New Immigration Rules affecting the Student and Child Student Visa Routes

Updated 18/11/25

Child Student Visa Route – Clarifications to the Safeguarding Rules

As outlined in our previous update, New Safeguarding Rule Changes for Child Student Visa Sponsors: What You Need to Know - Doyle Clayton, the Home Office introduced measures from 29 May 2025 designed to strengthen child safeguarding and ensure that sponsored Child Students are placed into appropriate care and living arrangements in the UK.

Updated List of Permitted UK Living Arrangements

The Child Student Visa Rules have been updated to confirm the permitted UK living arrangements for Child Student visa applicants, reducing the number from six to four. The new ‘UK Living Arrangement’ provisions now helpfully amalgamate the different types of permitted boarding arrangements under a single boarding category of the Child Student Visa rules. These provisions also formalise a previous concessionary arrangement whereby sponsored Child Students who are flexi and weekly boarders are also allowed to be in the care of a ‘Nominated Guardian’ when they are not staying at their residential boarding school.

Under the new Child Student Visa Rules, the Parental Consent letter must specifically confirm which UK living arrangements their son or daughter will enter into in the UK. According to paragraph 12.10 of SSG, sponsors must also ensure that students they sponsor on the Child Student Visa route enter into one of the following four permitted UK living arrangements.

1. Full, weekly or flexi boarding at a residential independent school, and during the period they are not boarding at the school staying with either:

• A Nominated Guardian (for a period of less than 28 continuous days) who is a British Citizen or settled in the UK; or
• A private foster carer who is a British Citizen or settled in the UK; or
• A close relative who is a British Citizen or settled in the UK; or
• Their parent who has permission as a Parent of a Child Student.

2. Living full time with a private foster carer or close relative who is a British Citizen or settled in the UK.

3. Living full time with a parent or legal guardian who has permission as a Parent of a Child Student

4. Aged 16 or 17 and living independently

UK Living Arrangements Inserted in Evidence Used to Base Offer Section on Child Student CAS

Child Student sponsors should now confirm which permitted UK living arrangement the Child Student will enter into when assigning the CAS. Paragraph 3.12 of SSG states that sponsors should add this to the ‘Evidence Used to Base Offer’ field of the Child Student CAS. With measures introduced from 29 May 2025 to strengthen child safeguarding, Child Student sponsors were initially directed to confirm the permitted UK living arrangement by adding a Sponsor Note on the CAS.

Limited Flexibility with Permitted UK Living Arrangements

The latest version of the SSG also provides some helpful clarity on acceptable short term changes to the core permitted UK living arrangement, as approved by the Home Office at Child Student visa application stage. Paragraph 12.11 of the SSG now states as follows:

“Regardless of the term time arrangement, it is acceptable for students to stay with their parents in the UK outside of term time (for example, if they are visiting the UK), return home, or stay in school provided the school is still open with staff members present. Provided the core arrangement remains the same, Child Students are also able to have other brief care arrangements with the consent of their parents or legal guardian. This could include attending a school trip or staying with a friend for the weekend.”

Paragraph 12.12 of SSG further notes: “Sponsoring schools should have sufficient oversight of their students living arrangements to satisfy themselves that their students have appropriate care and accommodation in place and that these meet the requirements above.”

Accordingly, provided a Child Student sponsor obtains written parental consent and the school is fully aware of the brief change in the Child Student's UK care arrangements, a temporary change to the core permitted UK living arrangement should not be considered a breach of sponsor duties.

Reporting Changes to UK Living Arrangements

Paragraph 12.13 of the SSG has also been updated to confirm that Child Student sponsors must ensure a new Parental Consent letter (and Letter of Undertaking, if required) is obtained where a Child Student aged under 18 changes to a different permitted UK living arrangement after their Child Student visa is granted. Provided the new UK living arrangements falls under one of the four permitted UK living arrangements, it is not necessary to also report this change to the Home Office.

Where a Child Student changes to a UK living arrangement which is not permitted under the Child Student Visa Rules, however, this must be reported to the Home Office within 10 working days. A sponsor must include in their report to the Home Office what steps are being taken to rectify this.

