Set on reducing net migration at all costs, the Immigration White Paper is a confused document that is soft on addressing exploitation

After much speculation, the immigration white paper has finally been published. For migrants’ rights and workers’ rights advocates, it makes for painful reading. 

While the exploitation of migrant visa workers gets a few cursory references, the government’s commitments here are soft, centred on the provision of more information for workers, with only a vague promise to “explore” the reforms that could actually give migrant workers more flexibility and better hold non-compliant sponsors to account.

Instead, the government relies heavily on the assumption that ending overseas recruitment for social care visas, and raising the minimum skill level for new recruits under the Skilled Worker visa to degree level (RQF 6) will safeguard migrant workers. 

It is doubtful that these reforms will achieve their stated aim. But with plans to increase English language requirements and double the time before migrants qualify for settlement from 5 years to 10 years, among other things, what is clear is that this white paper prioritises reducing migration, no matter the costs. 

In this blog post, we dissect some of the key issues raised in the white paper and what they will mean for the fight against exploitation. We start with a review of the measures ostensibly designed to “protect the vulnerable from exploitation”, then reflect on broader reforms that can impact migrant worker welfare.

We argue that given the obstinate nature of the government’s focus on net migration, the paper is confusing and sometimes at odds with its own stated goals. If the government is serious about protecting all working people and stamping out exploitation, the promised exploration of reforms that will make it easier for workers to move between licensed sponsors needs to start today.

Exploitation is mentioned - but misunderstood

Given the well-documented issue of migrant worker exploitation in the UK in recent years, it was seemingly impossible for the government to ignore this topic in its white paper. The violation of migrant workers’ rights is mentioned substantively for the first time on page 7:

“High levels of migration can also result in widespread labour exploitation, as migrant workers’ rights are violated, and employers who play by the rules are undercut.”

This unfortunate conflation between reducing migrant numbers and upholding migrants’ employment rights sets the tone for a set of policies that are misunderstanding the drivers of exploitation, leaving the reforms with the most potential to safeguard workers who are already in the UK to an indeterminate future. 

Not quite “Protecting the vulnerable from exploitation”

The government offers just four proposals to protect the vulnerable from exploitation, nested in a short section at the end of a chapter on fair controls. 

1. The first is ensuring that workers have more information about their rights and how to report unethical practices. While better information tends to be the first step, it is not the lack of information that prevents most migrant workers from completing the complex journey to challenging exploitation, but the lack of power. 

In our previous report we highlighted the ways in which employer-sponsored visas enable employers to abuse foreign-born workers and stifle reporting, knowing that it is too complex and too costly for them to find another sponsored role and pay for another visa. Without giving migrant workers the power to leave rogue jobs and take up work elsewhere, and without removing the financial burden of making another visa application, this policy leaves them just as unprotected as they are at the moment.

2. The second proposal in this section falls similarly short. The government plans to raise the skills threshold of the Skilled Worker route to RQF 6 (covered in more detail below), as an “important safeguard in preventing future exploitation issues, as the evidence shows that in higher skilled occupations, there are fewer instances of exploitation.” However, people in higher-skilled occupations are not immune to abuse by visa sponsors, as our caseworkers know too well. Perhaps more importantly, despite the headline of higher-skilled migration, the government has acknowledged that several industries will continue to need, and will indeed be permitted to recruit international workers with lower levels of qualification under a Temporary Shortage List (as explained in our Skilled Worker section). 

3. The third proposal is a weak and inexplicable response to the exploitation of migrant domestic workers under the Overseas Domestic Worker (ODW) visa. Despite clear evidence of systemic failures and tireless campaigning from organisations like Kalayaan and Voice of Domestic Workers for the best part of over a decade, the government has only committed to reconsidering “the purpose of this route, acting to stop employers exploiting their staff”. A more effective approach would be to reinstate the pre-2012 version of the ODW visa which allowed workers the right to change employers and renew their visa provided their labour as a domestic worker was still required.

4. The only measure directly addressing the point around providing more worker flexibility, though welcome, is rather frustratingly left to the hazy horizon of future exploration. 

The government has confirmed that it will “explore [...] making it easier for workers to move between licensed sponsors for the duration of their visa, giving them more control over who they work for and reducing the risk of exploitation”. This is an important area of reform, which could make a real difference for workers, as described in our recent report, Safeguarding Sponsored Workers. 

We urge the government to prioritise developing these proposals, and to do so in consultation with migrant and workers’ rights advocates, to avoid unintended outcomes. In stark contrast to the firm tone struck on measures focused on immigration control, the language of “explore” suggests that these are not cast-iron commitments, but an intention. Delaying worker flexibility would miss a crucial opportunity to redress the power imbalance inherent in employer-sponsored visas, and truly protect the vulnerable.

