Internal Delegated Authority Policies: Why Clarity Isn’t Optional

What’s happening On 14 October 2025, the Home Office published its latest Statement of Changes (HC 1333), introducing the next phase of the government’s plan to ‘restore control’ over the immigration system. These changes implement key proposals from the May 2025 Immigration White Paper and represent one of the most significant overhauls of the UK’s immigration framework in recent years. The reforms affect work, study and family routes, with new eligibility criteria, shorter visa durations, and increased financial obligations for sponsors. While the stated aim is to strengthen integration and ensure the UK’s immigration system better serves economic and social priorities, the practical effect for many employers will be tighter compliance obligations, higher costs, and narrower access to international talent. Raising the English Language Requirement From 8 January 2026, applicants under the Skilled Worker, Scale-Up, and High Potential Individual (HPI) routes will need to demonstrate English language ability at B2 level (upper intermediate) under the Common European Framework of Reference for Languages (CEFR) — up from the current B1 (intermediate) standard. Applicants will be required (as is currently the case) to evidence their proficiency through approved Home Office test providers, as part of a broader policy drive to ensure migrant workers can fully engage in the UK workplace and wider community. What this means for employers: The higher threshold could make it harder to fill roles in sectors that previously relied on B1-level applicants, such as healthcare, engineering, hospitality, and construction. Employers should review upcoming sponsorship plans, identify candidates likely to be affected, and consider offering language-support initiatives or alternative recruitment strategies. Shortening of the Graduate Route From 1 January 2027, the Graduate visa will be shortened from 24 months to 18 months for most graduates, although PhD holders will retain their existing three-year permission. Impact: This shorter post-study window reduces the time international graduates have to secure longer-term sponsorship. Employers will need to accelerate onboarding and visa-switch processes to ensure promising graduates can move to the Skilled Worker route before their Graduate visa expires. Combined with the higher salary and skill thresholds introduced earlier this year, many sponsors may find that graduates once eligible for sponsorship now fall short of the new requirements. Expansion and Cap of the High Potential Individual Route The High Potential Individual (HPI) visa is open to graduates from top global universities, allowing for a stay of up to 2 years for graduates and 3 years for students with a PhD. Under current plans, this route will be expanded, doubling the number of universities on the Global Universities List for qualifications awarded between 1 November 2025 and 31 October 2026. However, a new annual cap of 8,000 applications will take effect from 4 November 2025. Impact: While this widens access to high-calibre international talent, the introduction of a quota will make early applications essential. Employers recruiting graduates via this route should monitor availability closely and plan recruitment cycles around the cap. New Opportunities for Student Entrepreneurs From 25 November 2025, certain international students completing their studies will be permitted to establish UK-based businesses by switching to the Innovator Founder route. For students completing their studies, switching directly into this route whilst remaining in the UK removes the disruption of having to leave the UK, and enables them to progress from academic research into commercial ventures straight after graduation. Impact: This welcome adjustment supports entrepreneurship among international graduates and may help retain talent in innovation-led sectors. However, eligibility remains narrow, limited to those switching into the Innovator Founder route, and is therefore unlikely to benefit the majority of students. Increase in the Immigration Skills Charge The Immigration Skills Charge, which is payable by sponsors for each sponsored worker, will rise by 32% from 16 December 2025. Large sponsors will pay £1,320 per worker per year (up from £1,000), and small sponsors £480 (up from £364). Impact: This cost cannot lawfully be passed on to sponsored employees and will therefore need to be absorbed by employers. Combined with higher salary thresholds and Certificate of Sponsorship fees introduced earlier in the year, this increase will further strain recruitment budgets. Strategic Implications for Employers Together, these reforms mark a decisive shift toward a high-skill, high-threshold immigration system. Employers should respond proactively by: reviewing recruitment pipelines: assess how higher language standards and shorter visa durations affect planned hires; updating sponsorship policies: ensure systems meet enhanced record-keeping and reporting standards; budgeting for cost increases: reflect the new Skills Charge and compliance costs in workforce planning; supporting candidates: offer language-testing guidance and clear communication about timing and documentation; monitoring developments: further secondary legislation is expected in early 2026, so vigilance will be essential. Boardside View While these reforms are positioned as measures to improve control and integration, they risk reducing workforce flexibility and increasing administrative burdens for employers. Businesses that begin adjusting now, by aligning hiring, sponsorship and compliance frameworks, will be best placed to maintain continuity and competitiveness in 2026 and beyond.

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UK Business Immigration: the next wave of change 

Sexual Harassment: when do social spaces become ‘The Workplace’?

