Winning the Workforce Question in Care Tenders After the Overseas Recruitment Ban
Overseas care recruitment closed in July 2025. Commissioners now read the workforce section for how you keep the staff you already have. How to answer it with real evidence.
Since 22 July 2025, care providers can no longer sponsor care workers from overseas, so the workforce section of a care tender can no longer lean on international recruitment. Commissioners now read that section for one thing: how you keep the staff you already have. "We will recruit to fill vacancies" no longer scores, because the pipeline it assumed has closed. The winning workforce answer is now built on retention evidence and real numbers.
What the evidence shows
- The Immigration White Paper of 12 May 2025 set out ending overseas recruitment of care workers. Overseas recruitment closed on 22 July 2025, so employers can no longer sponsor care workers or senior care workers applying from abroad. In-country switching remains available until 22 July 2028, but only for people already in the UK who have worked for the sponsor for at least 3 months, and care workers already here can continue working, extend and change sponsor.
- Skills for Care reports the adult social care vacancy rate at 6.2% in 2025/26, about 96,000 vacancies on any given day, the lowest since 2015/16, though still around three times the rate of the wider economy. International arrivals into direct care roles fell to about 30,000 in 2025/26 from about 50,000 the year before, and the number of British nationals in post fell by about 40,000 in a single year.
- Turnover is the real pressure, not headline vacancies. Skills for Care put sector turnover at 23.1% in 2024/25, about 335,000 leavers, with direct care worker turnover around 28 to 30%.
- Retention tracks employment practice closely. Turnover was 43.5% for people with under one year in the sector against 17.6% for those with 20 years or more, and staff with five positive employment factors present had a turnover rate of 14.4% against 42.2% for those with none of them.
- Pay is compressing against the legal floor. Median independent-sector care worker pay was £12.60 an hour to December 2025, and the National Living Wage rises to £12.71 from April 2026, so the minimum wage now sits at or above typical care pay for most workers.
Skills for Care states that employers "can no longer look to international recruitment in the way they've been able to in recent years", placing retention and domestic recruitment at the centre of workforce planning.
What this means for providers
The workforce answer has flipped from pipeline to retention. Commissioners increasingly expect evidence that you can hold your team together and draw on the domestic and displaced workforce, and they treat workforce instability as a delivery risk to be scored, not a footnote.
- "We will recruit to fill" is now a weak answer. Evaluators want real turnover and vacancy figures, retention initiatives with outcomes, and a safe staffing model that does not depend on an overseas pipeline that no longer exists.
- There is a domestic and displaced pool you are expected to use. ADASS has cited up to 40,000 visa-holding care workers in the country without a care job, and the Homecare Association reported about 39,000 displaced workers, roughly 30% of vacancies, with regional hubs having matched only about 3.4% of them. Commissioners increasingly expect providers to recruit from these routes before claiming vacancies are unfillable.
- The cost base is rising and it is linked to retention. Employer National Insurance rose to 15% from April 2025 with the threshold cut to £5,000, and the National Living Wage rises to £12.71 from April 2026, so a credible workforce answer and a realistic price have to be built together.
What to do about it
- Put your real numbers on the page: current turnover and vacancy rates, your length-of-service profile and the year-on-year trend, with a short, honest narrative on what is driving them.
- Evidence retention, not intention. Show the specific mechanisms (contracted hours instead of zero hours, pay above the floor, career pathways, supervision, wellbeing support) and the measurable outcomes they have produced for your service.
- Show you are working the domestic and displaced workforce: named links to regional recruitment hubs, matching schemes and local pipelines, so any residual vacancy claim reads as credible rather than convenient.
- Reconcile workforce with price. Model the National Living Wage and employer National Insurance across the full contract term, and make sure the staffing model your quality answer promises is actually funded by the rate you bid.
Frequently asked questions
Can care providers still recruit care workers from overseas? Not from abroad. Since 22 July 2025 employers can no longer sponsor care workers or senior care workers applying from outside the UK. In-country switching remains available until 22 July 2028 for people already in the UK who have worked for the sponsor for at least 3 months, and care workers already here can continue working, extend their visas and change sponsor.
What do commissioners now expect in the workforce section of a care tender? Evidence of retention rather than recruitment intention: real turnover and vacancy figures, the mechanisms you use to keep staff and the outcomes they produce, a safe staffing model, and use of domestic and displaced workforce routes. Requirements vary by authority, so the specific ITT always governs, but the direction of travel across the sector is consistent.
How do I evidence staff retention in a bid? Lead with your actual turnover rate and trend, then name the practices behind it (contracted hours, pay position, induction, supervision, career progression, wellbeing) and show the result each one has had. Skills for Care data shows turnover falls sharply where positive employment factors are present, so tie your mechanisms to that logic and to your own numbers.
Can TenderLab help us respond to this? Yes. We help providers rebuild the workforce, recruitment and retention answers around real evidence rather than an overseas pipeline. Most of our writers began their careers on the frontline and have managed rotas and led recruitment, so the response reflects how staffing genuinely works.
What is the realistic lead time to engage TenderLab? As early as possible. Reaching us when a tender is published, or as soon as it appears on your pipeline, leaves time to gather your workforce data, evidence retention properly and complete independent quality assurance. We work to tight deadlines when needed, but early engagement produces the strongest submission.
Are you interested in this topic? Contact TenderLab for a free consultation.