Change to the Definition of a Nominated Guardian

As outlined in our previous update, New Safeguarding Rule Changes for Child Student Visa Sponsors: What You Need to Know, additional requirements were introduced from 29 May 2025 relating to ‘Nominated Guardians’. Introduced as a new definition to the Immigration Rules earlier in the year, a ‘Nominated Guardian’ was defined as a person who is a carer for a Child Student visa holder outside of term time for less than 28 days. This definition has since been further amended in the Immigration Rules to clarify:

• It is less than 28 ‘continuous’ days
• Nominated Guardians can care for Child Students during term time as well as outside term time
• Where the Child Student is a full, weekly or flexi boarder, a Nominated Guardian also cannot be a member of staff at their sponsoring school.

These are helpful changes as private foster care arrangements can be triggered (with a corresponding duty to notify the local authority) where a sponsored Child Student aged 15 and under is cared for by someone who is not their parent or a close relative for a continuous period of 28 days or more. This change helps clarify that a sponsored Child Student aged 15 or under may stay with a ‘Nominated Guardian’ for more than 28 days throughout a whole academic year (ie including school holidays) without triggering a private foster care arrangement – provided that they do not stay with their ‘Nominated Guardian’ for more than 28 consecutive days.

New Definition and Evidential Requirements for a ‘Guardianship Organisation’

Many overseas parents appoint a guardianship organisation to act on their behalf to ensure the safety and care of their son or daughter when studying in the UK. Guardianship organisations often provide a local homestay family for sponsored Child Student boarders outside of school term time. Indeed, paragraph 12.8 of the SSG now helpfully clarifies where a guardianship organisation arranges a ‘Nominated Guardian’, they will often refer to these arrangements as home stays or host families.

Where a Child Student will have a ‘Nominated Guardian’ arranged through such a guardianship organisation, the Home Office’s Student and Child Student Caseworker Guidance confirmed that a ‘named contact’ at the organisation can meet the ‘British Citizen or settled’ criteria of the Child Student Visa route. The Caseworker Guidance also set out what details the organisation needed to provide a Child Student visa applicant in their Letter of Undertaking.

The following changes were made to the Immigration Rules to now formally recognise the role of guardianship organisations in the care of sponsored Child Students in the UK and how the associated eligibility and evidential visa requirements of the Child Student Visa Rules can be met:

• A new definition was added to the Immigration Rules to describe a guardianship organisation. This is defined as “an organisation, with the approval of the Child Student’s parents, legal guardian or school, that arranges a nominated guardian for a Child Student.”
• A new paragraph was added to the Child Student Visa Rules to cover the information a guardianship organisation needs to provide where an applicant does not have details of their ‘Nominated Guardian’ when they apply for their Child Student Visa. The new provisions provide in this scenario that “the named contact on the Letter of Undertaking from the guardianship organisation must be a British Citizen or settled in the UK.” 
  • The Letter of Undertaking from the Guardianship organisation must also now contain the following information:
  • The name and contact details of a member of staff at the guardianship organisation who is a British Citizen or settled in the UK;
  • The name and address of the guardianship organisation;
  • The date the guardianship organisation was established; and
  • Confirmation that all guardians that the organisation uses have a current enhanced Disclosure and Barring Check (England and Wales), Protecting Vulnerable Groups Scheme (Scotland) or Disclosure and Barring Check (Northern Ireland).

Refusal on Criminality Grounds and Those Living with Nominated Guardians

Under the new Child Student Visa rules introduced in May 2025, a Child Student’s visa application can be refused if their ‘Nominated Guardian’ in the UK regularly lives with ‘anyone’ that has a criminal conviction. This provision has now been amended so that this ground of refusal only applies if the person living with the Nominated Guardian is an ‘adult’.

The change is a helpful clarification that this ground of refusal does not apply to children living with a Nominated Guardian. This change should hopefully reduce the number of UKVI further information requests asking Child Student visa applicants for additional information about children living in the same household as their Nominated Guardian.

