16.While the new immigration policy will, according to the Government, mean that a “wide pool of skilled workers will be able to come to the UK from anywhere in the world”, as Kevin Foster said:
We can give migration routes, but we also have to be conscious in the back of our minds that we are in a competitive global market for highly trained and highly qualified people. They can go elsewhere.
17.Applications under the new immigration policy for the “Skilled Worker” visa opened on 1 December 2020 (so replacing the “Tier 2” visa of the previous immigration system). Compared to the previous equivalent visa requirements for skilled non-EEA workers, the proposed salary and skills levels of the replacement Skilled Worker visa (applicable for both EEA and non-EEA skilled workers) are lower: the salary requirement will be £25,600 (compared to £30,000 under the Tier 2 visa), and the skill level will be RQF3/SCQF6—equivalent to A-levels or Scottish Highers or similar (whereas the Tier 2 visa requirement was the equivalent of bachelor degree level). These changes were welcomed by the NFU who described it as “movement in the right direction, with the potential for flexibility on salary created by tradeable points being welcome”, a view shared by the FDF. However, the NFU stated that “it is a disappointing characteristic of the PBS that it devalues vocational skills, which often provide a far more tangible and economically valuable business contribution to Agriculture and Horticulture businesses”.
18.Kevin Foster said that under the new immigration system “we are going from a very academically focused level of skilled worker, graduate level, to school leaver level. It is broadening into a much greater range of genuine skills that people find in the workplace”.
19.The immigration policy will mean that the same administrative processes and fees will apply to EEA skilled workers as to those from the rest of the world:
20.Tim Rycroft, Chief Operating Officer, FDF, said that while there was no reason the PBS should “disadvantage the UK against its competitors” in principle, “because of the additional costs relative to our competitors and the additional bureaucracy, it does disadvantage us”. NFU Scotland stated that it was “concerned that the cost of sponsorship is prohibitively expensive in terms of both financial and administrative burden”.
21.In comparing the new Skilled Worker visa to the previous arrangements for Tier 2 visas (applicable to skilled workers from outside the EEA), Kevin Foster highlighted that the Government was “removing the resident labour market test, which is quite burdensome”, and also “suspending the cap in terms of the skilled worker visa, which will make it slightly simpler for those going through the recruitment process”. The effect of these two changes alone, he said, would be to “drop the time to bring a skilled worker into the UK by eight weeks”. Other changes highlighted included allowing applications to be made via a smartphone app, rather than having to visit a visa application centre, as part of the Government’s drive to “reform and simplify the sponsorship process”.
22.If a skilled worker can demonstrate that they have a job offer in an occupation listed in the Shortage Occupation List, then the immigration policy permits a salary lower than the minimum salary threshold of £25,600 to be paid (but no less than £20,480, or 80% of the going rate for the occupation, whichever is higher). The inclusion of an occupation on the SOL is subject to a recommendation of the Migration Advisory Committee (MAC) being accepted by the Government. The MAC will recommend adding an occupation to the SOL “where employers find it problematic to secure adequate numbers of workers with the required skills to fill their vacancies and where we judge that migration is a sensible response to that shortage”.
23.The MAC also determines the skill level required for an occupation, “based on the length of time it would take to train a new entrant to become fully competent in the performance of the tasks associated with a job”—skill levels “refer to the occupation rather than the person employed in that occupation”. As such, the MAC will make a recommendation on which occupations it determines have a skill level of RQF3/SCQF6 and therefore can be open to applications from migrant workers through the Skilled Worker visa route.
24.In September 2020, the MAC published its latest review of the SOL and recommended the addition of “around 70 entire occupations, or job titles within them […] for inclusion on the SOL, either at a UK-wide or Devolved Nation level”, including veterinary nurses, meat hygiene inspectors, jobs in the fishing industry, and butchers. It also called for two roles in the food supply chain (vent chick sexers, and deckhands on large fishing vessels) to be classified at RQF level 3 and therefore eligible for the Skilled Worker visa. However, the Government did not implement the changes, instead preferring to “pause” and assess changes in the UK labour market develops particularly in the light of how quickly the economy recovers from the covid-19 pandemic and the commencement of the new immigration policy.
25.The UK is competing globally for skilled labour, the availability of which is vital to the ongoing success of the UK food supply chain. It is important therefore that bureaucracy and fees are minimised, and their impact kept under review. We are concerned that many potential candidates from EEA countries may prefer to work in other countries within the European Single Market exercising their rights of freedom of movement. We welcome measures taken by the Government to reduce both the skill and salary level for the Skilled Worker visa, compared to the Tier 2 visa, as more food supply chain roles will now be eligible. However, we are disappointed that the Government decided not to implement the Migration Advisory Committee’s latest review of the Shortage Occupation List prior to the start of the new immigration policy. Defra and the Home Office should consult food supply chain businesses during the first half of 2021 on the impact of the PBS and associated paperwork and fees to ensure that they are able to recruit sufficient staff from overseas where this is necessary so to do. They should provide the Committee with the outcomes of those consultations before the summer recess. The Government should reconsider its decision not to implement the Migration Advisory Committee’s latest Shortage Occupation List review to help ensure that food supply chain businesses can secure the labour they need.
