Minister of Religion and Religious Worker Sponsors: The 29 October 2026 Changes and What HR Must Decide
Published 30 September 2026
Key Takeaways
- HC 584 changes both faith routes on 29 October 2026, and it is confirmed law. Paragraphs APP MOR1 to MOR10 and APP RW1 to RW10 of Statement of Changes HC 584, laid on 3 September 2026, take effect that day. An application made before 29 October 2026 is decided under the Rules in force on 28 October 2026, whatever date you assigned the Certificate of Sponsorship (CoS). The Home Office has not yet reissued the sponsor guidance for these routes, so version 04/26 is out of step with the new Rules.
- Your first decision is whether the role is entitled to the National Minimum Wage. If it is, the maintenance rules do not change. If it is not, the worker's own £1,270, your first-month certification and the 12-month exemption all stop counting for applications made from 29 October 2026.
- For a role outside the minimum wage, you must promise to maintain and accommodate the worker and their family for the whole stay. New paragraphs MOR 7.4, MOR 25.6, RW 6.4 and RW 16.6 require an A-rated sponsor to confirm this on the CoS for the worker, any partner and any children, for the full period of permission. The Rules set no cash limit.
- The undertaking reaches long-serving workers too, so get it approved before the CoS is assigned. Today a worker extending after 12 months in the UK needs no funds. From 29 October 2026, if the role is outside the minimum wage, the extension CoS must carry the whole-stay undertaking, and on the wording of the Rules a B-rated sponsor cannot give it.
- An exemption must rest on a named legal basis, written down before you rely on it. The main one is section 44A of the National Minimum Wage Act 1998, which covers residential members of a community that is, or was set up by, a charity and exists to practise or advance a religious belief. Section 28 presumes the worker qualifies unless you prove otherwise, and sponsor guidance paragraph MRW6.3 already requires the exemption to be explained on the CoS.
- Advertising no longer meets the Religious Worker resident labour consideration for applications from 29 October 2026. RW 4.2 falls from four options to three: a supernumerary role, a religious order role, or at least 6 months of religious duties outside the UK for the overseas organisation you are affiliated to, immediately before the application, shown by a letter from that organisation.
- Same-sponsor extensions stay outside the resident labour consideration on our reading, but the new wording leaves room for doubt. The current RW 4.1(i) already excuses them and HC 584 re-enacts that carve-out, yet the new RW 4.2 is worded as a requirement on every applicant, so file same-sponsor extensions by 28 October 2026 where you can. A Religious Worker changing sponsor inside the UK will rarely fit the affiliation option.
- Religious Worker roles must be mainly non-pastoral from 29 October 2026, so re-read every job description. The Home Office will revoke a licence for false or misleading information on a CoS, and Annex C1(s) of the sponsor guidance mandates revocation where the role does not match the CoS job description. Religious order members join senior posts as an exception to the Minister of Religion non-pastoral bar.
- Minister of Religion grants become a flat 3 years and the 6-year cap is deleted. MOR 10.1 limits entry clearance and permission to stay alike to 3 years, and MOR 10.2 goes, so a minister can extend in 3-year steps. Diary every expiry, because each extension is a fresh undertaking decision.
- Our sponsor licence compliance audit reviews your faith-route pipeline and records before 29 October 2026. The WPC HR sponsor licence compliance audit tests each candidate against the new Rules and checks your determinations, undertakings and affiliation evidence, and our HR compliance software holds those records and your extension diary in one place.
Introduction
On 29 October 2026, the rules for the two faith routes change. Statement of Changes HC 584, laid before Parliament on 3 September 2026, rewrites parts of Appendix T2 Minister of Religion and Appendix Temporary Work – Religious Worker. Its explanatory memorandum files both sets of changes under "Other Minor Changes". For a sponsor they are not minor. For any role outside the minimum wage, one of them turns a one-month certification of at least £1,270 into a promise, with no cash limit, to house and support the worker and their family for the whole of their permission.
This guide is for the people who sign off sponsorship at a church, mosque, temple, gurdwara, synagogue, religious order or faith charity: the Authorising Officer, the HR lead or administrator, the treasurer and the trustees. It covers what your organisation has to decide, what it has to commit to, what it has to keep on file, and what has to happen before 29 October 2026.
What is confirmed and what is not. The changes to the Immigration Rules are confirmed law: HC 584 was laid under the negative procedure, so it takes effect on the dates it states unless Parliament disapproves it, and it is not a proposal or a consultation. The sponsor guidance for these routes has not caught up: as at 30 September 2026, the current version is 04/26, published on 8 April 2026, and it still describes the rules as they stand today. Where this post says the Rules require something, that is law. Where it recommends a record, a sign-off step or a way of working, that is our practical advice, and we say so.
If you are the applicant, or you want to know which route a role belongs on, our sister firm WorkPermitCloud has written the applicant's guide to the Minister of Religion and Religious Worker routes, including costs, settlement and a table on whether to apply before or after 29 October. We do not repeat it here.
