IMPACT – MEDIUM

What is the change? The United Kingdom has launched an electronic visa waiver for Kuwaiti business travelers and tourists.

What does the change mean? Kuwaiti nationals may apply online for a visa waiver without needing to appear at a visa application center. The waiver allows a visit to the U.K. of up to six months.

  • Implementation time frame: Immediate.
  • Visas/permits affected: Electronic visa waiver (EVW).
  • Who is affected: Kuwaiti passport holders visiting the U.K. for business, travel or study.
  • Impact on processing times: The process eliminates the need to give biometrics or to appear at a visa application center.
  • Business impact: The waiver eases travel to the U.K. for Kuwaiti business visitors conducting permitted business activities.
  • Next steps: Applicants must still apply online at least 48 hours before travel and up to three months prior to travel.

Background: The EVW was piloted for Kuwaiti nationals last year and has now been fully introduced. Applicants must submit an online application at the EVW service website and supply their passport information, a U.K. address where they will be staying, and departure and arrival details. They will not need to make a full visa application, nor give biometrics at a visa application center. An additional government processing fee of £15 will be introduced later in the year. According to the U.K. Immigration Minister, visitors from Kuwait topped 100,000 last year.

BAL Analysis: The online application and visa waiver eliminates the need to appear in person to apply for a visa and give biometrics, greatly easing business travel for Kuwaiti nationals.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The Home Office announced Thursday that the United Kingdom’s Immigration Health Surcharge will be extended to Australian and New Zealand nationals beginning April 6.

What does the change mean? Beginning April 6, Australian and New Zealand nationals applying to stay in the U.K. for more than six months will be subject to the same £200 per year surcharge as other non-EEA nationals. A discounted rate of £150 per year will be applied to those applying to come to the U.K. on student visas or through the Youth Mobility Scheme.

  • Implementation time frame: April 6, 2016.
  • Visas/permits affected: Tier 1, Work visas under Tier 2 (General) sponsorship, Tier 4 (student) and Tier 5 visas.
  • Who is affected: Australian and New Zealand nationals applying to work or study in the U.K. for longer than six months.
  • Impact on processing times: The surcharge will not lengthen processing times, but applicants must pay the surcharge before their visa or extension applications will be processed. Any error in the payment could slow processing.
  • Business impact: The surcharge will increase the costs for employers sponsoring Australian and New Zealand employees under the Tier 2 (General) route in the U.K.

Background: The U.K. introduced mandatory health surcharges for most non-EEA visa applicants in April of 2015. Australian and New Zealand nationals were granted an exemption that will expire on April 6.

The Home Office says the fees are designed to ensure that the National Health Service “receives a fair contribution to the cost of healthcare from temporary migrants.” To date, the surcharges have contributed more than £100 million to the NHS. Migrants who pay the surcharge generally have access to free health care, but may be charged for some services, including dental care and prescriptions.

EEA nationals do not have to pay the surcharge. Non-EEA nationals who stay in the U.K. for less than six months are not required to pay the surcharge either, but must pay out of pocket for medical services they do receive. Under reciprocal agreements, Australian and New Zealand nationals who stay in the U.K. for less than six months will not be charged if they require health services that must be provided before they can return home.

BAL Analysis: Australian and New Zealand visa applicants should plan for the levies and be sure that the health surcharge is paid at the time of their application and covers their entire length of stay. The U.K.’s recent Migration Advisory Committee (MAC) report recommended an expansion of the Immigration Health Surcharge scheme in 2016, including extending it to intra-company transferees. BAL will report further expansions of the scheme as soon as they are made public.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The U.K. government’s new policy that requires landlords to check tenants’ right to rent is now in effect across England.

What does the change mean? All private landlords who are renting, subletting or taking in lodgers must check the papers of new adult tenants to make sure they have the right to live in the U.K.

  • Implementation time frame: The policy took effect Feb. 1 for all of England. It has been in effect as a pilot program in West Midlands since December 2014.
  • Visas/permits affected: All visas, travel documents and other evidence of immigration status.
  • Who is affected: Private landlords in England and all temporary migrants, permanent residents and British citizens seeking to rent in England.
  • Business impact: Employers who are renting on behalf of foreign employees may agree to a “tenancy in principle” before the employee arrives in the U.K., and the landlord would conduct a check of the right to rent when the employee arrives.
  • Next steps: Landlords should be familiar with the list of documents that prove right to rent, and foreign employees and assignees should be aware that they will have to present their passport, visa or other proof of right to rent.

