Why employers must plan ahead
These 28 will only receive temporary access for 18 months. No occupation was considered strong enough to justify access for the full three-year period as initially proposed in its Stage 1 report.
For employers, the message is simple: the current TSL of 52 occupations provided some breathing space after the major overhaul to the occupation codes in July 2025, but it should not be treated as a permanent recruitment solution, given the MAC’s recommendation to reduce it to 28 occupations and limit access to 18 months.
What is the Temporary Shortage List (TSL)?
The Temporary Shortage List, or TSL, allows certain medium-skilled occupations at RQF Levels 3 to 5 to qualify for Skilled Worker visa sponsorship.
Normally, new Skilled Worker applicants must be sponsored for a role assessed at RQF Level 6, broadly graduate level, or above. The TSL provides an exception for selected medium-skilled roles where there is evidence of a shortage, and the occupation is important to the Government’s Industrial Strategy or critical infrastructure.
It was never designed to give employers permanent access to overseas workers. Its purpose is to provide temporary support while employers, sectors and Government take steps to recruit, train, retain and upskill more people from within the UK workforce.
What has the MAC recommended?
The MAC considered 82 occupations during Stage 2 of its review but received Jobs Plans (industry submissions to justify why the role should be included) for only 46. Of those, it recommended 28 occupations for 18-month access to the TSL. No occupation was recommended for the full three-year period because none of the Jobs Plans was considered strong enough.
The MAC’s proposed 18-month period is expected to run from 1 January 2027 to 30 June 2028, if the Home Office accepts and implements the recommendations.
Employers cannot assume that every recommended occupation will be available for sponsorship from 1 January 2027. Until the Government changes the Immigration Rules, sponsors can continue to use the current TSL list until 31 December 2026, and visas will remain valid until their expiry date.
Which occupations have been recommended?
The following 28 occupations have been recommended for 18-month access. As you can see, they do align closely to the Government’s overhaul Industrial Strategy and the sectors they are focusing on for economic growth.
Advanced manufacturing
- 3112: Electrical and electronics technicians
- 3113: Engineering technicians
- 5211: Sheet metal workers
- 5213: Welding trades
- 5221: Metal machining setters and setter-operators
- 5223: Metal working production and maintenance fitters
- 5235: Boat and ship builders and repairers
Clean energy
- 3116: Planning, process and production technicians
- 5212: Metal plate workers, smiths, moulders and related occupations
- 5249: Electrical and electronic trades not elsewhere classified, limited to Overhead Line Workers
Digital and technology
- 3133: Database administrators and web content technicians
- 3544: Data analysts
- 5242: Telecoms and related network installers and repairers
Foundational industries and critical infrastructure
- 3114: Building and civil engineering technicians
- 3120: CAD, drawing and architectural technicians
- 3512: Ship and hovercraft officers
- 5214: Pipe fitters
- 5241: Electricians and electrical fitters
- 5313: Bricklayers
- 5314: Roofers, roof tilers and slaters
- 5315: Plumbers and heating and ventilating installers and repairers
- 5316: Carpenters and joiners
- 5319: Construction and building trades not elsewhere classified, limited to Building Envelope Specialists and Curtain Wall Installers
- 5321: Plasterers
- 5322: Floorers and wall tilers
- 5323: Painters and decorators
- 5330: Construction and building trades supervisors
- 8113: Chemical and related process operatives
The recommendations retain 20 occupations appearing on the current TSL list and add eight new occupations not currently included.
Why is this particularly important for the defence sector?
The position is unusual for defence employers. No defence Jobs Plans were submitted as part of the review, and the MAC did not hold a dedicated defence roundtable for that reason.
Defence has nevertheless benefited from the fact that many of its most important roles cut across other sectors, particularly advanced manufacturing. Several recommended occupations are directly relevant to defence supply chains, including:
- engineering technicians;
- welding trades;
- metal working production and maintenance fitters;
- electrical and electronics technicians;
- sheet metal workers; and
- boat and ship builders and repairers.
Defence is therefore not receiving a separate sector-specific solution. Instead, it may benefit indirectly because other sectors have made the case for occupations that defence employers also use.