What Changes on 29 October 2026 for Faith-Based Sponsors
HC 584 changes six things a faith sponsor does or promises. The table sets out the sponsor's side only, and adds two rows that stay the same because they are easy to misread. The rule references are to Appendix T2 Minister of Religion and Appendix Temporary Work – Religious Worker as amended.
| Sponsor obligation | Until 28 October 2026 | From 29 October 2026 | Rule |
|---|---|---|---|
| Maintenance where the role is entitled to the minimum wage | Worker shows £1,270 held for 28 days, or an A-rated sponsor certifies maintenance to the end of the first month; no funds needed after 12 months in the UK | Unchanged | MOR 7, RW 6 |
| Maintenance where the role is not entitled to the minimum wage | Same as above | A-rated sponsor confirms on the CoS that it will maintain and accommodate the worker for the whole period of permission; own funds, first-month certification and the 12-month exemption no longer apply | MOR 7.1, 7.2, 7.4; RW 6.1, 6.2, 6.4 |
| Dependants where the role is not entitled to the minimum wage | Dependants' own funds, first-month certification of each grant, or the 12-month exemption | The sponsor's undertaking must also cover the partner and any children for the whole period of permission | MOR 25.6, RW 16.6 |
| Religious Worker resident labour consideration | Four options: supernumerary role; religious order role; sponsor's national records; national recruitment search with at least 28 days' advertising in the 6 months before the CoS is assigned | Three options: supernumerary role; religious order role; at least 6 months' religious duties outside the UK for the affiliated overseas organisation, with a letter from it | RW 4.2 |
| Religious Worker extension with the same sponsor | No resident labour consideration needed | Carve-out re-enacted in RW 4.1(i); on our reading still not needed, but see the drafting point below | RW 4.1(i), RW 4.2 |
| Religious Worker role content | Religious duties within, or directed by, the sponsor; not a minister role | Must mainly involve non-pastoral religious duties; not a minister role | RW 4.3 |
| Minister of Religion non-pastoral bar | Mainly non-pastoral roles barred unless the post is senior | Also lifted for members of a religious order | MOR 5.1(h) |
| Minister of Religion grant length | Entry clearance up to 3 years and 1 month; extensions capped at 6 years across Minister of Religion, International Sportsperson and Skilled Worker | Up to 3 years for entry clearance and permission to stay; no 6-year cap | MOR 10.1; MOR 10.2 deleted |
Confirmed law, and the guidance that has not caught up
The implementation section of HC 584 names paragraphs APP MOR1 to MOR10 and APP RW1 to RW10 as taking effect on 29 October 2026. The explanatory memorandum gives the reasons: at paragraphs 5.33 and 5.34 it says the financial requirement changes because applicants exempt from the minimum wage do not receive a salary while in the UK, the affiliation requirement is meant to show an established connection to the sponsoring organisation, and the 6-year cap goes to align the Minister of Religion route with other work routes.
The Home Office has not reissued the sponsor guidance for Ministers of Religion and Religious Workers. Version 04/26 still tells Religious Worker sponsors to advertise or search national records (MRW5.14), still says a Religious Worker role can be pastoral or non-pastoral (MRW3.8), and still describes the 6-year maximum (MRW4.20 to MRW4.22). The general certification rule in Part 2 of the sponsor guidance (version 08/26) still describes a first-month undertaking that you may limit to no less than £1,270 (S7.25). Appendix D (version 08/26) lists the advertising evidence Religious Worker sponsors keep and says nothing about affiliation.
From 29 October 2026, where the guidance and the Rules differ, the Rules decide the application. We do not know what the reissued guidance will say, and we have not guessed. Check the guidance page on GOV.UK for a new version before you assign any CoS on these routes from mid-October.
The date of application decides, not the date of the CoS
HC 584 protects applications, not certificates. An application made before 29 October 2026 is decided under the Rules in force on 28 October 2026. A CoS you assign in September for an application made on or after 29 October 2026 is judged under the new Rules, even if everything on it was right when you assigned it.
That matters to you because the application date is in the candidate's hands, not yours. A CoS can be used for up to 3 months after you assign it (MOR 1.2(d) and sponsor guidance MRW7.8), so a certificate assigned now can easily be used after the change. Where a CoS relies on something that disappears on 29 October, such as an advertising campaign or the worker's own savings, either make sure the application goes in by 28 October 2026 or prepare it on a basis that survives. Dependants who apply separately are judged on their own application date. For the applicant's side of the timing decision, point candidates to WorkPermitCloud's filing table in the route guide, and to its HC 584 explainer for the rest of the statement.
The Decision Everything Turns On: Is the Role Entitled to the Minimum Wage?
