Code of practice for international recruitment (England)

The code is published on GOV.UK and was last updated on 27 March 2025. It has three parts: the code itself, the red and amber country list, and the ethical recruiters list kept by NHS Employers. It applies to health and social care employers in England, including NHS trusts, local authorities and independent providers, and to recruitment organisations, agencies and collaborations. It covers permanent, temporary and locum staff in clinical and non-clinical roles.

The code sets out five guiding principles, including that international recruits have the same legal rights, responsibilities and access to development as staff trained in the UK, and that there is no active recruitment from red-list countries without a government-to-government agreement.

The red list is based on the WHO health workforce support and safeguards list 2023. NHS Employers' list, updated on 27 March 2025, names 54 countries, including Bangladesh, Ghana, Nigeria, Pakistan and Zimbabwe. Employers and agencies must not actively recruit from these countries unless a government-to-government agreement allows managed recruitment. Kenya and Nepal are on the amber list: recruitment is allowed only in line with the agreements in place for those countries. NHS Employers says the list will be reviewed in 2026.

The code allows direct applications: someone from a red or amber list country can apply for an advertised job of their own accord, without being targeted by a recruiter, and this is not active recruitment.

• No fees. The code notes that under section 6(1) of the Employment Agencies Act 1973 it is illegal for a recruitment organisation to charge a fee for finding someone work.
• Repayment clauses must be transparent, proportionate and time-limited, tapering over no more than three years, and employers should consider waiving them case by case.
• Ethical recruiters only. Employers should use recruitment organisations on the ethical recruiters list. Organisations that breach the code can be removed from that list after an investigation.

1. Check your country on the NHS Employers red and amber list.
2. Check the recruiter on the ethical recruiters list.
3. Refuse any request for a placement fee.
4. Read any repayment clause before you sign, and check that it tapers.
5. Confirm the employer is a licensed sponsor before applying for a Health and Care Worker visa.

• Being asked to pay for a job offer or processing.
• Large repayment demands that do not reduce over time, or that are not explained before you sign.
• Being approached by a recruiter while living in a red-list country. Unless a government-to-government agreement applies, this is active recruitment the code does not allow; you can still apply to employers directly.
• Assuming the code covers Scotland, Wales or Northern Ireland; it is written for England, and other nations have their own arrangements.