiting non-EEA workers and its doubling will be felt by business. Companies should budget for the additional costs associated with hiring and retaining foreign workers.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – MEDIUM

The United Kingdom has reached agreements on Brexit and citizens’ rights with Iceland, Liechtenstein and Norway (the ‘EEA EFTA states’), and, separately, with Switzerland.

The four countries are all part of Europe’s single market, but are not full members of the European Union and are therefore not covered by the EU Withdrawal Agreement and the U.K.’s EU Settlement Scheme. The U.K. now has three agreements on the table – the primary withdrawal agreement with the EU (which is awaiting a critical vote the week of Jan. 14), one with the EEA EFTA states, and one with Switzerland. The agreements largely offer the same levels of security on citizens’ rights.

Key Points:

  • If the EEA-EFTA agreement is signed, it would provide certainty for U.K. citizens living in Iceland, Liechtenstein and Norway, and citizens from these countries living in the U.K. The agreement would allow these people to live, work, study and access benefits on largely the same terms post-Brexit as they do now.
  • The agreement with Switzerland would provide certainty for U.K. citizens in Switzerland and Swiss citizens in the U.K. on generally the same terms.
  • In the event of a “no deal” Brexit, the citizens’ rights agreement with Switzerland would still apply. The U.K. also continues to seek separate “no deal” agreement with the EEA EFTA states.

Analysis & Comments: The agreements are welcome news for some 50,000 U.K. citizens living and working in Iceland, Norway, Liechtenstein and Switzerland, and roughly 30,000 EEA-EFTA and Swiss citizens in the U.K., as well as their employers. More will be known in the coming weeks about the consequences of “no deal” on the future of mobility between the U.K. and these countries.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.