IMPACT – HIGH

The Home Office implemented a new simplified travel system and modified the entry requirements for individuals traveling to England and removed countries from the red-list.

Red-list travel requirements:

  • Only British nationals, Irish nationals or those with residence rights in the U.K. will be allowed to enter England if they have been in a red-list country within 10 days of arrival.
  • Individuals who are able to enter England from a red-list country regardless of their vaccination status must:
    • Take COVID-19 test within three days before departure.
    • Book a quarantine hotel package and take two additional COVID-19 tests.
    • Complete the passenger locator form within 48 hours of arrival.
  • More information regarding red-list travel requirements can be found here.

Rest of world travel requirements:

  • Fully vaccinated individuals who are traveling to England from a country not on the red list must:
    • Book and pay for a COVID-19 test to be taken on or before day two of arrival.
    • Complete the passenger locator form within 48 hours of arrival.
  • Individuals who are not fully vaccinated and who are traveling to England from a country not on the red list must:
    • Take COVID-19 test within three days before departure.
    • Book and pay for two additional COVID-19 tests to be taken on or before day two and on or after day eight of arrival.
  • Quarantine for 10 days.
    • Complete the passenger locator form within 48 hours of arrival.
  • As of Oct. 11, the red list includes: Colombia, Dominican Republic, Ecuador, Haiti, Panama, Peru and Venezuela.

Additional Information: Children under the age of five who are traveling from a red-list country are exempt from testing requirements but must carry out the mandatory quarantine. Travel requirements for Northern Ireland, Scotland and Wales may be different than the requirements for England. More information regarding travel from a country not on the red list and who qualifies as fully vaccinated can be found here.

BAL Analysis: The Home Office intends to simplify the travel requirements for those traveling to the U.K. Travelers should check the territory specific requirements before planning travel to the U.K. The response to the COVID-19 pandemic continues to develop, and BAL will provide additional updates as information becomes available.

This alert has been provided by the BAL Global Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The Home Office has updated its employer guidance for right-to-work checks for European Union Settlement Scheme (EUSS) applicants.

Key Points:

  • The updated guidance temporarily protects EUSS applicants and their family members who submitted applications after the June 30 deadline from losing their working rights and residence while the government processes their applications.
  • EUSS applicants and family members may now seek new employment while they wait for an application determination.
    • Before employment starts, employers should use the Employer Checking Service and the prospective employee’s Certificate of Application to confirm a valid application was submitted on or after July 1.
  • The guidance added more documents that EUSS applicants can use to meet the right to work requirements. The additions can be found in List B of Annex A here.

Additional Information: EEA citizens and family members must have valid immigration status in the U.K. From July 1, aside from Irish citizens, such individuals can no longer use their EEA passport or identity card to prove their right to work. Due to COVID-19, the Home Office has recently extended the temporary right to work check measures, allowing employers to continue checking right to work documents online.

BAL Analysis: Employers should review the recently published guidance and note the new acceptable documentation for right to work checks to ensure they are adhering to correct practices and procedures. BAL will continue to follow these changes and will provide more information as it becomes available.

This alert has been provided by the BAL Global Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The Home Office has published a Statement of Changes in the U.K. Immigration Rules outlining changes to its immigration system.

Key Points:

  • Beginning Oct. 1, European Economic Area and Swiss nationals will no longer be able to use national identity cards to enter the U.K. and will need to use a passport instead.
  • Beginning Oct. 6, all applicants who apply for any visa while in the U.K. must remain in the U.K., Ireland, Isle of Man or the Channel Islands from the date of submitting the online form until the application is decided.
  • Beginning Jan. 1, 2022, the Youth Mobility Scheme will be available to applicants from Iceland and India. There will be additional qualifying criteria for Indian applicants, including the need to have a degree level qualification or three years of skilled work experience.

Additional Information: The Home Office will provide additional updates and guidance on the new rules in the coming months.

BAL Analysis: Non-EU citizens with a Biometric Residence Permit (as well as EU citizens) applying for a Skilled Worker Visa or Student Visa from within the U.K. on or after Nov. 30, 2021, will be able to use the U.K. Immigration ID Check app. If they do, they will not need to attend an appointment and will receive a digital immigration status. BAL will continue to follow changes to the U.K. Immigration Rules and will provide more information as it becomes available.

This alert has been provided by the BAL Global Practice Group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

IMPACT – HIGH

The Home Office has extended the temporary right to work check measures until April. 5, 2022.

Key Points:

  • The temporary measures will remain in effect until April, 5, 2022. This means:
    • Checks can be conducted over video calls.
    • Job applicants and existing workers can send scanned documents or photos of documents for checks through emails or a mobile app. Original documents are not required.
    • Employers should use the Employer Checking Service if a prospective or existing employee cannot provide any of the accepted documents.
  • After April 5, 2022, employers must:
  • Employers do not need to carry out retrospective checks on those who had a COVID-19 adjusted check between March 30, 2020, and April 5, 2022 (inclusive).
    • It is still an offense to work illegally in the U.K.; any individual who is working illegally because of their immigration status may be subject to enforcement action.

