Response to the Migration Advisory Committee’s review of the Temporary Shortage List

Migration continues to play an essential role in Wales’ cultural vibrancy, economic strength and public services. As we look ahead the challenges and opportunities facing our nation are quite clear: an ageing population, persistent skills shortages, and the evolving demands of a modern, innovative economy. These pressures are, and will continue to be, felt across our communities, our businesses, and our public services. Therefore, ensuring that Wales has access to the right people and the right skills at the right time is critical to our future prosperity as a nation.

The Welsh Government welcomes the opportunity to contribute to Stage 2 of the Migration Advisory Committee (MAC)’s review of the Temporary Shortage List (TSL). While we support the UK Government’s ambition to strengthen domestic skills and encourage long‑term investment in the workforce, it is equally important that the UK’s immigration system reflects the realities of different nations and regions. Wales’ labour market is distinct, shaped by our demography, our industrial heritage, and the needs of sectors that are fundamental to our communities and public services.

This review takes place at a time when foundational sectors such as health, social care, hospitality, agriculture and food production face acute workforce shortages. These sectors, many of which rely heavily on international recruitment, are essential to the everyday functioning of Welsh society. Restricting migration routes in these areas risks compounding existing pressures on public services, communities and businesses. We must ensure that the UK’s immigration system is flexible enough to meet the needs of both high‑growth sectors of strategic importance and the foundational sectors that sustain our economy and wellbeing.

The Welsh Government remains committed to strengthening our domestic workforce through investment in skills, apprenticeships and lifelong learning. However, these measures take time, and in the short to medium term, international recruitment is an important and necessary part of our workforce strategy. It is vital that the Temporary Shortage List, and the wider immigration system, supports the development of a sustainable labour market in Wales.

We will continue to work constructively with the UK Government and the MAC to ensure that future migration policy reflects the needs of our economy, our communities and our public services. A fair, responsive and evidence‑based system is essential if we are to deliver sustainable economic growth, improve productivity and ensure that Wales remains a welcoming and prosperous nation.

In developing our response, the Welsh Government has reviewed, statistics, academic reports and engaged with partners across Wales. I want to thank all our partners that have both contributed to the Welsh Government’s response and engaged directly with both the MAC and the UK Government.

Jane Hutt MS

The Cabinet Secretary for Social Justice, Trefnydd and Chief Whip

On 12 May 2025, the UK Government published an Immigration White Paper (IWP) titled “Restoring Control over the Immigration System”, which outlined the government’s strategy for establishing an immigration system that fosters economic growth whilst ensuring proper control.

It was within this context and specifically following the increase in the skills threshold for the Skilled Worker visa, that the TSL was introduced. The TSL was intended to allow access to the immigration system for “a narrow list of critical shortage occupations… alongside workforce strategies to increase training and participation rates in the UK.” The IWP also established important tests that must be met in order for a Regulated Qualifications Framework (RQF) 3 to 5 occupation to be placed on the TSL:

• Is the occupation crucial to the Industrial Strategy or critical infrastructure? (Stage 1 consideration).
• Is the occupation in shortage, now or in the near future? (Stage 2 consideration).
• Is it sensible for migration to have a role in reducing the shortage? (Stage 2 consideration).
• Do the sectors that rely on this occupation have credible plans to maximise use of the domestic workforce? (Stage 2 consideration).

The TSL has been explicitly designed to provide time-limited access to the immigration system for those RQF 3 to 5 occupations where long term shortages have been identified, and which have been deemed as crucial to the delivery of the UK’s Industrial Strategy or critical infrastructure. 

Unless placed on the TSL (or the updated Immigration Salary List which remains until 31 December 2026), RQF 3 to 5 occupations will no longer have access to the immigration system. The TSL can therefore be seen as serving a key role in providing access to skilled migration for occupations deemed crucial to the government’s Industrial Strategy and growth agenda.

