UK-India Trade Agreement: New Service Supplier Visa Route and Global Business Mobility Changes

On 5 March 2026, the Home Secretary laid before Parliament a Statement of Changes to the Immigration Rules (HC 1691) that included, among many other amendments, the implementation of immigration provisions arising from the UK-India Comprehensive Economic Partnership Agreement (CEPA). The most significant of these is the opening of the Service Supplier visa route to Indian nationals from 26 March 2026, with an annual cap of 1,800 places. Alongside this, changes to the Secondment Worker route reduce the prior overseas employment requirement from twelve months to six, broadening eligibility for businesses that rely on international staff deployments.

This article analyses the new Service Supplier route for Indian nationals, the changes to the Secondment Worker route, and the practical implications for businesses, professionals, and immigration practitioners.

The UK-India CEPA: Background and Context

The United Kingdom and India concluded negotiations on the Comprehensive Economic Partnership Agreement in 2025, following several years of discussions that began shortly after the UK's departure from the European Union. The agreement covers goods, services, investment, and intellectual property, but its immigration provisions attracted particular attention because of their direct effect on the movement of professionals between the two countries.

India is the UK's largest source country for skilled worker visas, and Indian nationals constitute a substantial share of the UK's technology, financial services, and healthcare workforce. The CEPA's mobility provisions were designed to facilitate the temporary movement of service suppliers, a category that encompasses professionals providing contractual services on behalf of an Indian company to a UK client, without requiring the full apparatus of a Skilled Worker sponsor licence.

The immigration provisions of the CEPA are implemented through amendments to the Immigration Rules, specifically to the Global Business Mobility (GBM) route under Appendix Global Business Mobility. The GBM route was introduced in April 2022 as part of the broader overhaul of the UK's points-based immigration system and replaced the earlier Intra-Company Transfer and Representative of an Overseas Business categories.

The Service Supplier Route for Indian Nationals

From 26 March 2026, Indian nationals who are employed by an Indian company that has a contract to supply services to a UK-based client will be eligible to apply for entry clearance under the Service Supplier sub-category of the GBM route. This is distinct from the Skilled Worker route: it does not require the UK client to hold a sponsor licence, and the applicant remains employed by the overseas (Indian) company throughout their stay.

The key eligibility requirements, as set out in the amended Immigration Rules, are as follows. The applicant must be an Indian national. The applicant must be employed by an Indian company that has a genuine contract for the supply of services with a UK-based entity. The services to be provided must fall within one of the eligible occupations specified in Appendix Global Business Mobility. The applicant must hold the qualifications and, where applicable, the professional registrations required for the relevant occupation. The applicant must be paid at least the minimum salary applicable to the occupation in question.

Entry clearance under this route will be granted for a maximum period of twelve months. The annual cap of 1,800 places will be managed by UK Visas and Immigration, and applications will be processed on a first-come, first-served basis once the route opens. There is no provision for extending a Service Supplier visa beyond twelve months, and time spent on this route does not count toward settlement (indefinite leave to remain) in the UK.

Eligible Sectors and Occupations

The CEPA's mobility provisions are not open-ended. The Service Supplier route is limited to specific sectors and occupations that were negotiated as part of the trade agreement. While the full list is set out in the relevant appendices to the Immigration Rules, the principal sectors include information technology and computer services, engineering and technical consultancy, management consultancy, financial advisory services, and certain categories of creative and cultural services.

This sectoral limitation reflects the nature of the trade agreement itself: it is designed to facilitate the delivery of services under a commercial contract, not to provide a general work visa. Indian nationals who wish to work in the UK in a more permanent capacity, or in occupations outside the CEPA's scope, will still need to use the Skilled Worker route or another applicable visa category.

Changes to the Secondment Worker Route

In a separate but related change, effective from 8 April 2026, the minimum period of prior overseas employment required for the Secondment Worker sub-category of the GBM route has been reduced from twelve months to six months. The Secondment Worker route allows overseas workers to come to the UK as part of a high-value contract between their overseas employer and a UK business. Unlike the Senior or Specialist Worker category (which requires the worker to be employed by the same group of companies), the Secondment Worker route applies to workers deployed under third-party commercial contracts.

