Ethical Recruitment and the UK Red List, Explained
The UK restricts how employers and agencies may recruit health and care staff from countries facing severe workforce shortages, under the Department of Health and Social Care Code of Practice. Crucially, that Code restricts active recruitment by third parties — it does not remove an individual's own right to apply directly to an advertised UK job.
How the framework works
What the UK Code of Practice is
The UK Code of Practice for the International Recruitment of Health and Social Care Personnel (Department of Health and Social Care) sets ethical standards for how UK employers and recruitment organisations may recruit staff from overseas. It exists to protect the health systems of countries facing the most severe workforce shortages.
The WHO safeguards list and the UK red list
The UK red list mirrors the WHO 2023 Health Workforce Support and Safeguards List — 55 countries where active international recruitment by UK employers and agencies is not permitted. Active recruitment means targeting or marketing UK jobs to individuals in those countries.
What "active recruitment" means
Active recruitment includes advertising UK vacancies to people in a red-list country, agency sourcing, matching candidates to employers, incentivised referrals, or asking current staff to share specific vacancies with contacts back home. This is what the Code restricts — not the provision of general information.
The right to apply directly is preserved
The Code does not stop an individual from any country applying, on their own initiative, directly to a specific advertised vacancy with the sponsoring UK organisation. It restricts third parties from targeting them — it does not restrict the person's own choices.
Amber-list countries
A small number of countries (for example, on the current list, Kenya and Nepal) sit on an amber list, where active recruitment is only permitted under a government-to-government agreement. Without such an agreement, employers should treat them as effectively red for active recruitment.
Why GeraClinic publishes information only
GeraClinic is not a recruitment organisation and holds no government-to-government agreement. It provides general pathway information to anyone who independently seeks it, keeps that information country-neutral or limited to permitted corridors, markets no specific UK vacancies, and never charges an applicant a fee. The Employment Agencies Act 1973 also makes it illegal to charge a work-seeker a placement fee.
Active recruitment vs. providing information
Restricted from red-list countries
- · Advertising specific UK vacancies to people there
- · Agency sourcing and candidate–employer matching
- · Incentivised referrals for placements
- · Asking staff to share vacancies with contacts back home
- · Charging an applicant a placement fee (illegal anywhere)
Permitted
- · General educational information on how registration works
- · Explaining the standards, English tests and visa overview
- · An individual applying directly to an advertised vacancy
- · Country-neutral or permitted-corridor guidance
- · Information provided to people who independently seek it
The red and amber lists are revised periodically. Always confirm the current membership on the NHS Employers Code of Practice page (as of July 2026). This page describes the framework in general terms and is not legal advice.
Frequently asked questions
What is the UK Code of Practice for international recruitment?+
It is the Department of Health and Social Care framework that sets ethical standards for how UK health and social-care employers and recruitment organisations may recruit staff from overseas, designed to protect the health systems of countries with the most severe workforce shortages.
What is the WHO safeguards list and the UK red list?+
The WHO 2023 Health Workforce Support and Safeguards List names 55 countries facing the most pressing shortages of health workers. The UK red list mirrors it. UK employers and agencies must not actively recruit from red-list countries.
What counts as "active recruitment"?+
Advertising or marketing UK vacancies to individuals in a listed country, agency sourcing, matching candidates to employers, incentivised referrals, or asking current staff to share specific vacancies with contacts back home. It is these third-party targeting activities that are restricted.
Can someone from a red-list country still work in the UK?+
Yes. The Code restricts third parties from targeting people; it does not stop an individual applying, on their own initiative, directly to a specific advertised vacancy with the sponsoring organisation. A person's own direct application is always preserved.
What is the amber list?+
A small number of countries sit on an amber list, where active recruitment is permitted only under a government-to-government agreement. Without such an agreement, employers should treat those countries as effectively red for active recruitment. The current membership is on the NHS Employers website.
Why does GeraClinic only publish information?+
GeraClinic is not a recruitment organisation and holds no government-to-government agreement. It provides general pathway information to anyone who independently seeks it, keeps it country-neutral or limited to permitted corridors, markets no specific vacancies, and never charges an applicant a fee — which the Employment Agencies Act 1973 also prohibits.
Explore the rest of this guide
Related on the wider Gera network: allied-health roles on GeraClinic and healthcare jobs on GeraJobs. Applying to any specific vacancy is always done directly with the advertising employer.
Sources & further reading
These are the primary, official sources for everything on this page. Where figures appear, confirm the current value at the source before relying on it.
- UK Code of Practice for the International Recruitment of Health and Social Care Personnel (DHSC)
The ethical-recruitment framework and the red/amber country list.
- WHO Health Workforce Support and Safeguards List 2023
The 55 countries facing the most pressing health-workforce shortages.
- Health and Care Professions Council (HCPC)
UK statutory regulator for 15 health and care professions, including physiotherapists and radiographers.