In April 2012, the government changed the rules surrounding the T2 'cooling off period'.

The term, 'cooling off period', is used to describe an interval between successive tenures under a T2 visa (i.e., work permit).  Its purpose is to  combat abuse wherein T2 sponsors may attempt to avoid the 'Resident Market Labour Test'.  At the moment the T2 cooling off period for most scenario is 12 months.

The introduction of this rule in April 2012 created an awkward situation for graduate interns because they were effectively unable to switch from 'intern' to 'sponsored worker' without the requisite cooling off period.  Most agree that this happened as an unintended consequence because the rule was not sufficiently thought through before activation.

UKBA officials Rob Whiteman and Glyn Williams have assured UK businesses that a fix is being worked upon, but at the time of this writing (7 May 2012), nothing has been announced.  NOTE:  a temporary fix was announced on 30 May 2012.

Experts have also noted that the current T2 cooling off period is exclusionary to the few individuals who may be best qualified to do the work.  This aspect has received criticism because it could have been identified in a diligent impact assessment undertaken prior to launching the rule. 

Other changes in the T2 space which activated in April 2012 are....

• An important clarification of who can switch out of T1 (PSW) into T2 (General).  Applicants who do not meet the switching requirements will have to apply for entry clearance abroad.
• Changes to the periods of leave granted to T2 applicants (capped at 6 years)
• The 'cooling off' period (discussed above), which is now controversial
• Changes to the ILR salary hurdle (set to activate in 2016)
• Formalizing changes to the Resident Market Labour Test, plus two exemptions
• Minor changes to the intra-T2 switching rules

Updated 30 May 2012