Senior or Specialist Worker Route: ICT Visa Requirements Under Global Business Mobility

Introduction

The Senior or Specialist Worker Route, part of the UK’s Global Business Mobility (GBM) framework, replaced the Intra-Company Transfer (ICT) Visa in April 2022, enabling multinational companies to transfer key employees to their UK operations. For immigration specialists and HR directors, mastering this visa’s requirements is crucial for seamless workforce mobility, compliance with Home Office regulations, and strategic talent planning in 2025. With updates from the May 2025 Immigration White Paper, Restoring Control over the Immigration System, and the eVisa transition by 31 December 2026, this guide details eligibility, application processes, compliance obligations, and strategic considerations for the Senior or Specialist Worker Route.

Overview of the Senior or Specialist Worker Route

The Senior or Specialist Worker Route facilitates temporary transfers of senior managers, specialist employees, or graduate trainees from overseas branches to UK operations within the same corporate group. It is designed for short-term assignments, offering no direct path to Indefinite Leave to Remain (ILR) but supporting global business operations in sectors like technology, finance, and engineering.

Eligibility Requirements

To qualify for the Senior or Specialist Worker Route in 2025, both the employee and the sponsoring company must meet stringent criteria:

For Employees

1. Employment History:
   
   • Senior/Specialist Workers: Must have worked for the overseas company for at least 12 months outside the UK, unless earning £73,900 or more annually (exemption applies).
   • Graduate Trainees: Must have 3 months of employment with the overseas branch in a structured training program leading to a senior or specialist role.
2. Job Role:
   
   • Roles must be at RQF Level 6 (degree-level) or above, as defined in the Home Office’s Appendix Skilled Occupations.
   • Graduate trainee roles must align with a formal training program.
3. Salary:
   
   • Senior/Specialist Workers: Minimum £48,500 annually.
   • Graduate Trainees: Minimum £25,410 annually.
4. Certificate of Sponsorship (CoS):
   
   • A valid CoS from a UK sponsor with a GBM Sponsor Licence is required, detailing the role, salary, and duration.
5. No English Language Requirement:
   
   • Unlike the Skilled Worker Visa, no English proficiency test is needed, simplifying the process.

HR Action: Verify employees’ employment history and ensure job roles meet RQF Level 6 and salary thresholds. Confirm CoS accuracy to avoid compliance issues.

For Companies

1. Valid GBM Sponsor Licence:
   
   • The UK branch must hold a Global Business Mobility – Senior or Specialist Worker Sponsor Licence.
   • The licence must be linked to the overseas entity through common ownership or control (e.g., parent-subsidiary relationship).
2. Proof of Business Link:
   
   • Corporate documents (e.g., shareholder agreements, organisational charts) must demonstrate the connection between UK and overseas entities.
3. Compliance Systems:
   
   • Robust HR systems are required for record-keeping, reporting changes (e.g., role, salary) within 10–20 working days, and preparing for Home Office audits.

HR Action: Ensure the Sponsor Licence is active and corporate linkage is documented. Implement HR software to manage compliance duties.

Application Process

The application process for the Senior or Specialist Worker Route involves coordinated efforts between HR teams and employees:

1. Secure a GBM Sponsor Licence:
   
   • Apply via the UKVI portal (8 weeks standard processing or 10 days with £500 priority service).
   • Fees: £574 (small sponsors) or £1,579 (large sponsors).
2. Issue a Certificate of Sponsorship:
   
   • Assign a CoS detailing the role, salary, and duration.
   • Fee: £525 per CoS (increased April 2025).
3. Submit Visa Application:
   
   • Employees apply online via the UKVI portal, providing:
     
     • CoS reference number.
     • Passport and personal documents.
     • Proof of employment history (e.g., payslips, contract).
     • TB test results (if from listed countries).
   • Pay the visa application fee (£625–£1,423, depending on duration) and Immigration Health Surcharge (£1,035 per year).
4. Attend Biometric Appointment:
   
   • Provide fingerprints and photographs at a visa application centre (VAC).
5. Await Decision:
   
   • Standard processing: 3 weeks (outside UK) or 8 weeks (inside UK).
   • Priority service (if available): 5 working days (£500–£800).
   • Super Priority service (select VACs): Next working day (£800–£1,000).