Background: The U.K. government has published a user guide that details and depicts the various forms of acceptable evidence of right to rent. Foreign nationals holding temporary documents, such as travel vignettes, will be rechecked once the biometric residence permit is issued. Landlords are advised to make and keep copies of the documents, as they will have a statutory safe harbor if it is later found that they rented to someone who didn’t have the right to rent. Landlords face fines of up to £3,000 per tenant for failing to perform the checks.

BAL Analysis: The policy adds an administrative burden on property owners to understand the various immigration statuses and documents and to recognize fraudulent documents. Foreign nationals who have a pending application with the Home Office or whose identity documents are being held by the Home Office during processing may have to wait for the landlord to request a right to rent check by the Home Office and allow two days for a response.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The United Kingdom has expanded its Registered Traveller program to travelers from Hong Kong (SAR), Singapore, South Korea and Taiwan.

What does the change mean? Eligible travelers do not need to fill out a landing card and may use fast lanes at U.K. airports. Individuals holding biometric passports may use ePassport gates.

  • Implementation time frame: Immediate.
  • Visas/permits affected: Registered Traveller program.
  • Who is affected: Travelers holding passports from Hong Kong (SAR), Singapore, South Korea and Taiwan.
  • Impact on processing times: The program expedites border procedures.
  • Business impact: Frequent business travelers to the U.K. benefit from the service.
  • Next steps: Interested travelers may apply online.

Background: Applicants must be at least 18 years old and have a visa to the U.K. or have visited the U.K. at least four times in the last two years.

Registered Travellers may use U.K. and EU entry lanes and ePassport gates at Birmingham, East Midlands, Edinburgh, Gatwick, Glasgow, Heathrow, London City, Luton, Manchester and Stansted airports, as well as Eurostar train terminals at Paris, Brussels and Lille.

Other countries already in the program are Australia, Canada, Japan, New Zealand and the United States.

BAL Analysis: The U.K. continues to expand the Registered Traveller program – a convenient option for frequent travelers that also reduces queues at airports overall by diverting low-risk travelers to automated entry clearance gates.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – HIGH

What is the change? The Migration Advisory Committee has released a much-awaited report, recommending significant changes to Tier 2 visa categories for migrant workers.

What does the change mean? Among the changes, the committee recommended that the government raise minimum salary thresholds for Tier 2 (General) and Tier 2 (ICT), extend the Immigration Health Surcharge scheme to all intra-company transfers (ICTs), impose a new “Immigration Skills Charge” on employers across nearly all Tier 2 categories, and set up a separate route for third-party contracting of Tier 2 ICTs. The changes would make employing migrants, including assignees, significantly more difficult and expensive.

  • Implementation time frame: The government will review the report and is likely to introduce reforms by April 5, the date immigration rule changes typically come into effect.
  • Visas/permits affected: Tier 2 (General) and Tier 2 (ICT) visas.
  • Who is affected: Employers hiring skilled non-EU migrant employees and assignees.
  • Business impact: If adopted, the reforms would significantly increase business costs for companies hiring and assigning non-EU staff into the U.K.

Background: The government commissioned the committee to make recommendations on changes with an eye toward limiting net migration into the U.K. The committee is an independent group of five senior economists charged by the government to advise the Home Office on migration policy issues in light of independent socioeconomic data.

