Developers are in the unusual position of being wanted almost everywhere while facing immigration systems that were not designed with them in mind. The work is portable, the skills are legible across borders, and remote work has made employers comfortable with distributed teams — and none of that changes the fact that each country's route has a specific bottleneck.
This guide compares the three largest English-speaking destinations for a software developer, sets out where each one actually blocks you, and addresses the question that dominates every US conversation at the moment.
The United States: the fee that is not being charged
The main route for a developer is the H-1B specialty occupation visa. It is employer-sponsored, it runs on an annual cap, and entry to the cap is by registration and random selection. The cap is the bottleneck. In recent years far more registrations have been submitted than there are places, which means a strong candidate with a strong offer can simply fail to be selected, and must wait for the next cycle.
That has always been the structural problem. The newer one is the fee.
Where the $100,000 fee stands. In September 2025 a presidential proclamation imposed a $100,000 payment requirement in connection with certain H-1B petitions. A proclamation of 18 September 2026 extended the requirement through 21 September 2027.
The courts have not gone along with it.
- In State of California v. Mullin (District of Massachusetts), the court ruled on 8 June 2026 that the fee was an unlawful tax and vacated the policy. On 24 July 2026 the First Circuit declined to pause that ruling while the government appealed.
- In Global Nurse Force v. Trump (Northern District of California), the court on 30 September 2026 blocked the agency policies implementing both the original proclamation and the extension, pending proper rulemaking. The government appealed to the Ninth Circuit on 9 October 2026.
- In Chamber of Commerce v. DHS (District of Columbia), the fee was upheld in December 2025; that decision is on appeal and was argued in the D.C. Circuit in March 2026.
As at the time of writing, employers are not being required to pay the fee, and USCIS has indicated it will comply with the court orders.
Separately, a DHS proposed rule published on 25 August 2026 would create a fee of $103,265 on cap-subject H-1B petitions. That is a proposal. It is not in force.
What this means practically. This is live litigation with appeals pending in two circuits and a rulemaking in progress. The position could change. Do not plan on the basis that the fee will never apply, and do not accept an employer's assurance either way without a current check. If you are in an H-1B process, this is a question for the employer's immigration counsel on the day, not for any article.
The alternatives. The O-1A for individuals of extraordinary ability has no cap and is used more by senior engineers than people realise, though the evidentiary bar is real. The L-1 intracompany transfer works if your employer has a US entity and you have worked for them abroad for the qualifying period — a genuinely underused route for developers at multinationals. The TN is available to Canadian and Mexican nationals for certain occupations. And cap-exempt employers, principally universities and affiliated non-profits, can file H-1B petitions outside the lottery at any time of year.
The United Kingdom: employer-led, with a hard salary floor
The UK route is the Skilled Worker visa. There is no cap and no lottery, which makes it more predictable than the US. The constraint is different: you need a licensed sponsor, and the salary has to clear a threshold.
The general threshold is £41,700 per year, or the going rate for your occupation code, whichever is higher. A lower threshold of £33,400 applies in certain cases outside healthcare and education.
For developers this is mostly workable in London and the larger tech centres, and marginal elsewhere. A mid-level developer role in a smaller UK city may genuinely pay below the threshold, which makes it unsponsorable regardless of how much the employer wants you. Check the going rate for the relevant code before investing in an application.
Costs. The visa fee from outside the UK is £819 for up to three years and £1,618 for more than three. The Immigration Health Surcharge is £1,035 per person per year, paid up front for the full length of the visa. You also need £1,270 in maintenance funds held for 28 consecutive days, unless your employer certifies it will cover your first month.
A single developer on a three-year visa is therefore looking at roughly £3,900 before incidentals. With a partner and a child, well over £11,000.
Check the register. The Home Office publishes a list of licensed sponsors. A UK tech company not on that list cannot hire you, whatever the job advert says.
The unsponsored alternatives. Global Talent, via endorsement from a recognised body in digital technology, is not tied to an employer and is genuinely worth investigating for anyone with a public track record — open source contributions, a product with users, speaking, a strong commercial record. The High Potential Individual visa gives two years unsponsored to recent graduates of a defined list of overseas universities.
