The Rt Hon Shabana Mahmood MP
Secretary of State for the Home Department

03 November 2025

Dear Home Secretary,

Congratulations on your appointment. I wish you every success as you take on this important role at such a pivotal time for our country. As you begin your tenure, I hope we can work constructively together on matters affecting the nursing workforce and the wider health and care system.

As the world’s largest professional college and trade union for nursing, representing over 560,000 members, the Royal College of Nursing (RCN) advocates for the interests and welfare of nursing staff—who are essential to the health and wellbeing of our nation.

A quarter of all nurses on the Nursing and Midwifery Council (NMC) register are internationally educated. The RCN also represents a large number of nursing support workers, who play a vital role in health and care but are not required to register with the NMC. All these staff make an invaluable contribution to health and care services across the UK, and their skills, compassion and dedication must be recognised and protected.

Many of these colleagues joined the UK workforce during the Covid-19 pandemic, answering the call at a time of national crisis. They worked on the frontlines, often in unfamiliar systems and under extraordinary pressure, to care for our communities. Their contribution was vital to the country’s pandemic response, and they deserve policies that reflect the value of their service, not ones that make their future here more uncertain.

At the same time, the pandemic laid bare the fragility of health systems worldwide and deepened long-standing workforce shortages. Today, countries across the globe are facing a critical shortfall in nursing staff, and the UK is no exception. But our response must be both sustainable and ethical. While we must invest in growing our domestic pipeline of nurses and nursing support workers, we also have a duty to protect and support those who are already here–many of whom are now experiencing discrimination, uncertainty, and harm as a result of recent immigration policy changes.

This is particularly urgent given the concerning rise in xenophobic and anti-migrant sentiment in recent years. Immigration policymakers have a responsibility to avoid fuelling harmful and divisive narratives around migration. Nursing is a profoundly diverse profession, and the strength of our health and care services depends on the inclusion and wellbeing of all staff. Against this backdrop, the Government’s White Paper, Restoring control over the immigration system, published in May, proposed a number of changes which are therefore of deep concern to the RCN.

This includes the doubling of the qualifying period for Indefinite Leave to Remain (ILR) from five to ten years. The suggestion that such changes could apply retrospectively to those already living and working in the UK is unacceptable and has already caused alarm among our internationally educated colleagues. Many of these staff have long been embedded in our health and care services, having stepped into critical roles during some of the most challenging periods in recent history. Any extension to the qualifying period risks prompting an exodus of these critical staff, which would be catastrophic for workforce retention at a time when health and care services are already under immense strain. These colleagues are part of our communities, our hospitals, our care homes. They have built lives here, contributed to our society, and deserve security and respect –they deserve a faster, not longer, route to settlement.

The White Paper also proposed raising the skills threshold for all Skilled Worker visa routes from RQF Level 3 to RQF Level 6. While certain occupations, including nursing support worker roles (under occupation code 6131: nursing auxiliaries and assistants), are 
temporarily exempt, no impact assessment has been published to consider the longer-term implications of this policy on workforce planning. Care worker visas have also been closed to new entrants.

We recognise the need to reduce overreliance on international recruitment and to build a stronger domestic pipeline of nurses and nursing support workers. However, this will require sustained investment and innovation to make health and care careers more attractive and accessible to people across the UK. These efforts must also be matched by a realistic understanding of current workforce pressures. Immigration policy must not destabilise services in the short term, nor penalise those who are already contributing so much. We continue to urge the Government to ensure that departments work collaboratively to understand and mitigate the impact of immigration rule changes on the delivery of health and care.

We are also concerned about the effect of the immigration salary threshold increase introduced in April 2025. The threshold now stands at £25,000. For Band 3 staff in England on the first salary point, the 2025–26 NHS pay award leaves them just £63 short of this requirement. In Northern Ireland, where a pay agreement for 2025–26 has not yet been reached, no Band 3 roles currently meet the salary threshold. These changes risk making it even harder to recruit and retain essential staff, leaving remaining colleagues under growing pressure, with inevitable consequences for care standards, morale, and staff wellbeing. We have included in our submission to the consultation on the Budget that to protect the stability of the workforce, internationally recruited nursing staff on AfC Band 3.1 should be paid at least an additional £63 per annum to meet visa requirements.

Through a Freedom of Information request earlier this year, we found that nearly 15,000 staff with a non-British nationality are currently working in Band 3 point 1 roles. Yet the Government has not published an assessment of how many individuals could be affected by the threshold increase. The RCN has already been contacted by members fearful about their future in the UK. Band 3 staff on one-year visas are unable to renew their visa if it expires before they reach the next pay point, staff are unable to change employer, and those on graduate visas are unable to switch to a skilled worker visa once their current visa ends. Nursing support staff are vital to the functioning of the workforce, and these policies put them—and the services they underpin—at risk.

Finally, we welcome the White Paper’s commitment to tackle exploitation in the care sector, including by making it easier for care staff to move between licensed sponsors. Earlier this year, our members voted at RCN Congress for the College to lobby the UK Governments to develop measures that will reduce the effects of human trafficking, and we will continue to hold you to that commitment in the months ahead. During the General Election campaign, the Labour Party committed to an investigation into exploitation in the care sector to be led by the Fair Work Agency. However, immediate action is required. Staff continue to face exploitative practices, including extortionate repayment clauses designed to trap workers in contracts, illegal recruitment fees, and sub-standard terms and conditions. 

Nurses also have a crucial role to play in identifying victims of trafficking as over 80% of trafficking survivors seek medical care within the first year of being trafficked. Earlier this year at our Annual Congress, RCN members voted to campaign against human trafficking. We urge you to take action to address this issue, and ensure that protections are in place for victims. As the Border Security, Asylum and Immigration Bill passes through final stages of parliament I urge Government to consider the impact of the Bill. In particular the retention of Section 29 of Illegal Migration Act 2023 disapplies protections previously afforded to victims of modern slavery and human trafficking, and I am concerned will make it less likely for victims to come forward.

I would welcome the opportunity to meet with you to discuss these issues further, and to explore how the Home Office can work with the Department of Health and Social Care to ensure that immigration policy supports, rather than undermines, the health and care workforce.

Yours sincerely

Professor Nicola Ranger
General Secretary & Chief Executive