Whistleblowing: Post-Employment Protections Clarified

As part of its ongoing corporate transparency reforms, Companies House is introducing two important compliance requirements that directors and company secretaries should be aware of, one immediate, and one longer-term. Director ID Verification – Coming This Autumn From Autumn 2025, all company directors will be legally required to verify their identity with Companies House. This is part of the implementation of the Economic Crime and Corporate Transparency Act 2023, aimed at reducing fraud and improving corporate accountability. The process will involve confirming your identity through the Companies House portal or via an authorised third party. For UK nationals with a passport and standard secondary ID, the process is expected to be quick and fully digital. Directors who fail to verify their identity will be committing an offence and may be unable to act in that capacity until verification is complete. Boardside Law will become an authorised provider to carry out this process on behalf of clients. If this would be of interest to you, please let us know. Paper Accounts to Be Phased Out by April 2027 From 1 April 2027, Companies House will no longer accept paper accounts. All companies, including micro-entities and dormant companies, will be required to file accounts using compatible accounting software. This applies to: Audited and unaudited accounts Limited companies, LLPs and charitable entities Group accounts and subsidiaries Although the change is nearly two years away, we recommend that companies with financial year ends of 31 December or 31 March treat the 2026 accounting period as the transition year. This allows time to get familiar with digital filing tools ahead of the April 2027 deadline. A full list of compatible software providers is available here: gov.uk/software-company-accounts/y/audited/group There are also separate links for LLPs and charities. What You Should Do Now Directors: Watch out for further announcements about ID verification and ensure you complete this when required. Company Secretaries / Finance Teams: Review your current filing method and speak to your accountant about moving to compliant software if you haven’t already. If you would like advice on preparing your company for these reforms, or support with managing director filings or company secretarial duties, the Boardside team is here to help.

Whistleblowing: Reform on the Horizon 

The Government is backing a proposed major amendment to the Employment Rights Bill that would render certain non-disclosure agreements (NDAs) unenforceable. Specifically, the amendment targets clauses that prevent individuals from speaking out about unlawful behaviour, such as harassment, discrimination, sexual misconduct or bullying. This shift follows sustained criticism of how NDAs have been used to cover up workplace misconduct and protect serial offenders, particularly in high-profile sectors like media, technology and education. While the aim is to protect victims, the change could have unintended consequences for employers. If confidentiality can no longer be assured, some employers may be less inclined to settle disputes at all, which could in itself drive more claims to an Employment Tribunal. The proposals in terms of voiding certain agreements would also extend to employment contracts and internal policies, not just settlement agreements. What Is Changing? The proposed reform (an amendment to the Employment Rights Bill), which was tabled in Parliament on 7 July 2025, would: void any contractual clause that seeks to prevent a person from disclosing misconduct; apply not only to settlement agreements but also, potentially, to employment contracts, policy documents, and confidentiality agreements; introduce civil penalties for employers or advisers who breach the new provisions. Deputy Prime Minister Angela Rayner has stated that the purpose is to prevent NDAs from being used as “gagging clauses” that silence victims. Why This Matters for Employers: Fewer settlements? Without confidentiality, some employers may feel less secure in offering financial settlements to resolve complaints. Loss of control over reputation management: Public disclosure could increase the reputational risks for employers, particularly in unresolved or disputed allegations. Employee voice strengthened: The change would empower employees to speak out, but some may prefer private resolution. Removing this option may reduce flexibility. Boardside's View: We support the main aim of increasing transparency and preventing misuse of legal tool agreements which genuinely help parties resolve employment-based issues. We certainly accept that employers should not be allowed to abuse their positions. However, we share concerns that an outright ban may discourage settlement and create uncertainty for all parties. Action Points: Review all current template agreements and HR policies. Train HR teams and line managers on the lawful use of confidentiality provisions. Keep a close eye on the final form of the legislation as it progresses through Parliament. Boardside Law can support you in adapting your internal documents and approach to reflect the likely changes, as well as keeping you updated on the final wording and timeline of implementation. Contact us

AI and algorithmic decision-making is now deeply embedded in recruitment, performance tracking, and even disciplinary decisions. But the legal risks around automated decision-making is still evolving, and employers face serious compliance risks. What does the law say? Under UK GDPR, employees have the right not to be subject to solely automated decisions that have a significant effect on them. This includes decisions about recruitment (for example, CV screening by AI), disciplinary or capability outcomes, and performance rankings. Where such processing occurs, employers must: Provide meaningful information about the logic involved. Offer the right to obtain human intervention. Enable the individual to contest the decision. Key Risks Discrimination: biased data can lead to unlawful outcomes. Lack of transparency and explainability: AI systems are often ‘black boxes’, making it difficult to explain how decisions are made. Lack of documentation: employers may struggle to prove compliance without a proper audit trail. Failure to notify or offer human review. What employers should do Audit your use of AI tools in HR processes. Ensure there is always a human in the loop. Ensure transparency and accountability mechanisms are in place. Update internal data protection policies and privacy notices. Provide training to HR and senior leadership on AI compliance and ethical considerations. Boardside can support you in designing ethical and legally compliant approaches to AI in the workplace. Call us on 0330 0949338