Ukraine Permission Extension Scheme for Employers

The Ukraine Permission Extension Scheme (UPE) was introduced by the UK government to allow Ukrainian nationals and their family members, who previously received permission to remain under one of the Ukraine visa schemes, to extend their stay. The scheme is part of the UK’s humanitarian response to the war in Ukraine, providing continued security and stability to those already in the UK.

For employers, the scheme carries important implications. Ukrainian employees may rely on the extension to maintain lawful status and work rights in the UK. HR and compliance teams need to be aware of the scheme’s rules to ensure that workforce management, right to work checks, and immigration compliance obligations are met.

What this article is about:
This article explains the Ukraine Permission Extension Scheme in detail, including its purpose and scope, who can apply, how the application process works, and what employers need to do to maintain compliance. It also considers long-term implications for workforce planning and the steps HR teams should take to support employees affected by this scheme.

 

Section A: Understanding the Ukraine Permission Extension Scheme

 

The Ukraine Permission Extension Scheme (UPE) is a temporary immigration route designed to provide continuity for Ukrainians and their family members already lawfully present in the UK. It was introduced in response to the expiration of initial visa grants under the Ukraine Family Scheme, the Homes for Ukraine Scheme, and the Ukraine Extension Scheme. The government recognised that many individuals would require an extension of their status to remain lawfully in the UK and to continue contributing to UK society and the workforce.

 

1. Purpose and background

 

The scheme was created to ensure stability for Ukrainians living in the UK who may otherwise face uncertainty as their initial permission came to an end. The Home Office set out that the purpose of the UPE is to maintain lawful residence and prevent disruption to employment, housing, education and access to public services for Ukrainian nationals and their dependants.

For employers, this means that affected employees can continue to lawfully live and work in the UK, provided they make a valid application and secure the extension. It also ensures that employers retain continuity within their workforce without the need to consider alternative visa routes at short notice.

 

2. Relationship to other Ukraine visa schemes

 

The UPE operates alongside, but distinct from, the three earlier Ukraine visa schemes:

• Ukraine Family Scheme: For family members of UK-based sponsors.
• Homes for Ukraine Sponsorship Scheme: Allowing individuals and families to be hosted by UK residents.
• Ukraine Extension Scheme: For those already present in the UK when the conflict began.

 

The UPE is not an initial entry route but instead provides an extension to those who already hold valid permission under one of the existing schemes. Employers should recognise that the UPE does not introduce new eligibility for sponsorship or entry; it is a continuation of rights already held.

 

3. Policy objectives for employers and employees

 

The scheme’s objectives are humanitarian and practical. From an HR perspective, it supports workforce retention by preventing sudden loss of employees whose visas would otherwise expire. It also reduces pressure on employers to urgently consider skilled worker sponsorship or alternative visa categories.

For employees, the scheme provides reassurance and a clear pathway to maintain lawful status without excessive administrative burden. This stability can help with employee wellbeing and productivity by reducing stress associated with uncertainty over immigration status.

Section A Summary
The Ukraine Permission Extension Scheme was introduced as a pragmatic solution to extend the lawful stay of Ukrainians already in the UK. It is not a new entry route but a continuation of existing permissions, designed to ensure workforce and family stability. For employers, understanding the background and objectives of the scheme is critical to managing compliance and supporting affected staff.

 

Section B: Eligibility and Application Process

 

The Ukraine Permission Extension Scheme is limited in scope and applies only to individuals who have previously been granted leave under one of the Ukraine visa schemes. Employers should be aware of who can apply, how applications are made, and the key deadlines, to ensure workforce planning and compliance processes are aligned.

 

1. Eligible categories under the scheme

 

The scheme is available to:

• Ukrainian nationals who were granted permission to stay under the Ukraine Family Scheme, Homes for Ukraine Sponsorship Scheme, or Ukraine Extension Scheme.
• Their family members who were also granted permission under these schemes.

 

Applicants must already hold valid leave under one of these schemes to qualify for the extension. New applicants who have never applied under the Ukraine visa schemes cannot use this route.

Eligibility is generally straightforward, but employers should remind employees that they must hold current permission under one of the schemes at the time of applying. Those with other types of UK immigration status, such as Skilled Worker or Student visas, are not eligible to transfer into the UPE.

 

2. Application process and required documentation

 

Applications are made online through the official GOV.UK portal. The process is free of charge and does not require payment of an application fee or Immigration Health Surcharge (IHS).

Key points of the application process include:

• Submission of an online form via GOV.UK.
• Proof of existing permission under one of the Ukraine visa schemes.
• Biometric enrolment (where required). Some applicants may need to attend a UK Visa and Citizenship Application Services (UKVCAS) appointment.
• Issuance of new documentation confirming the extended leave, typically in the form of updated digital immigration status or a Biometric Residence Permit (BRP).

 

Applicants must apply before their current leave expires. If they do not, they risk losing lawful status and the right to work. Employers should advise affected employees to retain copies of their application receipts and confirmation notices, as these can be used to evidence pending status if right to work checks fall due while an application is being processed.

It is also important to note that the 36 months of further permission is granted from the date of decision, not from the expiry of the previous visa. Employers should factor this into workforce planning.