From 29 October 2026, the maintenance rules on both routes ask one question: will the applicant be entitled to be paid the National Minimum Wage in respect of the role they are sponsored for? If yes, nothing changes. If no, the only way through is your whole-stay undertaking. Because the answer decides what you promise, the minimum wage position is now the first thing to settle for every faith-route CoS, not a box to tick at the end.
You already make this statement. MOR 5.1(i) and RW 4.1(h) require the CoS to confirm that pay complies with, or is exempt from, the minimum wage. Sponsor guidance paragraph MRW6.3 requires you to explain any exemption on the CoS, either in the gross salary box or in a sponsor note. MRW6.4 adds that you cannot refuse the minimum wage just because a worker can support themselves from their own funds or from donations. For how sponsored salaries and the minimum wage interact on other routes, see our guide to SOC codes and going rates.
The legal bases for saying a role is outside the minimum wage
Residential members of a religious community. Section 44A of the National Minimum Wage Act 1998 says a residential member of a community does not qualify for the minimum wage in respect of employment by that community, where the community is a charity or established by a charity, a purpose of the community is to practise or advance a belief of a religious or similar nature, and all or some of its members live together for that purpose. It does not apply to an independent school, an alternative provision Academy, or a provider of further or higher education. GOV.UK's page on who gets the minimum wage summarises it as "people living and working in a religious community". A monastic community of monks or nuns is the clear case. A minister who lives in their own home with their family and serves a congregation does not obviously fit, because the exclusion turns on members living together as a community.
Voluntary workers for a charity. Section 44 takes a worker employed by a charity outside the minimum wage if they receive no money except expenses, and no benefits in kind except subsistence or reasonable accommodation. A stipend, pocket money or a regular allowance above expenses takes the worker outside section 44, apart from a narrow exception for subsistence payments where a charity has arranged the placement. Sponsor guidance MRW6.5 requires the CoS to show every payment, including stipends, board and lodging, so what you declare must be consistent with the basis you claim.
No contract at all. The minimum wage applies to "workers", defined in section 54 of the Act by reference to a contract. In President of the Methodist Conference v Preston [2013] UKSC 29, the Supreme Court held that whether a minister serves under a contract of employment depends on how they were engaged and the rules governing their service, and that there is no presumption against a minister's service being contractual. That case was about employee status for unfair dismissal, not the minimum wage. We would not rely on "no contract" as the basis for a sponsored role without specific legal advice.
Who should make the call
The statement on the CoS is made by your organisation through the Sponsor Management System, and your Authorising Officer is accountable for what is done in it (see our guide to the Authorising Officer role). We recommend that HR or the administrator prepares a written determination, the Authorising Officer signs it, and the trustees or finance lead see it whenever it triggers the whole-stay undertaking. If the basis is anything other than a clear section 44A community, take employment law advice first.
What a written determination should record
The Rules do not prescribe a form. This is the record we recommend keeping for each sponsored role before the CoS is assigned.
| Field | What to record | Why it matters |
|---|---|---|
| Role and worker | Job title, the worker's name, route, CoS start and end dates | Ties the decision to one CoS; a new CoS needs a fresh check |
| Legal basis | The section relied on, for example section 44A, with each condition listed | MRW6.3 requires the exemption to be explained on the CoS |
| Facts for each condition | Charity number, the community's religious purpose, where the worker will live and with whom | Section 28 presumes the worker qualifies unless you prove otherwise |
| Exclusions checked | Confirmation the community is not an independent school, an alternative provision Academy or a further or higher education provider | Section 44A(3) removes those communities from the exclusion |
| Everything the worker receives | Stipend, board, lodging, allowances, expenses, any other benefit | Must match the CoS (MRW6.5) and fit the basis claimed |
| How it appears on the CoS | Gross salary box wording or the sponsor note text | The Home Office reads the CoS, not your file |
| Advice taken | Who advised, when, and the conclusion | Shows the decision was considered |
| Sign-off | Name, role and date of the Authorising Officer's approval | Accountability for a statement to the Home Office |
| Maintenance consequence | Whether the whole-stay undertaking is needed, and the approval reference | Links the two decisions |
| Review triggers | Move out of the community, new duties, a new payment, an extension | Any of these can change the answer |
What happens if the call is wrong
In the employment courts. Section 28(1) of the National Minimum Wage Act presumes that an individual qualifies for the minimum wage unless the contrary is established, so your file is your defence. Our guide to modern slavery and your sponsor licence explains how that reversed burden of proof works in practice. Under section 17, arrears are the higher of the shortfall and the shortfall recalculated at the rate in force when the arrears are determined. Minimum wage enforcement has sat with the Fair Work Agency since 7 April 2026. For current rates, see WorkPermitCloud's employer's guide to the UK minimum wage.
In the application. MOR 5.4 and RW 4.6 require refusal where the decision maker has reasonable grounds to believe the job does not comply with the National Minimum Wage Regulations, and MRW6.2 says the Home Office will also consider revoking your licence.
