Home Affairs Committee

Earned Settlement:
Examining the Government’s
proposed reforms

Sixth Report of Session 2024–26 HC 1409

Home Affairs Committee
The Home Affairs Committee is appointed by the House of Commons to
examine the expenditure, administration, and policy of the Home Office and
its associated public bodies.

Current membership
Dame Karen Bradley (Conservative; Staffordshire Moorlands) (Chair)
Lewis Atkinson (Labour; Sunderland Central)
Mr Paul Kohler (Liberal Democrat; Wimbledon)
Ben Maguire (Liberal Democrat; North Cornwall)
Robbie Moore (Conservative; Keighley and Ilkley)
Margaret Mullane (Labour; Dagenham and Rainham)
Chris Murray (Labour; Edinburgh East and Musselburgh)
Peter Prinsley (Labour; Bury St Edmunds and Stowmarket)
Joani Reid (Independent; East Kilbride and Strathaven)
Bell Ribeiro-Addy (Labour; Clapham and Brixton Hill)
Jo White (Labour; Bassetlaw)

Powers
The Committee is one of the departmental select committees, the powers
of which are set out in House of Commons Standing Orders, principally in SO
No. 152. These are available on the internet via [Link].

Publication
This Report, together with formal minutes relating to the Report, was
Ordered by the House of Commons, on 10 March 2026, to be printed. It
was published on 13 March 2026 by authority of the House of Commons.
© Parliamentary Copyright House of Commons 2026.
This publication may be reproduced under the terms of the Open Parliament
Licence, which is published at [Link]/copyright.
Committee Reports are published on the Committee’s website at
[Link]/homeaffairscom and in print by Order of the House.

Contacts
All correspondence should be addressed to the Clerk of the Home Affairs
Committee, House of Commons, London SW1A 0AA. The telephone number
for general enquiries is 020 7219 3440; the Committee’s email address is
homeaffcom@[Link]. You can follow the Committee on X (formerly
Twitter) using @CommonsHomeAffs.
 Contents
Summary1
1 Introduction 4
The planned changes 5
Our inquiry 8

2 The overall impact of the changes 10

What is the Government hoping to achieve? 10
The overall impact of the changes 11

3 Assessing contribution 14
Mandatory minimum income 14
Income-related reductions 15
Assessing contribution at an individual level 17

4 Workers 20
Classifying medium-skilled workers 20
Worker pay, progression and exploitation 22
Health and social care 24
Potential impacts of the changes 27

5 Children and young people 32

Access to university 36
Child poverty 37
Penalties for accessing public funds 41
The 10-year family or private life route 43
Children who have spent most of their life in the UK 47
Citizenship49
Divergent family routes 51
6 Transitional protections 52
7 Implementation 55
Conclusions and recommendations 57
Formal minutes 67
Witnesses70
Published written evidence 71
List of Reports from the Committee during the
current Parliament 77
Summary
Indefinite Leave to Remain (ILR), also known as settlement, is the right to
live and work permanently in the UK, free from restrictions associated with
immigration control. Securing ILR is a necessary precursor to becoming
naturalised as a British citizen. The Government has proposed a new
“Earned Settlement” model, under which the standard qualifying period
for immigrants to receive Indefinite Leave to Remain will increase from 5 to
10 years, with qualifying periods for individuals increased or decreased on
the basis of criteria that aim to measure individual contribution. The Home
Office has developed these proposals in response to the unprecedented
levels of immigration to the UK in recent years. The Government is
particularly concerned about the impact of a large number of immigrants
in lower paid roles—particularly in adult social care—receiving settlement
and becoming eligible to apply for benefits and social housing. We
recognise the challenge the Government is trying to respond to, and its
intention to promote contribution through its changes.
The Home Office recently held a consultation on its proposed changes,
which closed on 12 February. With a view to informing the Government’s
final policy, we conducted a short inquiry to consider specific aspects of the
changes set out in the consultation, with a particular focus on the proposals
in relation to medium-skilled workers, children and young people and
transitional protections.
The Government has proposed that adult immigrants be required to
meet new mandatory minimum income requirements in order to qualify
for settlement, although it is consulting on potential exemptions. It
is reasonable to expect most people who wish to settle to contribute
economically, and entering employment is also likely to foster and support
integration, so there is value in encouraging immigrants to work where
they are able. However, there will be people who are unable to meet this
requirement for good reason, and it is important that there are reasonable
exceptions.
These changes will affect hundreds of thousands of care workers and
their dependents and could have major consequences for the adult social
care sector. The Home Office’s mismanagement of the Health and Care
Worker visa between 2022 and 2024 meant that far more care workers and
their dependants came to the UK than the Home Office anticipated. Care
workers, especially those with children, are more likely to qualify for in-

1
work benefits—once they have settled status—than other immigrants, as
care work is generally low paid, and therefore could present a cost to the
public purse. Delaying settlement for this group is therefore likely to provide
short-term direct fiscal savings for the Government, but risks increasing
exploitation and poverty for these workers. The impact these changes
will have on the adult social care sector is unclear, but we have seen no
evidence that the Home Office has made efforts to join up its reforms with
the Government’s overall strategy for adult social care. It is possible that
these changes may increase social care cost pressures which could have
an indirect negative fiscal impact. If the Government places workers on
long routes to settlement, it should explore flexible visa options that allow
workers to move between employers to reduce the risk of exploitation. The
Government should also set out clearly how it will support decent pay and
conditions for immigrants working in adult social care.
It is currently unclear how these changes will apply to children, especially
children who turn 18 before their parents achieve settlement. As a matter
of principle, the Government should ensure that all children who arrive at a
young age and grow up in the UK are granted settled status by the age of
18. Children who arrive at a later stage—such as those in their mid-teens—
should have clear, realistic and accessible pathways to settlement that do
not inhibit them from beginning their adult lives. We received evidence that
these changes will increase child poverty, especially among the children
of care workers, and children in families on the current 10-year family or
private life route to settlement. The Government will need to understand
and mitigate any increase in child poverty. The 10-year private or family life
route is challenging and expensive for those who are on it and can cause
genuine hardship for children affected by it. People who under the current
system would be on a 10-year family or private life route to settlement
should be given a reasonable and achievable route to settlement under the
new rules.
The Government plans to apply these changes to people who are already
in the UK on a route to settlement. We have received a high volume of
representations from immigrants already in the UK, arguing that it would
be unfair to apply these changes to people who made the decision to
come here on the basis of a 5-year route. It is not unprecedented to apply
changes to people who are already in the immigration system. We believe
that it is in the interests of the Home Office, and the UK, to be consistent
in the application of immigration rules and policy. There is also a public
interest in responding to recent high rates of immigration, and the potential
direct fiscal impact of a large number of people in lower paid roles gaining
settled status and eligibility for benefits. The Government needs to carefully

2
consider and set out clear mitigations—including suitable transitional
arrangements—for people already in the UK who are affected by the
changes.
The Home Office has said that these changes will begin to be implemented
from April 2026 but has not given a clear timeline of when particular
changes will be implemented. The Home Office should learn from previous
reforms that it is more important to get changes right than to implement
them quickly. In order to deliver workable reforms of the kind set out in
its consultation, the department must take adequate time to assess the
impact of its final policy and put in place measures to avoid unintended
consequences. The Home Office should provide a clear and realistic
implementation timeline, so that people can make informed decisions about
their future.

3
 1 Introduction
1. Indefinite Leave to Remain (ILR), or settled status, is the right to live
and work permanently in the UK, free from restrictions associated with
immigration control. It is also a pre-requisite for qualifying for British
citizenship. The precise number of people who have settled status in the UK
is unknown. The Oxford Migration Observatory has estimated that it is likely
that there were between 620,000 and 820,000 non-EU nationals with ILR at
the end of 2024.1
2. The rate of settlement among immigrants varies depending on the reason
they came to the UK. For example, family visa holders are more likely to
settle than work visa holders.2 Most non-EU citizens who have come to the
UK on a work visa have not gone on to obtain settlement. Settlement rates
are expected to increase in the future. This is in part because of an increase
in the proportion of people arriving on work visas that provide a route to
settlement.3
3. Currently, the standard time for most immigrants to qualify for Indefinite
Leave to Remain is five years. In order to receive ILR, immigrants must
usually spend five years in the UK on a qualifying visa. Some visas—
for example, visitor visas and student visas—do not provide a route to
settlement. The main two visa types that lead to settlement are work visas,
including sponsored work visas that allow immigrants to come to the UK
to work in specified roles, and family visas, that allow British citizens and
those living permanently in the UK to sponsor immediate family members
(usually a spouse or partner) to join them in the UK. Immigrants must meet
the requirements of their visa for five years to qualify for ILR. For sponsored
work migrants, this requires maintaining sponsored work above specified
salary thresholds.4 For family migrants, this requires the family to meet
the minimum income requirement (currently £29,000 per year).5 Switching
between different visa routes—such as moving between work and family

1 Oxford Migration Observatory, Migrant Settlement in the UK, 24 February 2026

2 Home Office, Migrant journey: 2024 report, [Link] (accessed 4 March 2026)
3 Oxford Migration Observatory, Migrant Settlement in the UK, 24 February 2026
4 Home Office, Indefinite leave to remain if you have a Skilled Worker, Health and Care
Worker, T2 or Tier 2 visa: Overview, [Link] (accessed 6 February 2026)
5 Home Office, Indefinite leave to remain if you have family in the UK: Apply as a partner
(family visa), [Link] (accessed 6 February 2026)

4
 visas—can in some cases reset the five year waiting period.6 Once eligible
to apply for settled status, immigrants will usually need to pay a fee, pass
the Life in the UK test, and, if they have not already, demonstrate they meet
English language requirements before they are granted ILR. An immigrant
who has been granted ILR will usually be eligible to apply for British
citizenship one year later.
4. There are exceptions to the current 5-year route. Certain arrivals on the
Global Talent visa—for leaders and potential leaders in academia, the arts
and digital technology—can qualify after three years.7 Immigrants who
would not usually meet the immigration rules, but have the right to be in the
UK on the basis of their human right to family or private life, have a 10-year
route to settlement.8

The planned changes

5. The Home Office is planning major changes to eligibility for Indefinite Leave
to Remain. The standard baseline for qualifying for ILR will be increased
from five years to ten, and the mandatory criteria for qualifying for ILR will
be significantly tightened. The Home Office plans to introduce a model of
“Earned Settlement”, with routes to settlement for individuals increased
or decreased from the 10-year baseline on the basis of criteria that aim
to measure individual contribution—including reduced waiting times for
higher earners and fluent English speakers, and increased waiting times for
immigrants who claim benefits or entered the UK illegally. The Government
is also consulting on whether to apply the No Recourse to Public Funds
(NRPF) condition to people who have ILR. Many details of how the system
will work in practice have yet to be confirmed, and elements of the reforms
are subject to consultation. Under the proposals in the consultation some
immigrants could face waits for ILR as long as 30 years, while others will
wait as few as three. These changes are wide-ranging, complex, and likely
to have a significant impact on the people who are affected. The changes
will make the UK an outlier among most high-income countries, where the
standard settlement period is usually five years for those who have a path
to settlement, although Switzerland and Japan both have 10-year routes to
settlement.9

6 Home Office, Indefinite leave to remain if you have family in the UK: Apply as a partner
(family visa), [Link] (accessed 6 February 2026)
7 Home Office, Indefinite leave to remain if you have a business, investor or talent visa:
Time in the UK and financial requirements, [Link] (accessed 6 February)
8 Oxford Migration Observatory, Migrants on ten-year routes to settlement in the UK, 21
July 2021
9 Oxford Migration Observatory, Changes to settlement: what do they mean?, 10 February
2026

5
Overview of Earned Settlement proposals

Baseline eligibility periods

- Standard baseline: 10 years
- Baseline for medium skilled worker visa holders: 15 years
- Baseline for refugees granted asylum: 20 years

Mandatory minimum requirements

- Meet suitability requirements, such as not having a criminal conviction
- Have no outstanding government debt, including tax or debt to the NHS
- Speak English at level B2 level under the Common European Framework
of Reference for Language
- Pass the Life in the UK test
- Have annual earnings above £12,570 for a minimum of 3 to 5 years
(subject to consultation) or an alternative amount of income

Considerations that will reduce the baseline qualifying period (only the
largest applicable reduction applies)
- Speak English at level C1 under the Common European Framework of
Reference for Languages (minus 1 year)
- Earned a taxable income of £125,140 for 3 years immediately prior to
applying for settlement (minus 7 years)
- Earned a taxable income of £50,270 for 3 years immediately prior to
applying for settlement (minus 5 years)
- Been employed in a specified public service occupation for 5 years in a
highly skilled (RQF 6+) role (minus 5 years)
- Worked in the community (e.g. by volunteering) (minus 3–5 years)
- Is in the UK on a family visa as the parent/partner/child of a British citizen
and meets core family requirements (minus 5 years)
- Is in the UK on the Hong Kong British National (Overseas) route (minus 5
years)

6
 Considerations that will increase the baseline qualifying period (only
the largest applicable increase applies)
- Been in receipt of public funds for less than 12 months during route to
settlement (plus five years) or more than 12 months (plus 10 years)
- Arrived in the UK illegally (plus up to 20 years)
- Entered the UK on a visit visa (plus up to 20 years)
- Overstayed a visa for six months or more (plus up to 20 years)
Home Office, A Fairer Pathway to Settlement: A statement and
accompanying consultation on earned settlement, CP 1448, November 2025
6. Under the EU-UK Withdrawal Agreement, EU citizens who were living in the
UK before 31 December 2020—the end of the transition period—have rights
to remain in the UK, and were able to apply for pre-settled or settled status
under the EU settlement scheme.10 The EU settlement scheme will remain
unchanged under the Earned Settlement proposals,11 but the reforms will
affect EU citizens living in the UK—or who come to the UK in the future—who
are not eligible for the EU settlement scheme.
7. The Home Office is also making major changes to asylum and refugee
policy, which were set out in a November 2025 policy statement on reforms
to the asylum system.12 Until 1 March 2026, refugees were granted initial
leave to remain in the UK for five years and would qualify for Indefinite Leave
to Remain after five years, without needing to pay a fee, demonstrate their
English language ability or pass the Life in the UK test. People claiming
asylum from 2 March 2026 onwards who have a successful asylum claim will
be granted temporary protection status, which they will need to renew every
30 months. Refugees will be expected to return to their country of origin if
it later becomes safe.13 Under the Government’s proposals, those granted
refugee status will only become eligible for settlement after 20 years.
Refugees may be able to qualify for settlement in 10 years by moving to a
new “work and study” route, the details of which have not been confirmed.14
For this brief inquiry, we have not examined in depth the proposed changes
to asylum and refugee policy, but we will continue to scrutinise the Home
Office on this important policy area.

10 House of Commons Library, UK-EU Withdrawal Agreement: Implementation of citizens’

rights, Research Briefing 9657, 28 November 2023, p9
11 Home Office, A Fairer Pathway to Settlement: A statement and accompanying
consultation on earned settlement, CP 1448, November 2025, p6
12 Home Office, Restoring Order and Control: A statement on the government’s asylum and
returns policy, CP 1418, November 2025, p13
13 Asylum Changes HCWS1373, 2 March 2026
14 Home Office, Restoring Order and Control: A statement on the government’s asylum and
returns policy, CP 1418, November 2025, p13

7
 Our inquiry
8. The Government first announced its intention to make major changes to
settlement policy in its May 2025 immigration white paper ‘Restoring control
over the immigration system’.15 We launched this inquiry on 21 October
2025 with the aim of examining the potential impact of the changes, and
to consider how any new earned settlement rules should work. On 20
November 2025 the Home Office launched a consultation, which outlined the
options currently under consideration. When announcing the consultation,
the Home Secretary informed the House of Commons that the Government
intends to begin implementing at least some of the changes from April
2026.16 The Government’s consultation closed on 12 February 2026 and the
Home Secretary told us it had received around 130,000 responses as of
early February.17
9. Given the Government’s timetable for consulting on and implementing
changes to routes to settlement, we decided to conduct a rapid inquiry,
scrutinising the proposals set out in the Earned Settlement consultation,
so that we could report on these before the Home Office finalises its policy.
It has not been possible to examine all the proposals set out in the Earned
Settlement consultation, so we have focused our inquiry on aspects of
the proposals where we felt there was a significant risk of unintended
consequences, and those that were prominent in the written evidence we
had already received. The areas of focus we chose were:
a. Potential transitional protections, for people who arrived in the UK
before the changes were announced;
b. The impact of the changes on children and young people; and
c. The proposal to apply a 15-year route to settlement for medium-skilled
workers.
10. To inform this report we held two oral evidence sessions—hearing from
immigration and legal experts, representatives of charities supporting
children and young people, and representatives of employers and trade
unions—and questioned the Home Secretary on the proposed reforms.18

15 Home Office, Restoring control over the immigration system: white paper, CP 1326, May
2025, pp68–70
16 HC Deb, 20 November 2025, col 893
17 Oral evidence taken on 4 February 2026, Q14
18 A full list of witnesses who gave oral evidence is included at the end of this report.
This inquiry was also informed by oral evidence from Brian Bell, Chair of the Migration
Advisory, and Dr Madeleine Sumption, Deputy Chair, in a one-off session on the Work
of the Migration Advisory Committee on Tuesday 4 November 2025. We questioned the
Home Secretary on the proposed reforms during a regular accountability session on
Wednesday 4 February 2026.

