Key changes in UK immigration law affecting the offshore energy sector

There have been several important changes in UK immigration law that will significantly impact the offshore industry operating in the UK and UK waters. Please see the details below.
 

Skilled Worker Salary Compliance

Since 8 April 2026, the Home Office has revised its approach to assessing salary compliance for Skilled Workers. Previously, the salary threshold could be met on an annual basis; for example, as long as the Skilled Worker was paid the minimum gross annual salary within a 12-month period, they would satisfy the requirements.

Under the new rules, sponsored workers must be paid the required salary for each pay period.

For offshore workers with irregular and variable hours, a 17-week pay period applies. This means that in any rolling 17-week period, they must be paid at least 17/52 of the required gross annual salary.

This change makes salary compliance more challenging, particularly for offshore workers with variable schedules. To assist our clients, we have developed a salary tracker tool to help monitor compliance. It is crucial that Skilled Workers meet the salary requirements, as non-compliance can result in sponsor licence revocation and visa cancellation.
 

Extension of Right to Work Checks

From 1 October 2026, the UK government is expanding right to work check obligations to cover a wider range of working relationships, including subcontractors and workers supplied via online platforms.

This is a significant change, and the requirements are complex. We strongly recommend seeking legal advice, as non-compliance with these extended right to work checks could result in a civil penalty of up to £60,000 per illegal worker.

Read about the extension of Right to Work (RTW) checks here.
   

Temporary Shortage List (TSL)

Certain roles on the TSL are heavily relied upon in the offshore energy sector (e.g. ship and hovercraft officers).

The TSL is currently scheduled to end at the end of this year, which means that roles listed on the TSL would no longer be eligible for sponsorship and crew undertaking these roles would not be able to obtain work visas.

The government is consulting with the Migration Advisory Committee (MAC), and MAC has recommended that certain offshore roles remain on the TSL. However, the government has not yet confirmed its final position. If the TSL ends without a replacement or extension, affected roles could lose eligibility for sponsorship. We strongly advise clients to begin contingency planning now in case the TSL is not replaced or extended.

If you have any questions or require further guidance, please contact us for tailored legal advice.