On your licence. Paragraph C1.53 of Part 3 of the sponsor guidance makes complying with minimum wage law a sponsor duty, and a breach of any C1 duty is grounds for normal revocation under Annex C2(a). Providing false information to the Home Office is also a normal revocation ground under Annex C2(f). Our guide to suspension, downgrade and revocation sets out what follows.
The Whole-Stay Undertaking: What Your Organisation Is Promising
What the undertaking covers
The new MOR 7.4 says that where the applicant will not be entitled to the minimum wage, "the applicant's A-rated sponsor must confirm on the Certificate of Sponsorship that they will maintain and accommodate the applicant for the duration of the period of permission in the UK". RW 6.4 is identical for Religious Workers. MOR 25.6 and RW 16.6 extend it to the partner and any children.
- It is two promises. Maintain means meeting the worker's living costs. Accommodate means providing somewhere to live. The Rules do not define either word further.
- It covers the family. Worker, partner and children, if they come.
- It lasts for the whole period of permission. Up to 3 years for each Minister of Religion grant, repeated at each extension, and up to 24 months in total for a Religious Worker.
- It has no cash limit. The Rules state no amount.
Compare today's certification. You promise to maintain and accommodate the worker "if it is necessary", only to the end of the first month, and Part 2 of the sponsor guidance (S7.25) lets you cap the promise at no less than £1,270. The new wording drops the words "if it is necessary". What that means in practice will depend on the reissued guidance, which has not been published.
Three consequences in the wording
Long-serving workers are caught at extension. HC 584 amends MOR 7.1 and RW 6.1, the rules that let a worker who has been in the UK with permission for 12 months or more skip the financial requirement, so that they no longer apply to roles outside the minimum wage. A minister who has served you for years and applies to extend on or after 29 October 2026 now needs your whole-stay undertaking on the extension CoS.
The family has no other way through. For roles outside the minimum wage, the dependants' 12-month exemption, own funds and first-month certification are all switched off too (amended MOR 25.1, MOR 25.2, RW 16.1 and RW 16.2). If your undertaking does not cover the partner and children, on the text of the Rules they cannot meet the financial requirement. Today you can opt out of certifying dependants with a sponsor note (Part 2, S7.24); from 29 October 2026 that choice decides whether the family can come. The Rules tie the dependants' undertaking to the main worker's CoS and the guidance does not yet say how a family member who joins later is handled, so decide at the CoS stage whether the undertaking covers family who may join later.
Only an A-rated sponsor can give it. MOR 5.3 and RW 4.5 let a B-rated sponsor support an extension for its own worker, and MRW7.3 lets it assign that CoS. But MOR 7.4 and RW 6.4 require the undertaking to come from an A-rated sponsor. Read literally, a B-rated sponsor cannot support an extension for a worker outside the minimum wage once the new Rules apply. If you are on an action plan, see our guide to suspension, downgrade and revocation and plan any such extension for before 29 October 2026.
Who should approve it, and when
The undertaking is given on the CoS, so the decision has to be made before the CoS is assigned. It commits the organisation's money and property for up to three years at a time, so it should not rest with the Authorising Officer alone. We recommend a written approval from the trustees or the finance committee, recorded in their minutes, that names the worker, the family members covered, the period and how the costs will be met. Whether a particular commitment sits within your charity's objects and powers is a question for your own charity law adviser.
Cost-planning checklist
No figures appear here because the Rules set none and every organisation's costs differ. Answer each question in writing before sign-off.
| Cost area | Questions to answer before sign-off | Evidence to keep |
|---|---|---|
| Accommodation for the worker | Where will they live? Who owns or rents it? Is it available for the whole period? | Property details, tenancy or title, the approval minute |
| Accommodation for the family | Is it suitable for a partner and children? What if the family grows during the grant? | Room and occupancy details, the family members covered |
| Subsistence | How will food, utilities, clothing and day-to-day costs be met, and by whom? | Written arrangement, budget line |
| Dependants | Which family members are covered, including any who may join later? | The list attached to the approval |
| Duration | When does permission end? How many extensions do you expect? | Extension diary entry |
| Total exposure | How many undertakings are already running, and what do they commit in total? | Register of undertakings |
| Change of circumstances | What happens if the worker falls ill, the accommodation is lost or the role ends early? | Contingency note in the approval |
| Funding source | Which budget or fund meets the cost, confirmed by the treasurer or finance lead? | Treasurer's confirmation |
What the guidance does not say yet
As at 30 September 2026, nothing published by the Home Office says how the undertaking will be recorded on the CoS, whether it can be limited, or what happens if a sponsor does not honour it. Part 3 of the sponsor guidance contains no provision on the point. We have not invented a penalty. The nearest existing rule is S7.27 of Part 2, which says that where you certify maintenance and the worker or dependants claim public funds with your knowledge, the Home Office may take compliance action against you. The undertaking is also a statement to the Home Office on the CoS, and sponsor guidance treats false or misleading CoS information as grounds for revocation (MRW5.12 and MRW5.26). Do not give it unless you can keep it.