8
 We received over 5,700 written submissions in response to our call for
evidence.19 The overwhelming majority of these came from immigrants
who already live in the UK and are on a pathway to settlement, and are
concerned about what these changes will mean for them and their families.
We recognise the strength of feeling and anxiety felt among those who
could be affected by these changes and thank everyone who took the time
to contribute to our inquiry.

19 Due to the volume of evidence that the Committee received, only written evidence from
organisations and subject specialists has been published. Written evidence submitted by
individuals has been read and has informed the Committee’s findings.

9
 2 The overall impact of the
changes

What is the Government hoping to achieve?

11. These reforms have been designed primarily in response to the
unprecedented levels of immigration seen in recent years. Between 2021
and 2023 immigration was unusually high due to a confluence of factors,
including a growth in the number of people coming to work in the UK and the
lifting of Covid-19 immigration restrictions. According to Office of National
Statistics (ONS) estimates, immigration to the UK peaked in the year ending
March 2023, when around 1,469,000 people (including British and foreign
nationals) came to live in the UK. Immigration has fallen significantly
since—in the year ending June 2025, around 898,000 people migrated to
the UK. High immigration led to high net migration—the total number of
people entering the country to live here for more than a year, minus the
total number leaving—and according to the latest ONS estimates, annual
net migration stood at 944,000 at the end of March 2023. Net migration fell
to 204,000 in the year ending June 2025, a result of a fall in immigration,
especially for work and study, and an increase in emigration.20 The Home
Office expects there to be an increase in the number of people settling in
the UK as a result of recent high levels of immigration and has estimated
that between 1.3 million and 2.2 million people will settle between 2026 and
2030, although there is significant uncertainty about the potential rate of
settlement.21 The Home Office estimates that between 359,000 and 620,000
people will settle in 2028, when it expects settlement to peak. This would be
a significant growth in the number of grants of settlement—in 2024, around
163,000 people were granted settlement (not including EU Settled status).22

20 Office for National Statistics, Long-term international migration, provisional, 27

November 2025
21 Home Office, A Fairer Pathway to Settlement: A statement and accompanying
consultation on earned settlement, CP 1448, November 2025, p12
22 Home Office, Immigration system statistics data tables, Settlement detailed datasets,
year ending December 2025, Table Se_D02

10
12. The Home Secretary told us reforms to settlement were precipitated by
“the scale of change that the country has seen in recent years”.23 The
Government is particularly concerned by the high number of recent arrivals
on care work and medium-skilled visas, and their dependants (spouses
and children), and the potential impact on public finances.24 Care work in
particular is poorly paid and care workers with children are more likely
than other work migrants to be eligible for support from the state through
in-work benefits once they have received settled status.25 Immigrants with
temporary permission to be in the UK are usually subject to the No Recourse
to Public Funds (NRPF) condition, which means they are not eligible for most
benefits. Once an immigrant is granted Indefinite Leave to Remain, they
become eligible for accessing benefits on the same terms as British citizens.
13. The Home Secretary has been clear that the aim of these changes is not
to reduce net migration by deterring immigrants from coming to the UK,
but to address the potential impact of people already in the UK achieving
settlement.26 The Government is also aiming to “restore the element of
contribution” to settlement and, by doing so, improve cohesion.27 Under
the current system, it is relatively straight forward to secure settlement,
irrespective of contribution, and most migrants satisfy the requirements
at five years. The Earned Settlement consultation describes settlement as
“not a right but a privilege” that must be earned.28 The consultation states
that the reformed system will reward “sustained and measurable economic
contribution to the UK”, based on the principle that a shortened pathway to
settlement should be earned through active participation in the economy.29
The Government’s proposals would still mean it is possible for people to
reach settlement in most cases, but would increase the requirements and
standard timeframe for reaching settlement.

The overall impact of the changes

14. The direct fiscal impact of immigration is determined by looking at the
impact on public finances—how much is received in taxes, and how much
is spent in public services. The fiscal impacts of changes to settlement
policy are difficult to predict and will depend on the final detail of the

23 Oral evidence taken on 4 February 2026, Q2

24 Oral evidence taken on 4 February 2026, Q2
25 Oxford Migration Observatory, Changes to settlement: what do they mean?, 10 February
2026
26 Oral evidence taken on 4 February 2026, Q2
27 Oral evidence taken on 4 February 2026, Q3
28 Home Office, A Fairer Pathway to Settlement: A statement and accompanying
consultation on earned settlement, CP 1448, November 2025, p3
29 Home Office, A Fairer Pathway to Settlement: A statement and accompanying
consultation on earned settlement, CP 1448, November 2025, p7

11
 reforms. According to the Migration Advisory Committee, all else being
equal, acquiring Indefinite Leave to Remain worsens the direct fiscal
impact of migrants who have come to the UK—because they stop paying
immigration fees and are able to claim benefits, if eligible. Extending routes
to settlement would increase the amount of time immigrants are liable to
pay visa fees, and are not permitted to access public funds, creating fiscal
gains for the UK. Arrivals on the Skilled Worker visa are generally unlikely
to qualify for benefits due to their high income, but lower paid workers on
the Health and Care Worker visa—such as care workers—are more likely
to qualify.30 Restricting access to benefits for low paid workers who are
more likely to qualify for benefits is likely to create a direct fiscal benefit in
the short-term, although the impact of this will be limited, as the largest
costs are likely to come later in these migrants’ lives.31 However, extending
routes to settlement could become fiscally negative to the UK, costing the
country more than it saves, if the changes deter high earners from coming
here, or if the changes limit the job progression and integration of migrants
in the UK, leading to worse employment outcomes and lower economic
contributions.32 The Home Office is also consulting on whether to apply the
NRPF condition to people who have Indefinite Leave to Remain, which is an
alternative approach that may address the direct fiscal impact of people
acquiring settlement. We did not examine this proposal in detail in the
course of our inquiry. It is extremely difficult to predict what impact these
changes will have on decision making among migrants, and therefore rates
of immigration and emigration. We have heard evidence that while some
specific groups may be discouraged from coming to the UK, it seems likely
that a significant proportion of recent arrivals will choose to remain in the
UK on a longer route to settlement.33
15. As well as fiscal contribution, the Government’s Earned Settlement
consultation highlights the importance of integration, and the Home
Secretary told us that she believes the changes will encourage a
greater sense of cohesion.34 We received a significant volume of written
evidence arguing that the proposed changes would undermine and
worsen integration and make it harder for immigrants to make long-term
commitments in the UK.35 Immigrants told us that uncertainty associated

30 Oxford Migration Observatory, Changes to settlement: what do they mean?, 10 February

2026
31 Oxford Migration Observatory, Changes to settlement: what do they mean?, 10 February
2026
32 Migration Advisory Committee, MAC Annual Report, December 2025, p25
33 Q2
34 Oral evidence taken on 4 February 2026, Q3
35 Dr Ally Shepherd (Researcher in the School of Education at University of Leeds) and Prof
Gabriella Alberti (Professor of International Labour Migration at the Business School at
University of Leeds) (RTS4617), Professor Jonathan Portes (Professor of Economics and
Public Policy at King’s College London) (RTS1292)

12
 with temporary immigration status undermines feelings of belonging.36
We heard evidence arguing that financial pressures associated with
immigration for some immigrants can also act as a barrier to community
participation, as immigrants must prioritise earning.37 It is difficult to predict
the exact impacts on integration, but there is evidence that permanent
status, and citizenship, have a positive impact on economic and social
integration, including by enabling people to progress in their careers
and earn more.38 While the Home Office may be able to incentivise some
behaviours that promote integration through the earned settlement criteria,
it appears that the changes as a whole risk harming integration.

16. conclusion
The Government has developed the proposals in its Earned Settlement
consultation to respond to the unprecedented levels of immigration to
the country in recent years, particularly of medium-skilled workers. We
recognise that the Government is responding to a challenging situation,
as a large number of people will soon become eligible for settlement due
to the recent spike in immigration, especially in 2022–23. We support the
Government’s stated aim to promote contribution and improve the fiscal
impact migration has on the UK. It is not possible to be certain of the
impacts of the changes, especially in the absence of a finalised policy.
There may be direct fiscal benefits from extending routes to settlement
for some migrants, especially in the short-term, but there is a risk that
the changes will undermine integration, which any changes should seek
to promote. It is important that the Home Office thoroughly assesses the
impacts of its final policy, before implementation.

36 Written evidence accepted confidentially

37 Dr Natalie Sedacca (Assistant Professor in Employment Law at Durham University)
(RTS4682), para 9
38 Oral evidence taken on 4 November 2025, Q41 [Dr Madeleine Sumption]

13
 3 Assessing contribution

Mandatory minimum income

17. The Government intends to introduce new mandatory minimum
requirements which applicants would need to meet in order to qualify
for settlement. This would include minimum earnings of £12,570 a year—
the minimum threshold for paying income tax and national insurance
contributions—for three to five years.39 The Government is consulting on
potential exemptions for those on maternity leave and people with long-
term illnesses and disabled people and has also asked if any other groups
should be exempt from this requirement.40
18. The Government has proposed that the mandatory minimum economic
requirement be applied to everyone on a route to settlement, except
for dependent children. This includes adult dependants accompanying
work visa holders, people travelling to the UK on family visas to join their
British partners, refugees and people on a Hong Kong British National
(Overseas) (BN(O)) visa. The Home Office is proposing that these mandatory
requirements apply at an individual—rather than household level—as part
of proposals for dependants to earn settlement in their own right.
19. The mandatory minimum income requirement is set relatively low and
should be achievable for working adults, but if this requirement is applied
to everyone on a route to settlement it is likely to make hundreds of
thousands of people currently on routes to settlement ineligible for settled
status, based on their current circumstances.41 The requirement is likely to
disadvantage certain groups. We received evidence that the requirement
could disadvantage Hong Kong BN(O) visa holders, who were not subject to
income requirements when they came to the UK, and many of whom rely on
assets or savings.42 The consultation states that the mandatory economic
requirement could be met by “an alternative amount of income”—which
suggests that the requirement may be met through, for example, pension

39 Home Office, A Fairer Pathway to Settlement: A statement and accompanying

consultation on earned settlement, CP 1448, November 2025, p21
40 Home Office, A Fairer Pathway to Settlement: A statement and accompanying
consultation on earned settlement, CP 1448, November 2025, p44
41 Oxford Migration Observatory, Changes to settlement: what do they mean?, 10 February
2026
42 Hong Kong Watch (RTS5627)

14
 income or savings, which may address this issue. The requirement is likely
to make it harder for parents who have chosen to act as the primary care
giver, rather than seeking employment, to secure settled status. This would
affect households that are overall directly fiscally positive for the UK, such
as arrivals on work visas where the main applicant is a very high earner,
and their partner does not work, which we were told could have a deterrent
effect on highly skilled workers coming to the UK.43 It would also mean that
individuals who are unable to find work—and do not have another source of
income—would never be able to achieve settled status, irrespective of how
long they have lived in the UK, unless they qualify for an exemption.

20. conclusion
The Government has proposed requiring all immigrants to earn at least
£12,570 a year in order to be able to settle permanently in the UK. This
will apply more widely than just to economic migrants—family migrants
and arrivals on humanitarian routes will also be affected. It is reasonable
to expect most people who wish to settle to contribute economically, and
entering employment is also likely to foster and support integration, so
there is value in encouraging immigrants to work where they are able.
However, there will be people who are unable to meet this requirement
for good reason.

21. recommendation
There should be reasonable and clear exceptions to the mandatory
minimum economic contribution requirement so that people are not
prevented from settling where there are legitimate reasons they cannot
meet this requirement. This could include exemptions for disabled
people, people over pension age, those who are studying full-time, and
those with full-time caring responsibilities.

Income-related reductions
22. The Home Office is consulting on earnings-based reductions to eligibility
periods for reaching settlement. The proposed reductions are:
○ A 5-year reduction for people who earn a taxable income of
£50,270 for 3 years immediately prior to applying for settlement.
○ A 7-year reduction for people who earn a taxable income of
£125,140 for 3 years immediately prior to applying for settlement.

43 Q2

15
 The Oxford Migration Observatory estimates that most main applicants on
a Skilled Worker visa will qualify for the 5-year reduction, as the median
income for Skilled Workers (excluding those on the Health and Care Worker
visa) was £56,600 in 2023/24.44
23. The reduction thresholds are based on current income tax thresholds, but
the Government does not plan to keep these in line with tax thresholds in the
future.45 The threshold for paying a higher rate of tax, and the threshold for
making a positive contribution to public finances—paying more in tax than
you use in services—are not the same. Dr Madeleine Sumption described
the use of tax thresholds as “a little arbitrary”, telling us that arrivals
under the Skilled Worker route, which has a general salary threshold of
£41,700, are “already comfortably fiscally positive over the course of their
lifetimes”.46 Professor Alan Manning—former chair of the Migration Advisory
Committee—told us there was little point in the £50,270 threshold, and that
this would give an incentive to employers to suppress wages for migrant
workers to delay their settlement, as settlement would make it easier for an
employee to leave their current job.47

24. conclusion
The Government’s current proposals would allow shorter routes to
settlement based on meeting earning requirements set at current
income tax thresholds. This means that people who make a net positive
direct fiscal contribution to the UK, but earn below the higher rate tax
threshold, could face a 10-year route to settlement. The Government
has not been clear about the basis on which the reduction thresholds
have been set, nor what outcome they are intended to achieve. Given
the Home Office does not intend to keep reduction thresholds in line with
tax thresholds in the future, it appears that that current tax thresholds
have been used as a convenient, but not yet justified, basis for setting
the earnings required to reduce waiting periods for settlement. This also
adds a layer of administrative complexity, and therefore potential for
abuse, to a system the Home Office already struggles to manage.

44 Oxford Migration Observatory, Changes to settlement: what do they mean?, 10 February

2026
45 Home Office, A Fairer Pathway to Settlement: A statement and accompanying
consultation on earned settlement, CP 1448, November 2025, p23
46 Q53
47 Q9

16
25. recommendation
We recommend that the Home Office sets out clear objectives for the
basis on which fiscal contributions qualify immigrants for a reduction
to their wait for settlement. The Home Office should then commission
the Migration Advisory Committee to advise on appropriate thresholds
based on these objectives.

Assessing contribution at an individual

level
26. The Earned Settlement consultation proposes that immigrants living in the
UK as adult dependants should earn settlement in their own right, with
their route to settlement “separately determined according to their own
attributes and circumstances”. This means that the dependant partners of
an economic migrants “will not necessarily enjoy the same qualifying period
for settlement as their partner” and may have a longer or shorter wait for
settlement.48
27. We received evidence that odd or undesirable outcomes would occur from
applying income-related reductions separately to individuals in the same
household. Matthew Percival—Director (Future of Work and Skills) at the
Confederation of British Industry—told us that the changes could lead to
differing outcomes for households that, as a whole, have the same income.49
As an example, in a family in which both parents earn £52,000 a year, both
parents would be on a 5-year route to settlement. In a household where
one parent works part-time to care for children, and earns £30,000, while
their partner earns £74,000, the parent working part-time will be on a
10-year route to settlement, while their partner will be on a 5-year route,
even though this household overall has the same income as the former
household—and pays more in taxes. This risks deterring high earners with
lower earning spouses from coming to the UK, and penalising households
that make a greater direct economic contribution to public finances. Dr
Madeleine Sumption told us that, if the Government is concerned with the
fiscal or economic impact of work migrants and their dependants, it makes
sense to consider the household as unit, as it does not matter from an
economic point view if you have household with two medium earners, or a
household with one very high earner and one non-earner.50

48 Home Office, A Fairer Pathway to Settlement: A statement and accompanying

consultation on earned settlement, CP 1448, November 2025, p26
49 Q117
50 Q45

17
28. Average wages of dependants of Skilled Workers migrants are significantly
lower than average wages of main applicants. The median earnings of
employed Skilled Worker dependants—excluding Health and Care—in
2023/24 were £30,200, and the median earnings of employed Health and
Care dependants was £22,100.51 This means that most dependants of Skilled
Workers would not receive the 5-year reduction and would be on a 10-year
route to settlement, unless they can qualify for a reduction in another way.
This may have a gendered impact, given the different proportions of male
and female main applicants on different routes. For example, on average
women made up 73% of dependants on the Skilled Worker visa—excluding
Health and Care—between 2021 and 2024, while men made up 72% of
dependants on the Health and Care Worker visa.52
29. Dependant partners will remain reliant on their partner for their immigration
status, until they are able to achieve settled status. The Immigration Law
Practitioner’s Association (ILPA) told us that decoupling routes to settlement
for couples could increase risks of abuse. If a woman, and, by extension,
any of her children, is on a longer route to settlement than her husband,
ILPA told us that “coercive control and power will be shifted from the current
equal position of families settling together, to one where the husband holds
all the cards, as he is a British citizen already settled, and his wife is in a
precarious situation.”53

30. conclusion
Applying income-based reductions to qualifying periods for settlement
at an individual, rather than a household level, could lead to perverse
outcomes, and obscure the contribution of immigrants who take on a
greater proportion of caregiving, whose care may enable their partners
to take on more demanding and higher earning careers. These changes
may also deter high earning immigrants that we want to come to the
UK, if their partners are on much longer routes to settlement than them.
However, we recognise that assessing income at a household level also
could lead to inconsistent outcomes, such as two colleagues on an
identical income having different paths to settlement based on how well-
off the person they married is.

51 Oxford Migration Observatory, Changes to settlement: what do they mean?, 10 February

2026
52 Oxford Migration Observatory, Migration and gender in the UK, 17 October 2025
53 Immigration Law Practitioners’ Association (RTS5788) para 54

18
31. recommendation
We recommend that the Home Office applies reductions to qualifying
periods for settlement for direct fiscal contribution at a household level,
not at an individual level, to recognise that generally households make
financial decisions as units.