HR Action: Guide employees through the application, ensuring timely document submission and biometric appointments. Use priority services for urgent transfers.

Benefits of the Senior or Specialist Worker Route

For Companies

• Global Mobility: Transfer key personnel to support UK projects, expansions, or training without a UK labour market test.
• Streamlined Process: No English language requirement reduces administrative barriers.
• Operational Flexibility: Ideal for time-bound assignments in high-skill sectors like tech or finance.
• Compliance Support: Simplified reporting compared to Skilled Worker Visa, with fewer ongoing checks.

For Employees

• Career Development: Gain international experience in a global economic hub.
• Family Inclusion: Bring dependants (spouse, children) with work and study rights.
• NHS Access: Utilize UK healthcare via the Immigration Health Surcharge.
• Duration: Up to 5 years (9 years for high earners above £73,900), suitable for medium-term assignments.

HR Action: Highlight these benefits in employee communications to enhance engagement and retention during transfers.

Compliance Obligations in 2025

The Home Office has intensified compliance requirements in 2025, particularly for the Senior or Specialist Worker Route:

• Reporting Duties:
  
  • Report changes in role, salary, or location within 10 working days via the Sponsor Management System (SMS).
  • Report organisational changes (e.g., address, ownership) within 20 working days.
• Right-to-Work Checks:
  
  • Conduct checks before employment and annually, using eVisa share codes (post-2026) or Biometric Residence Permits (BRPs) until 31 December 2026.
• Record-Keeping:
  
  • Retain records of CoS, payslips, contracts, and right-to-work documents for the sponsorship period plus 1 year.
• Audits:
  
  • Prepare for unannounced Home Office visits, ensuring compliance with salary thresholds (£48,500 or £25,410) and corporate linkage.
• eVisa Transition:
  
  • By 31 December 2026, all workers must use eVisas, requiring UKVI accounts for status verification.

HR Action: Implement HR software to automate SMS reporting and right-to-work checks. Conduct quarterly internal audits to ensure audit readiness.

Challenges and Mitigation Strategies

• High Salary Thresholds: The £48,500 minimum for senior/specialist roles may limit candidate pools. Mitigate by targeting high-value roles or using graduate trainee routes (£25,410).
• No ILR Pathway: Lack of settlement may deter long-term commitment. Communicate temporary assignment goals or support transitions to Skilled Worker Visas for ILR eligibility.
• Corporate Linkage Proof: Complex structures may delay licence approval. Prepare detailed corporate documentation (e.g., shareholder agreements) in advance.
• Audit Risks: Non-compliance risks licence suspension or revocation. Conduct mock audits and retain comprehensive records.

HR Action: Develop a compliance checklist and provide employee guidance on visa limitations and eVisa transitions.

Strategic Considerations for 2025

• Stricter Audits: Increased Home Office inspections in 2025 require robust systems and accurate reporting.
• eVisa Transition: Support employees in setting up UKVI accounts by Q1 2026 to ensure seamless verification.
• Cost Management: Budget for rising fees (e.g., 7% increase in April 2025) and potential priority processing (£500–£1,000).
• Talent Planning: Align visa choices with project timelines and employee career goals, considering ICT’s temporary nature vs. Skilled Worker’s ILR pathway.

HR Action: Integrate visa planning into workforce strategies, using cost-benefit analyses to justify expedited services for critical transfers.

Conclusion

The Senior or Specialist Worker Route under the Global Business Mobility framework is a vital tool for transferring key employees to UK operations in 2025. Immigration specialists and HR directors must navigate eligibility, compliance, and the eVisa transition to ensure seamless transfers. By leveraging robust systems, preparing for audits, and aligning with business objectives, HR teams can maximize the route’s benefits while minimizing risks, supporting global mobility and operational success.

‍