The Affiliation Test Replaces Advertising for Religious Workers
Four options become three
Today RW 4.2 gives a Religious Worker sponsor four ways to meet the resident labour consideration. HC 584 removes two of them: the search of the sponsor's own national records, and the national recruitment search with at least 28 days' advertising in the 6 months before the CoS is assigned. It keeps the supernumerary role and the religious order role. It adds one: the applicant must have performed religious duties outside the UK for the same faith-based organisation to which you are affiliated, for at least 6 months immediately before the date of application, and a letter from that overseas organisation detailing this must be provided.
So the correct summary is four options to three, not "advertising removed". The new option also turns on the candidate's history, not on anything you do. If a candidate has not worked for your overseas affiliate for the 6 months running up to the application, advertising will not help them after 28 October 2026.
Evidencing the affiliation
The Rules require the letter. They do not define "affiliated" or say how the link between your organisation and the overseas one should be shown, and the guidance for the new option has not been published. We recommend holding the following.
| Item | What it should show | Status |
|---|---|---|
| Letter from the overseas organisation | Required content: that the applicant performed religious duties for the organisation outside the UK for at least 6 months immediately before the application. Our advice: add their full name as on their passport, exact start and end dates, and a signature from someone with authority, with contact details | Letter required by RW 4.2(c); extra details recommended |
| Evidence of the affiliation | The link between your organisation and the overseas one, for example governing documents, denominational membership or a formal agreement | Recommended |
| Description of the overseas duties | What the applicant did, where, and how often, so it is clear the duties were religious | Recommended |
| Verification note | Who in your organisation checked the letter, how, and when | Recommended |
| Dates check | That the 6 months run immediately before the planned application date, with no gap | Recommended |
| Sponsor note on the CoS | Which limb of RW 4.2 you rely on, with a summary; MRW7.17 already requires a note explaining how the test was met | Required today; wording for the new limb not yet published |
The words "immediately prior to the date of application" matter. If a candidate stops their overseas duties months before applying, for example while waiting for a CoS, the six months may no longer run up to the application date. That is our reading of the wording; plan the timetable so the letter and the application are close together.
The supernumerary explanation is a record, not a label
A role is supernumerary if it is over and above your normal staffing, so that if the worker were not there nobody else would fill it (MRW5.9). The guidance gives two examples of roles that are not supernumerary: a pastor leading regular worship for their congregation, and a translator whose work would still need doing (MRW5.10). MRW5.11 says that stating "the role is supernumerary" is not enough; you must explain why in a sponsor note. MRW5.12 warns that the Home Office will revoke your licence if you give false or misleading information on the CoS. Keep an internal note behind the sponsor note: your normal staffing, why this role sits outside it, and what happens to the work when the worker leaves.
What this does to recruitment planning
Advertising has a deadline. A CoS that relies on an advertising campaign or a national records search only works for an application made by 28 October 2026.
In-country changes of sponsor rarely fit the new option. Only an existing Religious Worker can apply for permission to stay on the route (RW 1.4A). A worker who has been in the UK will not have performed duties outside the UK in the 6 months before applying, so a change of sponsor will usually need to rest on the supernumerary or religious order option.
Same-sponsor extensions: not new, but watch the wording. The current RW 4.1(i) and MRW5.8 already excuse a worker extending with the sponsor who assigned their last CoS, so some commentary is wrong to present this as new. HC 584 re-enacts the carve-out in RW 4.1(i). There is a drafting catch. Today RW 4.2 only defines the test, which bites through the CoS confirmation in RW 4.1(i). The new RW 4.2 opens "The applicant must either", which reads as a requirement on every applicant. Our reading is that the re-enacted carve-out still governs, because there would be no point re-enacting it otherwise. But until the guidance confirms it, file same-sponsor extensions by 28 October 2026 where you can, and where you cannot, record in the file whether the worker also meets the supernumerary or religious order option.
Keep recruitment evidence anyway. Section 2.2 of Appendix D says that where no formal test applied, you must still keep evidence of any recruitment activity or be able to explain how you found the worker. MRW5.7 applies the same duty to Minister of Religion sponsors. Our Appendix D guide covers the general rules.
Re-Check Every Job Description Before You Assign a CoS
From 29 October 2026, RW 4.3 requires a Religious Worker role to mainly involve non-pastoral religious duties, and still excludes minister roles (leading a congregation in the rites and rituals of the faith and preaching the essentials of the creed). The sponsor guidance glossary lists pastoral duties as leading worship, religious education by preaching or teaching, leading marriages, funerals and other services, counselling and welfare support for members, and recruiting, training and co-ordinating volunteers and lay preachers. A Religious Worker role built mainly around those duties will not meet RW 4.3 for applications from 29 October 2026, including extensions.