19
 4 Workers
32. While most immigrants will have a 10-year baseline route to settlement,
the Government is consulting on whether workers classed as “medium-
skilled” and below should have a baseline waiting period of 15 years. This
includes most care workers, but will affect a wide range of professions,
such as chefs, welders and various administrative and business roles.
The Government has significantly restricted the number of occupations
where medium-skilled workers can be recruited from abroad, and banned
medium-skilled workers from bringing dependants to the UK, so this change
is most likely to affect people already in the country.54 This change would
affect a large cohort of people—at least 325,000 visas have been granted
to workers in medium-skilled jobs since 2021, not including dependants.55
We asked the Home Office on 5 February 2026 to provide the number of
medium-skilled workers currently in the UK who would be in scope for a 15-
year route to settlement. The Home Office did not provide this information in
time for inclusion in this report. It is disappointing and concerning that the
Home Office has not been able to provide this information, which is essential
for assessing the scale of the impact of its proposed reforms.

Classifying medium-skilled workers

33. The Home Office classifies occupations according to their skill level using
the Regulated Qualifications Framework (RQF), which categorises the level
of regulated educational qualifications. Roles that are RQF level 6 and
above (roughly speaking, graduate level) are considered to be highly skilled.
Roles that are classed at RQF level 3 to 5 (roughly speaking, from A Level to
foundation level) are considered to be medium skilled.56 The Government
has proposed applying the 15-year route to settlement to all immigrants
who have arrived via the Skilled Worker or Health and Care Worker route
and are working in roles below RQF 6.57

54 Home Office, Explanatory Memorandum to the statement of changes to the Immigration

Rules: HC 997, 1 July 2025
55 Oxford Migration Observatory, Changes to settlement: what do they mean?, 10 February
2026
56 Home Office, A Fairer Pathway to Settlement: A statement and accompanying
consultation on earned settlement, CP 1448, November 2025, p15
57 Home Office, A Fairer Pathway to Settlement: A statement and accompanying
consultation on earned settlement, CP 1448, November 2025, p6

20
34. The Home Office has said the 15-year route for medium-skilled workers is
necessary because of the potential fiscal impact of granting low-wage
migrants settlement after five years, after which they would entitled to
access public funds.58 The Government has said that migrants working in
RQF 3 to 5 roles have a median salary around £12,000 lower than the overall
median for Skilled Worker and Health and Care Worker visa holders—
excluding care workers.59 While medium-skilled roles are, on average, lower
paid, it is not necessarily the case that a worker in a role that is classified as
below RQF 6 will be poorly paid. Nicolas Rollason, Head of Immigration Law
at Kingsley Napley, shared an example of a worker who would be affected
by the 15-year route despite being a high earner: a general manager of a
luxury hotel, who is very well paid and managing hundreds of staff, but
comes under the “Hotel and accommodation managers and proprietors”
code, which is classed as medium skilled.60 Dr Madeleine Sumption told us
that if the goal of these changes is fiscal, “it is not clear why we would care
about the RQF level of the occupation”.61

35. conclusion
It appears that the main purpose of putting medium-skilled workers on
a 15-year route to settlement is fiscal, because medium-skilled workers
are, on average, lower earners. It is odd and unnecessary to use RQF skill
levels as a proxy for income when making decisions about settlement,
rather than assessing income directly. Making decisions in this way will
lead to high earners in skilled roles being put on longer routes for a
reason that is fundamentally arbitrary.

36. recommendation
If the Home Office proceeds with putting lower-paid workers on a 15-year
route to settlement, it should do so on the basis of income, and not the
RQF classification of their role, as this will not necessarily reflect their
direct economic contribution, which appears to be the Government’s
justification for this reform. If the Government has other reasons for
using RQF classifications to determine the length of routes to settlement,
it should explain these to demonstrate the rationale for this choice.

58 Home Office, A Fairer Pathway to Settlement: A statement and accompanying

consultation on earned settlement, CP 1448, November 2025, p4
59 Home Office, A Fairer Pathway to Settlement: A statement and accompanying
consultation on earned settlement, CP 1448, November 2025 p17
60 Q29
61 Q31

21
 Worker pay, progression and exploitation
37. Immigrants in the UK on the Skilled Worker and Health and Care Worker
visas need to be sponsored to work in a qualifying job by a licenced
employer. This enables the Home Office to ensure that work visas are only
issued for qualifying jobs. Extending routes to settlement will extend the
amount of time that workers need to maintain sponsored employment.
38. Extending the amount of time a worker needs to be in sponsored
employment can reduce their job mobility, and so inhibit their progression,
as it is harder for people to switch roles when they need a licenced
sponsoring employer. In relation to care, which we discuss later in more
detail, Professor Alan Manning told us that this change was likely to leave
workers “stuck” in their current roles for longer.62 Dr Madeleine Sumption
told us that there could be particular challenges for medium-skilled workers
on a 15-year route. As the Government has significantly limited new overseas
recruitment of medium skilled workers, there may over time be diminishing
incentives for employers in these sectors to maintain sponsorship licences.
This means that as time goes on, workers in medium-skilled occupations
are likely to find it increasingly difficult to switch jobs.63 Dr Sumption told
us that because one of the main reasons people switch jobs is to increase
their wages, delaying access to settlement could have the negative impact
of keeping medium-skilled workers in their current jobs. This would prevent
these workers from moving to better paid work which would increase
both their own income and their contribution to the public purse through
taxation.64
39. Workers on sponsored visas can be at increased risk of exploitation. Peter
Wieltschnig, Policy Lead at Trades Union Congress, told us that “high levels
of power disparity” result from sponsorship based systems, as employees
are reliant on their employer for their immigration status.65 Professor Brian
Bell, Chair of the Migration Advisory Committee, told us that an advantage
of receiving settled status is that it gives people more power in employment
relationships, as they are able to freely move between employers.66 Issues
of exploitation are often more prevalent in lower paid sectors such as adult
social care, as we discuss later in this Chapter, so it is likely that the 15-
year route will affect those who are already at greater risk of exploitation.
Longer routes to settlement for workers on employee-sponsored visas can
also increase the risk of workers losing their immigration status, should
they lose their job. Peter Wieltschnig told us that these individuals would be

62 Q16
63 Q18
64 Q34
65 Q110
66 Oral evidence taken on 4 November 2025, Q40

22
 “at incredibly high risk of exploitation”.67 The Government has legislated to
introduce the Fair Work Agency, which will be established on 7 April 2026, to
address issues of enforcement relating to worker’s rights and exploitation.68
40. There are different ways to deliver the outcome of enabling worker mobility
while achieving the Government’s goal of limiting the direct fiscal impacts
of lower earning immigrants settling. Allowing settlement for these
workers while applying the No Recourse to Public Funds (NRPF) condition to
Indefinite Leave to Remain (ILR) would have this outcome, and Professor Bell
argued that there is no principled reason why freedom from immigration
control should be given at the same time as access to benefits.69 However,
there are questions about the legality of applying NRPF to people with
ILR as it would restrict access to benefits based on citizenship (which is
covered by the protected characteristic of nationality in the Equality Act
2010), rather than immigration status. Chrisann Jarrett—CEO at We Belong,
a charity that supports young people with insecure immigration status—
told us that applying NRPF to people with ILR would be problematic as it
would undermine the permanence meant to be created by settlement.70 We
also received evidence that extending NRPF to more people would deepen
child poverty.71 Anna Skehan, Solicitor at Islington Law Centre, argued
that applying NRPF to people with ILR would be unfair given the fees that
immigrants pay to gain settlement, and told us that it would disadvantage
children whose future is in the UK.72 We consider the potential impact on
children of the Government’s proposed reforms in Chapter Five.
41. Delaying settlement for medium-skilled workers but granting them freedom
to move between employers is another option that could help protect
workers while mitigating the direct fiscal impacts of immediate settlement.
Peter Wieltschnig, Trades Union Congress, told us that the provision of
a sector-wide adult social care visa—where migrant workers are not
sponsored by a specific employer—would “go some way towards making
sure that workers could move freely.” 73 However, this new approach would
raise challenges of its own. Professor Martin Green, CEO of Care England,
told us that a sector-wide visa would need to be funded, as there would
not be an incentive for employers to pay for a visa that does not guarantee
them workers.74 Matthew Percival—Director (Future of Work and Skills) at
the Confederation of British Industry—told us that a work visa system that

67 Q129
68 Department for Business and Trade, Factsheet: The Fair Work Agency, [Link] (accessed
10 March 2026)
69 Oral evidence taken on 4 November 2025, Q53
70 Q90
71 For example: Helen Bamber Foundation (RTS4357), Barnardo’s (RTS5793) paras 13–14
72 Q90
73 Q127
74 Q128

23
 was not reliant on particular employers would require the Home Office to
design new enforcement mechanisms, as under the current system the
Home Office is able to shift compliance requirements onto employers.75 Dr
Madeleine Sumption told us that the trade-off for removing sponsorship
requirements would be that the Home Office would lose control and
oversight over employment and pay.76

42. conclusion
There is a benefit to having a sponsored work visa system in that it
supports oversight and makes it easier for the Home Office to confirm
immigrants are coming to work in genuine roles. However, sponsorship-
based visa systems increase the amount of power that employers
have over their workers and limit the ability of workers to progress and
increase their earnings. Requiring workers to stay on sponsored worker
visas for up to 15 years is likely to exacerbate these power dynamics and
increase risks of exploitation.

43. recommendation
The Home Office should explore more flexible visa arrangements for
workers it is planning to place on long routes to settlement, so they are
not reliant on a particular employer to maintain their immigration status.
Workers granted sponsored visas could transition to a more flexible
visa after a set amount of time. Workers granted freedom to move
employers in this way could still be subject to the No Recourse to Public
Funds (NRPF) condition. Any flexible visa arrangements should provide
a clear route to settlement for these workers. The Government should
also consider what role the Fair Work Agency should have in tackling
exploitation for this group.

Health and social care

44. The large number of arrivals of immigrant care workers in recent years is
one of the key drivers of the Government’s planned reforms, although the
proposed 15-year eligibility period will also affect people in other medium-
skilled roles. Due to acute staff shortages in the social care sector, in
February 2022 social care roles were added to the Health and Care Worker
visa and the Shortage Occupation List, which enabled the expanded
overseas recruitment of care workers.77 Skills for Care estimates that
between March 2022 and March 2025, 230,000 recent overseas arrivals

75 Q129
76 Q36
77 House of Commons Library, Visas for social care workers, Insight, 3 October 2023

24
 entered care roles in the independent care sector.78 In contrast, Skills for
Care estimates that the number of British people working in the care sector
has fallen by 85,000 since 2020/21.79 The Government closed the care work
visa route to new entrants from outside the UK in July 2025, due to concern
about abuse and exploitation and in order to the move the UK away from
dependence on overseas workers.80
45. The Home Secretary told us that the Home Office has seen “particular
issues in relation to some types of work visas, in particular the Health and
Care visa for social care workers, where there was an intention to fill a gap
of between 6,000 and 40,000 work places but, in fact, 616,000 people
arrived.”81 We understand that the estimates of 6,000 to 40,000 were of
expected arrivals per year, rather than an estimate of the total number of
arrivals under the route.82 The Home Office press release accompanying
the launch of the Earned Settlement consultation likewise referred to “Low-
paid workers, such as the 616,000 people and their dependants who came
on health and social care visas between 2022 and 2024”.83 This significantly
overstates the scale of arrival of low-paid social care workers on Health and
Care Worker visas. A total of 616,000 people arrived on a Health and Care
Worker visa between 2022 and 2024.84 This includes doctors (around 25,000
workers), nurses (around 55,000 workers) and therapists (around 3,000
workers),85 and also the dependants of these workers.86
46. Nonetheless, it is true that a high number of people arrived on a Health
and Care Worker visa to work in social care jobs between 2022 and 2025,
and that this was greater than the demand anticipated by the Home Office.
157,490 entry visas for social care workers were issued between the start of
2021 and September 2025. The majority of these—105,432—were issued in

78 Skills for Care, The size and structure of the adult social care sector and workforce in
England - 2025, 29 July 2025 (updated 10 October 2025), p13
79 Skills for Care, The size and structure of the adult social care sector and workforce in
England - 2025, 29 July 2025 (Updated 10 October 2025), p14
80 Home Office, Restoring control over the immigration system: white paper, CP 1326, May
2025, p 27
81 Oral evidence taken on 4 February 2026, Q1
82 Independent Chief Inspector of Borders and Immigration, An inspection of the
immigration system as it relates to the social care sector August 2023 – November 2023,
March 2024, para 3.23
83 Home Office, Biggest overhaul of legal migration model in 50 years announced, [Link],
20 November 2025
84 Home Office, Immigration system statistics data tables, Entry clearance visa applications
and outcomes detailed datasets, year ending December 2025, Table Vis_D02
85 Home Office, Immigration system statistics data tables, Sponsored work entry clearance
visas by occupation and industry (SOC 2020), year ending December 2025, Table Occ_D02
86 It is not possible to match dependants to particular occupations based on current Home
Office data, so we cannot say exactly how many dependants came with care workers,
rather than workers in other occupations.

25
 2023. Workers also switched from other routes to care work after arriving in
the UK—between 2021 and 2025, there were 48,328 in-country switches from
study visas to social care jobs.87 Under current rules the earliest of these
arrivals would start to be eligible to apply for settled status from 2026. The
Home Office has estimated that around 117,000 care workers and 79,000
adult dependants of care workers will settle between 2026 and 2030.88 It is
important to note that while more people arrived on care worker visas than
the Home Office’s higher estimate of 40,000 workers a year, this does not
mean that arrivals over and above the Home Office’s figure of 40,000 were
not coming to work in genuine care roles. The Home Office did not conduct
an impact assessment prior to opening the care route,89 and appears to
have had limited understanding of the care sector, which likely contributed
to the underestimation of demand.
47. The Earned Settlement consultation states that fraud was “rife” on the
care work route.90 The Home Secretary told us that it is not fair to workers
that are “legitimately working” to ignore “the many thousands that were
unexpected or the dodgy practices in this part of the labour market.”91 It
is true that the care route was very poorly managed, and lack of oversight
allowed fraud and exploitation to take place. The Independent Chief
Inspector of Borders and Immigration (ICIBI) inspected the workings of the
immigration system in relation to social care in 2023 and found “numerous
examples” of organisations being granted sponsor licences in “questionable
circumstances”, including cases of immigrants arriving in the UK to find no
work available.92 Workers who were genuinely working in care have also
experienced mistreatment and exploitation. There are now substantial
numbers of immigrant care workers who have lost their jobs as a result
of employers having their sponsor licences revoked for non-compliance;
as of June 2025, the Home Office estimated that more than 40,000 care
workers had been affected.93 We asked the Home Office for an updated
number of displaced care workers on 5 February 2026, but the department
has not yet provided this information. It is important to note that while the

87 Oxford Migration Observatory, Changes to settlement: what do they mean?, 10 February

2026
88 Home Office, Estimated lifetime net fiscal costs for care workers and their adult
dependants, [Link], 5 March 2026
89 National Audit Office, Immigration: Skilled Worker visas, Report by the Comptroller and
Auditor General, HC (2024–25) 745, 17 March 2025, para 7
90 Home Office, A Fairer Pathway to Settlement: A statement and accompanying
consultation on earned settlement, CP 1448, November 2025, p3
91 Oral evidence taken on 4 February 2026, Q32
92 Independent Chief Inspector of Borders and Immigration, An inspection of the
immigration system as it relates to the social care sector August 2023 – November 2023,
March 2024, para 1.10
93 Letter from the Home Secretary on the work of the Home Office following the evidence
session on Tuesday 3 June, 22 July 2025

26
 Home Secretary has highlighted “dodgy practices”, the Home Office plans
to extend settlement routes for all care workers, including those who have
filled genuine vacancies and fully complied with the immigration rules, and
those who have entered the care sector in good faith but been exploited by
their employers.

48. conclusion
There were fundamental failures in the implementation and oversight
of the care worker visa route when it was expanded in 2022, which led
to unexpectedly high numbers of arrivals in a short space of time. The
Home Office significantly underestimated the level of demand for the
route and was slow to respond when the number of arrivals outstripped
its highest estimates. Inadequate oversight also meant that, while many
workers did come to fill genuine vacancies, there was also fraud and
exploitation, which the Home Office was slow address. The Home Office
should look urgently at reforming its processes to learn lessons and
ensure this failure is not repeated.