Additional Information: If the job applicant or existing worker cannot show their documents, employers must contact the Home Office Employer Checking Service. If the individual has a right to work, a “Positive Verification Notice” will be sent which provides a statutory excuse for six months from the date of the notice.

The Home Office has indicated it is developing a post-pandemic solution such that all employees will be able to demonstrate a right to work online. This would mean, for example, that British and Irish citizens would not need to provide their original documents and may mean the end of all physical document checks.

BAL Analysis: The extension of the temporary measures will benefit those who have been conducting modified right to work checks since March of 2020. However, employers are reminded to take note of the April 5, 2022, date for when temporary measures are set to end. BAL will continue to monitor right to work check measures and will provide more information as it becomes available.

This alert has been provided by the BAL Global Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

The U.K. government recently announced that it would update the red, amber and green lists on Aug. 30.

Key Points:

  • Canada, Denmark, Finland, Liechtenstein, Lithuania and Switzerland will be moved to the green list on Aug. 30.
    • Individuals may travel to the U.K. if they have been in a green list country for at least 10 days.
    • Individuals traveling from green list countries must take a COVID-19 test within 72 hours of departure, schedule a COVID-19 test for day two of arrival and complete the passenger locator form.
  • Montenegro and Thailand will be moved to the red list on Aug. 30.
    • Individuals who have been in a red list countries with 10 days of intended travel to the U.K. are barred from entering the country unless they are British or Irish nationals or have residence rights in the U.K.
    • Individuals permitted to enter the U.K. from a red list country must take a COVID-19 test within 72 hours of departure, book a quarantine hotel package and complete the passenger locator form.

Additional Information: A number of countries are at risk of being moved to the amber list. Unvaccinated travelers from amber list countries must quarantine for 10 days; vaccinated travelers must take a COVID-19 test on or before day two of arrival.

BAL Analysis: The response to the COVID-19 pandemic continues to develop, and BAL will provide additional updates as information becomes available.

This alert has been provided by the BAL Global Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries, please contact copyright@bal.com.

In the recently published UK Innovation Strategy, the Home Office announced that two new immigration routes are forthcoming and that it will revitalize the Innovator route.

High-Potential Individual route:

  • This new route will make it easier for high-potential foreign nationals who have graduated from top global universities to enter the U.K. with no job offer.
  • The route will give individuals the ability to work, change jobs and contribute to the U.K. economy, as well as extend their visa to stay in the country.

Scale-up route:

  • This new route will allow foreign nationals with a high-skilled job offer from a designated scale-up business who meet the required salary level to enter the U.K.
  • Businesses are considered scale-ups if they can prove an annual average revenue or employment growth rate over a three-year period greater than 20% and have a minimum of 10 employees at the start of the three-year period.

Revitalized Innovator route:

  • Applicants will now only need to show that their business venture is innovative, has a high potential to grow and adds value to the U.K.
  • Applicants will no longer be required to have GBP 50,000 in investment funds to apply through the Innovator route.
  • Applicants that have been accepted on the Global Entrepreneur Program will be automatically eligible for this route.

Background: The U.K. says it is promoting innovation to enhance productivity across its economy and bring jobs, growth and prosperity to the entire country. The U.K. Innovation Strategy outlines how the government will accomplish these goals by bolstering businesses, people, institutions and technologies. More information on the U.K. Innovation Strategy can be found here.

BAL Analysis: The new immigration routes are designed to improve the U.K. immigration system and compete in the global labor market. BAL will continue to monitor the implementation of these routes and will provide additional information as it becomes available.

This alert has been provided by the BAL Global Practice group. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

The Home Office recently exempted certain senior executives traveling to the U.K. from quarantine requirements.

Key Points:

  • Two categories of senior executives traveling from amber- and red-list countries can temporarily leave quarantine if they are carrying out activities of “significant economic benefit” to the U.K.
    • Multinational executives. This group includes executives working for a multinational business based in another country who are visiting U.K. branches or subsidiaries.
    • International executives. This group includes executives working for a company based in another country who are seeking to invest in a U.K.-based business or establish a new business within the country.
  • Senior executives must complete a Business, Jobs and Investment Exemption Notification form and send it to businessjobsandinvestmentexemption@beis.gov.uk before travel. A letter should be received within five business days approving the exemption or requesting for additional information. If approved, the letter must be shown to Border Force officers when entering the U.K.
  • More information and specific guidance on eligible business activities can be found here.

Additional Information: Foreign national senior executives will not qualify for the exemption if their activities can be completed remotely or by someone not required to quarantine, including those traveling from green-listed countries. All other entry requirements remain in place for senior executives traveling to the U.K.

“Significant economic benefit” is defined as having greater that a 50% chance of creating or preserving at least 500 U.K.-based jobs in an existing or new U.K.-based business.

BAL Analysis: The new exemption policy enables senior executives to carry out business activities without having to stay in quarantine. BAL is able to assist individuals who may qualify for the quarantine exemption.