No occupations below RQF Level 6 will have access to work visas going forward, except for a group of mid-skilled occupations which will have time-limited access because they are:

1. crucial to the Industrial Strategy or critical infrastructure and
2. sectors have demonstrated workforce shortages and the steps they are pursuing to utilise domestic workers, are investing in training, and effectively managing exploitation risks

The review of the Temporary Shortage List

On 2 July 2025, the UK Government’s Home Secretary commissioned the Migration Advisory Committee to undertake an in-depth review of salary requirements for work visas and requested advice on the new TSL.

The Home Secretary requested advice on 3 main areas:

1. The occupations that are crucial to the delivery of the Industrial Strategy or to critical infrastructure
2. Which of those occupations should be included on the TSL, including an assessment of sector workforce strategies to maximise use of the domestic workforce
3. The terms and conditions of the TSL visa, including visa caps and visa lengths

The MAC were tasked with responding to the UK Government within 12 months of the commission.

The MAC has decided to approach the review in 2 stages. In Stage 1 (which is now complete, the findings published on 9 October 2025) the MAC identified the occupations eligible for inclusion on the TSL, defined as being potentially crucial to the delivery of the Industrial Strategy or critical infrastructure.

Stage 2 runs from the launch of the call for evidence on 5 November until July 2026.

As part of Stage 2 the MAC is seeking further evidence on the occupations that passed Stage 1 to identify which of these occupations they recommend adding to the TSL, to which this response relates. All responses must be submitted to the MAC Committee by the deadline of the 2 February 2026.

Stage 1 findings

The Stage 1 report of the TSL was published by the MAC on the 9 October 2025 and identifies which occupations should progress to Stage 2 for further review. The report includes 82 occupations at RQF levels 3 to5, selected based on their strategic importance to the Government's Industrial Strategy and their contribution to critical UK infrastructure. The MAC recommends that occupations remain on the list for 3 years to allow sectors to address temporary shortages and develop domestic workforce strategies. The TSL replaces the previous Immigration Salary List and creates a route for skilled workers to fill jobs at RQF levels 3 to5 where genuine labour shortages exist. Read information on the occupations identified in stage 1 report on GOV.UK.

The Welsh Government acknowledges that the TSL has been created in the context of incentivising firms to employ and invest in domestic workers as a means of addressing shortages and we will continue to work with the UK Government on this agenda. We welcome the UK Government’s commitment to working with the Devolved Governments, including through the newly created Labour Market Evidence Group (LMEG), to gather and share evidence about the state of the workforce, training levels and participation by the domestic labour market.

However, data limitations currently make it difficult for the Devolved Governments to fully contribute to discussions and evidence on labour market issues and reliance on overseas workers. Therefore, this paper focuses on providing an overview of the economic and demographic landscape of Wales, with a high-level analysis of our important sectors alongside evidence of some of the skills gaps identified. Due to the limitations in devolved-level occupational data it is acknowledged our ability to influence the occupations on the TSL list is somewhat limited.

Welsh demographics

Welsh demographics must be considered by the MAC and the UK Government when considering the TSL within the context of wider labour supply and economic prosperity.

Wales currently has the highest proportion of people aged 65 and over of any UK nation, and our population continues to age. Over the decade leading up to 2019, the proportion of people in Wales who are of working age (between 16 and 64 years old) steadily declined. Since then, that trend has levelled off. In 2024, 61.1% of the population were of working age, and this proportion is projected to continue declining over the next 25 years.

The Welsh Government recognises population decline in Wales is not inevitable and is amenable to various policy interventions. We are already taking cross-government actions to make Wales an attractive place to live, work and study but an immigration system that recognises demographic and geographical differences would alleviate some pressures in Wales.

However, if the trends noted were to continue and net migration declined, this would give rise to a risk of a reduced future workforce in Wales, impact the Welsh tax base and have broader implications for future relative economic performance as well as for Welsh society. A TSL focused only on occupations related to the UK’s Industrial Strategy and increased salary thresholds will inevitably mean that sectors in Wales which are reliant on international workers wholly due to demographic issues will find it increasingly hard to recruit in the future.