The reduction in the prior employment requirement from twelve to six months is a meaningful change for businesses that operate in project-based industries. In sectors such as construction, energy, and technology, where projects may have compressed timescales and where the specialist staff needed may have been recruited relatively recently by the overseas contractor, a twelve-month employment requirement was often a barrier. A worker who had been with the overseas employer for only eight or nine months, for example, would have been ineligible regardless of their skills or the urgency of the UK deployment.

The new six-month threshold brings the Secondment Worker route into closer alignment with the practical realities of international project deployment. UK businesses that use this route to bring in specialist staff from overseas contractors should review their workforce planning to identify any workers who may now become eligible as a result of this change.

Salary Compliance: Pay Period Monitoring

HC 1691 also introduced a change to salary compliance monitoring that applies across the sponsored worker routes, including the GBM categories. Previously, UK Visas and Immigration assessed salary compliance by reference to the worker's total pay over a twelve-month period, which allowed for some degree of variation between pay periods. A worker who was underpaid in one month but overpaid in another could still be treated as compliant if the annual total met the required threshold.

Under the amended rules, sponsored workers must now be paid at least the minimum required salary in each pay period. This means that a shortfall in any single month could constitute a compliance breach, even if the worker's annual salary exceeds the minimum threshold. For sponsors, this requires closer attention to payroll processing, particularly for workers whose pay includes variable components such as bonuses, overtime, or commission. Payroll systems should be configured to flag any pay period in which a sponsored worker's gross pay falls below the minimum salary for their occupation.

The rationale behind this change is straightforward: it enables UKVI to detect and act on underpayment more quickly. Under the previous annual averaging approach, an employer could underpay a sponsored worker for several months before the shortfall became apparent at the point of visa extension or compliance audit. The new per-period requirement creates a more immediate accountability mechanism.

Implications for Pakistani Professionals and Businesses

While the Service Supplier route under the CEPA is specific to Indian nationals, the broader changes to the GBM route, particularly the Secondment Worker amendments and the salary compliance changes, apply to all nationalities. Pakistani professionals who are employed by overseas companies with UK service contracts may benefit from the reduced six-month prior employment requirement under the Secondment Worker route.

For Pakistani businesses that operate in the UK or that have UK clients, the changes to salary compliance monitoring require careful attention. If a Pakistani company has a UK subsidiary or branch that sponsors workers, it must ensure that its payroll systems reflect the new per-period salary requirement. Similarly, Pakistani IT and consultancy firms that deploy staff to the UK under commercial contracts should review whether the Secondment Worker route, with its reduced eligibility threshold, may now be a viable option for their deployments.

It is also worth noting that the CEPA model could serve as a precedent for future UK trade agreements with other countries, including Pakistan. While no UK-Pakistan trade agreement is currently under negotiation, the structure of the CEPA, with its capped, sector-specific visa provisions, provides a template that could be applied in future bilateral arrangements. Pakistani trade and industry associations may wish to study the CEPA provisions as they consider what a future UK-Pakistan trade agreement might include on the mobility front.

Other Notable Changes in HC 1691

The March 2026 Statement of Changes contains several additional amendments worth noting. The English language requirement for settlement has been increased from B1 to B2 on the Common European Framework of Reference for Languages, with effect from 26 March 2027. This gives applicants approximately one year to prepare for the higher standard, which will affect settlement applications under the Skilled Worker, Global Talent, Innovator Founder, Scale-up Worker, Representative of Overseas Business, and UK Ancestry routes.

The Global Talent route has been expanded to include a new design pathway, and the requirements for PhD-level researchers in academic and research leadership roles have been simplified. Nationals of Nicaragua and St Lucia have been removed from the Electronic Travel Authorisation eligible list and will now require visit visas. Asylum seekers who wish to work will now be limited to occupations at RQF Level 6 and above, aligning the asylum work permission framework with the Skilled Worker route's focus on higher-skilled occupations.

LexForm's Immigration team advises both individuals and businesses on the full range of UK visa routes, including the Global Business Mobility categories discussed in this article. If you are considering deploying staff to the UK or exploring the new Service Supplier route, we can provide a tailored assessment of your eligibility and assist with the application process.