Potential impacts of the changes

49. Care work is one of the most poorly paid occupations in the UK, and there
are limited opportunities for career progression.94 Arrivals on the Health
and Care Worker visa—of which care workers formed a high proportion
in 2022 and 2023—were more likely to bring dependants when this was
permitted; 27% of children arriving in the UK on visas between 2021 and
2024 were dependants of health and care workers.95 As result, this group
of migrants are more likely to be eligible for in-work benefits should they
receive Indefinite Leave to Remain. Lower paid workers will pay less in
tax and are more likely to have a negative direct fiscal impact on public
finances over the course of their lives. Based on the Migration Advisory
Committee’s estimates of the fiscal impact of immigrants on the care route,
the Home Office has estimated that the net lifetime costs of care workers
and adult dependants who arrived in the UK between 2021 and 2025 is £9.5
billion.96 These costs are estimates, and the greatest direct fiscal costs of
immigrants—as with British citizens—come later in life, limiting the savings
of increasing the qualifying period of settlement. It should be noted that this
calculation does not reflect the impact that immigrant care workers have
on the wider economy and government finances by filling care roles that
would otherwise be vacant. While it is difficult to predict the overall fiscal

94 House of Commons Library, Adult social care workforce in England, Research Briefing
9615, 10 October 2024, p5
95 Oxford Migration Observatory, Children of migrants in the UK, 7 November 2025
96 Home Office, Estimated lifetime net fiscal costs for care workers and their adult
dependants, [Link], 5 March 2026

27
 impact of the proposed changes to settlement, and there may be negative
fiscal impacts stemming from reduced labour mobility, it appears likely
that delaying settlement for this cohort will provide short-term direct fiscal
savings for the Government.
50. The proposed 15-year route is likely to increase in-work poverty for care
workers—and as a result their children—by delaying their ability to access
public funds. Immigrant care workers would also have extremely limited
options for moving into better paid work, as they could only take on roles
in Home Office approved occupations, offered by a licenced employer.
Professor Alan Manning told us that as a consequence of these changes
the children of care workers “would be growing up in probably some of the
poorest households in the UK”.97 We discuss in Chapter Five the potential
impacts of these changes on child poverty in more detail.
51. As we discussed earlier in this Chapter, sponsored work visas can increase
risks of exploitation and mistreatment by creating a power imbalance
between employers and their workers. Adult social care is a high-risk sector
for exploitation.98 It appears likely that extended routes to settlement for
social care workers will exacerbate these risks.
52. Professor Martin Green, the CEO of Care England, argued that the changes
would have a major negative effect on the adult social care sector. He told
us that the changes were likely to make it harder to recruit and retain staff,
which could lead to “care deserts” in some areas, as the UK becomes a less
attractive place for care workers to work. Professor Green also told us that
the changes would significantly increase costs for social care providers, as
they will be liable to pay sponsorship fees for longer.99 Conversely, Professor
Alan Manning told us that delaying Indefinite Leave to Remain could
increase the retention of immigrant care workers in the sector, as once
immigrant care workers are granted Indefinite Leave to Remain, they would
have the freedom to move into other jobs. Professor Manning said extending
routes to settlement would leave workers “stuck” in care.100
53. The Government intends to address the workforce challenges stemming
from low pay in the adult social care workforce through the introduction
of fair pay agreements for the adult social care sector in England. The
Government has said the first fair pay agreement will be in place in 2028,
well after the Home Office plans to introduce these changes to settlement,
and three years after the suspension of international recruitment for care

97 Q16
98 Independent Chief Inspector of Borders and Immigration, An inspection of the
immigration system as it relates to the social care sector August 2023 – November 2023,
March 2024, para 3.19
99 Q104
100 Q16

28
 workers.101 The Government has also commissioned Baroness Casey to
chair an independent commission into adult social care, with the final
phase reporting in 2028.102 The Home Office does not set out in the Earned
Settlement consultation what impact it expects changes to eligibility for
settlement to have on the social care sector or how these reforms align with
the Government’s overall strategic vision for the sector and the timeline
for reforms to social care. We have seen no evidence that there has been
genuine join up with the Department of Health and Social Care—or the
social care sector—to ensure that the Home Office’s reforms are designed
with an understanding of their impact on the adult social care workforce. If
the reforms lead to workforce shortages in the adult social care sector, it is
possible that this could lead to increased costs to Government, both to fund
adult social care, and to address knock-on impacts on the NHS.
54. The Government has acknowledged the contribution of immigrants who
work in public services—such as the NHS—and is proposing that eligible
public sector workers qualify for a 5-year reduction to their waiting period
for Indefinite Leave to Remain. This reduction will only apply to people in
graduate level—or highly skilled—public sector roles, so adult social care
workers will not benefit. Other health and care roles that are medium skilled
or below—such as nursing associates—will also not be eligible for the
proposed reduction. The consultation document states that applicants who
have been “employed in a specified public service occupation” for five years
would qualify for this reduction.103 The policy is aimed at workers whose
earnings are based on national pay scales—such as health and education
roles—but it is unclear whether the Government intends for this reduction to
apply only to people working directly in public sector services, or whether it
would apply to people delivering public services in the private or charitable
sectors.
55. There is a direct link between capacity within the social care sector
and pressures faced by the NHS. NHS Employers told us that the
interdependencies between social care and the NHS mean that “parity
between NHS and care sector workers is crucial”.104 Care England told us
that, if the 5-year reduction only applied to public sector employers such as
the NHS, nurses and other highly skilled workers in adult social care would
be incentivised to leave the sector to join the NHS.105

101 Department of Health and Social Care, Fair pay agreement process in adult social care -
consultation document, [Link], updated 20 October 2025
102 Department of Health and Social Care, Independent commission into adult social care:
terms of reference, [Link], updated 11 July 2025
103 Home Office, A Fairer Pathway to Settlement: A statement and accompanying
consultation on earned settlement, CP 1448, November 2025, p24
104 NHS Employers (RTS4240)
105 Care England (RTS5785)

29
56. conclusion
The Home Office is facing an extremely difficult choice. If no changes
are made to eligibility for settled status, hundreds of thousands of
care workers and their dependants will become eligible for settled
status in the next few years—gaining access to public funds and likely
drawing on the public purse. If the Government proceeds with plans
for a 15-year route for care workers this will likely lead to one of two
outcomes for affected workers: they will leave the sector and return to
their countries of origin, increasing vacancies in the social care sector,
reducing the availability of care and increasing cost pressures which
the Government may need to cover, or they will remain in the UK care
sector, at prolonged risk of poverty and exploitation. This dilemma
emanates from the long-standing issue of low pay and poor conditions
in the care sector, and the Home Office’s mismanagement of the Health
and Care Worker visa. It is important to acknowledge that migrants who
work in our care sector make a genuine and valuable contribution to our
country. There is also a legitimate public interest in responding to the
recent high levels of migration through the care route, and addressing
the direct fiscal impacts associated with this group reaching settlement
after five years. Extending routes to settlement for care workers will have
unintended consequences, and the Government will need to be prepared
to identify these and mitigate them where necessary.

57. recommendation
If the Government implements a 15-year qualifying period for adult social
care workers, we recommend that it takes urgent action to support
decent pay and conditions for this group. The Home Office should set
out in response to this report the steps it will be taking to support
migrant care workers. We have previously recommended that the Home
Office explore flexible visa arrangements for workers placed on long
routes to settlement, so they are not reliant on their employer for their
immigration status.

30
58. conclusion
It is extremely hard to predict what impact these changes will have
on the social care workforce. Given the level of overseas recruitment
that has taken place, decisions about routes to settlement for social
care workers are likely to affect a significant proportion of the care
workforce, which could have a major effect on the social care sector
and the essential care delivered to vulnerable people in this country.
It is not clear what impact the Government expects these changes to
have on the social care workforce and we have seen no evidence that
the Home Office has made efforts to integrate these reforms with the
Government’s overall strategy for adult social care. Outcomes in the NHS
and the social care sector are inextricably linked and changes that affect
social care will have a knock-on effect on the NHS. If the Government
applies reductions to waits for settlement for employment in public
services to the NHS but does not apply equivalent reductions for workers
in social care, this could contribute to staff shortages in social care that
ultimately harm the whole system.

59. recommendation
The Home Office should—in partnership with the Department of Health
and Social Care—conduct a full assessment of the potential impact
of its planned changes to routes to settlement on the adult social care
workforce, and on the stability of the sector. The Home Office should
not rush to make changes before fully understanding their implications.
Whatever changes the Government proceeds with, there should be parity
between workers in the NHS and workers in adult social care for any
reductions to qualifying periods for settlement.

31
 5 Children and young
people
60. Children occupy a unique place in the immigration system and it is
important that they are given special consideration.106 Children do not have
control over their immigration status and are reliant on the responsible
adults in their lives to make decisions in their best interests. Childhood and
young adulthood are formative periods of life where identity is developed
and so a child’s experience of immigration to the UK will be fundamentally
different to that of an adult. The law explicitly recognises the importance of
protecting children in the immigration system—section 55 of the Borders,
Citizenship and Immigration Act 2009 requires that the Home Office
discharges its functions with regard to the need to safeguard and promote
the welfare of children who are in the UK.107
61. Children’s routes to settlement are usually linked to their parents. For
example, the child of a skilled worker can come to the UK as a dependant
on their parent’s visa and will receive settlement at the same time as their
parents. Likewise, the child of an asylum seeker will be a dependant on their
parent’s claim, and will be granted leave to remain in line with their parents,
should their refugee claim be granted.108 A young adult can remain on their
parent’s visa and qualify for settlement as a dependant after they have
turned 18, as long as they were a child when they first arrived in the UK and
they do not lead an independent life.109 In certain circumstances children
and young people can qualify for settlement independently of their parents,
such as on the basis of their private life, which we discuss in more detail
later in this Chapter. There are different rules for children born in the UK to
immigrant parents, which we also discuss later in this Chapter.
62. The current immigration rules in relation to children are extremely complex
and the proposed changes to settlement will increase that complexity.
The Earned Settlement consultation states that the Home Office intends
to take full account of appropriate pathways for children and the needs of

106 In the UK a child is defined as anyone under the age of 18.

107 Borders, Citizenship and Immigration Act 2009, section 55
108 Under the Government’s proposals, children in refugee families may need to wait up to 20
years in order receive settled status, under the “Core Protection” route. This inquiry has
not examined in depth the proposed changes to asylum and refugee policy and so does
not comment on the specific impacts of the proposed 20-year route.
109 Home Office, Appendix Children: caseworker guidance, [Link], 11 October 2024, pp7–8

32
 vulnerable children and families,110 but it is currently very unclear exactly
how the proposals will apply to children and young people and so we cannot
say with certainty what the actual impact will be. The consultation accepts
that many of the requirements in the earned settlement model cannot
be met by those who may still be children at the point that their parents
become eligible for settlement, but suggests that some of those arriving
as children could be required to qualify for settlement in their own right
at some point after turning 18. The Home Office has said this could involve
specifying an age limit below which some mandatory requirements, such
as the minimum income requirement, are waived.111 The lack of clarity about
how the Government intends to reform routes to settlement for children has
made it challenging to scrutinise the potential impact of the Government’s
reforms on children before they are finalised and implemented. This lack of
clarity will also have made it difficult for those who may be affected by the
reforms to give detailed feedback to the Government’s consultation.
63. Based on the proposals set out in the Earned Settlement consultation, there
are some reasonable conclusions that can be drawn about likely outcomes:
○ At least some children who immigrate to the UK—or have already
done so—will be subject to longer routes to settlement.
○ Children are likely to face different routes to settlement,
depending on the contributions of their parents, as child
dependants usually receive settlement at the same time as both
their parents.
○ At least some immigrants who arrived in the UK as children will
be expected to meet new mandatory requirements before being
granted settled status, if they reach adulthood before becoming
eligible for Indefinite Leave to Remain.
How these changes work in practice will be highly dependent on whether
the Home Office makes any changes to existing settlement provisions
specifically tailored for children, and how any such changes operate.
According to the Oxford Migration Observatory, there were roughly 430,000
to 520,000 children on a potential pathway to settlement at the end of
2024, so changes to settlement policy could potentially affect hundreds of
thousands of children.112

110 Home Office, A Fairer Pathway to Settlement: A statement and accompanying

consultation on earned settlement, CP 1448, November 2025, p7
111 Home Office, A Fairer Pathway to Settlement: A statement and accompanying
consultation on earned settlement, CP 1448, November 2025, p26
112 Oxford Migration Observatory, Changes to settlement: what do they mean?, 10 February
2026

33
64. It appears that, under the proposed system, a child’s pathway to settlement
will be determined by the contributions of their parents. Children in lower
income households will therefore face a longer wait to settlement. Children
of care workers, and other medium-skilled workers, may need to wait 15
years for settlement—or even longer if their parents are subject to any
penalties or are unable to meet new mandatory requirements. The Home
Office has proposed that adult dependants be required to earn settlement
in their own right, which could put couples on routes to settlement with
very different lengths. Under current rules, both parents must usually have
settled status for a child to be granted settlement.113 If the Home Office
maintains the rule that both parents must obtain settlement before a child
can settle, children in households where one parent is not earning, or earns
much less, would face longer routes to settlement, or be unable to settle at
all, while they are dependants.114
65. We have heard arguments that it is not fair for the immigration outcomes
of children to be based on an assessment of the contributions of their
parents.115 Professor Alan Manning told us:
to hold children responsible for the acts of their parents is
fundamentally unfair. You need something to say that children who
have spent basically their entire life in the UK, and who know nothing
else, are British for all intents and purposes.116
The Home Secretary emphasised to us that the first choice to bring children
to the UK is made by their parents, and that parents are responsible for the
life choices that their children have to navigate.117
66. Longer routes to settlement will increase the number of children who turn
18 before their parents reach settlement. Under the current system, young
adults can settle in line with their parents as long as they arrived as child
dependants. These young adults cannot forge an independent life—getting
married or moving out of their parents’ homes—without jeopardising their
immigration status.118 Longer routes to settlement would mean that people
who came to the UK as children could be well into adulthood—potentially
in their 30s—before their parents achieve settlement. Without proper
mitigation, this runs the risk of requiring these young people to delay their
independence in order to maintain their immigration status—despite
having potentially grown up and spent much of their life in the UK—or to

113 UK Visas and Immigration, Guidance: Dependent family members in work routes, [Link],
11 November 2025
114 Q41
115 Refugee and Migrant Children’s Consortium, Coram Children’s Legal Centre (RTS4937),
section 7
116 Q48
117 Oral evidence taken on 4 February 2026, Q22
118 Q41

34
 return to their country of origin without their parents. The Home Office is
consulting on how the principle of dependants qualifying in their own right
could be applied to these young adults and will develop proposals for how
young adults may, after a certain age, transition to their own immigration
pathway.119
67. Anna Skehan—Solicitor at Islington Law Centre—argued that flexibility is
essential for young people entering adulthood and said the Government
needs to account for the specific needs of young people, including
children with disabilities. She made the case that “allowing children and
young people to take steps towards the form of leave to remain that
best allows them to fulfil their potential is in everyone’s interests.”120
The Institute for Public Policy Research (IPPR) argued that it would be
unjustified to immediately expect young immigrants to meet the income
criteria associated with the earned settlement model, as this would be
“inappropriate for the first few years of their adult life.”121
68. The proposed changes are likely to mean that many children spend most
of their childhood with temporary status. We received extensive evidence
that immigration status can have a significant impact on children and
young people’s sense of integration and belonging. Chrisann Jarrett—CEO
of We Belong—told us that long routes to settlement for young people who
have lived in the UK most of their lives create a sense of “state-imposed
unwantedness” for many young people, leaving them feeling shame, and
that there is something wrong with them.122 We also received evidence that
long periods with temporary status can damage employment outcomes
for young people.123 The Refugee and Migrant Children Consortium told us
that children who have grown up in the UK and gone through the British
education system are “de facto” British. For children without settled status,
their immigration status is out of line with their everyday reality.124

119 Home Office, A Fairer Pathway to Settlement: A statement and accompanying

consultation on earned settlement, CP 1448, November 2025, p26
120 Q93
121 Institute for Public Policy Research (RTS5639)
122 Q79
123 Professor Nando Sigona (Professor of International Migration and Forced Displacement at
University of Birmingham) (RTS4197)
124 Refugee and Migrant Children’s Consortium, Coram Children’s Legal Centre (RTS4937)

35
69. conclusion
The planned changes to settlement routes will see some children
who arrive in the UK at a young age spending most, if not all, of their
childhood with temporary immigration status. The changes will also
see some young people who came to the UK as children entering their
late twenties or even early thirties before their parents are able to apply
for settlement. If dependent children continue to achieve settlement
at the same time as their parents, this would almost certainly lead to
negative outcomes for young people—where they cannot begin to forge
independent lives as they must remain dependant on their parents to
maintain their immigration status. It is currently unclear the age at which
young people would need to qualify for settlement in their own right,
and how they would be expected to do so. If young people are required
to meet minimum economic requirements to achieve settled status,
this could place unreasonable expectations on young people who are
beginning their careers or lead them to prioritise low-paid work over
education and training. Without robust protections for young people,
there is a risk of settlement policy being incoherent and leading to unfair
outcomes, based on factors entirely out of the control of the young
people affected.

70. recommendation
Children who arrive at a young age and grow up in the UK should be
granted settled status by the age of 18 without needing to fulfil the
requirements of the ‘Earned Settlement’ model, in recognition of the
fact that Britain is their home. Children who arrive at a later stage—
such as those in their mid-teens—should have clear, fair and accessible
pathways to settlement that do not inhibit them from beginning their
adult lives. Young adults should not be subject to the same economic
requirements as their parents. The Home Office should also recognise the
specific needs of disabled young people, who may reach independence
later than their peers.

71. recommendation
Under the proposed reforms parents may settle at very different times
from each other. In cases where parents are placed on different routes
to settlement, children should achieve settlement with whichever parent
settles first.

Access to university
72. We received evidence from immigrants on routes to settlement who were
particularly concerned about the impact of the changes on their children’s
ability to access a university education. Generally speaking, individuals are

36
 required to have settled status or citizenship in order to qualify for ‘home
fee’ status—where tuition fees are subject to a Government cap—or to
be able to access student loans.125 The difference between home fees and
fees for international students can be tens of thousands of pounds a year.
Nicolas Rollason told us that extending routes to settlement would increase
the number of young people who are not able to access university in the
UK.126 This could potentially affect children who have spent a long time in the
UK, such as children of people on the proposed 15-year route.