Welsh migration statistics

On the 27 November the Office for National Statistics (ONS) published its latest bulletin on Long-term international migration, provisional year ending June 2025. These estimates are for the UK. The ONS does not currently publish long-term international migration estimates for Wales. 

The main findings are outlined below:

Net migration

• Long-term net international migration is continuing to decrease for the UK, with net migration provisionally estimated at around 204,000 in year ending June 2025, two-thirds lower than the year previously (649,000 in the year ending June 2024). 
• The decrease in net migration is driven by fewer non-EU+ nationals arriving for work and study related reasons, and a continued gradual increase in levels of emigration.
• Non-EU+ migration has been driving the overall trend since 2021. The provisional net migration estimate for non-EU+ nationals was 383,000 in the year ending June 2025, continuing a downward trend since 2022. 
• By contrast, both EU+ and British national groups saw more people leave the UK than arrive. EU+ nationals' net migration is provisionally estimated at negative 70,000, continuing a downward trend since the 2016 EU membership referendum, and negative 109,000 for British nationals, remaining broadly stable.

Immigration

• For the year ending June 2025, long-term immigration into the UK was provisionally estimated at 898,000, a decrease of 401,000 from the updated year ending June 2024 estimate of 1,299,000. This continues a downward trend from the peak of 1,469,000 in the year ending March 2023.
• Most people arriving to the UK in the year ending June 2025 were non-EU+ nationals, estimated at 670,000, a decline from 1,063,000 in YE June 2024. 
• This decline is primarily attributed to fewer people arriving on work and study dependant visas, where there has been a decrease of approximately 70%.

Emigration

• The provisional estimate of the number of people emigrating out of the UK long-term for the year ending June 2025 was approximately 693,000. This is 43,000 higher than year ending June 2024.
• Most people who left the UK in the year ending June 2025 were non-EU+ nationals (286,000), with around half of those leaving originally arriving on study-related visas.
• Emigration of British nationals in the year ending June 2025 (252,000) is now at similar levels to non-EU+ emigration.

Although these statistics represent UK-level data, we can still make assumptions that the number of migrants travelling to Wales to work or study continues a downward trajectory. This trajectory coupled with a declining and aging population and a lower than UK average annual salary level will undoubtedly result in labour shortages across a number of sectors in Wales, not only those delivering for the UK Industrial Strategy.

High Level Analysis of the Industrial Strategy Growth Sectors in Wales

The UK Government’s Immigration White Paper makes it clear that the proposed immigration reforms aim, among other things, to support the skills needs and labour supply of the developing UK Industrial Strategy. 

We welcome the inclusion of a range occupations which will be critical to the future growth of key sectors in Wales. The tables below illustrate where employment has grown at a faster rate compared to Great Britain. It is noted that the growth sectors which have been identified in Wales are Advanced Manufacturing, Clean Energy, Defence, Digital and Technologies, Life Sciences and Creative Industries, therefore we would expect these sectors in particular to grow in future years.

Source: Business Register and Employment Survey (ONS/NOMIS).

The table below provides a list of specific subsectors within financial services and manufacturing which are growing quickly and where we are likely to see demand rise for key occupations in the short to medium term.

Source: Business Register and Employment Survey (ONS/NOMIS).

The list below shows employment figures for important sectors in the Welsh economy between 2018 to 2024, the majority of which have seen growth in employment in recent years. This illustrates that these sectors make up a significant percentage of the economy in Wales. It is also noted that the demographic make-up of Wales means that there are higher levels of employment in health and social care sectors compared to the wider UK economy. Future changes to migration patterns will inevitably mean future skills gaps will grow and filling vacancies within these key sectors will become more challenging in the future.

Source: Business Register and Employment Survey; (ONS/NOMIS).