‘Exploring’ further action against sponsors

Another set of reforms that could raise the stakes of non-compliance, but are similarly couched in the language of exploration, include enforcement measures against rogue sponsors.

The government has confirmed that it will be exploring a series of further measures around sponsor compliance, including “innovative financial measures, penalties or sanctions, including for sponsors of migrant workers or students, which will incentivise them to show greater responsibility in their sponsorship practices…”. Additionally, it “will build on the tougher rules on sponsors flouting employment law introduced by the Home Office in November 2024.” 

This broadly echoes a call we and colleagues in the sector made in our recent open letter to the government, calling for greater criminal and/or civil penalties to be applied on individuals who abuse the work-sponsorship system. But key details of how this will work and, crucially, the extent to which they will contribute to compensating workers are yet to be hashed out. Perhaps most importantly, officials should ensure that workers are not punished for the actions of their sponsors by introducing a UK Workplace Justice Visa to protect their immigration status when speaking out against exploitation. 

Expecting that less migration will lead to less exploitation 

In contrast to the cautious phrasing around future worker flexibility, the government is firmly relying on the assumption that it can safeguard against exploitation by reducing net migration. 

This is most explicitly stated in relation to the changes to the Skilled Worker route, which will require new applicants to be qualified at graduate level or equivalent (RQF level 6), and in relation to the announcement that the overseas recruitment of social care workers will end.

As we argue below, this is not only unlikely to have the stated effect on exploitation - it may in fact exacerbate it.

Other policies that will impact migrant worker welfare

In addition to proposals explicitly framed as a response to exploitation, the white paper makes several other changes that are ostensibly designed to reduce net migration but will likely impact migrant worker welfare - whether this was the government’s intention or not.

New English language requirements will be introduced across a range of immigration routes. Albeit modest in practice and already reflected in the conditions for the most popular visa routes, this sends a message of hostility and puts pressure on English for Speakers of Other Languages (ESOL) courses.

More concerning are the changes to the qualifying period for settlement, which is set to increase to 10 years for most people. While the Home Office may cash in on additional fees obtained from required extension applications, migrants and their families will remain in a transitory position for an extended period, making the end goal of “integration and community cohesion” as set out in the white paper much harder to realise in practice.

How can exploited migrant workers actually be helped? In our recent report, we outlined three changes within the existing sponsorship system that could help workers to leave exploitative employment and take their labour to the businesses that really need and value it. This includes extending the time that workers have to find alternative sponsored employment, a new Workplace Justice Visa to stop workers from falling into irregular migration status through no fault of their own, and stronger sanctions on rogue employers. 

Beyond this, the government needs to have a long term plan for the thousands of displaced care workers currently in limbo, including the prospects of long term-settlement. Without this, we are likely to see more families pushed into destitution and re-exploitation.

Conclusion: tough on rhetoric, soft on exploitation  

Though the changes envisaged by the white paper will have their own timelines and will likely require a change to primary legislation, delaying implementation until the next parliamentary session in 2026, the fallout on migrant workers and their families is likely to be immediate. That the Prime Minister’s foreword to the paper includes such demeaning language around migration - phrases like “damage”, “wound” and “distorted by perverse incentives to import workers” as particular low points - is a sad indication of where conversations around migration in the UK are currently at. 

But while the tough language continues, the financial and personal hardship endured by many migrants at the sharp end of exploitation shows no signs of abating. The soft-touch nature of the government’s commitments around migrant worker welfare is painfully ironic given its manifesto commitments on upgrading workers’ rights via its new Employment Rights Bill. Migrant workers are part of the “working people” the government is claiming to act in the best interests of, but this is not currently being reflected in its policymaking.

We and other migrants’ rights advocates have spent years researching and making proposals for reform to the work sponsorship system that would be beneficial for workers, simpler for businesses, and entirely realisable by this government. Seeing these proposals acknowledged as something the government will explore is a thin silver lining. But if the government is serious about protecting all working people, concrete action needs to start now.

By choosing to be intransigent about the narrative of control over all other policy norms and objectives, the government’s white paper is likely to please very few. Fundamentally, it has failed migrant workers. Similarly, many businesses, most notably in social care, will be worried about the future sustainability of their sectors and the extent to which the government is even listening to their concerns. 

But it is not too late to steer course. We urge the government to heed the concerns of migrant communities and take measurable steps to protect their safety and integrity, not buy into gimmicks and cheap scare tactics.