73. conclusion
Extending routes to settlement will increase the number of children and
young people in the UK who are not eligible for home fee status. This
is likely to lead to some young people delaying or missing out on going
to university. Access to education promotes integration and enables
greater contribution to society by boosting employment prospects, so it
would be counter to the overall aims of the Earned Settlement proposals
to restrict access to the university for young people who are resident in
the UK.

74. recommendation
Eligibility for home fee status should be reviewed in light of the changes
to routes to settlement, to ensure that children and young people who
have lived in the UK for a significant period of time are not prevented
from going to university due to lack of home fee status. Home fee status
could, for example, be granted on the basis of a minimum period of UK
residence in childhood, such as five years. As education is a devolved
matter, the Home Office and Department for Education should engage
with the devolved administrations on the impact of the changes, and
implications for access to home fee status in Scotland, Wales and
Northern Ireland.

Child poverty
75. While there is considerable uncertainty about how the Government’s policy
will apply to children, it appears likely that no matter how the policy is
applied it will lead to more child poverty. We received evidence arguing
that extending settlement routes will increase and deepen child poverty, by
leaving more children in households that are subject to the No Recourse to

125 There is an existing exemption for some children and young people who have spent most
of their lives in the UK. Children and young people who meet the 5-year private life route
requirements (discussed later in this Chapter) and have been lawfully resident in the
UK for three years can qualify for home fee status. Source: UK Council for International
Student Affairs, Long Residence (accessed 17 February 2026)
126 Q12

37
 Public Funds (NRPF) condition.127 Project 17—a charity that provides support
to children in households subject to NRPF—told us about children in families
currently subject to NRPF who are living “in situations of deep poverty for
extended periods of time”, with their basic needs going unmet.128 Michelle
Lee-Izu—Chief Operating Officer at Barnardo’s—told the Committee
that families with NRPF come to Barnardo’s for basics that they cannot
provide for their children, such as coats, shoes and beds.129 Michelle told
us that Barnardo’s is seeing children in poverty experiencing malnutrition
and stunted growth.130 Eligibility for public funds is usually based on the
parent’s, not the child’s, immigration status, so these changes will affect
British and settled children.131
76. Children of lower paid workers, who are likely to have longer routes to
settlement than those on higher incomes, are more likely to be living in
poorer households as a result of the changes. As we discussed in Chapter
Four, a cohort particularly vulnerable to poverty will be the children of adult
social care workers, who will not be able to access public funds, and will
be required to remain working in a low-paid sector for 15 years to maintain
their immigration status. Professor Alan Manning highlighted this group and
told us that he would expect child poverty to go up as result of the changes,
although some of this impact will be mitigated by local authority support.132
77. Local authorities have a legal obligation to safeguard the wellbeing
of children, regardless of their immigration status, and so will provide
accommodation and subsistence support to immigrant families where
necessary to safeguard the welfare of a child—even if they are subject to
the NRPF condition.133 The bar for accessing this support is higher than the
bar for accessing benefits, so not all children in families with NRPF that are
in poverty will be able to access local authority support. We have received

127 For example: Barnardo’s (RTS5793), Institute for Research into International Migration
and Superdiversity (IRIS) (RTS4453), Project 17 (RTS5787), Refugee and Migrant Children’s
Consortium, Coram Children’s Legal Centre (RTS4937)
128 Project 17 (RTS5787)
129 Q77
130 Q89
131 Home Office, Public Funds, [Link], 9 April 2025, p11
132 Q50
133 Under Section 17 of the Children Act 1989, local authority social services may provide
accommodation and financial support to households with NRPF when a child in that
household has been assessed as being “in need”. According to the NRPF Network, it is
highly likely that a child would be found to be in need if they are homeless, or at risk of
becoming homeless, or when their parents are not able to meet their basic living needs.
This provision applies in England. There are equivalent legal obligations in Scotland,
Wales and Northern Ireland. Source: NRPF Network, Social services support for families:
When will a family be eligible (accessed 9 February 2026)

38
 evidence that children and families already face significant barriers to
accessing local authority support, and that this support often does not
actually meet their needs.134
78. The proposed reforms are likely to increase financial pressures on local
authorities, which do not receive additional central government funding for
support provided to families with NRPF. In 2024/25, the 91 local authorities
that provided data to the NRPF Network spent £94 million on support to
NRPF households.135 As we discussed earlier in this report, the Home Office
is concerned about the potential fiscal impact of a large number of people,
particularly low paid workers with children, gaining settlement and access
to public funds in the next few years, and reducing this expenditure is a key
goal of the Government’s changes. The additional costs to local authorities
of supporting families who cannot access mainstream benefits will need
to be included in any calculation of the fiscal impact of the Government’s
plans.
79. The Government’s child poverty strategy—which was presented as the “first
step on our road to ending child poverty”—outlines the economic costs of
child poverty. Children who grow up in poorer households earn less at 30
years old than their peers, and are more likely to be out of work, education
or training in early adulthood. Child poverty also worsens health outcomes,
increasing costs to the NHS.136 The Home Office will also need to consider
these costs when conducting their analysis of the fiscal impact of the
changes.
80. The Government’s child poverty strategy states that the Government is
committed to ensuring that vulnerable migrant children receive the support
that they require, regardless of their immigration status.137 When we asked
the Home Secretary what the Home Office’s assessment of the impact of the
changes on child poverty was, she told us:
This is a system of economic migration. It is right for the state to
expect people who are coming here to work to be able to support
themselves and, if they choose to bring their families with them, that
they will be able to support their families as well.138
The Government’s reforms will apply in some form to almost everyone
currently on a route to settlement—including family members of British
citizens and people with settled status, and people in the UK on the basis

134 Project 17 (RTS5787)

135 NRPF Network (RTS2501) para 10
136 Cabinet Office, Our Children, Our Future: Tackling Child Poverty, CP 1449, December 2025,
p5
137 Cabinet office, Our Children, Our Future: Tackling Child Poverty, CP 1449, December 2025,
p98
138 Q28

39
 of their right to family or private life—and not just economic migrants. We
discuss later in this Chapter the potential impact on people in the UK on
the current 10-year family or private life route, who are at particular risk of
poverty.
81. The Government has conducted an Equality Impact Assessment (EIA) of
the earned settlement model set out in its consultation,139 which might
give some indication of the expected impact of the Government’s reforms
on children but has declined to publish or share this with the Committee.
The Home Secretary has said that the Government will publish a final EIA
alongside the Government’s formal response to the consultation.140

82. conclusion
The changes set out in the Earned Settlement consultation will place
lower earning families on longer routes to settlement. This will very
likely increase child poverty, and the harms resulting from child poverty.
The children of care workers, who are poorly paid and would face a
15-year route to settlement, are a group that would be particularly
vulnerable. Increasing poverty in immigrant families is likely to increase
costs for local authorities and increase the indirect costs that arise
from children growing up in poverty. We heard evidence that very
often supporting destitute families with No Recourse to Public Funds
where there is a statutory child protection duty leads to significant
costs for local councils. We agree with the Home Secretary that it is
generally reasonable to expect economic migrants to be able to support
themselves and their families. However, if the Government proceeds with
these reforms it must be prepared for the eventuality that immigrants
will stay in country despite experiencing poverty and take action to
mitigate the impact this will have on children.

83. recommendation
We recommend that the Government conducts and publishes an
assessment of the impact on child poverty of its planned changes to
routes to settlement, before finalising and implementing these changes.
To mitigate the impact of the changes, the Home Office should make it
easier for parents who are subject to the No Recourse to Public Funds
(NRPF) condition to access financial support where this is essential
for supporting the welfare of a child. The Government should also
adequately fund local authorities to cover the costs of supporting
households who are subject to the NRPF condition.

139 Immigration PQ 93724, 27 November 2025

140 Letter from the Home Secretary to the Chair regarding the Equality Impact Assessment
(EIA) for the proposed changes set out in the consultation ‘A Fairer Pathway to
Settlement’, 2 February 2026

40
 Penalties for accessing public funds
84. The Government has proposed that immigrants who access public funds
face an extended route to settlement. Immigrants who claim public funds
for less than a year would have an additional five year wait for settlement,
while immigrants who claim public funds for more than a year would face an
additional 10 year wait. When explaining the proposals, the Home Secretary
told us that the system of reductions and penalties is “about showing that
contribution, staying in work, making a contribution to the taxpayer and
your good character all count towards earning settled status.”141
85. The largest cohort of immigrants that are eligible to access public funds are
refugees. The Home Office plans to address the issue of refugee settlement
through its new ‘core protection’ model. It is not fully clear whether refugees
would be covered by the time adjustment-based model set out in the Earned
Settlement consultation, although it appears the intent of the policy is to
deal with them separately. If refugees were subject to the penalties set
out in the Earned Settlement consultation, this would put them on very
long routes to settlement. Subjecting refugees to these penalties would
also risk breaching the UK’s obligations under the Refugee Convention,
which requires refugees to be given the same access to “public relief and
assistance” and to social security as is accorded to British citizens.142
86. Aside from refugees, immigrants are generally not allowed to access public
funds. Those who have been granted leave on the basis of their human right
to family or private life, and those on Hong Kong BN(O) visas, are eligible to
apply for a change in conditions to allow them to access benefits in special
circumstances.143 The Home Office also has discretion to allow access to
public funds for other immigrants. Eligible immigrants can apply for a
change of conditions to access public funds if one of the following is true:
○ they are destitute or are at imminent risk of destitution;
○ there are reasons relating to a child’s welfare which means they
need access to public funds, or
○ they are facing exceptional circumstances affecting their income
or expenditure.
Anna Skehan, solicitor at Islington Law Centre, told us that circumstances
that might lead to an application to access public funds might include an
injury or illness, a mental health crisis, or a relationship breaking down
due to domestic abuse.144 Grants of access to public funds are not very

141 Oral evidence taken on 4 February 2026, Q4

142 UNHCR, 1951 Convention Relating to the Status of Refugees, Article 23 and Article 24(1)(b)
143 Home Office, Permitting access to public funds, [Link] (accessed 19 February 2026)
144 Q87

41
 common when considering the number of immigrants in the UK; in 2024,
approximately 2,000 applications for a change of conditions were granted
by the Home Office.145
87. The NRPF Network—an organisation that provides advice to local
authorities on NRPF issues—told us that applying for access to benefits
through a change of conditions is typically “a last resort”. The NRPF Network
argued that penalising people for accessing public funds would increase
risks of poverty, abuse and exploitation.146 The Convention of Scottish Local
Authorities (COSLA) told us that applying this penalty would deter people
from applying for a change of conditions and shift costs to local authorities
social care teams, “where support is intensive and more costly than
mainstream provision.”147 COSLA told us that applying the penalty to people
who have already claimed benefits would penalise individuals who were
following immigration advice that was correct at the time of application and
who were assured by immigration advisers that their application for public
funds would not affect their eligibility for settlement.148

88. conclusion
Most immigrants can only access benefits in rare circumstances and
must be granted permission to do so by the Home Office. We are
concerned that penalising people in difficult circumstances who urgently
need support will deepen poverty and increase pressures on local
authorities. It would be deeply unfair to apply the penalty to people who
have already been granted access to public funds and would not have
known that this could extend their route to settlement. Doing so would
also make implementation more practically difficult.

89. recommendation
We recommend that the Home Office does not apply any penalties for
accessing public funds on the basis of benefit claims that preceded the
Government’s new policy. There should be discretion for reasonable and
fair exemptions to this penalty, where the applicant can demonstrate
that they have only accessed public funds due to particularly challenging
circumstances.

145 Home Office, Migration Transparency Data, Immigration and protection data: July to
September 2025, Table CoC_01
146 NRPF Network (RTS2501) paras 21, 27
147 Convention of Scottish Local Authorities (COSLA) (RTS5782)
148 Convention of Scottish Local Authorities (COSLA) (RTS5782)

42
 The 10-year family or private life route
90. The 10-year family or private life route is currently the longest route to
settlement for immigrants in the UK. People are placed on the 10-year route
when they would not otherwise qualify for permission under the immigration
rules but have a right to stay in the country on the basis of their human right
to private or family life. The Oxford Migration Observatory estimated that in
2021 there were around 170,000 people on the 10-year route.149 The 10-year
route provides a pathway to settled status for those who previously did not
have a lawful basis to be in the UK, but where it would not be reasonable
to remove them, for example because of family ties—such as having a
British child—or the establishment of private life on the basis of very long
residence in the UK.150 This can provide a route to settlement for people who
have previously broken immigration rules, for example by overstaying a
visa. It also provides a route for people who would qualify for a family visa,
but cannot meet the financial requirements, where there are exceptional
circumstances.151 People on this route have often been living in the UK for a
long time,152 and are unlikely to leave the UK. There is a shorter, 5-year route
to settlement for children and young people who have spent most of their
lives in the UK, which is discussed below.
91. Leave to remain on the 10-year route is granted for no longer than 2.5 years.
Applicants must renew their leave at least three times following their initial
application before they become eligible to apply for settlement. Each in-
country application for 2.5 years of leave costs £1,321 per person. Applicants
are also required to pay the Immigration Health Surcharge at the point
of renewal—£2,587.50 per adult and £1,940 per child.153 People granted
leave on the 10-year route do not usually have access to public funds but
may be eligible to apply for a change of conditions, as discussed above.

149 Oxford Migration Observatory, Migrants on ten-year routes to settlement in the UK, 21
July 2021
150 Oxford Migration Observatory, Migrants on ten-year routes to settlement in the UK, 21
July 2021
151 Home Office, Family Policy: Family life (as a partner or parent) and exceptional
circumstances, [Link], 30 December 2025, p26
152 IPPR, GMIAU and Praxis, ‘A punishing process’: Experiences of people on the 10-year route
to settlement, 2 March 2023, p19
153 Home Office, Family visas: apply, extend or switch, [Link] (accessed 13 February 2026)

43
 Immigration fees generate substantial income for the Home Office,154 and
are higher than the cost of administration, in some cases by a significant
margin.155
92. We received evidence that the combination of high visa fees, No Recourse
to Public Funds (NRPF) and instability can cause significant hardship to
families. Chrisann Jarrett—CEO of We Belong—told us that paying visa fees
has left families unable to afford the basics, such as food, electricity and
their children’s school uniform.156 We heard that this can affect British or
settled children whose parents are on the 10-year route.157 People applying
for leave on the basis of their family or private life can apply for a fee waiver
if they cannot afford to pay the fee. However, we heard that in practice fee
waivers are difficult to access. Islington Law Centre described applying
for these waivers as “complex, intrusive and time-consuming”. If a fee
waiver application is rejected, all fees must be paid within 10 days, or the
applicants will lose their immigration status.158 Chrisann Jarrett told us that
families who were able to save up for some, but not all, of the fees ended up
being penalised, because they are considered too rich to be eligible for the
fee waiver, but do not actually have enough money to pay the fees.159
93. It can be very difficult for individuals and families on the 10-year route to
achieve settled status, due to the costs and complexity of applications.160
Anna Skehan, Solicitor at Islington Law Centre, described maintaining lawful
presence on a 10-year route as a “feat of endurance and will and, to an
extent, luck”.161 The number of people achieving settled status at the end of
the 10-year route is much smaller than the number who entered it 10 years
ago, suggesting that people are falling off the route,162 likely at least in part
because of the challenges of maintaining status via this route. We heard
that children are particularly at risk of losing their immigration status: Anna
Skehan told us that some families cannot afford to pay the visa fees for
all members of their household, and in these cases they usually prioritise
renewing the status of the adult earners in the household, as this enables
the main earner to keep working to feed and house the family.163 Islington

154 In 2024/25 UK Visas and Immigration had an overall income of around £3 billion and a
surplus of £1.8 billion once the cost of delivery is taken into account. The cost recovery
rate for visa fees was 256%. Source: Home Office, Home Office annual report and
accounts: 2024 to 2025, HC 1133, 17 July 2025, p192
155 House of Commons library, Immigration Fees, Research Briefing 9859, 13 February 2026,
pp9–11
156 Q86
157 Q77
158 Islington Law Centre (RTS5741) para 16
159 Q86
160 Q64 [Anna Skehan]
161 Q81
162 Q15 [Dr Madeleine Sumption]
163 Q77

44
 Law Centre also told us that for cultural and economic reasons, families
who cannot pay all the fees will often prioritise securing leave for men,
meaning women in the household are more likely to lose their immigration
status.164
94. Families experience significant barriers to accessing immigration and legal
advice. There are areas of the country where it is extremely difficult to
access immigration advice due to a lack of advisers and ongoing challenges
in the legal aid sector.165 Legal aid is currently only available for asylum
cases and a small set of immigration cases, such as immigration bail.166
People with cases outside the scope of legal aid, including family or private
life applications, can only access legal aid if they qualify for exceptional
case funding.167 Islington Law Centre told us that the plans proposed in
the Earned Settlement consultation will require a significant increase in
capacity in the legal aid sector, given the additional applications that will
be required.168 The NRPF Network told us the proposals risk an increase in
the number of people who fail to maintain lawful immigration status, in part
because of the shortage of immigration advice.169
95. The proposed earned settlement reforms will not alter the baseline for
settlement for these families, which will remain at 10 years. However,
proposed “non-compliance and negative contribution” penalties are likely to
affect at least some people on the 10-year route. These proposed penalties
are:
○ An additional 5-year wait for people who have been in receipt of
public funds for less than 12 months
○ An additional 10-year wait for people who have been in receipt of
public funds for more than 12 months
○ Up to an additional 20-year wait for people who arrive in the UK
illegally
○ Up to an additional 20-year wait for people who entered the UK
on a visit visa