Other sectors not identified within the Industrial Strategy

The UK Government’s Immigration White Paper makes it clear that the proposed immigration reforms aim, among other things, to support the skills, needs and labour supply of the developing UK Industrial Strategy. Whilst the Welsh Government acknowledges the importance of a UK Industrial Strategy, unfortunately the skills needs of Wales are not necessarily synonymous with those of England or the rest of the UK, and this means that there are occupations and sectors that are reliant on international workers and which will now fall outside the remit of the Temporary Shortage List; occupations that are of significance to the Welsh economy, culture and Welsh Government priorities.

Limiting the scope of the review of the Temporary Shortage List to occupations deemed as being significant to the delivery of the UK Government’s Industrial Strategy has meant that several sectors in Wales have not been given the opportunity to put forward evidence for occupations that they are currently struggling to fill.

Retail, Agriculture, Health, Social Care, Food Manufacturing and Hospitality are a few of a number of sectors in Wales that rely on lower skilled international workers for a number of significant reasons. The Welsh Government feels that it is just as important to feedback information on not only the 81 occupations noted in the MAC’s Stage 1 publication but also other occupations that are of significance to economic and societal development in Wales.

Salary statistics for Wales

In its recent review of the TSL which was published on 17 December 2025 the MAC recommended that the general threshold for the TSL should be set at least as high as the 30th percentile of the UK’s full-time annual earnings distribution (approximately £30,900), ensuring migrants are paid a wage that affords a reasonable standard of living. 

Wales’ ability to attract talent to work in key occupations within growth industries identified in the Industrial Strategy will be an important factor with respect to successfully securing investment and improving productivity levels in Wales. Although the MAC does not support a regional difference in thresholds they do propose that occupations on the TSL should continue to have occupation-specific salary thresholds at the median and the Welsh Government welcomes that approach in the absence of regional variation.

Skills gaps/pipelines

The Employer Skills Survey (ESS) 2024 is the seventh in a series of large-scale telephone surveys in the UK which provide labour market information on the skills challenges faced by employers. In 2024, the ESS 2024 comprised 22,712 interviews with UK employers including 5,605 employers in Wales. The findings from the Employer Skills Survey for Wales) suggest that:

• employers in Wales are facing more challenges in 2024 recruiting the skills they need compared to earlier years (2011 to 2017)
• over a quarter (28%) of all vacancies in Wales were reported to be hard to fill due to applicants lacking the skills, experience or qualifications employers require (i.e., skill‑shortage vacancies, SSVs), falling from 35% in 2024, but higher than across 2011 to 2017 (18% to 27%). This figure was similar across nations in 2024, although highest in Wales
• the Manufacturing and Construction sectors were most affected by SSVs in Wales, with more than half of vacancies reported as SSVs by employers in each (54% for Manufacturing and 53% for Construction)

Over a quarter of Welsh employers have recruited, or tried to recruit, non-UK nationals to fill hard-to-fill vacancies. While this is the lowest proportion among UK nations, Manufacturing and Health and Social Work employers were more reliant on recruiting non-UK nationals:

• 27 (27%) of Welsh employers have recruited, or tried to recruit, workers who are non-UK nationals in order to fill hard-to-fill vacancies; 20% of which were non-UK nationals already living in the UK, 6% who moved / planned to move to the UK for the job, and 1% have remained / would remain living overseas). These figures were the lowest proportion among UK nations.
• Whilst data for all sectors in Wales is not available due to sample size limitations, employers in the Manufacturing (53%) and Health & Social Work sectors (48%) were most likely to recruit or try to recruit non-UK national to fill hard-to-fill vacancies.