If a current Religious Worker's role is mainly pastoral, a same-sponsor extension made on or after 29 October 2026 will fail on RW 4.3. The sponsor-side answer is either an extension made by 28 October 2026 (within the 24-month maximum) or the Minister of Religion route, which needs a licence for that route. Our Appendix A guide covers the extra Minister of Religion evidence, and WorkPermitCloud's sponsor licence application service can add the route.
On the Minister of Religion route, the CoS must confirm the role will not involve mainly non-pastoral duties, such as school teaching, media production, domestic work or administrative and clerical work, unless the post is senior or, from 29 October 2026, the worker is a member of a religious order (MOR 5.1(h)). If your organisation is a religious order, you must confirm the worker is a member (MRW7.16).
Each of these is your statement, not the worker's. Annex C1(s) of the sponsor guidance mandates revocation where the role a worker actually does does not match the job description on the CoS, and Annex C1(z) covers an exaggerated or incorrect job description written deliberately to fit a route. We recommend writing duties by the share of time they take, so the pastoral and non-pastoral split is visible, and having the line manager sign it. Our CoS guide for HR managers covers the wider assignment checks.
Minister of Religion Grants and Your Extension Diary
From 29 October 2026, MOR 10.1 grants entry clearance and permission to stay for the shorter of up to 14 days after the employment period on the CoS, or 3 years. Today entry clearance can run to 3 years and 1 month. MOR 10.2 is deleted, and with it the rule limiting extensions to the balance of 6 years across the Minister of Religion, International Sportsperson and Skilled Worker routes. The check in MRW4.26 for workers near the 6-year limit falls away for applications from 29 October 2026.
Because a 3-year CoS now produces at most 3 years of permission, the permission can end before the employment period on the CoS does. Put each worker's permission expiry in a diary, and work back from it: the CoS must be assigned no more than 3 months before the application, and the application must be made before the current permission ends. For a role outside the minimum wage, each extension is also a new undertaking decision and a fresh determination. Your reporting duties continue throughout; our sponsor duties checklist and SMS guide cover them. Settlement for ministers is covered in our settlement reform guide for employers.
Nothing changes for Religious Worker duration: a maximum of 24 months, and a 12-month cooling-off period before a new entry clearance on the Religious Worker or Charity Worker route.
Your Pre-29 October Pipeline Review
List every person you expect to assign a faith-route CoS to before the end of the year, and every current worker whose permission expires in the next 12 months. Mark which change bites, then decide the sponsor-side action. The applicant's own timing choice belongs to them; point them to WorkPermitCloud's filing table, or its Minister of Religion and Religious Worker visa services.
| Situation | Change that bites | Sponsor-side action before 29 October 2026 |
|---|---|---|
| Religious Worker candidate whose CoS relies on advertising or national records | RW 4.2 | Assign the CoS without delay, complete the sponsor note and aim for an application by 28 October 2026, or re-base the role on another option |
| Religious Worker candidate with 6 months' duties for your overseas affiliate | RW 4.2(c) | Request the letter and assemble the affiliation evidence; check the dates run to the planned application date |
| Religious Worker extending with the same sponsor | RW 4.1(i), RW 4.2 | File by 28 October 2026 where possible; otherwise record whether the role also meets the supernumerary or religious order option |
| Religious Worker role, new or extending, that is mainly pastoral | RW 4.3 | Rewrite the duties only if the role is genuinely mainly non-pastoral; otherwise extend by 28 October 2026 or plan for the Minister of Religion route |
| Any role outside the minimum wage, new or extending | MOR 7.4, 25.6; RW 6.4, 16.6 | Written determination, costed undertaking and trustee or finance approval before the CoS; decide which family members are covered |
| Worker with 12 months or more in the UK extending in a role outside the minimum wage | MOR 7.1, RW 6.1 | Do not assume no funds are needed; the undertaking applies if they apply from 29 October 2026 |
| B-rated sponsor with a worker outside the minimum wage due to extend | MOR 7.4, RW 6.4 | Plan the extension application for before 29 October 2026 and work to restore the A-rating |
| Minister whose extension is cut short by the 6-year cap | MOR 10.2 deleted | An application from 29 October 2026 can be sponsored for up to 3 years |
| Religious order member in a mainly non-pastoral role, suited to the Minister of Religion route | MOR 5.1(h) | Application from 29 October 2026; confirm order membership on the CoS |
The Faith-Sponsor File After 29 October
Appendix D keeps documents for a sponsored worker throughout the sponsorship and until the earlier of one year after it ends or a compliance officer approving them. Minimum wage records, where a worker qualifies, must be kept for six years under regulation 59(8) of the National Minimum Wage Regulations 2015. We recommend keeping the minimum wage determination for at least the six-year period, because it is your answer to the section 28 presumption. Items marked recommended are our advice; Appendix D has not yet been updated for these changes.