The key recommendations in the nearly 400-page report are:

  • Higher minimum salary thresholds. Tier 2 (General) and Tier 2 (ICT) should be raised to £30,000 (from the current £20,800) in order to restrict Tier 2 migration and to reflect the higher skill level for these routes. A lower threshold of £23,000 should be offered to graduate hires who have just completed university. Given that minimum salaries are often set for each occupational role according to Standard Occupation Codes, this will impact certain sectors more than others.
  • A new Tier 2 (ICT) route for third-party contracting. A separate category for ICTs servicing third-party contractors should be introduced with a salary threshold of £41,500 in order to ensure that this route is only used by highly specialized migrants and benefiting the U.K. economy as a whole. This sector can expect further scrutiny once it is placed under a separate route to ensure there is no undue displacement of resident labor.
  • Immigration Skills Charge. Employers who use migrant labor should pay a skills levy, which would help fund training of resident labor and reduce the need for foreign workers. The committee suggests an upfront levy of £1,000 per year for each Tier 2 migrant, except for ICTs in the Graduate Trainee and Skills Transfer sub-routes.
  • Criteria for Tier 2 (ICT) route. Tier 2 ICTs (Long-Term and Short-Term Staff) should be required to have two years of experience (instead of one year under current rules) and employers should be required to provide a more detailed description of the role to ensure that it is used only for specialists. All ICTs should be required to pay the Immigration Health Surcharge from which they are currently exempt.
  • In-country conversions. Employers should be required to conduct resident labor market testing when hiring Tier 4 students and others who are switching to Tier 2 (General) in-country. Further, in-country switchers to Tier 2 (General) should be included in the annual limit on Tier 2 migration.
  • Shortage Occupation List. Tier 2 (General) should not be restricted only to occupations on an expanded shortage occupation list, nor should the jobs on the list automatically sunset. However, employers should provide evidence of upskilling the resident labor force for jobs to remain on the list.
  • Family dependents. The automatic right to work of family members of skilled migrants should not be restricted.

BAL Analysis: The Migration Advisory Committee took the approach that the best way to stem skilled migration is through price. If the committee recommendations are adopted, employers will face higher costs in the form of increased Tier 2 salaries and a new Immigration Skills Charge for most Tier 2 workers as incentives to reduce the reliance on migrant labor. Tier 2 ICTs servicing third-party contractors will have to meet higher salary thresholds in order to limit this route to senior managers and specialists, although the committee recommended further research on skills shortages specifically within the information technology (IT) sector. On the positive side, the committee did not recommend absolute time limits on jobs listed as shortage occupations or eliminating the automatic right to work for spouses of skilled migrants.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The United Kingdom has announced that it will introduce two-year multiple entry visas to Chinese visitors beginning next week.

What does the change mean? The change is part of a reciprocal visa arrangement with China, which has said that it will issue two-year multiple-entry visas to U.K. nationals as well. The visas will make it easier for U.K. and Chinese business travelers to visit each other’s countries without having to renew their visas every six months, as is currently required.

  • Implementation time frame: The U.K. will start issuing the new visas Monday.
  • Visas/permits affected: Visitor visas.  
  • Who is affected: Chinese and U.K. nationals traveling to each other’s countries.
  • Impact on processing times: The longer validity will eliminate renewal processing for each new trip.
  • Business impact: The change is intended to boost business and tourist travel between the two countries and will benefit frequent business travelers.
  • Next steps: The U.K. and China have agreed to work toward implementing 10-year multiple-entry visas in the future.

Background: The two countries agreed to the new visa arrangement in October, during President Xi Jinping’s visit to the U.K. The U.K. Home Office announced this week that it would begin issuing the two-year visas to Chinese travelers beginning Monday. The visas will cost £85, the same amount as the current six-month visas. China has agreed to reciprocate, and will provide two-year multiple-entry visas to U.K. nationals for the equivalent of £85. Chinese Foreign Minister Wang Yi said in a Jan. 5 statement posted on the Chinese Embassy’s website that China is “willing to issue two-year multiple-entry visas to UK’s citizens,” but did not provide an implementation date.

BAL Analysis: The longer-validity visas will make travel more convenient for frequent business travelers in the U.K. and China.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – LOW

What is the change? The Department of Health released a consultation on ways to recoup £500 million per year by expanding the charging of foreign visitors and migrants for health care services in the U.K.

What does the change mean? The department is seeking comments on the proposals until March 7, 2016 from employers and other interested parties. The current proposals would affect foreign visitors and non-EEA nationals as well as EEA or Swiss nationals residing in England.