Employers in the Health and Social Work sector in Wales are the most reliant on staff working in the UK on a visa:

• 6 (6%) of employers in Wales reported having staff who are ordinarily resident outside the UK and currently working in the UK on a visa. This question was not asked of the other UK nations so it is not possible to compare. Among these employers in Wales, around one-third (34%) reported they were actively sponsoring visas for any of their staff who are from outside the UK. 
• Health and Social Work employers (25%) in Wales were more than twice as likely to have staff on a visa as employers in other sectors, followed by Hotels & Restaurants (12%) and Manufacturing (8%).
• The likelihood of having any staff in the UK on a visa increased with site size in Wales. Nearly half (45%) of the largest sites with 100 or more employees reported they have staff working in the UK on a visa, compared with 2% of the smallest sites with 2 to 4 employees.

Employment projection

The Skills Imperative 2035 is a strategic research partnership led by the National Foundation for Educational Research and funded by the Nuffield Foundation which aims to identify the essential employment skills people will need for work by 2035. The Skills Imperative includes employment projections up to 2035, including projections for Wales.

• Employment in Wales is projected to grow by 5.4% between 2020 and 2035, equating to an increase of around 78,400 more people being in employment. The projected increase is less than the projection for the UK (7.4%) over the same time.
• Exploring projections by business sector, the sector with the largest projected increase in employment between 2020 and 2035 is Health and Social Work, which has a projected increase of 38,200, equivalent to an increase of 17.4%. This was the largest sector in 2020 and it is projected to remain so in 2035, growing much faster than the second largest sector, Wholesale and Retail Trade (projected growth of 3,200 or 1.5%). These projections highlight the potential for rising future demand in Health and Social Work, and given the sector’s current reliance on non‑UK nationals and visa‑sponsored staff (as identified in the ESS 2024, above) underline the importance of ensuring a sustainable supply of skilled workers.
• Behind Health and Social Work, the greatest projected increases in the number employed are in Education (11,900), Accommodation and Food (10,700), Professional Services (9,500) and Support Services (9,500). 
• Sectoral growth projections tend to go in the same direction for both Wales and the UK, with a few exceptions. These include Finance and Insurance, which is projected to increase in Wales but decline in the UK; Real Estate, projected to decline in Wales but grow in the UK; and Other Services, projected to decline in Wales and remain relatively unchanged in the UK.
• The continued expansion of higher-level qualifications amongst those in employment can be seen. Between 2020 and 2035, the proportion of those in employment who are qualified at Regulated Qualifications Framework (RQF) level 6 or above is projected to increase from 31.6% to 43.9%
• The opposite effect can be seen for those with lower-level qualifications or holding no qualifications. Large declines are projected in the proportion of those in employment in Wales holding RQF level 2 (22.6% to 16.4%) and RQF level 1 (11.7% to 6.8%), whilst more moderate declines are projected in the proportion of employed people holding RQF level 3 (19.8% to 17.9%) and holding no qualifications (4.0% to 3.5%).

Welsh sector specific responses

Aeronautics

There is an overall concern that the occupations linked to future aeronautical engineering cannot and will not be able to be filled by the UK labour supply alone. There are several occupations listed on the TSL important to the sector in the UK and Wales, including (but not limited to) engineering technicians, data analysts, electrical and electronic technicians, science, engineering and production technicians. The sector has informed the Welsh Government that it is important that these occupations remain on the list to enable us to continue operations in Wales and the wider UK which will in turn deliver growth for the whole of the UK and, importantly, align with the ambitions of the UK’s Industrial Strategy. 

Health

Within NHS Wales, SOC 3132 roles are integral to local and national digital and IT support teams, ensuring that clinical and administrative staff have reliable, secure and timely access to essential digital systems. These roles continue to experience recruitment and retention challenges, reflecting wider labour market pressures in digital and IT professions. 

The Welsh Government and NHS Wales are actively developing domestic capability through the Digital and Data Strategy for Health and Social Care, with Health Education and Improvement Wales embedding digital and data skills across the workforce, and Digital Health and Care Wales strengthening specialist digital support. 

Therefore, we welcome the inclusion of SOC 3132 on the TSL to support service continuity while longer-term workforce development initiatives take effect. 