Australia: the one you can start without an employer
Australia is the only one of the three where you can begin on your own.
The points route. Submit an Expression of Interest, be invited, apply. No employer needed. The catch for developers is that IT occupations have historically been crowded, which means the points score that actually receives an invitation can sit well above the eligibility floor. You will need a skills assessment from the designated assessing authority for your occupation, and that assessment is the slow step — start it months before you plan to do anything else.
The sponsored route. The Skills in Demand visa, subclass 482, requires an approved sponsor. The salary must meet the Core Skills Income Threshold of AUD 79,423 from 1 July 2026, and the annual market salary rate for the role. The threshold is indexed every 1 July, so a nomination's timing matters if the salary is near the line.
Age is the thing to watch. Points fall away sharply after 32 and again after 40. A developer in their late thirties considering Australia should run the points calculation before doing anything else, because the answer may be that the sponsored route is the only realistic one.
Canada, which belongs in this comparison
Most developers comparing destinations leave Canada out, and it is frequently the best answer.
Express Entry is a points-based system for permanent residence, managed through a pool and periodic draws. Candidates receive a Comprehensive Ranking System score based on age, education, language, work experience and other factors, and the highest scorers in each draw are invited to apply. Crucially, this is permanent residence directly — not a temporary visa with a conversion step — and it does not require a job offer.
There are also category-based draws that target specific occupation groups, which have at times included STEM occupations. A developer whose general score would not clear a standard draw may be invited in a category draw at a much lower score.
The Global Skills Strategy offers expedited work permit processing for certain high-skilled occupations where an employer is hiring, which makes Canada unusually fast on the employer-sponsored side as well.
The honest trade-offs are compensation, which is generally lower than equivalent US roles, and the fact that draw thresholds move with demand. But for a developer who wants permanent status without a lottery and without being tied to an employer, it is the most direct route available in North America.
The intracompany transfer, which almost nobody considers first
If you currently work for a company that has an office in the country you want to move to, stop reading job boards.
Intracompany transfer routes exist in every major destination — the L-1 in the United States, the Senior or Specialist Worker route in the UK, the equivalent provisions in Australia and Canada. They typically require that you have worked for the group for a qualifying period, often twelve months, and that you are moving into a role at a comparable level.
Why this is the fastest route in practice: the employer already has the entity, usually already has the licence or registration, already knows you, and does not need to run a recruitment process. The decision is internal and can be made by one or two people. Many transfers happen within weeks of the conversation.
The way to trigger it is to tell your manager that you would be interested in a role in that office if one came up. Not to apply externally to your own company, which is how it is usually attempted and usually goes nowhere.
What a sponsorable developer profile looks like
Salary thresholds mean that all three systems effectively filter by seniority. Understanding where the line sits tells you whether to apply now or build first.
In the UK, the general threshold of £41,700 sits above what many non-London mid-level developer roles pay. That makes London, and senior roles elsewhere, the realistic target. A developer with three years' experience applying to a regional UK company is likely to find that the salary cannot clear the floor even when the employer is licensed and willing.
In Australia, the Core Skills Income Threshold of AUD 79,423 is more forgiving relative to local developer salaries, but the points competition for IT occupations has historically been fierce, which pushes people towards state nomination or the regional routes.
In the United States, the H-1B prevailing wage requirement operates by occupation and geography, and the practical constraint is the lottery rather than the salary.
In all three, the specialisms that travel best are the ones with a thin global supply: distributed systems, security engineering, machine learning infrastructure, embedded and real-time systems, and anything with a regulatory dimension such as payments or health data. Generalist web development is sponsorable but faces the deepest local competition everywhere.
Evidence beats claims. A repository with a history, a product with users, a conference talk, a technical blog that demonstrates reasoning rather than tutorials. An employer weighing whether to take on sponsorship cost and delay is buying down uncertainty, and public work is the cheapest way for them to do that.