164 Islington Law Centre (RTS5741) para 47

165 Citizens Advice (RTS3118), Dr Jo Wilding, No Access to Justice 2, 9 June 2025
166 NRPF Network, Legal aid: Immigration and asylum cases (accessed 13 February 2026)
167 Exceptional Case Funding can be granted in cases that would not usually be eligible if the
applicant’s human rights are at risk. Source: Legal aid: Funding for exceptional cases,
[Link] (accessed 13 February 2026)
168 Islington Law Centre (RTS5741) para 18
169 NRPF Network (RTS2501)

45
 ○ Up to an additional 20-year wait for people who have overstayed
permission for six months or more.170
Only one of these penalties would apply to an individual case—if more than
one condition is applicable then the largest increase is applied. The Earned
Settlement consultation states that the Government “believes it is right
that those who do not comply with immigration laws should expect this to
impact on their pathway to settlement”.171
96. The above penalties are more likely to affect people on the 10-year route
than other immigrants because the route provides a way for people who
do not otherwise have permission to regularise their status, although not
everyone on the route will be affected. This would include, for example,
people who have overstayed their visa. As we have discussed, there are
challenges to maintaining lawful status on the route, which can lead to
individuals overstaying—this could lead to people on the current 10-year
route having to wait 30 years to achieve settlement. People on the 10-year
route are one of the few groups of immigrants who are generally permitted
to apply for permission to access public funds, meaning this group is also
one of the ones most likely to have their route extended by the penalty
for accessing public funds, which could place them on a 20-year route to
settlement.
97. We received evidence that extending routes to settlement for families by
up to 20 years would cause significant harm to children and young people
affected. We discussed earlier in this report the evidence we received
that extending NRPF is likely to increase poverty among children who are
affected. Anna Skehan emphasised to us that even if only the parents face
an extended route, this will still create harm and instability for the children
as family resources “are diverted away from what is best for those children
and what will bring them most safely to adulthood, and into managing an
increasingly unmanageable route to settlement”.172 Anna told us that, given
the challenges families currently face completing the 10-year route, she
expects that a 30-year route to settlement would significantly increase the
number of people who do not manage to reach settlement, and become
undocumented.173

170 Home Office, A Fairer Pathway to Settlement: A statement and accompanying

consultation on earned settlement, CP 1448, November 2025, p23
171 Home Office, A Fairer Pathway to Settlement: A statement and accompanying
consultation on earned settlement, CP 1448, November 2025, p25
172 Q85
173 Q81

46
98. conclusion
The current 10-year family or private life pathway is a challenging route
to settlement for families who are on it. The route is expensive, and
it is easy for people who are trying to comply with the rules to fall off
the route. The 10-year route can cause genuine hardship for children
affected by it. The changes set out in the Earned Settlement consultation
could lead to some people on the current 10-year route having to wait
30 years for settlement. A 30-year route is too long, and the costs of the
route would mean that in practice, many people would never achieve
settlement.

99. recommendation
We recommend that people who under the current system would be
on a 10-year family or private life route to settlement be given a route
under the new rules that is reasonable and achievable. People should
not be placed on a 30-year route to settlement. To reduce the financial
pressures associated with repeat applications, and the risk of people
losing status, the Home Office should increase the duration of leave to
remain on the family or private life route from 2.5 to 5 years, and set visa
fees for people granted leave on the basis of their family and private life
at no higher than the cost of administration.

Children who have spent most of their life

in the UK
100. There are special provisions in the immigration rules for children and young
people who were brought to this country at a young age and grew up here,
but do not have valid immigration permission. This is in recognition of the
fact that these children had no control over their immigration status and
that the UK has a duty “to safeguard and promote the welfare of a child
when carrying out immigration functions”. Home Office guidance notes that
children brought to the UK and raised here are likely to have been educated
in the UK, have strong English language skills, and be well integrated into
British society.174
101. Until 2022, children and young people in this cohort could apply for leave
to remain under the 10-year route to settlement discussed above. In 2022,
changes were made to the immigration rules, creating a 5-year route to
settlement, which children and young people can apply for if:
○ They are under the age of 18, have lived in the UK for seven years,
and it would not be reasonable for them to leave, or

174 Home Office, Private life, [Link], 30 December 2025, p9

47
 ○ They are aged 18 to 24 and have spent at least half their life in the
UK.175
In order to qualify for this route a child will need to have arrived in the UK by
the age of 12 years and 6 months. There are separate provisions for children
born in the UK to immigrant parents—a child who was born in the UK and
has lived here for the first seven years of their life can apply for immediate
Indefinite Leave to Remain.176
102. We Belong told us that it is common for young people without valid
immigration status to only discover this when they turn 18 and find that they
are unable to progress to university along with their peers. We Belong told
us that these young people, having lived in the UK for most of their lives,
consider the UK to be their home, but can experience hardship as result
of the current settlement process, including the loss of educational and
employment opportunities.177 Chrisann Jarrett, the CEO of We Belong, told
us that the immigration system harms the wellbeing and sense of identity of
children and young people.178
103. Chrisann Jarrett told us that the introduction of the 5-year route has
been “transformative” for young people who have benefited, by providing
security and permanence, and allowing them to pursue opportunities that
they previously could not. However, Chrisann told us that the impact of the
5-year route has been limited due to the costs involved—it would cost a
young adult at least £6,496 to be granted leave on the 5-year route and it
costs £3,029 to apply for Indefinite Leave to Remain (ILR). Chrisann told us
We Belong sees young people falling off the route as they are unable to pay
visa fees, or becoming trapped on the route as they are unable to pay the
fee for ILR.179 Chrisann told us longer routes as a whole are likely to increase
the number of young people growing up in the UK with precarious status,
and that retaining the 5-year route would not, alone, address the potential
impacts on children and young people.180
104. The Home Secretary assured us that the Home Office will “protect the
position of those are already here” in this cohort but did not rule out making
changes to this route in the future.181

175 Home Office, Private life, [Link], 30 December 2025, p9

176 Home Office, Indefinite leave to remain (private life): Eligibility, [Link] (accessed 17
February 2026)
177 We Belong (RTS2965)
178 Q79
179 Q65
180 Q86
181 Oral evidence taken on 4 February 2026, Q26

48
105. conclusion
Children who are brought to the UK at a young age and grow up here
are, for all intents and purposes, British. These children and young
people should not be required to “earn” their right to remain in the
UK. The rights of these children and young people should be protected
regardless of any changes made to settlement policy. The introduction
of the 5-year private life route for children and young people has been a
positive step. However, the cost of the route means that its impact has
been limited, and there are children and young people who have spent
most of their life in the UK who are unable to access a realistic route to
settlement.

106. recommendation
As we previously recommended, the Government should ensure that all
children who come to the UK at a young age and grow up in the UK are
granted settled status by the age of 18. The Government should also
maintain the 5-year private life route for children and young people who
have lived in the UK for most of their lives, as a backstop and for where
this would be a faster route to settlement than granting it at 18. The
Home Office should ensure that the Earned Settlement changes do not
in any way disadvantage this group. Fees applied to these children and
young people should be set at a level no higher than the administrative
cost of processing the applications.

Citizenship
107. The proposed changes to eligibility for settled status would have a direct
impact on entitlements to British citizenship for those born in the UK to
immigrant parents. A child who is born in the UK will automatically be a
British citizen if one of their parents is a British citizen or has settled status.
If a child is born in the UK to a foreign national who does not have ILR, but
their parent secures settled status before they turn 18, they have a statutory
right to register as a British citizen. A child born in the UK who has lived in
the UK for the first 10 years of their life, with no absences from the country of
more than 90 days, also has the right to register as a citizen, regardless of
the immigration status of their parents.182
108. Extending routes to settlement is likely to increase the number of children
born in the UK while their parents are still on a visa, which will mean more
children born and raised in the UK without automatic citizenship. This will
mean more children will need to register in order to become British citizens.
It will also delay eligibility for registration as a British citizen for many
children and young people.

182 British Nationality Act 1981, section 1

49
109. The Project for the Registration of Children as British Citizens (PRCBC) told
us that people with the right to register as a British citizen face barriers to
registration. PRCBC highlighted a lack of awareness among young people
that they are not citizens, and that they need to register.183 People who’s
right to register is reliant upon a parent receiving settled status must apply
for registration before they turn 18 in order to gain citizenship. PRCBC told
us that people face practical barriers to exercising their right to register,
which can make it harder for some people to access their citizenship rights.
These include the cost of fees184—it costs £1,214 for a child to register as
British, and £1,576 for an adult185—and difficulties securing evidence that
they qualify, especially for those that need to prove they have lived in the
UK continuously for the first 10 years of their life.186 The PRCBC told us that
the lack of legal aid for citizenship cases is a barrier to children and young
people registering as British Citizens.187 We heard that lack of citizenship
can be a barrier to education, employment and travel, and result in children
feeling “not fully assimilated into the fabric and social culture of the UK”.188

110. conclusion
A child who is born in the UK to someone who has settled status will
automatically be British. Extending the waiting period for settlement will
therefore increase the number of children born in the UK who are not
automatically British citizens and will need to register at a future date in
order to become citizens. Under the current system, people with the right
to register face barriers that mean they can lose out on their citizenship
rights.

111. recommendation
The Home Office should review barriers to the registration of children
and young adults as British citizens in light of the proposed changes to
routes to settlement and take action to improve access to citizenship
for children and young adults who are entitled to register as British
citizens. This could include only charging applicants for registration
the administrative cost of processing their application and running an
awareness campaign to promote registration.

183 Amnesty International UK, Project for the Registration of Children as British Citizens
(RTS4685) para 21
184 A fee waiver is available for eligible children to apply to register, but not adults.
185 Home Office, Fees for citizenship applications and the right of abode from 9 April 2025,
[Link], 29 July 2025
186 Amnesty International UK, Project for the Registration of Children as British Citizens
(RTS4685) para 25
187 Amnesty International UK, Project for the Registration of Children as British Citizens
(RTS4685) paras 28–29
188 Q70

50
 Divergent family routes
112. These changes as a whole are likely to lead to increasing numbers of
children who grow up in the UK and view Britain as their home, but whose
parents have limited leave to remain in the UK. Some of these children
will be British citizens, having been granted the right to register under the
10-year provision. Some of these children will not be citizens but will have
a right to live in the UK on the basis of their private life. It is important
that there are protections in place for children and young people who
have grown up in the UK and consider it home, which is why we have
recommended that the Government ensures these children are granted
settlement by the age of 18. However, a side effect of these provisions would
be that more young people are achieving settlement or citizenship faster
than their parents. This could lead to unintended consequences—especially
in cases where the parent of a British or settled child loses their own
immigration status before reaching settlement—that the Home Office will
need to address.

113. conclusion
There is a significant risk that extending routes to settlement will
increase the number of families who are deeply rooted in the UK but have
precarious immigration status. This is obviously not an intended goal
of the Home Office and would increase administrative pressures on the
immigration system, as well as having adverse consequences for the
families affected.

51
 6 Transitional protections
114. The Home Office is planning to apply the changes set out in the Earned
Settlement consultation to people who are already in the UK, with the
potential for some transitional protections. This means the changes would
apply to immigrants who made the decision to come to the UK before
the Earned Settlement changes were announced and were expecting to
qualify under a 5-year route. It is common for the Home Office to apply
transitional protections when making changes to the Immigration Rules—
so that immigrants are covered by the rules that were in place at the
time they received their visa, with regards to both settlement and other
aspects of immigration policy189—but there is also precedent for changes to
Immigration Rules being applied to people already in the UK.190
115. We have received a very high volume of representations from immigrants
in the UK calling for the changes not to be applied to people who are
already in the country. Immigrants have told us that they made major life
decisions—moving their families, selling properties or closing businesses in
their home country, turning down other opportunities, and in some cases,
delaying having children—on the expectation that they would be able to
secure settled status after five years. It is clear from the evidence we have
received that some immigrants would have made different choices had
they been aware that their route to settlement might change in the way
proposed by the Government.
116. The Law Society told that us that applying these changes to immigrants who
have already arrived in the UK would undermine “fundamental principles
of fairness and expectation”.191 Concerns about fairness were reflected in
much of the evidence we received, including from employers,192 unions193
and charities.194 We Belong argued that applying these changes to people

189 For example: Home Office, Statement of Intent: Family Migration, June 2012, para 132
190 For example: Home Office, Explanatory Memorandum to the statement of Changes in
Immigration Rules laid on 30 March 2006 (HC 1016), 30 March 2006, para 7
191 The Law Society (RTS5775) para 13
192 NHS Employers (RTS4240), Forvis Mazars LLP (RTS4710), Care England (RTS5785)
193 Trades Union Congress (TUC) (RTS4512), Unite the Union (RTS5780), Royal College of
Nursing (RTS4705)
194 Citizens Advice (RTS3118), We Belong (RTS2965), Mencap (RTS4769), Citizens UK (RTS5276)

52
 already in the UK undermines the principle that residents and citizens know
where they stand in relation to the law and “makes the law appear as a
bad-faith actor”.195
117. We also received evidence arguing that applying the rules to those already
in the UK would create uncertainty about the stability of UK immigration
arrangements and make the UK less attractive as a destination. Jonathan
Portes, Professor of Economics and Public Policy at King’s College London,
argued that applying the proposed changes retrospectively would damage
the attractiveness of the UK to highly skilled migrants, by increasing
uncertainty about what is, for high earners, akin to an investment
decision.196
118. A key goal of the changes is to respond to recent high levels of immigration,
particularly in 2022 and 2023, and the potential direct fiscal impact of lower
paid workers, such as those in the care sector, receiving settlement. For the
Government to achieve its stated goal of addressing the impact of these
arrivals, it is necessary that the changes apply to at least some people who
are already in the country. When we asked the Home Secretary about the
fairness of these proposals, she told us that the changes are a fair response
to the recent high levels of immigration:
What you are trading off is a set of potential obligations to people who
have come to the country, versus your obligations to your citizens and
your own long-term residents in the country. There is a choice—and
a trade-off—here, and we are trying to find a balanced way through
what is a very difficult problem.197
119. Applying the changes to people already in the UK will inevitably have
more significant consequences for some people than others. It would be
especially difficult for people who are close to achieving settlement under
the current rules and have planned on that basis but would now miss out.
It would also be particularly challenging for people on existing 10-year
routes—the private or family life route and the 10-year long residency route.
We discussed earlier in this report the significant obstacles people on the
current 10-year family or private life route experience in trying to achieve
settlement. The long residency route allows immigrants who have been
lawfully in the UK for 10 years to qualify for settlement, including counting
time spent on visas that would otherwise not qualify—for example, time
spent on a student or graduate visa.198 Individuals could have spent as long
as nine years on a route, planning on the basis of settlement after 10 years.

195 We Belong (RTS2965)

196 Professor Jonathan Portes (Professor of Economics and Public Policy at King’s College
London) (RTS1292)
197 Oral evidence taken on 4 February 2026, Q18
198 Home Office, Long residence, 24 November 2025, p4

53
 The Government plans to abolish the continuous residence route as part of
its changes, which means individuals who had been relying on this route
would be either prevented or significantly delayed from settling.199 As the
Government is principally concerned with the impact of arrivals after 2021,
applying these changes to people who arrived prior to this date does not
appear to meet the key objectives the Government has set out as the basis
for these changes.

120. conclusion
We are concerned about the plans to apply the proposed Earned
Settlement model to people who are already in the country. It is in the
interests of the Home Office, and the UK’s reputation, to be consistent
in the application of immigration rules and policy. We agree that the
Government needs to weigh and consider the broader impacts of
settlement policy on the UK—including what is fair to British people and
people already settled here—and understand that extending routes to
settlement for at least some people already in the UK is essential for the
Government to be able to meet its objective of reducing the impact of
the large number of immigrants who arrived to the UK in recent years. It
is not clear that applying these changes to people who arrived prior to
introduction of new immigration rules in 2021—after the UK’s exit from
the EU—is necessary for the Government to achieve its stated policy
aims, and so it is difficult to see a justification for applying the changes
to this cohort.

121. recommendation
We recommend that the Government carefully consider and set out clear
mitigations—including suitable transitional arrangements—for people
already in the UK who are affected by changes to routes to settlement.
There should be specific protections for vulnerable people who may
struggle to meet the criteria of the new system. The changes should not
be applied to people in the UK who arrived before 2021 and would under
the current rules be on track to settle in the UK through a 10-year route.