| Record | Contents | Basis |
|---|---|---|
| Minimum wage determination | The completed determination for each role and CoS, signed by the Authorising Officer | Recommended; supports MRW6.3 |
| Undertaking approval | Trustee or finance minute, cost plan, family members covered, period | Recommended |
| Copy of the CoS and sponsor notes | Including the exemption wording and the undertaking as recorded | Recommended |
| Evidence the undertaking is kept | Accommodation details, records of subsistence provided | Recommended |
| Affiliation letter and evidence | The overseas letter, the affiliation evidence and the verification note | Letter required by RW 4.2(c); rest recommended |
| Supernumerary or religious order explanation | Internal note behind the sponsor note | Recommended; the sponsor note itself is required by MRW5.11 and MRW7.17 |
| Job description | Duties by share of time, pastoral and non-pastoral marked, signed | Recommended; supports MOR 5.1(h) and RW 4.3 |
| Recruitment evidence | Adverts or national records for applications before 29 October 2026; otherwise how the worker was found | Appendix D sections 2.1 and 2.2 |
| Pay and benefits | Payslips and records of stipend, board, lodging and allowances | Appendix D section 3 |
| Extension diary | Permission expiry, CoS dates, next undertaking decision | Recommended |
How Can WPC HR Help?
The most useful thing to do before 29 October 2026 is a pipeline and records review. Our sponsor licence compliance audit takes every faith-route candidate and extension on your list, tests each against the new Rules, and checks that your minimum wage determinations, undertaking approvals, affiliation letters and supernumerary explanations would stand up to a compliance officer. You get a prioritised list of what must be done before 29 October and what can wait.
After that, the records have to live somewhere. WPC HR's HR compliance software holds the determination, the approval, the affiliation letter and the CoS for each worker in one file, and keeps the extension diary so that no permission expires without an undertaking decision being made in time.
| Get in touch with our team via our contact page. 📞 Call us: 020 8087 2343 📧 Email: info@workpermitcloud.co.uk 📅 Book a free compliance audit: wpchr.co.uk/sponsor-licence-compliance-audit 🔗 See the platform: wpchr.co.uk/hr-compliance-software-features |
Conclusion
HC 584 is confirmed law, and the date of application decides which Rules apply. For faith sponsors the change that matters most is the one the explanatory memorandum calls minor: for any role outside the minimum wage, you will promise to maintain and accommodate the worker and their family for the whole stay, with no limit, and the promise reaches workers who have been with you for years.
So settle the minimum wage position for every role in writing, get the undertaking approved by the people who control the money, collect affiliation letters now for Religious Worker candidates who need them, and re-read every job description. Then check GOV.UK for the reissued sponsor guidance before you assign your next CoS.
Glossary
| Term | Definition |
|---|---|
| HC 584 | The Statement of Changes to the Immigration Rules laid on 3 September 2026; its faith-route changes take effect on 29 October 2026 |
| Statement of Changes | A document laid before Parliament that amends the Immigration Rules |
| Explanatory memorandum | The Home Office document that explains the reasons for a Statement of Changes |
| Appendix T2 Minister of Religion | The part of the Immigration Rules for ministers, missionaries and members of religious orders in key leading roles |
| Appendix Temporary Work – Religious Worker | The part of the Immigration Rules for temporary religious work of up to 24 months |
| Certificate of Sponsorship (CoS) | The electronic record a licensed sponsor assigns to a worker, confirming the job and the sponsor's statements |
| Sponsor note | Free text a sponsor adds to a CoS after assigning it |
| Sponsor Management System (SMS) | The Home Office online system sponsors use to assign CoS and report changes |
| Authorising Officer | The senior person responsible for the sponsor's use of the SMS and its sponsor duties |
| A-rated sponsor | A licensed sponsor in good standing |
| B-rated sponsor | A sponsor downgraded and placed on an action plan |
| National Minimum Wage | The legal minimum hourly pay for workers under the National Minimum Wage Act 1998 |
| Section 44A | The rule excluding residential members of a charitable religious community from the minimum wage |
| Residential member | A member of such a community who lives together with other members for its religious purpose |
| Voluntary worker | A worker for a charity who receives only expenses, subsistence or reasonable accommodation (section 44) |
| Minimum wage determination | Our term for the sponsor's written decision on whether a role is entitled to the minimum wage |
| Certifying maintenance | Today's sponsor promise to maintain and accommodate a worker to the end of their first month |
| Maintain and accommodate undertaking | The sponsor's promise on the CoS, from 29 October 2026, to support and house the worker and family for the whole period of permission |
| Period of permission | The length of time a grant of entry clearance or permission to stay allows |
| Financial requirement | The rule that an applicant can support themselves, met by funds or a sponsor's promise |
| Resident labour consideration | The Religious Worker test that the role does not displace a suitable settled worker |
| Supernumerary | Over and above normal staffing, so nobody else would fill the role if the worker left |
| Religious order | A community living set apart from society in accordance with religious devotion, such as monks or nuns |
| Affiliation requirement | The new option requiring 6 months' religious duties overseas for the sponsor's affiliated organisation |
| Pastoral duties | Leading worship, preaching or religious teaching, conducting ceremonies and counselling members |
| Non-pastoral duties | Religious support work that is not pastoral, such as administration or domestic work within a religious setting |
| Settled worker | Broadly, a British citizen or a person with settled status or indefinite leave |
| Date of application | The date that decides which version of the Rules applies to an application |
| Entry clearance | Permission to come to the UK, applied for from outside the UK |
| Permission to stay | Permission applied for inside the UK, such as an extension |
| Dependant | A partner or child applying on the basis of the main worker's permission |
| Appendix D | Sponsor guidance on the records sponsors must keep |
| Annex C1 and C2 | Lists in Part 3 of the sponsor guidance of grounds on which a licence will, or will normally, be revoked |
| Fair Work Agency | The body that has enforced the minimum wage since 7 April 2026 |
| Cooling-off period | The 12-month gap required before a new Religious Worker or Charity Worker entry clearance |
FAQ
Frequently asked questions
On 29 October 2026. HC 584 was laid on 3 September 2026 and its implementation section names paragraphs APP MOR1 to MOR10 and APP RW1 to RW10 for that date. Any application made before 29 October 2026 is decided under the Rules in force on 28 October 2026.
