On May 29th, 2025, the UK Home Office implemented significant changes to the Immigration Rules (HC 733) concerning child student visas.
These new regulations introduce stricter eligibility and safeguarding requirements for both applicants and the educational institutions that sponsor them.
In this update, we outline the most significant reforms and offer insights about how families, schools and colleges can meet these new requirements.
Child Student Visa Updates - April & May 2025
1. Application Fee Increase
From April 9th, 2025, the application fee for child student visas increased from £490 to £524. This fee applies to students applying outside or within the UK.
The increase in visa application fees impacts all visa categories, as outlined in UKVI’s policy paper.
2. Nominated Guardian Definition & Requirements
The UK’s immigration rules now include a formal definition of ‘nominated guardian’ (page 6):
A person aged 18 years old or over who is appointed by the Child Student’s parent, legal guardian, or school as the Child Student’s carer in the UK outside of term-time for less than 28 days and/or is the school’s emergency contact in the UK for the Child Student. The person must not be:
(a) a private foster carer (for the purposes of section 66 of the Children’s Act 1989); or
(b) close relative the Child Student is living with during term-time; or
(c) the Child Student’s parent or legal guardian who has permission as a Parent of a Child Student.
At the time, only a child’s close relative, legal guardian or private foster carer would submit a letter of undertaking to support the visa application. This new policy change means that nominated guardians can undertake care for full-time boarders, rather than relying solely on a foster carer or close relative.
Nominated guardians must now complete a letter of undertaking, which includes confirming the names, registered address and contact details of anyone regularly living with the guardian.
3. Care and Criminality Requirements
Applicants must also demonstrate they have appropriate care, living and guardianship arrangements in place to safeguard the child student while they reside in the UK.
The Home Office can now refuse an application based on whether the close relative, private foster carer, legal guardian, nominated guardian or the individuals living with said guardian have criminal records.
Specifically, the Home Office must refuse the application if any of the individuals (page 22):
(a) has been convicted of a criminal offence in the UK or overseas for which they have received a custodial sentence of 12 months or more; or
(b) is a persistent offender who shows a particular disregard for the law; or
(c) has committed a criminal offence, or offences, which caused serious harm.
The application can also be refused if the carer has a conviction with a custodial sentence of less than 12 months, or has received a non-custodial sentence or out-of-court disposal recorded on their criminal record.
4. Permitted Living Arrangements
Child student applicants must now demonstrate in their parental consent letter or their intended carer’s letter of undertaking that they will live in one of the following arrangements:
(a) Full boarding at a residential independent school during term time, with out-of-term holidays spent with a British citizen or settled person (i.e., nominated guardian (only for less than 28 days), private foster carer or close relative).
(b) Weekly boarding, with weekends and holidays spent with an eligible British citizen or settled person.
(c) Flexi boarding and care by a British citizen or a settled person.
(d) Full-time stay with a private foster carer or close relative who is a British citizen or settled in the UK.
(e) Full-time stay with a parent or legal guardian who has entered on a parent of a child student visa.
(f) Aged 16 or 17 and living independently.
The financial requirements have also been updated to align with these six living arrangements.
5. Increased Due Diligence for Child Student Sponsors
If you are a licensed educational institution, you will now have an additional sponsorship duty to collect information on the travel arrangements for students with a nominated guardian.
You will need to keep records of:
- When the child arrives
- Who will be collecting the child
- Where the child will be staying if they are not going directly to school
- Reports to the relevant authority if the child does not enrol
Student sponsors must keep note of their ‘reasonable attempts’ to collect this information. For more information, refer to UKVI’s latest student sponsor duties guidance or speak to our team for help with your next steps.
What Do These Changes Mean for Schools?
Home Office caseworkers have increased powers to refuse a child student visa application. Educational institutions must take greater care in maintaining their due diligence and record-keeping to avoid having student applications rejected.
With stronger due diligence measures, schools will have a larger administrative burden, which will take time away from work that matters.
Michelle Holmes, Managing Director at Holmes & Partners, adds:
“The updated UKVI guidance on Child Student visas, particularly around living arrangements and guardianship, introduces much-needed clarity but also new administrative burdens for schools and families. While the formal requirement for a letter of undertaking brings consistency and strengthens safeguarding standards, it also creates practical challenges — especially where guardianship arrangements are managed by companies and host families may not yet be appointed at the time of application.
One key concern is the potential for visa delays or refusals if documentation is incomplete or misunderstood. Schools must now ensure they have robust systems in place to verify living arrangements, gather guardian information early, and guide families through the evolving requirements.
To prepare, schools should review and update their admissions checklists, communicate early with parents and guardianship organisations, and maintain clear records of all care arrangements. Staff should also be trained to recognise when a nominated guardian is required — and importantly, when a living arrangement does not meet UKVI criteria.
These changes underline the growing scrutiny of international student care in the UK. By taking a proactive and well-documented approach, schools can remain compliant while continuing to offer a supportive environment for overseas pupils.”
Next Steps
The new requirements for applicants and child student sponsors are in force. To maintain compliance, schools must take the necessary steps:
- Receive letters of undertaking, parental letters of consent and other documentation before issuing a CAS.
- Confirm which of the six permitted living arrangements the student will fall into.
- Update school safeguarding policies and procedures for international students.
- Maintain communications with parents, nominated guardians and other caregivers.
- Conduct staff training to raise awareness and ensure everyone is up to speed on the changes.
Need Help Navigating These Changes?
Holmes & Partners is a trusted immigration consultancy to independent schools across the UK. Our team can assist with updating policies, maintaining compliance with sponsor duties and keeping student visa applications on track.
If you need support, contact our team, and we will get in touch.