Comparing the three for the same person
| United States | United Kingdom | Australia | |
|---|---|---|---|
| Need an employer first | Yes | Yes | No, for points routes |
| Cap or lottery | Yes, H-1B | No | Invitation rounds |
| Salary floor | Prevailing wage | £41,700 or going rate | AUD 79,423 or market rate |
| Leads to permanence | Via separate green card process | Yes, period under review | Points routes are permanent from grant |
| Main bottleneck | The lottery | Finding a licensed sponsor at the salary | Skills assessment and points competition |
| Age matters | No | No | Significantly |
What actually gets developers hired internationally
Have something public. A repository with real commits, a product with users, writing that demonstrates how you think. An employer deciding whether to take on the cost and risk of sponsorship is looking for evidence that reduces their uncertainty, and public work does that better than a CV.
Target companies that already sponsor. Not companies that might. Check the register, check published disclosure data, look at who has done it before.
Be specific about your status in the first message. "I would need Skilled Worker sponsorship" costs one line and saves months.
Consider the transfer route. If you work for a company with an office in the country you want to move to, an internal transfer is frequently the fastest and cheapest route in existence, and it is available to you right now rather than after a job search.
Be realistic about seniority. All three systems have salary floors that effectively exclude junior roles. If you are early in your career, the honest path is usually to build seniority at home first, or to enter through study.
What this guide will not claim
There is no reliable published figure for how long any of these routes takes in practice, because published service standards move and do not account for cases that go to further checks. There are no trustworthy "demand" numbers for developers by country — the figures that circulate come from recruitment firms with an interest in the answer. And nobody can tell you your odds in the H-1B lottery, because they depend on how many other people register.
What is solid: the salary thresholds, the structure of each route, and the current status of the H-1B fee litigation. Everything else, check on the day.
Frequently asked questions
Is the $100,000 H-1B fee being charged? Not as at the time of writing. It has been vacated in one case and the implementing policies blocked in another, with appeals pending. Verify the current position before relying on it either way.
Can I move to the US without the H-1B lottery? Yes — O-1A, L-1 intracompany transfer, TN for Canadians and Mexicans, or a cap-exempt employer such as a university.
Do I need a computer science degree? For the US H-1B, the specialty occupation test generally expects a relevant degree or an equivalent combination of education and experience. The UK and Australian routes care more about the job and the salary, though Australia's skills assessment will look closely at qualifications.
Can I go to Australia without a job offer? Yes, through the points-tested routes, subject to a skills assessment and an invitation.
Which country is fastest? Usually an internal transfer at a company you already work for, in any of the three. Beyond that, the UK is more predictable than the US because there is no lottery, but it requires a sponsor and a salary above the threshold.
Does remote work for a foreign company give me a visa? No. Working remotely for an overseas employer is not an immigration route, and doing it from a country on a tourist visa is usually a breach of that visa's conditions.
What is a cap-exempt H-1B employer? Primarily universities and their affiliated non-profit entities, plus certain non-profit and government research organisations. They can file H-1B petitions outside the annual cap at any time of year, which removes the lottery entirely.
Is an O-1A realistic for an engineer? More often than people assume. It is evidence-based rather than title-based, and a developer with significant open source contributions, published technical work, judging or reviewing experience, and a record of high remuneration can meet the criteria. It is an evidence-assembly exercise, and it benefits from being prepared over months rather than weeks.
Does Canada require a job offer? Not for Express Entry, which is a points-based route to permanent residence. A job offer can add points but is not a prerequisite.
How much do these moves cost me personally? In the UK, roughly £3,900 for a single applicant on a three-year visa, mostly health surcharge. Australia and Canada charge visa application fees plus skills assessment and language testing. The US H-1B is largely an employer cost, though attorney fees vary in who pays them.
Should I take a lower salary to get sponsored? Be careful. Salary floors exist precisely to prevent that, and an offer below the threshold is not sponsorable regardless of willingness on either side.
Sources: Skilled Worker visa: your job, GOV.UK · Skilled Worker visa: how much it costs, GOV.UK · Salary requirements to nominate a worker, Department of Home Affairs · What is happening to the $100,000 H-1B fee, Ahluwalia Law · Judge strikes down latest version of $100,000 H-1B immigration fee, Forbes