This is helpful in the short term, but it creates a risk. Defence employers should not rely on the fact that these roles will remain eligible simply because they are important to national capability. Continued access is likely to depend on improved Jobs Plans and evidence that sectors are taking credible steps to develop the domestic workforce.
What does this mean for other sectors?
Office-based occupations such as marketing associate professionals, financial and accounting technicians, business sales executives, IT operations and IT user support technicians and certain business associate professional roles were among those considered less suitable for the new TSL list. The MAC’s view was that these roles often rely on relatively transferable skills that may already exist in the UK labour market or can be developed through workplace training.
For HR and recruitment teams, the practical issue is that a role which is eligible for sponsorship today may not remain eligible under the future list that is very likely to be accepted by the UK Government. This could affect current recruitment campaigns, candidates already in the onboarding process and medium-term workforce plans, especially for Graduate level roles.
The MAC has also indicated that it will monitor visa use, including whether employers begin using alternative occupation codes after their usual codes become ineligible. The selected SOC code must therefore accurately reflect the worker’s actual duties and responsibilities.
The overall message is not that international recruitment is ending. It is that access is becoming more selective, temporary in nature and more closely connected to skill level. Employers should immediately check whether potential roles can be sponsored for visas after 1 January 2027.
What happens in June 2028, after the 18-month period?
Before access to the new TSL expires, the MAC proposes a lighter-touch review. Updated Jobs Plans from industry could be considered from October 2027, with further recommendations made in early 2028. Occupations with convincing evidence of progress could potentially have their access extended to three years. Those without improved plans may lose access after June 2028.
In other words, the 28 recommended occupations have not been promised a permanent place. The quality of the next Jobs Plans may be decisive.
There is also continuing uncertainty about salary requirements and whether workers sponsored in TSL occupations will retain the same route to settlement. The MAC has indicated that its proposed salary approach may need to be revisited if TSL roles continue to lead to settlement.
What should employers do now?
Employers should consider taking the following steps:
- Review workforce planning for 2026 and 2027 – submit any potential or pending Skilled Worker applications (for medium-skilled roles) before 31 December 2026.
Where a role qualifies under the current arrangements but may not qualify under the future TSL, employers should take advice on whether an application can and should be made before the rules change. Identify any current employees on Graduate Visas or new hires at entry level roles as these are most likely to use the TSL.
- Immediately audit current employees sponsored on the TSL.
Identify candidates who are currently sponsored under the TSL whose roles may no longer qualify for Skilled Worker visa extension under the TSL if the MAC’s recommendations are implemented from January 2027. - Map TSL sponsored visa roles against the new reduced TSL
Identify which current employees and planned hires are in medium-skilled occupations and check whether their codes appear on the recommended TSL and the impact if their role falls off the current list. - Keep evidence of workforce investment
Record recruitment difficulties, unsuccessful advertising, apprenticeship programmes, training expenditure, retention initiatives and partnerships with colleges or training providers as this may help future Job Plans. - Build immigration into workforce planning
Immigration should not be addressed only after a preferred candidate has been selected. HR, recruitment, finance and operational teams should consider sponsorship eligibility when roles and hiring budgets are first approved.
How We Can Help
The TSL may preserve visa sponsorship options for some employers, but it should not be treated as a long-term guarantee.
Defence employers are currently benefiting from their overlap with advanced manufacturing and other priority sectors. Employers in construction, clean energy, digital technology and critical infrastructure may also benefit from the recommendations, but they face the same need to plan for future change.
Our Immigration team can help employers:
- audit their sponsored workforce and recruitment pipeline;
- check Standard Occupational Classification (SOC) code selection and role eligibility;
- identify roles that may be affected by the proposed changes;
- consider the timing of future Skilled Worker applications;
- review salary and settlement implications; and
- develop a sponsorship strategy that supports wider workforce planning.
If your organisation recruits internationally into medium-skilled roles, now is the time to review which positions may be protected, which may be at risk and what action can be taken before the proposed changes take effect.
If you would like to discuss how these changes above may affect your organisation, please contact our immigration team.