Social care

Social care roles, including social workers, are either out of scope or ineligible for inclusion on the TSL. This is a concern because reliance on overseas workers in social care varies significantly across Wales, with some providers heavily dependent on overseas workers to keep services running. Overseas workers have helped fill gaps in recent years, and without them, many services would struggle to operate,leading to delays in care and increased pressure on local authorities and providers. Due to the lack of devolved-level data, we do not have accurate numbers of overseas workers in Wales. However, feedback from Welsh providers and trade unions makes it clear that international recruitment is vital in this sector. 

Between the 2011 and 2021 censuses, the percentage of the population aged 65 and over in Wales rose to 21.5%, compared to 18.6% in England. This means demand for care is increasing, while the sector continues to face ongoing recruitment and retention challenges without the workforce sufficiency to meet this growing need. The UK Government’s recent immigration changes have already created significant uncertainty across the sector, with the stop to overseas recruitment into social care roles and the increase in the minimum salary threshold. These measures could exacerbate existing workforce shortages, placing additional pressure on providers and local authorities, and having a direct impact on the wider health system. Delays in arranging care packages can prevent people from leaving hospital, creating extra strain on NHS capacity and patient flow. 

Combined with exclusion from the TSL, these changes leave us preparing for a future with no new overseas workers recruited into social care. Whilst the Welsh Government is investing in training and domestic recruitment and retention initiatives, these take time and resources. Without a flexible system and alternative recruitment options, such as overseas recruitment, social care in Wales faces serious risks to workforce sustainability, which will affect vulnerable people and communities.

The arts

The Arts Council of Wales welcomes the inclusion of the arts-related occupations on the TSL.

Dance and music in particular are so highly internationalised in terms of workforce, they need to make sure the sector in Wales and the UK have access to the best talent. The current salary thresholds for other visas, along with other requirements of the UK’s points-based system, mean that it is difficult for artists to meet the requirements. Being on the TSL is one of the only ways the sector can access the talent that it requires to sustain its continuation.

Organisations such as the BBC National Orchestra of Wales, the Welsh National Opera, National Dance Company of Wales and NoFit State Circus all employ international artists; musicians, actors, dancers, choreographers etc. and need to be able to access the best talent from around the world Read the Creative Industries Policy and Evidence Centre’s report.

Dance companies in Wales are concerned about the difficulties the removal of dancers and choreographers from the list would cause the sector. 

Higher education

The UK higher education and research sector relies on a highly skilled technical workforce. Technical professionals underpin world-class research, education, and innovation, from operating and maintaining advanced equipment to training students and researchers in critical skills. Without the ability to recruit and retain this workforce, the UK’s ambitions in science, technology and high value manufacturing, as outlined in the recent Industrial Strategy will be undermined.

Without technicians, universities and research institutes cannot deliver world-leading research, education, or innovation. Immigration policy must therefore be part of the solution to the current lack of skilled workers resident in Wales to fill these occupations.

Without the ability to recruit and retain this workforce, the UK’s ambitions in science and technology, as outlined in the UK Government’s Industrial Strategy, will be undermined. These are roles that cannot easily be filled by the domestic labour market and are also not areas in which it is easy to upskill quickly. It is essential that Higher Education Institutes can fill positions at RQF 3 to 5 that support their academic and operational infrastructure and inclusion of those roles in the TSL would support that.

The Technician Commitment, led by the Institute for Technical Skills and Strategy and launched in 2017, was designed to address systemic recruitment challenges. Over 130 universities, research institutes, and sector organisations have signed the Commitment and are taking tangible action. However, building a sustainable domestic pipeline will take time. While apprenticeships, education, and career development initiatives are being scaled up, the sector must be able to continue to recruit globally in the short to medium term.

Universities and research institutes play a dual role both as major employers of technicians and as trainers of the future workforce, but in the short term the UK must be able to recruit globally to maintain competitiveness.

The sector has called for a prioritisation of technical roles on the TSL, enabling universities and research institutes to continue to recruit internationally.

