UK employers review recruitment ahead of expiry of Temporary Shortage List

The UK’s Temporary Shortage List is due to expire at the end of December, potentially closing off access to Skilled Worker sponsorship for a number of occupations that employers rely on to fill hard-to-recruit roles. With just a few months to go, employers that rely on overseas recruitment may need to review their recruitment plans and consider alternative ways to fill key roles. We’ll speak to an immigration expert who is helping a number of clients with that exercise. 

The Temporary Shortage List was introduced in July last year as part of the Government’s wider immigration reforms. It allows employers to use the Skilled Worker route for a limited number of medium-skilled occupations below the usual skill threshold for sponsorship. The route was always intended to be temporary and, under the current rules, the occupations on it are due to expire at the end of the year. The issue has attracted attention because it contrasts with recent moves in Ireland to widen access to overseas workers in sectors facing labour shortages. For UK employers that currently rely on Temporary Shortage List roles, the key question is what happens next. 

Earlier I spoke to immigration lawyer Shara Pledger and I started by asking her what impact the expiry of the List could have on employers that currently rely on sponsorship to fill hard-to-recruit roles.

Shara Pledger: “I think in the UK we have a very set direction to continually reduce our net migration and it's come down significantly. If you look at the peaks that we saw in the past few years, we're down, way down, compared to those numbers and so a lot of the measures that we've brought through have had that desired effect. What we're now looking at as we get towards the end of 2026 is the continuation of the bite of those measures. So the Temporary Shortage List, for example – it has temporary in its name – and it was always intended that it would be withdrawn at some point, and as things are currently drafted, that point is the 30th of December.”

Joe Glavina: “What should UK employers be doing now to assess whether future recruitment plans could be affected by changes to sponsorship eligibility?”

Shara Pledger: “I think for UK employers, the really big thing is to continually just make sure that they keep abreast of these changes as they're happening because things like the Temporary Shortage List, for example, have now been part of the rules for over a year. It's very easy to forget that that's going to stop. So they might have been still recruiting into roles that are included in that list quite happily over the last 12 plus months, and it's very easy to forget that perhaps in the next tranche of recruitment, or whatever it happens to be in terms of how recruitment practices work for a particular business, those roles might not be available at that time. There are things that can be done, however. So while the Temporary Shortage List remains active and available for use, it's possible to sponsor people in that route for quite a long period of time. The list itself will be potentially withdrawn on the 30th of December but, as of today, you could sponsor somebody for a code that was under that list for anything up to five years. So there can still be a short to medium term plan in relation to some of these roles, but the long term focus will have to be acknowledgement and acceptance of the fact that people cannot continually be recruited into those roles if they need to be sponsored and so an alternative arrangement will have to be made, whether that is putting something in place now that will be a long-term training programme to have some perhaps new homegrown talent, or whatever it happens to be, there does need to be a long-term plan in the in the mix.”

Joe Glavina: “Looking ahead, how do you see employers adapting their workforce planning strategies if access to sponsorship becomes more limited for some roles?

Shara Pledger: “I think it's really important to try and cast our minds back to the white paper that was released in May of 2025. That really set out the blueprint for a lot of the measures that we have already seen implemented. So things like the Temporary Shortage List, for example, and the increasing levels of skill requirement in order to be sponsored. Now, an aspect of that did revolve around the idea of training and this onus on sponsors in the UK to be able to demonstrate that they have a committed and structured training programme to try and create a pipeline of local talent for some of the roles that have previously, perhaps, been more reliant on sponsored workers. So that is potentially going to be a real focus, certainly, for the Home Office moving forward. It's certainly a practical way for businesses to try and solve some of these issues moving forward. So strategically, long-term plans about engagement with the local community, perhaps through colleges or universities, about courses, etcetera, getting people into those roles and training them up so they don't need that sponsorship will be a focus.”

Joe Glavina: “Finally Shara, what should employers be watching out for between now and the planned withdrawal date?”

Shara Pledger: “At the moment, we know that the intention is to remove the Temporary Shortage List from the rules on the 30th of December, but obviously not everything is set in stone and there will be continuing consultations and assessments until that date is reached. We know that there are some roles that are still very widely used that are included on that list. I personally work with a lot of clients who are in offshore or shipping as sectors, and there are a lot of roles that fit within work on vessels, for example, that currently are included on the Temporary Shortage List and it's very, very difficult to be able to source enough people from the UK to fill those roles. So it's possible that areas like that, perhaps particular sectors, or particular roles, might have some kind of reprieve, whether that's permanent or temporary, but I think with six months to go it really is important for businesses to at least be mindful of the fact that there may be a hard stop on the 30th of December.”

So, the key takeaway for employers is that while the Temporary Shortage List remains available for now, businesses that rely on it should not assume those sponsorship routes will continue beyond the end of the year. With the current deadline approaching, now may be the time to review recruitment plans and consider longer-term workforce strategies. If you’d like help with that, please do contact Shara – her details are on the screen for you.