 

3. Key dates, deadlines, and Home Office guidance

 

The Home Office has set clear timelines for applications, usually requiring them to be submitted before the expiry of the current leave. Typically, grants under the UPE are issued for a period of up to 36 months from the date of decision.

Employers should maintain close communication with affected employees to ensure that applications are made in good time. HR teams should diarise expiry dates and follow up regularly to avoid lapses in lawful status, which would result in employees losing the right to work.

Up-to-date guidance is published on GOV.UK and employers should check regularly for changes. While the government has not yet set a closure date for the scheme, employers should not assume indefinite availability and should continue monitoring policy announcements.

Section B Summary
Eligibility under the Ukraine Permission Extension Scheme is limited to those who already hold valid leave under a Ukraine visa scheme. The application process is free, straightforward, and requires online submission, with some applicants needing biometric enrolment. Employers should support employees in meeting deadlines, ensure applications are submitted before expiry, and keep accurate records to remain compliant with right to work obligations.

 

Section C: Implications for UK Employers

 

The Ukraine Permission Extension Scheme provides stability for employees, but it also places clear responsibilities on UK employers. HR leaders and compliance teams must ensure that right to work checks are correctly managed, sponsorship duties are not confused with this scheme, and appropriate support is offered to employees navigating the extension process.

 

1. Right to work checks and extension verification

 

Employers are legally required to conduct right to work checks on all staff. Where an employee applies to extend under the UPE, employers must ensure that checks are correctly updated.

Key considerations include:

• Digital status verification: Many Ukrainians hold digital status which can be checked using the Home Office online right to work service. Employees provide a share code, and employers can confirm current permission.
• Pending applications: If an employee’s permission is close to expiring and they have submitted an extension application in time, their work rights continue under Section 3C leave. Employers should also use the Employer Checking Service (ECS) to obtain a Positive Verification Notice, which provides a statutory excuse against illegal working while the application is processed.
• Repeat checks: Employers must diarise the new expiry dates after an extension is granted and ensure follow-up checks are conducted on time.

 

Failure to carry out repeat checks or to obtain a Positive Verification Notice when required exposes employers to the risk of a Home Office civil penalty, currently up to £60,000 per illegal worker.

 

2. Impact on sponsorship duties and HR systems

 

The Ukraine Permission Extension Scheme operates outside the points-based sponsorship system. Employers are not required to hold a sponsor licence to employ individuals under this route.

However, HR systems should be updated to record:

• Employee visa type and permission expiry dates.
• Copies of confirmation of extension, application receipts or Positive Verification Notices.
• Reminders for when the next right to work check is due.

 

Employers should also train HR staff on distinguishing between sponsored workers and UPE holders to avoid unnecessary sponsorship considerations or reporting errors.

 

3. Supporting employees during the extension process

 

From an HR and employee relations perspective, employers should provide practical support to affected staff. This might include:

• Allowing flexibility for attending biometric enrolment appointments.
• Providing reassurance that continued employment is possible, subject to valid applications being made on time.
• Offering clear guidance on the documents or digital codes required for right to work checks.

 

Proactive support can reduce stress for employees, minimise disruption to operations, and help retain valuable staff during a time of uncertainty.

Section C Summary
For employers, the Ukraine Permission Extension Scheme means careful attention to right to work checks, clear record-keeping, and proactive support for employees. Although sponsorship duties do not apply, HR teams must ensure they are equipped to handle the extension process, verify lawful status, and protect against civil penalty risk while supporting affected employees.

 

Section D: Future Considerations for Employers

 

The Ukraine Permission Extension Scheme provides temporary stability, but employers should plan for longer-term implications. Immigration policies continue to evolve, and businesses must anticipate potential changes to maintain compliance and workforce continuity.

 

1. Potential transition to longer-term visas

 

Although the UPE provides up to 36 months’ permission, it is not a route to settlement. Employees who wish to remain in the UK beyond this period will need to transition to other visa categories. Options could include:

• Skilled Worker visa, where eligible employment and sponsorship requirements are met.
• Family visas, if employees have close relatives in the UK with settled status or citizenship.
• Other work or study-related visas, depending on individual circumstances.

 

Importantly, time spent under the UPE does not count towards Indefinite Leave to Remain (ILR). Employers should be aware that employees aiming for settlement will need to switch into a qualifying visa route to begin accumulating residence for ILR.

 

2. Workforce planning and employee relations

 

From a strategic HR perspective, employers should identify which roles are filled by staff on UPE visas and assess the potential impact if those employees are unable to transition to longer-term status. Workforce planning should incorporate:

• Succession strategies for business-critical roles.
• Communication with employees about future visa options.
• Balancing employee wellbeing with compliance obligations.

 

Transparent communication can help maintain trust and loyalty while minimising the risk of sudden workforce disruption.

 

3. Government updates and monitoring compliance risks

 

The Home Office has not committed to keeping the UPE scheme open indefinitely. Policy updates could affect deadlines, eligibility, or transition pathways.

Employers should:

• Monitor official Home Office updates and announcements.
• Review internal compliance processes regularly.
• Seek legal advice where employees may face complex circumstances.