This alert has been provided by Berry Appleman & Leiden LLP. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

The Home Office officially opened the new Graduate immigration route on July 1, 2021.

Key Points:

  • U.K. graduates from higher education institutions can now apply for a two- or three-year visa enabling approved individuals to stay and work in the U.K.
  • Eligibility requirements include:
    • Applicants must hold a valid Tier 4 or Student visa and have received a degree at the undergraduate level or above from a Higher Education Provider with a track record of compliance to meet eligibility requirements.
    • The education program must have been started and finished entirely in the U.K.
    • Applicants must have completed the qualification named on the Confirmation of Acceptance for Studies (CAS) that corresponds with the Student or Tier 4 visa.
  • Applications can be submitted once the university has sent final course results; applicants do not need to wait until graduation to apply.
  • Applications must be submitted while in the U.K. and applicants should not leave the country or Common Travel Area while the application is being processed.

Additional Information: If an applicant’s visa expired after a Graduate route application is submitted, the applicant can remain in the U.K. until a decision is made. The new route was initially announced in March of this year as part of the U.K. government’s switch to a points-based immigration system.

BAL Analysis: The Graduate route provides international students additional time to work in the U.K. following graduation and serves as a pathway to apply through the Skilled Worker route.

This alert has been provided by Berry Appleman & Leiden. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

The United Kingdom has implemented a new process for employers completing right-to-work checks on EU, EEA, and Swiss nationals.

Key Points:

  • As of July 1, employers can no longer accept EU/EEA/Swiss passports or ID cards as proof of an applicant’s right to work in the U.K. Instead, they must check the applicant’s right to work online using a share code and their date of birth.
  • The change applies to all EU/EEA/Swiss nationals with the exception of Irish nationals. Irish nationals can continue using their passport, or other valid documents, as proof of their right to work.
  • Employers are not required to complete retrospective right-to-work checks for EU/EEA/Swiss nationals who started employment before July 1.
  • Between now and Dec. 31, employers do not need to terminate employment if they learn that the immigration status of an EU/EEA/Swiss employee hired before July 1 has lapsed because he or she did not apply for the EU Settlement Scheme by the June 30 deadline.
  • In these cases, employers should advise the employee to apply for the EU Settlement Scheme within 28 days. Late applications may be accepted if an applicant has reasonable grounds for missing the deadline. Employers should ask the employee to provide them with a Certificate of Application (CoA). Employers then must contact the Home Office Employer Checking Service (ECS) to confirm the individual has applied. Full guidance on this process is available here.

Background: U.K. employers are required to conduct a right-to-work for all new employees.

Generally, an online check is required for applicants who have digital proof of their immigration status, including most EU/EEA/Swiss nationals. Manual checks of passports or other valid documents can be completed for U.K. and Irish nationals. Manual checks are also required for foreign nationals who cannot prove their immigration status online, including most non-EU/EEA/Swiss visa holders.

Temporary COVID-19 measures in place until Aug. 31 allow employers to conduct right-to-work checks over video calls with scanned or photographed documents sent via email or mobile app. Additional information on the temporary measures is available here.

BAL Analysis: Employers are encouraged to review their internal right-to-work check procedures to ensure they are in compliance with the new rules for EU/EEA/Swiss nationals. Employers are also reminded that temporary COVID-19 measures on right-to-work checks are set to expire after Aug. 31. BAL is able to assist employers in ensuring they remain in compliance with current procedures.

This alert has been provided by Berry Appleman & Leiden. For additional information, please contact berryapplemanleiden@bal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.

IMPACT – HIGH

The Home Office has extended the temporary guidelines for right-to-work checks until Aug. 31.

Key Points:

  • The temporary guidelines will remain in effect until Aug. 31. This means that until then:
    • Checks can be conducted over video calls.
    • Job applicants and existing workers can send scanned documents or photos of documents for checks through emails or a mobile app. Original documents are not required.
    • Employers should use the Employer Checking Service if a prospective or existing employee cannot provide any of the accepted documents.
  • Beginning Sept. 1, employers must either:
  • Employers do not need to carry out retrospective checks on those who had a COVID-19 adjusted check between March 30, 2020, and Aug. 31, 2021.

Additional Information: If the job applicant or existing worker cannot show their documents, employers must contact the Home Office Employer Checking Service. If the individual has a right to work, a “Positive Verification Notice” will be sent, which provides a statutory excuse for six months from the date of the notice.

For right-to-work checks from July 1, EEA citizens can no longer rely on an EEA passport or national identity card (aside from Irish citizens). EEA citizens will evidence their right to work by sharing their immigration status digitally through the Home Office online right-to-work service or by providing accepted physical documents. More information on EEA citizens’ right-to-work checks can be found here and here.

BAL Analysis: The extension of the temporary measures will benefit those who have been conducting modified right-to-work checks since March of 2020. However, employers are reminded to take note of the Aug. 31 date for when temporary measures are set to end.

This alert has been provided by Berry Appleman & Leiden. For additional information, please contact berryapplemanleiden@balglobal.com.

Copyright © 2021 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@balglobal.com.