199 Home Office, A Fairer Pathway to Settlement: A statement and accompanying

consultation on earned settlement, CP 1448, November 2025, p23

54
 7 Implementation
122. The Home Secretary has said she intends to begin implementing these
changes from April 2026. However, it appears likely that a fully-fledged
contribution-based system will not be introduced immediately. The Home
Secretary told us:
Once we have finalised the policy, then we will be able to do the full
impact assessments, specifically on equalities, and at that point we
will have to design the system to make sure that it can cope with those
new changes, but I am confident that that can be done.200
Assessing the impact of the finalised policy, designing a system, and
then implementing it will inevitably take time. The Home Secretary told
us that she expects some elements that are not under consultation to be
implemented more quickly.201 Changes to English language requirements for
settlement, which were not under consultation, were introduced through
changes to the immigration rules on 5 March 2026 and will come into force
on 26 March 2027.202
123. Some of the proposals set out in the Earned Settlement consultation are
unclear or not fully developed. As we previously discussed, the Home
Office has not set out how the new proposals will apply to children and
young people. As noted in Chapter Four, the Government has not yet
fully considered the impact of the changes for the adult social care
system, which will be essential to complete prior to implementation if the
Government is to avoid the risk of disrupting the provision of adult social
care. We have received evidence that uncertainty about the changes, and
about how and when they will be applied, is already causing distress for
people in the UK who are unclear about their future.203
124. The Home Office will face a number of practical challenges in implementing
the proposed changes. It will require the department to implement a
much more complex system to assess settlement applications: assessing
applicant’s earnings, employment, past compliance with immigration
rules, history of claiming benefits, and potentially volunteering history. Dr
Madeleine Sumption told us that the current process for demonstrating that

200 Oral evidence taken on 4 February 2026, Q35

201 Oral evidence taken on 4 February 2026, Q35
202 Home Office, Explanatory memorandum to the statement of changes in the Immigration
Rules: HC 1691, 5 March 2026, paras 5.60–5.62
203 Project 17 (RTS5787)

55
 one meets the income requirements for a family visa is “overwhelmingly
complicated”. Dr Sumption told us that while many aspects of the changes
are feasible to implement, if everyone applying for settlement is required to
demonstrate their income, without changes to simplify the process, there is
a risk that this could create a significant operational burden for the Home
Office.204 Extended routes to settlement will mean that immigrants will also
need to apply for visa renewals more times before reaching settlement,
which will increase the volume of case work the Home Office needs to
process. The Home Office has previously struggled with implementing
large-scale system changes, especially where these require new IT systems.
For example, the implementation of eVisas has led to technical problems,
leaving some individuals struggling to prove their immigration status.205
The Home Office also has a history of moving large numbers of staff around
to meet emerging pressures, meaning that the need to increase casework
capacity could lead to a loss of capacity in other areas.

125. conclusion
The Home Office has said that changes to eligibility for settlement will
begin to be implemented from April 2026 but has not given a clear
timeline of when specific changes will be implemented. Key elements of
the proposals that could have unintended consequences remain unclear
and under-developed. The Home Office will need to implement significant
changes to its systems, processes and staffing to deliver its new system
of settlement. It is obvious that the Home Office is not in a position
to fully implement changes of the scale proposed in its consultation
from April 2026. Indicating that this is when the changes would be
implemented has no doubt caused unnecessary distress among
immigrants close to qualifying for settlement.

126. recommendation
The Home Office should learn from previous reforms that it is more
important to get changes right than to implement them quickly. In order
to deliver workable reforms of the kind set out in its Earned Settlement
consultation, the department must take adequate time to assess the
impact of its final policy and put in place measures to avoid unintended
consequences. Ministers should ensure that the Home Office is prepared
to effectively administer what will be a much more complicated system.
The Home Office should provide a clear and realistic implementation
timeline, so that people can make informed decisions about their future.

204 Q56
205 Oral evidence taken on 28 January 2026, Q95 [Monique Hawkins, Head of Policy and
Advocacy, the3million]

56
 Conclusions and
recommendations

The overall impact of the changes

1. The Government has developed the proposals in its Earned Settlement
consultation to respond to the unprecedented levels of immigration to
the country in recent years, particularly of medium-skilled workers. We
recognise that the Government is responding to a challenging situation,
as a large number of people will soon become eligible for settlement due
to the recent spike in immigration, especially in 2022–23. We support the
Government’s stated aim to promote contribution and improve the fiscal
impact migration has on the UK. It is not possible to be certain of the
impacts of the changes, especially in the absence of a finalised policy. There
may be direct fiscal benefits for extending routes to settlement for some
migrants, especially in the short-term, but there is a risk that the changes
will undermine integration, which any changes should seek to promote. It is
important that the Home Office thoroughly assesses the impacts of its final
policy, before implementation. (Conclusion, Paragraph 16)

Assessing contribution
Mandatory minimum income
2. The Government has proposed requiring all immigrants to earn at least
£12,570 a year in order to be able to settle permanently in the UK. This will
apply more widely than just to economic migrants—family migrants and
arrivals on humanitarian routes will also be affected. It is reasonable to
expect most people who wish to settle to contribute economically, and
entering employment is also likely to foster and support integration, so
there is value in encouraging immigrants to work where they are able.
However, there will be people who are unable to meet this requirement for
good reason. (Conclusion, Paragraph 20)
3. There should be reasonable and clear exceptions to the mandatory
minimum economic contribution requirement so that people are not
prevented from settling where there are legitimate reasons they cannot

57
 meet this requirement. This could include exemptions for disabled people,
people over pension age, those who are studying full-time, and those with
full-time caring responsibilities. (Recommendation, Paragraph 21)

Income-related reductions
4. The Government’s current proposals would allow shorter routes to
settlement based on meeting earning requirements set at current income
tax thresholds. This means that people who make a net positive direct
fiscal contribution to the UK, but earn below the higher rate tax threshold,
could face a 10-year route to settlement. The Government has not been
clear about the basis on which the reduction thresholds have been set, nor
what outcome they are intended to achieve. Given the Home Office does not
intend to keep reduction thresholds in line with tax thresholds in the future,
it appears that that current tax thresholds have been used as a convenient,
but not yet justified, basis for setting the earnings required to reduce
waiting periods for settlement. This also adds a layer of administrative
complexity, and therefore potential for abuse, to a system the Home Office
already struggles to manage. (Conclusion, Paragraph 24)
5. We recommend that the Home Office set out clear objectives for the basis
on which fiscal contributions qualify immigrants for a reduction to their
wait for settlement. The Home Office should then commission the Migration
Advisory Committee to advise on appropriate thresholds based on these
objectives. (Recommendation, Paragraph 25)

Assessing contribution at an individual level

6. Applying income-based reductions to qualifying periods for settlement at an
individual, rather than a household level, could lead to perverse outcomes,
and obscure the contribution of immigrants who take on a greater
proportion of caregiving, whose care may enable their partners to take on
more demanding and higher earning careers. These changes may also deter
high earning immigrants that we want to come to the UK, if their partners
are on much longer routes to settlement than them. However, we recognise
that assessing income at a household level also could lead to inconsistent
outcomes, such as two colleagues on an identical income having different
paths to settlement based on how well-off the person they married is.
(Conclusion, Paragraph 30)
7. We recommend that the Home Office applies reductions to qualifying
periods for settlement for direct fiscal contribution at a household level, not
at an individual level, to recognise that generally households make financial
decisions as units. (Recommendation, Paragraph 31)

58
 Workers
Classifying medium-skilled workers
8. It appears that the main purpose of putting medium-skilled workers on a
15-year route to settlement is fiscal, because medium-skilled workers are,
on average, lower earners. It is odd and unnecessary to use RQF skill levels
as a proxy for income when making decisions about settlement, rather
than assessing income directly. Making decisions in this way will lead to
high earners in skilled roles being put on longer routes for a reason that is
fundamentally arbitrary. (Conclusion, Paragraph 35)
9. If the Home Office proceeds with putting lower-paid workers on a 15-year
route to settlement, it should do so on the basis of income, and not the
RQF classification of their role, as this will not necessarily reflect their
direct economic contribution, which appears to be the Government’s
justification for this reform. If the Government has other reasons for
using RQF classifications to determine the length of routes to settlement,
it should explain these to demonstrate the rationale for this choice.
(Recommendation, Paragraph 36)

Worker pay, progression and exploitation

10. There is a benefit to having a sponsored work visa system in that it supports
oversight and makes it easier for the Home Office to confirm immigrants are
coming to work in genuine roles. However, sponsorship-based visa systems
increase the amount of power that employers have over their workers and
limit the ability of workers to progress and increase their earnings. Requiring
workers to stay on sponsored worker visas for up to 15 years is likely to
exacerbate these power dynamics and increase risks of exploitation.
(Conclusion, Paragraph 42)
11. The Home Office should explore more flexible visa arrangements for
workers it is planning to place on long routes to settlement, so they are
not reliant on a particular employer to maintain their immigration status.
Workers granted sponsored visas could transition to a more flexible visa
after a set amount of time. Workers granted freedom to move employers
in this way could still be subject to the No Recourse to Public Funds (NRPF)
condition. Any flexible visa arrangements should provide a clear route to
settlement for these workers. The Government should also consider what
role the Fair Work Agency should have in tackling exploitation for this group.
(Recommendation, Paragraph 43)

59
 Health and social care
12. There were fundamental failures in the implementation and oversight of
the care worker visa route when it was expanded in 2022, which led to
unexpectedly high numbers of arrivals in a short space of time. The Home
Office significantly underestimated the level of demand for the route and
was slow to respond when the number of arrivals outstripped its highest
estimates. Inadequate oversight also meant that, while many workers did
come to fill genuine vacancies, there was also fraud and exploitation, which
the Home Office was slow address. The Home Office should look urgently
at reforming its processes to learn lessons and ensure this failure is not
repeated. (Conclusion, Paragraph 48)
13. The Home Office is facing an extremely difficult choice. If no changes
are made to eligibility for settled status, hundreds of thousands of care
workers and their dependants will become eligible for settled status in the
next few years—gaining access to public funds and likely drawing on the
public purse. If the Government proceeds with plans for a 15-year route
for care workers this will likely lead to one of two outcomes for affected
workers: they will leave the sector and return to their countries of origin,
increasing vacancies in the social care sector, reducing the availability of
care and increasing cost pressures which the Government may need to
cover, or they will remain in the UK care sector, at prolonged risk of poverty
and exploitation. This dilemma emanates from the long-standing issue
of low pay and poor conditions in the care sector, and the Home Office’s
mismanagement of the Health and Care Worker visa. It is important to
acknowledge that migrants who work in our care sector make a genuine
and valuable contribution to our country. There is also a legitimate public
interest in responding to the recent high levels of migration through the care
route, and addressing the direct fiscal impacts associated with this group
reaching settlement after five years. Extending routes to settlement for
care workers will have unintended consequences, and the Government will
need to be prepared to identify these and mitigate them where necessary.
(Conclusion, Paragraph 56)
14. If the Government implements a 15-year qualifying period for adult social
care workers, we recommend that it takes urgent action to support decent
pay and conditions for this group. The Home Office should set out in
response to this report the steps it will be taking to support migrant care
workers. We have previously recommended that the Home Office explore
flexible visa arrangements for workers placed on long routes to settlement,
so they are not reliant on their employer for their immigration status.
(Recommendation, Paragraph 57)

60
15. It is extremely hard to predict what impact these changes will have on the
social care workforce. Given the level of overseas recruitment that has taken
place, decisions about routes to settlement for social care workers are likely
to affect a significant proportion of the care workforce, which could have
a major effect on the social care sector and the essential care delivered to
vulnerable people in this country. It is not clear what impact the Government
expects these changes to have on the social care workforce and we have
seen no evidence that the Home Office has made efforts to integrate these
reforms with the Government’s overall strategy for adult social care.
Outcomes in the NHS and the social care sector are inextricably linked and
changes that affect social care will have a knock-on effect on the NHS. If
the Government applies reductions to waits for settlement for employment
in public services to the NHS but does not apply equivalent reductions for
workers in social care, this could contribute to staff shortages in social care
that ultimately harm the whole system. (Conclusion, Paragraph 58)
16. The Home Office should—in partnership with the Department of Health
and Social Care—conduct a full assessment of the potential impact of its
planned changes to routes to settlement on the adult social care workforce,
and on the stability of the sector. The Home Office should not rush to make
changes before fully understanding their implications. Whatever changes
the Government proceeds with, there should be parity between workers in
the NHS and workers in adult social care for any reductions to qualifying
periods for settlement. (Recommendation, Paragraph 59)

Children and young people

17. The planned changes to settlement routes will see some children who
arrive in the UK at a young age spending most, if not all, of their childhood
with temporary immigration status. The changes will also see some young
people who came to the UK as children entering their late twenties or
even early thirties before their parents are able to apply for settlement. If
dependent children continue to achieve settlement at the same time as their
parents, this would almost certainly lead to negative outcomes for young
people—where they cannot begin to forge independent lives as they must
remain dependant on their parents to maintain their immigration status. It
is currently unclear the age at which young people would need to qualify
for settlement in their own right, and how they would be expected to do so.
If young people are required to meet minimum economic requirements to
achieve settled status, this could place unreasonable expectations on young
people who are beginning their careers or lead them to prioritise low-paid
work over education and training. Without robust protections for young
people, there is a risk of settlement policy being incoherent and leading to
unfair outcomes, based on factors entirely out of the control of the young
people affected. (Conclusion, Paragraph 69)

61
18. Children who arrive at a young age and grow up in the UK should be granted
settled status by the age of 18 without needing to fulfil the requirements of
the ‘Earned Settlement’ model, in recognition of the fact that Britain is their
home. Children who arrive at a later stage—such as those in their mid-
teens—should have clear, fair and accessible pathways to settlement that
do not inhibit them from beginning their adult lives. Young adults should not
be subject to the same economic requirements as their parents. The Home
Office should also recognise the specific needs of disabled young people,
who may reach independence later than their peers. (Recommendation,
Paragraph 70)
19. Under the proposed reforms parents may settle at very different times
from each other. In cases where parents are placed on different routes
to settlement, children should achieve settlement with whichever parent
settles first. (Recommendation, Paragraph 71)

Access to university
20. Extending routes to settlement will increase the number of children and
young people in the UK who are not eligible for home fee status. This is likely
to lead to some young people delaying or missing out on going to university.
Access to education promotes integration and enables greater contribution
to society by boosting employment prospects, so it would be counter to
the overall aims of the Earned Settlement proposals to restrict access to
the university for young people who are resident in the UK. (Conclusion,
Paragraph 73)
21. Eligibility for home fee status should be reviewed in light of the changes
to routes to settlement, to ensure that children and young people who
have lived in the UK for a significant period of time are not prevented from
going to university due to lack of home fee status. Home fee status could,
for example, be granted on the basis of a minimum period of UK residence
in childhood, such as five years. As education is a devolved matter, the
Home Office and Department for Education should engage with the
devolved administrations on the impact of the changes, and implications
for access to home fee status in Scotland, Wales and Northern Ireland.
(Recommendation, Paragraph 74)

Child poverty
22. The changes set out in the Earned Settlement consultation will place lower
earning families on longer routes to settlement. This will very likely increase
child poverty, and the harms resulting from child poverty. The children
of care workers, who are poorly paid and would face a 15-year route to
settlement, are a group that would be particularly vulnerable. Increasing

62
 poverty in immigrant families is likely to increase costs for local authorities
and increase the indirect costs that arise from children growing up in
poverty. We heard evidence that very often supporting destitute families
with No Recourse to Public Funds where there is a statutory child protection
duty leads to significant costs for local councils. We agree with the Home
Secretary that it is generally reasonable to expect economic migrants to be
able to support themselves and their families. However, if the Government
proceeds with these reforms it must be prepared for the eventuality that
immigrants will stay in country despite experiencing poverty and take action
to mitigate the impact this will have on children. (Conclusion, Paragraph 82)
23. We recommend that the Government conducts and publishes an
assessment of the impact on child poverty of its planned changes to
routes to settlement, before finalising and implementing these changes. To
mitigate the impact of the changes, the Home Office should make it easier
for parents who are subject to the No Recourse to Public Funds (NRPF)
condition to access financial support where this is essential for supporting
the welfare of a child. The Government should also adequately fund local
authorities to cover the costs of supporting households who are subject to
the NRPF condition. (Recommendation, Paragraph 83)
24. Most immigrants can only access benefits in rare circumstances and must
be granted permission to do so by the Home Office. We are concerned that
penalising people in difficult circumstances who urgently need support will
deepen poverty and increase pressures on local authorities. It would be
deeply unfair to apply the penalty to people who have already been granted
access to public funds and would not have known that this could extend
their route to settlement. Doing so would also make implementation more
practically difficult. (Conclusion, Paragraph 88)
25. We recommend that the Home Office does not apply any penalties for
accessing public funds on the basis of benefit claims that preceded the
Government’s new policy. There should be discretion for reasonable and
fair exemptions to this penalty, where the applicant can demonstrate
that they have only accessed public funds due to particularly challenging
circumstances. (Recommendation, Paragraph 89)

The 10-year family or private life route

26. The current 10-year family or private life pathway is a challenging route to
settlement for families who are on it. The route is expensive, and it is easy
for people who are trying to comply with the rules to fall off the route. The
10-year route can cause genuine hardship for children affected by it. The
changes set out in the Earned Settlement consultation could lead to some
people on the current 10-year route having to wait 30 years for settlement.