 

Remaining proactive ensures that HR teams are not caught off-guard by sudden policy changes, including potential transitional arrangements if the scheme closes.

Section D Summary
The Ukraine Permission Extension Scheme offers short-term continuity but does not provide a settlement pathway. Employers must plan for potential transitions to longer-term visas, integrate these considerations into workforce planning, and monitor government updates closely to avoid compliance risks.

 

FAQs

 

What is the Ukraine Permission Extension Scheme?
The Ukraine Permission Extension Scheme (UPE) allows Ukrainians and their family members, already in the UK under one of the Ukraine visa schemes, to extend their permission to stay. It provides stability for individuals and employers by granting up to 36 months of further lawful residence from the date of decision.

How does the scheme affect right to work checks?
Employers must continue to carry out right to work checks. Employees with digital status should provide a share code, while those with pending applications may require verification through the Employer Checking Service. If an application is made in time, Section 3C leave preserves work rights until a decision is made.

Can employees switch from UPE to other visa routes?
Yes, but the UPE itself does not lead to settlement. Employees wishing to remain longer-term may need to apply for a Skilled Worker visa, a family visa, or another relevant route. Time spent on the UPE does not count towards the qualifying period for Indefinite Leave to Remain (ILR).

How long is permission granted under this scheme?
Permission is typically granted for up to 36 months from the date the application is decided. Employees must apply before their current leave expires to avoid gaps in lawful status and the right to work.

What should HR do if an employee’s permission is expiring?
HR teams should:

• Encourage employees to apply before expiry.
• Record evidence of the application, such as receipts or confirmation emails.
• Use the Employer Checking Service if needed to protect against illegal working risk.
• Diarise new expiry dates once decisions are made to ensure repeat right to work checks are carried out on time.

 

Conclusion

 

The Ukraine Permission Extension Scheme is a critical element of the UK’s humanitarian and immigration response, providing Ukrainians and their families already in the UK with a pathway to extend their lawful stay. For employers, the scheme removes immediate uncertainty over immigration status, ensuring that valuable employees can continue to live and work in the UK.

HR and compliance teams must remain vigilant. Right to work checks must be carried out correctly, records updated, and employees supported through the application process. Although the scheme provides temporary stability, it does not lead to settlement and time spent under the UPE does not count towards Indefinite Leave to Remain. Employers should therefore plan for possible transitions to other visa routes if staff members intend to stay in the UK beyond the extension period.

Failure to comply with right to work obligations exposes employers to the risk of Home Office civil penalties, currently up to £60,000 per illegal worker. Proactive workforce planning, transparent communication with affected employees, and regular monitoring of Home Office updates are key. By staying informed and supportive, employers can remain compliant while retaining the trust and loyalty of employees who have faced significant disruption in their personal lives.

 

Conclusion

 

The Ukraine Permission Extension Scheme is a critical element of the UK’s humanitarian and immigration response, providing Ukrainians and their families already in the UK with a pathway to extend their lawful stay. For employers, the scheme removes immediate uncertainty over immigration status, ensuring that valuable employees can continue to live and work in the UK.

HR and compliance teams must remain vigilant. Right to work checks must be carried out correctly, records updated, and employees supported through the application process. Although the scheme provides temporary stability, it does not lead to settlement and time spent under the UPE does not count towards Indefinite Leave to Remain. Employers should therefore plan for possible transitions to other visa routes if staff members intend to stay in the UK beyond the extension period.

Failure to comply with right to work obligations exposes employers to the risk of Home Office civil penalties, currently up to £60,000 per illegal worker. Proactive workforce planning, transparent communication with affected employees, and regular monitoring of Home Office updates are key. By staying informed and supportive, employers can remain compliant while retaining the trust and loyalty of employees who have faced significant disruption in their personal lives.

 

Glossary

 

Term	Definition
Ukraine Permission Extension Scheme (UPE)	A UK immigration route allowing Ukrainians and their family members, already in the UK under a Ukraine visa scheme, to extend their stay for up to 36 months from the date of decision.
Right to Work Check	The process employers must follow to confirm that an individual has legal permission to work in the UK.
Employer Checking Service (ECS)	A Home Office service employers can use to verify an employee’s right to work when their immigration status is pending. It provides a Positive Verification Notice as a statutory excuse.
Biometric Residence Permit (BRP)	A secure card issued by the Home Office confirming an individual’s immigration status, visa type, and work entitlements.
Digital Immigration Status	An online immigration record provided by the Home Office, accessed using a share code and checked via the Home Office online service.
Section 3C Leave	A provision under the Immigration Act 1971 that extends a person’s existing leave while a timely extension application is pending, preserving their work rights.

 

Useful Links

 

Resource	Link
GOV.UK: Ukraine Permission Extension Scheme	gov.uk
GOV.UK: Employer right to work checks	gov.uk
DavidsonMorris: Homes for Ukraine	davidsonmorris.com
DavidsonMorris: Ukraine Permission Extension Scheme	davidsonmorris.com
Xpats.io: Ukraine Permission Extension Scheme	xpats.io