  • Implementation time frame: Ongoing. The Department of Health is aiming to publish an Implementation Plan for 2016-18.
  • Visas/permits affected: EEA nationals, Tier 2 (ICTs) and others outside the current immigration health surcharge regime, and visitors.      
  • Who is affected: Employers and migrants paying the Immigration Health Surcharge will not be affected – that regime remains in place. The proposals essentially affect EEA residents without a European Health Insurance Card, non-EEA nationals who are currently exempt from the healthcare surcharge, i.e., Tier 2 Intra Company Transferees, and visitors (including business visitors).
  • Business impact: The proposed expansion of health care fees may increase living costs for some EEA and Swiss nationals and non-EEA nationals visiting or taking residence in the U.K., but will not affect direct business costs.

Background: The current Immigration Health Surcharge regime, which applies to many foreign workers (but not to EEA nationals working in the UK, or to intra-company transferees on assignment), may be viewed here.

The intention of the proposed changes is to tackle perceived abuse of the U.K.’s National Health Services from within the European Union and to shore up the European Health Insurance Card system to allow costs to be recovered from European member states. The consultation proposes to both expand charges for health services and recoup costs from the home country of EEA nationals with permanent resident status in the U.K. who currently receive free healthcare alongside British residents. The proposal would redefine “ordinary resident” for purposes of receiving free health care to exclude EEA nationals whose home country is responsible for their healthcare costs. It also seeks to prevent “health tourism” by other measures.

Key proposals include:

  • Primary care: EEA residents who do not have a European Health Insurance Card (or provisional certificate) and non-EEA nationals who do not pay the health surcharge would be charged for primary medical care. Consultations by a nurse or general practitioner would remain free of charge.
  • Drugs: Foreign visitors would be required to pay a charge for prescription medications. Currently, several exemptions apply for adults over 60, children under 16, pregnant women and individuals with certain medical conditions. The exemptions would continue to apply to U.K. and EEA residents, but most non-EEA residents who are not subject to the health surcharge would have to pay a prescription charge.
  • Dental care: Most non-EEA residents who are not subject to the health surcharge would pay a banded dental charge depending on the treatment provided. Currently National Health Services sets three price bands that cover varying levels of treatment. Exemptions for youths, students, pregnant women and others would continue to apply for EEA and U.K. residents.
  • Eye care: Free sight tests and vouchers for eyeglasses would no longer be available to most non-EEA residents who do not pay the healthcare surcharge.
  • Emergency care: Foreign visitors would be charged for all types of accident and emergency care, including treatment at walk-in centers, urgent care centers and minor-injuries units. Exemptions would apply to those who pay the health surcharge or are exempt from it, and for EEA residents who are able to produce a European Health Insurance Card (or provisional certificate).
  • Ambulance services: All treatment by ambulance services, such as on-site accident care and paramedic services, would be charged to the patient. EEA residents who are able to show their European Health Insurance Card or Provisional Replacement Certificate would be exempt as would non-EEA residents who pay the health surcharge or are exempt from it. The department is also looking into the feasibility of charging patients for air ambulance services.
  • Other services. Fertility services would only be available if both partners demonstrate they are ordinarily resident at the time of treatment; for non-EEA nationals, both partners must have indefinite leave to remain. Those who have paid the healthcare surcharge would no longer have the right to NHS-funded fertility services. Foreign visitors seeking any out-of-hospital care or NHS-funded care by a non-NHS provider would be charged for those services. Individuals who are not ordinarily resident and receive continuing healthcare (such as a visitor with a multi-entry visa who is too ill to return home) may be brought under the charging regulations.

The full contents of the Department of Health’s consultation and soliciting of public comments may be read here.

BAL Analysis: Employers and other stakeholders interested in participating in the consultation or submitting comments may respond directly to the questionnaire contained in the consultation or contact their BAL professional.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? The Home Office has revised the rules for Tier 2 skilled workers applying for settlement in the U.K. (also known as “indefinite leave to remain” or permanent residence), including introduction of a new minimum salary threshold and a redefinition of the qualifying period of residence and ongoing employment.

What does the change mean? The new minimum annual salary for Tier 2 skilled workers applying for settlement on or after April 6, 2016 will be £35,000. This minimum will increase annually over the next five years to ensure that settlement is only available for higher earners. However, exemptions are available for certain Ph.D. level occupations, shortage occupations, certificates of sponsorship assigned before April 6, 2011, and applicants in previously listed shortage occupations under certain circumstances who are considered valuable to the U.K. despite potentially lower salaries.