No. The transitional rule turns on the date the application is made, not the date the CoS was assigned. A CoS assigned in September and used for an application made on or after 29 October 2026 is judged under the new Rules, so anything it relies on that disappears on that date, such as advertising, no longer counts.
Any Minister of Religion or Religious Worker sponsor assigning a CoS for a role in which the worker will not be entitled to the National Minimum Wage, for an application made from 29 October 2026. It applies to new workers and to extensions, including workers who have been in the UK for 12 months or more. Roles paid at least the minimum wage are unaffected.
The Rules state no cash limit. The undertaking covers maintaining and accommodating the worker, and any partner and children, for the whole period of permission. Today's certification can be limited to no less than £1,270 for the first month, but nothing in HC 584 carries that limit over. The reissued guidance may say more; as at 30 September 2026 it has not been published.
Not if the role is outside the minimum wage and the application is made from 29 October 2026. HC 584 limits the own-funds option and the first-month certification to workers who are entitled to the minimum wage. For roles outside it, the sponsor's whole-stay undertaking is the only way to meet the financial requirement.
If they are to come, yes. For a role outside the minimum wage, the dependants' 12-month exemption, own funds and first-month certification are all switched off, and MOR 25.6 and RW 16.6 require your undertaking to cover them for the whole period. If your undertaking does not cover them, on the text of the Rules they cannot meet the financial requirement.
Your organisation does, because the CoS must confirm the pay complies with or is exempt from the minimum wage and explain any exemption. We recommend a written determination prepared by HR, signed by the Authorising Officer and seen by the trustees or finance lead. In civil proceedings, section 28 of the National Minimum Wage Act 1998 presumes the worker qualifies unless you prove otherwise.
Not automatically. The main exclusion, section 44A of the National Minimum Wage Act 1998, covers residential members of a charitable religious community who live together for its religious purpose. A minister living in their own home and serving a congregation does not obviously fit it. Whether a minister has a contract at all depends on how they were engaged, so take advice before relying on that.
Only for applications made by 28 October 2026. From 29 October 2026 RW 4.2 no longer accepts advertising or a search of national records. The remaining options are a supernumerary role, a religious order role, or at least 6 months of religious duties overseas for your affiliated organisation immediately before the application.
RW 4.2(c) requires a letter from the overseas faith-based organisation detailing that the applicant performed religious duties for it outside the UK for at least 6 months immediately before the date of application. We recommend it also gives the exact dates, describes the duties, confirms the organisation's link to your UK organisation, and is signed by someone with authority who can be contacted.
On our reading, no, and that is not new. The current RW 4.1(i) and sponsor guidance paragraph MRW5.8 already excuse a worker extending with the sponsor who assigned their last CoS, and HC 584 re-enacts that carve-out. The new RW 4.2 is worded as a requirement on every applicant, though, so until the guidance confirms the position, file same-sponsor extensions by 28 October 2026 where you can. A worker changing to a new sponsor needs one of the three options.
Not as at 30 September 2026. The current guidance is version 04/26, published on 8 April 2026, and it still describes advertising, the first-month certification and the 6-year cap. Where it conflicts with HC 584, the Rules decide applications from 29 October 2026. Check GOV.UK for a new version before assigning a CoS.
Not for applications from 29 October 2026. HC 584 deletes MOR 10.2, which capped extensions at the balance of 6 years, and makes every grant up to 3 years. A minister can extend in 3-year steps, and each extension for a role outside the minimum wage needs a fresh whole-stay undertaking.
