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UK Points-Based Immigration System: A Technical Reference for HR Teams and Compliance Developers (2026)

The UK's Points-Based Immigration System (PBS) has been live since January 2021, replacing free movement for EU citizens and consolidating most work visa routes into a single framework. For HR professionals, compliance teams, and developers building immigration tooling, understanding the mechanics of the system is essential for correct implementation.

This is a technical and compliance-oriented overview of how the PBS works, what triggers each eligibility pathway, and where the common implementation errors occur.

System Architecture: How Points Are Allocated

The PBS uses a points threshold model. For the Skilled Worker visa — the primary employment route — applicants must accumulate 70 points across mandatory and tradeable criteria.

Mandatory criteria (50 points, non-negotiable)

Criterion Points Notes
Valid Certificate of Sponsorship (CoS) from licensed sponsor 20 Employer must hold active Tier 2/Skilled Worker sponsor licence
Job at eligible skill level (RQF Level 3+) 20 Occupation code must appear on Appendix Skilled Occupations
English language requirement met 10 Degree taught in English, approved test, or exemption by nationality

Tradeable criteria (20 points needed from this pool)

Criterion Points Notes
Salary meets general threshold (£38,700 or role-specific threshold, whichever is higher) 20 As of April 2024
Job is on the Immigration Salary List (shortage occupation) 20 Replaces old shortage occupation list; 20% discount removed
PhD in a subject relevant to the role 20
PhD (STEM, not necessarily role-relevant) 10
New entrant rate applies (age under 26, recent grad, switching from student/graduate visa) 20 Salary threshold drops to £30,960

The tradeable model means an applicant who meets the salary threshold doesn't need a PhD or shortage occupation. An applicant in a shortage occupation who meets the new entrant threshold doesn't need the full salary figure. This creates combinatorial eligibility paths that compliance tools must correctly model.

Sponsor Licence: The Gating Mechanism

No Skilled Worker application can proceed without an employer holding a valid sponsor licence. This is the primary point of failure in enterprise hiring workflows.

Key implementation notes:

  • Licence status can be verified via the public Register of Licensed Sponsors (GOV.UK). The register lists ~125,000 active sponsors and is updated periodically.
  • Licence tiers: Organisations hold an A-rated or B-rated licence. B-rated sponsors are under a performance improvement plan and cannot assign new Certificates of Sponsorship.
  • CoS assignment: Each sponsored worker requires an individual Certificate of Sponsorship, which carries a unique reference number and is tied to a specific role, salary, and start date.
  • SMS access: HR administrators manage CoS assignments through the Sponsor Management System (SMS), the Home Office's online portal.

If your HR system integrates with onboarding workflows for overseas hires, validation against the register and CoS assignment tracking should be treated as blocking steps, not optional checks.

Route Map: Which PBS Route Applies?

Different worker profiles route into different visa categories. This matters for salary thresholds, eligibility conditions, and CoS requirements:

Applicant Profile Correct Route CoS Required?
Skilled worker, employer-sponsored Skilled Worker visa Yes
NHS / social care worker Health and Care Worker visa Yes (employer must be CQC-registered or NHS)
International student post-graduation Graduate visa No — unsponsored, 2-year limit
High-achieving researcher / tech leader Global Talent visa No — endorsement-based
Entrepreneur launching new business Innovator Founder visa No — endorsement required
Full-time student at licensed institution Student visa No CoS — Confirmation of Acceptance for Studies (CAS) instead

A common compliance error is attempting to assign a Skilled Worker CoS to an applicant who should be on the Health and Care Worker route, or vice versa. Each route has its own fee structure, NHS surcharge rules, and dependant eligibility conditions.

Salary Thresholds: April 2024 Changes

The April 2024 changes significantly raised salary floors and should be reflected in any HR system built before that date:

  • General threshold: £26,200 → £38,700
  • New entrant threshold: £20,960 → £30,960
  • Shortage occupation salary discount: Removed entirely (was 20% below general threshold)
  • Going rate: Role-specific salary minimums remain; whichever is higher between going rate and general threshold applies

Roles in healthcare, education, and social care have separate SOC-based going rates that may exceed the general threshold. Systems that hardcode £38,700 as the single salary check will produce incorrect eligibility outputs for these occupations.

English Language Requirement: Acceptable Evidence Paths

Applicants must meet CEFR B1 (for most roles) or B2 (for some healthcare roles). Accepted evidence:

  • Degree taught and assessed in English from a UK institution or approved equivalent
  • Secure English Language Test (SELT) from an approved provider
  • Citizenship from a majority English-speaking country (MESC) as defined in Appendix KOLL

Note: Home Office MESC list is not identical to common assumptions. Always verify the current Appendix rather than relying on assumptions about which countries qualify.

Compliance Audit Points for HR Systems

If you're building or auditing an immigration compliance workflow, the following are the most common failure modes:

  1. Salary threshold not updated post-April 2024 — hardcoded values from pre-2024 will produce false positives
  2. Occupation code mismatch — job titles don't map to SOC codes deterministically; multiple codes may apply
  3. Shortage/Immigration Salary List not refreshed — the list changes; static copies go stale
  4. B-rated sponsor not caught — public register check must include rating, not just presence
  5. CoS expiry not tracked — a CoS has a defined use-by date; assignment after expiry is invalid
  6. New entrant eligibility over-applied — "new entrant" has a specific definition; applying it to all junior hires is incorrect

Further Reference

For live queries against GOV.UK immigration policy — including salary requirements, occupation eligibility, and sponsor status — ImmigrationGPT provides a RAG-based assistant trained on official policy documents and the live UK sponsor register.


Information correct as of May 2026. Immigration rules are subject to change. Verify current thresholds and requirements via GOV.UK Appendix Skilled Occupations and the Immigration Rules before making compliance decisions.

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