26.The British Veterinary Association (BVA) highlighted the work in abattoirs of Official Veterinarians (OV), vets who work on behalf of the Government to “both certify and supervise the import and export of animals and animal products to and from third countries”. It describes their role as “vital” to protecting public health, food safety, animal health and animal welfare. Furthermore, the end of the Brexit transition period was likely to lead to a marked increase in the workload of OVs, as they would be required to provide Export Health Certificates for all exports of products of animal origin to the EU. Simon Doherty, then Senior Vice President of the BVA, told us that “roughly 95% of vets working in abattoirs and meat plants are EEA-qualified nationals”. He highlighted the working conditions of OVs as a factor: “the vast majority of us apply to go and study in veterinary school to come out and go into general practice and work as clinicians. It is a select part of the profession that would choose to get up at 4 o’clock or 5 o’clock in the morning and go and stand at the meat plant. It is a different type of work”. The benefit for vets from the EEA was that OV work may lead to clinical practice work, although he questioned under the new immigration policy “how easy it would be for them to change jobs—change roles”.
27.Simon Doherty said that from the current position of “already having a shortage, we are then looking at significant problems if we have anything that will affect the supply of vets coming in from the EEA to work in the UK”. The BVA’s particular concerns were that:
Any additional barriers to the movement of EEA-qualified vets to the UK have significant consequences for animal health, animal welfare, public health, and trade […] A visa-based system will place significant administrative and financial burdens on veterinary businesses, who will be required to sponsor recruits from outside of the UK. Furthermore, if the UK establishes additional barriers this could make other countries within the EEA more attractive for EEA vets.
In addition, Simon Doherty said that the “complete lack of clarity about how many vets we will need to do export health certification” was making him “not very confident at all that we can adequately plan our workforce”.
28.Victoria Prentis MP, Parliamentary Under Secretary of State at Defra, told us that Defra had “provided funding for training for vets to become OVs” which had helped increase the number of OVs from “around 600 people […] less than two years ago to double that now” and that “the number of vets in the country is something we need to keep a close eye on”. Kevin Foster said that “immigration should be about where you cannot recruit. For example, technical vets are one of the things regularly talked about in the sector of food production where we do not train enough here in the UK. That is something we need to resolve to get more people into those types of careers”. He added: “I accept that that is a five or six-year training course. Even if everyone wanted to be a vet today, they could not start doing that job for a number of years”. The Government had also taken steps to reduce the workload of vets, such as introducing paraprofessionals such as Certification Support Officers in order to reduce the burden of work for OVs.
29.The example of the veterinarian sector highlights the important role that overseas-trained employees undertake in the food supply chain, in this case working in abattoirs that are unattractive to UK-trained vets. In addition, these Official Veterinarians face an increase in their workload due to increased checks on exports as a result of Brexit. These factors, combined with the fact it takes several years to train vets, risk creating a situation where there is insufficient veterinary labour, without which animal products cannot be cleared for export.
30.For those employing skilled workers, it is important to ensure that pay and conditions reflect the nature of the work in order to help attract more UK workers into the food supply chain. For example, the Government’s work to increase the number of Official Veterinarians and introduce Certification Support Officers is welcome although questions remain about whether they go far enough to meet the increased workload after the end of the transition period. Both Government and business have a role to play in ensuring that skilled work in the food supply chain is an attractive career option in order to address some sub-sectors’ reliance on migrant staff. However, in the short to medium-term the Government, in designing its policy, must also be more conscious of the time and investment it takes to train new skilled workers, especially professionals such as vets. This is particularly important when the industry faces substantial uncertainty such as new rules on trade and the impact of the pandemic. It should closely monitor the impact of the new immigration policy on the supply of skilled workers in the food supply chain and make immediate adjustments if bottlenecks emerge.
37 HM Government, (February 2020), p5, para 5;
38 Points-based immigration system opens, , 1 December 2020
39 HM Government, (February 2020), p5, paras 4–5
40 National Farmers Union () para 7; Food and Drink Federation () para 12
41 National Farmers Union () para 13
43 Under freedom of movement, skilled workers from the EEA could work in the UK without the need for a visa or the payment of any fees. Non-EEA skilled workers coming to the UK before 1 January 2021 were already subject to visa-related paperwork and fees.
44 HM Government, (November 2020), pp3, 10 and 12,
45 For occupations listed on the SOL, the rates are reduced to £464 for stays of up to three years or £928 for stays of more than three years. In addition, for all the application fee rates, citizens of the EU and certain other countries qualify for a £55 reduction.
46 GOV.UK, ‘’, accessed 14 December 2020
48 NFU Scotland () para 20
52 HM Government, (July 2020), p18, Table 1
53 Migration Advisory Committee, (September 2020), pp12–13
54 Migration Advisory Committee, (September 2020), p17
55 Migration Advisory Committee, (September 2020), p17, pp638–641, Table 9.1, p644, para 9.17
56 Home Office, (23 October 2020)
57 British Veterinary Association () para 9
58 British Veterinary Association () para 9
59 The BVA notes that “The final details of the UK’s future relationship with the EU, including the operation of the Northern Ireland Protocol, are unknown. However, it appears likely that these requirements for goods moving from Great Britain to the EU Single Market will apply to goods entering Northern Ireland. Therefore, EHCs would likely be required (British Veterinary Association () para 20).
64 British Veterinary Association () paras 24–26
68 British Veterinary Association () paras 36–37