Universities have taken proactive steps through the Technician Commitment to strengthen the workforce pipeline but sustainability will inevitably take time. Immigration policy must therefore support immediate recruitment needs by recognising the following technical roles as skilled and placing them on the TSL:

• 3111: Laboratory technicians
• 3119: Science, engineering and production technicians n.e.c.
• 3131: IT operations technicians
• 2132: IT user support technicians
• 3133: Database administrators and web content technicians
• 3533: Financial and accounting technicians

Third sector employment

Third sector organisations in Wales have raised concerns that a number of occupations highly relevant to Welsh economic needs, migrant employment pathways and organisational workforce planning have been marked “Out of Scope” in the review of the TSL, including: 

• charity and voluntary sector managers (SOC 1241, 1250 series)
• youth and community workers (SOC 3231)
• business, project, and operations managers in third-sector settings (SOC 1135)
• driving occupations (including delivery, van driving, taxi/private hire, logistics)
• entry and mid-level hospitality roles
• early years support roles (below RQF 6)

The proposed classification creates 2 significant challenges in that it will restrict legitimate employer sponsorship for third sector organisations, specifically migrant-led employers who are actively supporting staff and volunteers to progress from insecure immigration statuses into stable, long-term employment.

It also excludes the majority of realistic employment pathways for migrant service users, where data shows that the most common roles pursued by migrants are:

• driving occupations (delivery, taxi, logistics)
• hospitality roles (kitchen, waiting, front-of-house, bar)
• care support roles below managerial level
• community-facing roles
• cleaning and facilities roles
• security roles

Most of these are either Out of Scope or Ineligible for TSL consideration despite reflecting lived employment experiences of migrants. The call from the third sector is to ensure that the immigration system reflects realistic employment patterns of migrants; not solely degree-level or managerial professions and where occupations are not recognised in the review of the TSL they must be recognised elsewhere in the immigration system.

Welsh manufacturing

Manufacturing companies have concerns regarding skills issues, qualified candidates across ‘High Value Manufacturing’ (defence, space, aerospace, automotive, life sciences, food processing) and how to attract the next generation into what can be seen as traditional manufacturing roles. 

Clean energy

If we are to achieve our ambitions to scale up clean energy in Wales, we will need a significant scaling up in our workforce. The Welsh Government continues to work with industry to identify the skills gaps and workforce needs for the clean energy sectors. With a significant development pipeline for onshore and offshore wind in Wales, recent analysis conducted for the Offshore Wind Industry Council and Renewable UK shows that a detailed breakdown of job roles identifies Wind Turbine Technicians as the most in-demand occupation, with significant needs also projected for High Value Manufacturing cable specialists, installation engineers, fabrication specialists, planning officers and technical managers.

We have identified actions through our Offshore Wind Task and Finish Group. To deliver for Wales, skills policy, funding mechanisms, and planning systems must work in tandem with industry to effectively anticipate and respond to skills needs. Training providers need confidence and support to invest ahead of demand, and industry must be incentivised to work with Welsh institutions to co-design training pathways. Greater flexibility in how programmes are funded and delivered will be vital, notably to support low-cohort specialisms, digital and blended models, and access in rural and deprived areas.

Welsh semiconductor sector

The UK Industrial Strategy identifies semiconductors as a Frontier Industry within the Digital and Technologies growth sector. South Wales is home to an exceptionally strong compound semiconductor cluster, recognised internationally for its advanced design and manufacturing capabilities.

Within the Welsh Government, the Semiconductor Programme team leads efforts to secure inward investment from existing businesses and attract new international investors. While we can provide practical support, it is important to note that UK semiconductor strategies are not resourced at the same level as the “Chips Acts” in other global regions; we cannot compete on subsidies. However, Wales remains an attractive destination for investment thanks to the reputation of this highly specialised cluster and its open-access infrastructure.