The Child Student Visa Rules were also amended to confirm that the following details must be provided in the Letter of Undertaking about adults that regularly live with a Nominated Guardian, “details of the name, date of birth, registered address, contact details and, if they have one, national insurance number, of any adult regularly living with the Nominated Guardian.”

Duty to take Reasonable Steps to Check Child Student can meet Financial Requirement

Unlike in the Student Visa Route, there have been no changes to the financial requirements in the Child Student Visa route, with the existing maintenance sums per month for Child Students aged 16/17 and living independently in the UK remaining unchanged. Changes to the financial requirement on the Student Visa route are covered below.

However, Child Student sponsors should be aware they now have a specific duty as set out in paragraph 12.6 of SSG to “take reasonable steps to consider whether the Child Student has access to the required funds to pay their school fees and support themselves in the UK.”

Many Child Student sponsors already take certain measures to ensure that a prospective sponsored Child Student has sufficient funds before assigning a CAS so as to avoid a visa refusal on financial grounds. This is because visa refusals count adversely towards a student sponsor's visa refusal rate for Basic Compliance Assessment purposes.

Such pre CAS financial checks may include insisting on a tuition fees deposit, an Admissions interview to determine sources of funds and/or checking that the student/parent’s bank statement shows sufficient level of funds for the required 28 day consecutive period.

It is important to recognise that such pre CAS checks are also now important in demonstrating to the Home Office, where necessary, that ‘reasonable steps’ have been taken to ensure the Child Student has access to the required funds to study in the UK. Another reasonable step could include requesting evidence that a prospective or existing Child Student visa holder eligible to apply in the UK has held UK immigration permission for 12 months or more. This is because where someone is applying in the UK to extend their Child Student visa or switching to a Child Student visa from another UK visa category and they have held UK visa permission for 12 months or more, the Child Student Rules deem the financial requirement automatically met.

Student Visa Route – Increase to Financial Requirement since 11 November 2025

There is a maintenance requirement for Student Visa applicants to demonstrate they have sufficient funds to support themselves for each month of their course (up to nine months). The level of funds is a fixed amount per month and aligns with the maintenance loans available for home students. The level of funds that must be available each month has increased to match the maintenance loans available for home students for the 2025/2026 academic year. For those applying on or after the 11 November 2025 on the Student Visa Route, the new amounts are as follows:

• £1529 per month in London, up to a maximum of nine months (an increase from £1,483 per month)
• £1171 per month outside London, up to a maximum of nine months (an increase from £1,136 per month).

The maximum amount of money that can be offset for accommodation has also increased in line with the changes to the maintenance requirement. This is now £1529 for those applying under the Student Visa Route on or after 11 November 2025.

Graduate Visa Route

As forecast in the May 2025 Immigration White Paper, the Graduate Visa Route will be reduced from two years to 18 months from 1 January 2027. As explored in further detail in our article Full speed ahead for the White Paper immigration reforms, the reduction in the length of the post study Graduate Route will not apply to anyone making a Graduate Visa application before 1 January 2027. Successful PhD or doctoral qualification holders will not be affected by the six month reduction and will continue to receive three years’ immigration permission on the Graduate Visa Route.

Students switching to Innovator Founder route

In a change to the work conditions of Student Visa holders due to take effect from 25 November 2025, a student will be permitted to be self-employed to establish a business where they have completed their sponsored studies and are switching to the Innovator Founder Visa route. This replaces a similar provision to those switching into the Start Up route, which is now closed to new applicants. Apart from this specific scenario, Student Visa holders remain strictly prohibited from being self-employed or engaging in business activities.

German School Groups

Since 11 November 2025, German students under the age of 19 can come to the UK without an advance permission (an Electronic Travel Authorisation or visa) when they are travelling as part of a party of five or more. The rule change will also allow EU, EEA, and Swiss nationals aged 19 and under who are studying at the school or educational institution to travel on a national identity card to the UK rather than a passport.

Removing such administrative barriers for German school groups visiting the UK mirrors the similar arrangement that the UK already has with France.