The new rules also clarify the definition of the required five years of continuous lawful presence for Tier 2 migrants before applying for settlement. In addition, the new rules require that the employer who issued the certificate of sponsorship must still hold a Tier 2 sponsor license and certify the migrant’s future employment and salary.

  • Implementation time frame: The new salary thresholds will apply beginning April 6, 2016.
  • Visas/permits affected: Indefinite leave to remain.
  • Who is affected: Tier 2 (General) visa holders applying for indefinite leave to remain.
  • Business impact: Companies should budget for the new salary thresholds that will rise again in 2018, 2019 and 2020.
  • Next steps: U.K. employers and foreign employees affected by the change may contact their BAL team to determine if an exemption from the salary thresholds applies.

Background: The concept of applying minimum salary thresholds to all Tier 2 settlement applicants was approved in 2012 and will be brought into force for all applications filed on or after the following dates:

April 6, 2016 – £35,000

April 6, 2018 – £35,500

April 6, 2019 – £35,800

April 6, 2020 – £36,200

Please note that the base annual salaries do not include allowances outside of the guaranteed salary package or other benefits or incentives.

BAL Analysis: Businesses should assess any current Tier 2 workers who are due to apply for settlement after April (due to accrual of five years of residence in the U.K.) and ensure that the upcoming minimum salary requirement can be met. Applications that do not meet the salary requirements will be rejected.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – HIGH

What is the change? Employers sponsoring foreign workers have been targeted by fraudulent callers pretending to be U.K. Visas and Immigration officials and asking for their user details to access the Sponsor Management System (SMS).

What does the change mean? U.K. sponsors should be extra vigilant in protecting their SMS user details and be aware that the UKVI will never ask sponsors to divulge their user name or password under any circumstances. Sponsors who reveal their user details or agree to exchange money for certificates of sponsorships will be in breach of their sponsor duties and may be subject to compliance action, including revocation of their sponsor license.

  • Implementation time frame: Immediate and ongoing.
  • Visas/permits affected: UKVI sponsorship.
  • Who is affected: All sponsors using the SMS.
  • Business impact: Disclosing SMS level 1 details to a third party constitutes a breach of sponsor rules.
  • Next steps: Sponsors should not reveal their SMS user details to anyone, including individuals claiming to be from UKVI.

Background: In recent days, several sponsors have reported receiving phone calls from individuals claiming to be from UKVI and asking for the sponsor’s username and password. In one case, the sponsor was told that its account was locked and needed to be reset; in another, the caller asked the sponsor to change its login details and provide them to the caller for which they would be paid £2000 for each certification of sponsorship assigned.

BAL Analysis: Employers should make sure staff are warned about the scams and are reminded that UKVI does not ask sponsors for their user details under any circumstances.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – MEDIUM

What is the change? Under a legislative change taking effect Nov. 12, nationals of European Economic Area member states applying for British citizenship must include documentary proof of permanent residency in the U.K.

What does the change mean? Before applying for citizenship, EEA nationals must obtain one of the following: a permanent resident card, a document certifying permanent residence, or a residence document or residence permit indicating indefinite leave to remain in the U.K.

  • Implementation time frame: Nov. 12.
  • Visas/permits affected: Naturalization.
  • Who is affected: Nationals of EEA member states.
  • Impact on processing times: EEA nationals should plan to apply for the appropriate documents and allow several months for processing.
  • Next steps: BAL can assist in applying for the appropriate documentation.

Background: EEA nationals are automatically granted permanent residency status after five years of qualifying residency in the U.K. and are eligible to apply for British citizenship after an additional year of permanent residency.

Under a legislative change beginning Nov. 12, EEA nationals will have to obtain a document certifying their permanent resident status before they can apply for citizenship. Previously, documentary evidence of permanent residency was not required.

BAL Analysis: To avoid delays in applying for British citizenship in light of the new requirement, EEA nationals should apply as soon as possible for a permanent resident card or other document certifying permanent resident status and allow up to six months to obtain the document.

This alert has been provided by the BAL Global Practice group in the United Kingdom. For additional information, please contact uk@bal.com.

Copyright © 2016 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.