A critical factor for investors is access to a skilled workforce. We work proactively with industry and training providers to deliver relevant training, promote career opportunities, and maintain a healthy skills pipeline. Nevertheless, access to skilled workers via the TSL continues to play an important role in providing a continued and future workforce.

Although it is not currently possible to predict the specific roles future investors will require, they are likely to align with those currently in demand within the compound semiconductor sector. Broadly, these occupations at RQF Level 3 to 5 fall into 3 categories:

1. Semiconductor: process technicians for specialist chemical processes in wafer and device fabrication.
2. Engineering: electronics technicians and engineering technicians for manufacturing processes, equipment maintenance, testing, and quality assurance.
3. IT and Software: process control technicians and software developers for digital design and verification.

The Welsh Government welcomes the opportunity to contribute to Stage 2 of the MAC’s review of the TSL. While we recognise the need for an immigration system that supports the UK’s Industrial Strategy and encourages investment in the domestic workforce, it remains essential that the system also reflects the distinct demographic, economic, and labour market realities in Wales.

Wales continues to experience an ageing population, lower average salary levels, persistent skills shortages, and sectoral reliance on international workers across a range of industries, not all of which fall within the scope of the UK Government’s Industrial Strategy. These demographic and structural pressures mean that a more flexible approach to migration is necessary to ensure the resilience of key services and the continued growth of emerging and foundational sectors.

We welcome the inclusion of a number of RQF 3 to 5 occupations of strategic importance to the Welsh economy in Stage 1 of the TSL review, particularly those supporting advanced manufacturing, digital technologies, clean energy, the creative industries, and higher education. However, further evidence provided by Welsh partners demonstrates the critical importance of maintaining migration routes for technical, digital, engineering and scientific support roles at these levels. These roles underpin research, innovation, and economic growth and are essential for future investment in areas such as semiconductors, offshore wind, and aerospace.

The Welsh Government remains concerned that the narrow focus of the TSL excludes occupations fundamental to Wales’ societal and economic wellbeing, including health and social care, hospitality, agriculture, food manufacturing, and third sector services. Many of these sectors face acute recruitment challenges due to demographic pressures and long‑standing workforce shortages. The removal of migration routes for these roles risks exacerbating existing gaps, increasing pressure on public services, and undermining efforts to support vulnerable communities – particularly in social care, where reliance on overseas workers remains significant.

We also note that limitations in devolved-level occupational data restrict Wales’ ability to fully evidence labour shortages. Improved access to regional labour market data through closer collaboration with the UK Government and the Labour Market Evidence Group will be critical to future reviews.

While Wales is committed to strengthening domestic skills pipelines through investment in apprenticeships, training, and workforce development, these interventions take time to mature. In the short to medium term, international recruitment remains a necessary and practical component of ensuring service stability, meeting projected sectoral growth, and sustaining economic competitiveness across Wales.

The Welsh Government urges the MAC to:

• continue to include key technical and mid‑skilled roles of strategic importance to Wales on the TSL
• recognise the unique demographic and labour market challenges Wales faces, particularly in Health, Social Care, and foundational sectors
• ensure that occupations vital to Wales’ economic and social wellbeing, but outside the scope of the UK Government’s Industrial Strategy, are accommodated elsewhere within the immigration system
• work with the devolved governments to improve access to regionalised workforce and migration data to support future evidence‑based decisions

A migration system that supports both the UK’s strategic priorities and the distinct needs of its Nations is essential. Wales requires an approach to migration that enables sustainable population growth, supports key economic sectors, and ensures the continued delivery of vital public services. The Welsh Government stands ready to continue working collaboratively with the MAC and UK Government to develop a system that delivers these outcomes.

RenewableUK Offshore Wind Skills Report 2025

Offshore Wind Task and Finish Group Action Plan 2025 to 2026

PEC Creative Industries Report

Skills Imperative 2035 (Wales)

Employer Skills Survey 2024 (UK)

ONS Long-Term International Migration Provisional

Technician Commitment