63
 A 30-year route is too long, and the costs of the route would mean that
in practice, many people would never achieve settlement. (Conclusion,
Paragraph 98)
27. We recommend that people who under the current system would be on a 10-
year family or private life route to settlement be given a route under the new
rules that is reasonable and achievable. People should not be placed on a
30-year route to settlement. To reduce the financial pressures associated
with repeat applications, and the risk of people losing status, the Home
Office should increase the duration of leave to remain on the family or
private life route from 2.5 to 5 years, and set visa fees for people granted
leave on the basis of their family and private life at no higher than the cost
of administration. (Recommendation, Paragraph 99)

Children who have spent most of their life in the UK

28. Children who are brought to the UK at a young age and grow up here are,
for all intents and purposes, British. These children and young people should
not be required to “earn” their right to remain in the UK. The rights of these
children and young people should be protected regardless of any changes
made to settlement policy. The introduction of the 5-year private life route
for children and young people has been a positive step. However, the cost
of the route means that its impact has been limited, and there are children
and young people who have spent most of their life in the UK who are unable
to access a realistic route to settlement. (Conclusion, Paragraph 105)
29. As we previously recommended, the Government should ensure that all
children who come to the UK at a young age and grow up in the UK are
granted settled status by the age of 18. The Government should also
maintain the 5-year private life route for children and young people who
have lived in the UK for most of their lives, as a backstop and for where
this would be a faster route to settlement than granting it at 18. The Home
Office should ensure that the Earned Settlement changes do not in any way
disadvantage this group. Fees applied to these children and young people
should be set at a level no higher than the administrative cost of processing
the applications. (Recommendation, Paragraph 106)

Citizenship
30. A child who is born in the UK to someone who has settled status will
automatically be British. Extending the waiting period for settlement will
therefore increase the number of children born in the UK who are not
automatically British citizens and will need to register at a future date in

64
 order to become citizens. Under the current system, people with the right to
register face barriers that mean they can lose out on their citizenship rights.
(Conclusion, Paragraph 110)
31. The Home Office should review barriers to the registration of children and
young adults as British citizens in light of the proposed changes to routes
to settlement and take action to improve access to citizenship for children
and young adults who are entitled to register as British citizens. This could
include only charging applicants for registration the administrative cost
of processing their application and running an awareness campaign to
promote registration. (Recommendation, Paragraph 111)

Divergent family routes

32. There is a significant risk that extending routes to settlement will increase
the number of families who are deeply rooted in the UK but have precarious
immigration status. This is obviously not an intended goal of the Home
Office and would increase administrative pressures on the immigration
system, as well as having adverse consequences for the families affected.
(Conclusion, Paragraph 113)

Transitional protections
33. We are concerned about the plans to apply the proposed Earned Settlement
model to people who are already in the country. It is in the interests of the
Home Office, and the UK’s reputation, to be consistent in the application
of immigration rules and policy. We agree that the Government needs to
weigh and consider the broader impacts of settlement policy on the UK—
including what is fair to British people and people already settled here—
and understand that extending routes to settlement for at least some
people already in the UK is essential for the Government to be able to meet
its objective of reducing the impact of the large number of immigrants who
arrived to the UK in recent years. It is not clear that applying these changes
to people who arrived prior to introduction of new immigration rules in
2021—after the UK’s exit from the EU—is necessary for the Government to
achieve its stated policy aims, and so it is difficult to see a justification for
applying the changes to this cohort. (Conclusion, Paragraph 120)
34. We recommend that the Government carefully consider and set out clear
mitigations—including suitable transitional arrangements—for people
already in the UK who are affected by changes to routes to settlement.
There should be specific protections for vulnerable people who may struggle
to meet the criteria of the new system. The changes should not be applied to

65
 people in the UK who arrived before 2021 and would under the current rules
be on track to settle in the UK through a 10-year route. (Recommendation,
Paragraph 121)

Implementation
35. The Home Office has said that changes to eligibility for settlement will begin
to be implemented from April 2026 but has not given a clear timeline of
when specific changes will be implemented. Key elements of the proposals
that could have unintended consequences remain unclear and under-
developed. The Home Office will need to implement significant changes to
its systems, processes and staffing to deliver its new system of settlement.
It is obvious that the Home Office is not in a position to fully implement
changes of the scale proposed in its consultation from April 2026. Indicating
that this is when the changes would be implemented has no doubt caused
unnecessary distress among immigrants close to qualifying for settlement.
(Conclusion, Paragraph 125)
36. The Home Office should learn from previous reforms that it is more
important to get changes right than to implement them quickly. In order
to deliver workable reforms of the kind set out in its Earned Settlement
consultation, the department must take adequate time to assess the
impact of its final policy and put in place measures to avoid unintended
consequences. Ministers should ensure that the Home Office is prepared
to effectively administer what will be a much more complicated system.
The Home Office should provide a clear and realistic implementation
timeline, so that people can make informed decisions about their future.
(Recommendation, Paragraph 126)

66
Formal minutes

Tuesday 10 March 2026

Members present
Dame Karen Bradley, in the Chair
Lewis Atkinson
Paul Kohler
Robbie Moore
Margaret Mullane
Chris Murray
Peter Prinsley
Jo White

Earned Settlement: Examining the

Government’s proposed reforms
Draft report (Earned Settlement: Examining the Government’s proposed
reforms), proposed by the Chair, brought up and read.
Ordered, That the draft Report be read a second time, paragraph by
paragraph.
Paragraphs 1 to 15 read and agreed to.
Paragraph 16 read.
Amendment proposed, after “fiscal impact migration has on the UK” to
insert “; however these aims should not come at the expense of reneging
on commitments made to those already on pathways to settlement, who
have complied with their visa requirements and acted in good faith on the
basis of the rules that applied when they made life changing decisions to
contribute to the UK and its economy.”—(Paul Kohler)

67
Question put, That the Amendment be made.
The Committee divided.

Ayes, 2 Noes, 4
Paul Kohler Lewis Atkinson
Margaret Mullane Robbie Moore
Chris Murray
Jo White
Question accordingly disagreed to.
Paragraph 16 agreed to.
Paragraphs 17 to 119 read and agreed to.
Paragraph 120 read.
Amendment proposed, after “people already settled here” to leave out
remaining words and insert “but believe that balance can be achieved by
the Home Office vigorously applying existing visa requirements to those
already on pathways to settlement, rather than introducing retrospective
changes that undermine the UK’s reputation as a reliable good faith actor
whose word is its bond.”—(Paul Kohler)
Question put, That the Amendment be made.
The Committee divided.

Ayes, 2 Noes, 4
Paul Kohler Lewis Atkinson
Margaret Mullane Robbie Moore
Chris Murray
Jo White
Question accordingly disagreed to.
Paragraph 120 agreed to.
Paragraph 121 read.
Amendment proposed, after “Government carefully consider” to leave out
remaining words and insert “the consequences of retrospectively changing
the rules applicable to those already on pathways to settlement which, as
the evidence has clearly shown, is based on problematic fiscal assumptions

68
and will cause injustice, unintended consequences and risks undermining
current and future initiatives to grow the economy by damaging the UK’s
reputation in the international labour market as a country that can be
relied upon to honour its commitments. As such an approach is not required
to effectively address any abuses that did, and still are occurring, under
the existing rules—often cited as a reason for making these changes
retrospective—we call upon the Government to actively enforce current
visa requirements and only make those changes, with which it decides
to proceed, applicable to those not already embarked on a pathway to
settlement.”—(Paul Kohler)
Question put, That the Amendment be made.
The Committee divided.

Ayes, 2 Noes, 4
Paul Kohler Lewis Atkinson
Margaret Mullane Robbie Moore
Chris Murray
Jo White
Question accordingly disagreed to.
Paragraph 121 agreed to.
Paragraphs 122 to 126 read and agreed to.
Summary agreed to.
Resolved, That the Report be the Sixth Report of the Committee to the
House.
Ordered, That the Chair make the Report to the House.

Adjournment
Adjourned till Tuesday 17 March 2026

69
Witnesses
The following witnesses gave evidence. Transcripts can be viewed on the
inquiry publications page of the Committee’s website.

Wednesday 21 January 2026

Dr Madeleine Sumption MBE, Director, Oxford Migration Observatory; Alan
Manning, Professor of Economics, London School of Economics; Nicolas
Rollason, Partner and Head of Immigration, Kingsley Napley LLP Q1–61

Tuesday 3 February 2026

Solange Valdez-Symonds, CEO, Project for the Registration of Children
as British Citizens; Chrisann Jarrett MBE, CEO, We Belong; Anna Skehan,
Legal Practice Lead, Migration and Refugee Children’s Legal Unit, Islington
Law Centre; Michelle Lee-Izu, Chief Operating Officer, (Children’s Services)
Barnardo’s Q62–100
Peter Wieltschnig, Policy Lead - Employment Rights & Labour Markets,
Trades Union Congress; Professor Martin Green OBE, CEO, Care England;
Matthew Percival, Director - Future of Work and Skills, Confederation of
British Industry Q101–130

70
Published written evidence
The following written evidence was received and can be viewed on the
inquiry publications page of the Committee’s website.
RTS numbers are generated by the evidence processing system and so may
not be complete.
1 Adage Digital Ltd  RTS0513
2 Amnesty International UK; and Migrant Voice  RTS4678
3 Amnesty International UK; and Project for the Registration
of Children as British Citizens  RTS4685
4 Andromeda-Sim  RTS0514
5 Anonymised  RTS4659
6 Anonymised  RTS4656
7 Association of Pakistani Physicians of Northern Europe;
Punjab Medical College Alumni; and Rawalpindi Medical
College Alumni  RTS4499
8 Asylum Matters  RTS4677
9 BMA (British Medical Association)  RTS4689
10 Baobab Womens Project CIC  RTS5091
11 Barbulescu, Dr Roxana (Associate Professor, University of
Leeds)  RTS5669
12 Barnardo’s  RTS5793
13 Belong - The Cohesion and Integration Network  RTS3185
14 Brexit Couples Project  RTS4516
15 British Malayali Charity Foundation  RTS5100
16 British Red Cross  RTS4597
17 Brooks, Professor Thom (Principal of Collingwood College &
Professor of Law, Ethics and Government, Durham University)  RTS5700
18 Brushstrokes Community Centre  RTS0102
19 Burley in Wharfedale Community Managed Library  RTS1977
20 Business Science Corporation  RTS4623

71
21 Cambridge Cameroon Community (CCC)  RTS3200
22 Campaign for Science and Engineering (CaSE)  RTS3125
23 Care England  RTS5785
24 Catholic Bishops’ Conference of England and Wales  RTS4169
25 Centre for Migration, Diaspora, Identity and Citizenship at
University of the West of Scotland  RTS4536
26 Centre for Policy Studies  RTS4708
27 Centre on Migration, Policy and Society (COMPAS)  RTS5781
28 Cheshire, Halton & Warrington Race & Equality Centre  RTS3569
29 Citizens Advice  RTS3118
30 Citizens UK  RTS5276
31 Convention of Scottish Local Authorities (COSLA)  RTS5782
32 Crisis  RTS3289
33 Dance Base; Shotput; Fleur Darkin Presence Projects;
Scottish Dance Theatre; The Work Room; City Moves
Dance; Dance North Scotland; Curious Seed; All or Nothing
Aerial Dance Theatre; and Traditional Dance Forum of
Scotland  RTS5584
34 Dilek Fidler, Dr Setenay (Senior Lecturer, University of
Westminster-Westminster Business School); Prof Linda
Clarke (Prof, University of Westminster/Westminster
Business School); and Dr Rebecca Yi Wang (Assistant Head
of School of School of Organisations, Economy and Society,
University of Westminster/Westminster Business School)  RTS1942
35 Dorset Local Medical Committee  RTS3592
36 English National Ballet  RTS4766
37 Exriz Ltd  RTS0042
38 Focus on Labour Exploitation  RTS3066
39 Forvis Mazars LLP  RTS4710
40 Goodwin, Robin (Professor, University of Warwick); Olena
Orlova (Research assistant, University of Warwick); and
Tarandeep Kang (Doctoral researcher, University of Warwick)  RTS3209
41 Greater Manchester Immigration Aid Unit  RTS4555
42 Haggar, Tianne (Research Associate, The Policy Institute,
King’s College London); Marypaz Ventura-Arrieta
(Research Assistant, The Policy Institute, King’s College
London); Kirstie Hewlett (Senior Research Fellow, The

72
 Policy Institute, King’s College London); Suzanne Hall
(Director of Research, The Policy Institute, King’s College
London); and Heather Rolfe (Director of Research and
Relationships, British Future)  RTS3420
43 Hampshire and Isle of Wight Local Medical Committee  RTS3581
44 Haringey Migrant Support Center (HMSC)  RTS4307
45 Helen Bamber Foundation  RTS4357
46 Hibiscus Initiatives  RTS4616
47 Home Office  RTS5789
48 Hong Kong Aid Services CIC  RTS4626
49 Hong Kong Watch  RTS5627
50 Human Rights Solidarity  RTS4697
51 Immigration Law Practitioners’ Association  RTS5788
52 Immigration Law and Policy Clinic, Goldsmiths University
of London  RTS4473
53 India Labour Solidarity; and Brighton Ambedkar Reading
Circle  RTS5701
54 Indian Overseas Congress-UK Kerala Chapter  RTS0872
55 Institute for Public Policy Research  RTS5639
56 Institute for Research into International Migration and
Superdiversity (IRIS)  RTS4453
57 Islington Law Centre  RTS5741
58 Jithus Ltd  RTS3454
59 John Gilbert Architects  RTS4750
60 Justice For Sponsored Workers  RTS4153
61 Kingsley Napley LLP  RTS5294
62 L’Arche  RTS3204
63 Labour Friends of Hong Kong  RTS4743
64 Latin American Women’s Rights Service (LAWRS)  RTS5319
65 Laura Devine Immigration  RTS5783
66 Leeds Teaching Hospitals NHS Trust  RTS4161
67 Lewis Silkin LLP  RTS5784
68 Loughborough University and College Union Branch
Committee  RTS3333

73
69 Malayali Association Of Dudley  RTS2520
70 Matchingham Games Limited  RTS4638
71 Mencap  RTS4769
72 Migrant Help  RTS4727
73 Migrants’ Rights Network; and Not a Stranger Campaign  RTS3296
74 Migrate UK  RTS4187
75 Migration Yorkshire  RTS4664
76 Mirza, Mr Salman (Immigration Asylum Advisor,
Brushstrokes Community Project & The Children’s Society)  RTS2519
77 NHS Employers  RTS4240
78 NRPF Network  RTS2501
79 New Arrivals Voice  RTS3412
80 Nigerian Doctors in the UK  RTS4070
81 Nigerian Lawyers in the UK; Midpoint Career and Business
Training; and Nigerian Lawyers in Scotland  RTS3907
82 No Recourse North East  RTS4593
83 Northern Ballet  RTS5135
84 Peace Haven Foundation  RTS4633
85 Pinter, Dr Ilona (Research Associate, University of Glasgow)  RTS5791
86 Policy Exchange; and Policy Exchange  RTS4842
87 Portes, Professor Jonathan (Professor of Economics and
Public Policy, King’s College London)  RTS1292
88 Professional Alliance of Indian Radiographers, UK  RTS4627
89 Project 17  RTS5787
90 Project X Dance CIC; Theiya Arts; We Are Here Scotland
CIC; Scottish Contemporary Arts Network (SCAN); Scottish
BPOC Writers Network; [Link]; and ID.Y CIC  RTS5535
91 Re-Water CIC  RTS4469
92 Reading Hongkongers CIC  RTS3743
93 Refugee Council  RTS5073
94 Refugee and Migrant Children’s Consortium; and Coram
Children’s Legal Centre  RTS4937
95 Refugee and Migrant Forum of Essex and London (RAMFEL)  RTS3358
96 Refugee, Asylum Seeker & Migrant Action  RTS5239

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97 Reunite Families Uk  RTS4553
98 Ricardo Plc  RTS1729
99 Royal British Legion; and Army Families Federation  RTS3300
100 Royal College of General Practitioners  RTS4483
101 Royal College of Nursing  RTS4705
102 Royal Incorporation of Architects in Scotland (RIAS)  RTS5652
103 Sameeksha UK  RTS5526
104 Salusbury World Refugee Centre  RTS5790
105 Scottish BPOC Writers Network  RTS5017
106 Scottish Government  RTS4398
107 Scottish Refugee Council  RTS2451
108 Sedacca, Dr Natalie (Assistant Professor in Employment
Law, Durham University)  RTS4682
109 Seraphus  RTS3096
110 Shepherd, Dr Ally (Researcher in the School of Education,
University of Leeds); and Prof Gabriella Alberti (Professor
of International Labour Migration at the Business School,
University of Leeds)  RTS4617
111 Sigona, Professor Nando (Professor of International
Migration and Forced Displacement, University of
Birmingham)  RTS4197
112 Skyscanner  RTS3270
113 Southall Black Sisters  RTS5786
114 Sutton Hong Kong Cultural & Arts Society  RTS5041
115 TKO Group  RTS1748
116 The Law Society  RTS5775
117 The Royal Society  RTS3301
118 The Runnymede Trust; and Praxis  RTS5792
119 The Society of Motor Manufacturers & Traders Limited  RTS4611
120 The UK-EU Committee of Assembly of Citizens’
Representatives, Hong Kong (ACRHK)  RTS4087
121 The Unity Project  RTS5737
122 Theiya Arts  RTS3501
123 Together HK CIC  RTS2264

75
124 Trades Union Congress (TUC)  RTS4512
125 Tuckett, Dr Anna (Senior Lecturer, Brunel University of
London)  RTS4569
126 UK Welcomes Refugees  RTS4477
127 UNISON  RTS2377
128 Ukraine Policy Network, University of Birmingham  RTS4148
129 Unite the Union  RTS5780
130 Universities and Colleges Employers Association; and
Universities UK  RTS4243
131 University and College Union  RTS2513
132 University of Cambridge  RTS3058
133 Volunteering Matters  RTS3234
134 W Legal Limited  RTS0006
135 We Belong  RTS2965
136 Welsh Refugee Council  RTS3522
137 Work Rights Centre  RTS2510
138 Zhang, Dr Chi (Assistant Professor, University of Warwick)  RTS2007
139 iProtectU Limited  RTS1686

76
List of Reports from the
Committee during the current
Parliament
All publications from the Committee are available on the publications page
of the Committee’s website.

Session 2024–26
Number Title Reference
5th Maccabi Tel Aviv fan ban HC 1553
4th The Home Office’s management of asylum HC 580
accommodation
3rd Tackling violence against women and girls: HC 741
funding
2nd Police response to the 2024 summer disorder HC 381
1st Appointment of the Independent Chief Inspector of HC 713
Borders and Immigration
3rd The Home Office’s management of asylum HC 1642
Special accommodation: Government Response
2nd Tackling violence against women and girls: HC 1352
Special Funding: Government Response
1st Police response to the 2024 summer disorder: HC 1099
Special Government Response

77