Written evidence submitted by Malayali Association of Dudley (RTS2520)

Introduction

I am submitting this evidence on behalf of Malayalai association of Dudley(MAD) in west midlands, which is a group of members and family of health care workers (carers,doctors,nurses),coming from the state of Kerala,India.We area a community of more than 300 families with a total of 1000+ members including children ,working mostly in health care under tier 2 skilled worker visa .All of us and our partners work full time and contribute and is socially active in the community .Our children are in school and many of us are already in the process of settling here, invested into properties, businesses, education. We are very concerned and uncertain about our future due to recent ILR proposals and feel the country has broken it's promises. We request the committee to review the evidence suggesting that the ILR extention goes aginst the rules and policies under which we all came to this country and is against ECHR article 8.

              Executive summary

• Raising qualifying periods and adding income/“contribution” tests will reduce and slow rates of settlement, raise uncertainty for migrants, and create measurable workforce/retention impacts for employers — particularly in sectors that rely on international recruits (healthcare, tech, hospitality). The government’s consultation and independent commentary acknowledge these trade-offs.
• Skilled migrants are, on average, net fiscal contributors — changing settlement rules risks losing those contributions and making talent pipelines more costly for UK employers.
• Evidence from evaluation work (Skilled Worker research) and country examples (Australia, Canada, Germany) shows that faster, clear, predictable routes promote retention and integration; contribution/points systems work only if they are transparent, administratively simple and predictable.

• Scale of migrant care workers in England ≈ 290k. If ILR qualifying periods are made much longer (10–15 years) a meaningful number of skilled migrants could leave the UK or be deterred from coming — producing substantial lost gross wages and lost tax/NIC revenue to England. (Skills for Care)

• Illustrative fiscal loss (annual, England social care example): under plausible retention shocks (10% / 25% / 50% of migrant care workers leaving), lost gross wages would be roughly £0.67bn / £1.67bn / £3.34bn per year, and corresponding lost fiscal receipts (employer employee NI/tax at ~25.8%) ≈ £0.17bn / £0.43bn / £0.86bn per year respectively. (See detailed calculations below.) (Skills for Care)

• Human-rights & child impacts: extending ILR waits to 10–15 years risks breaching Article 8 ECHR / interfering with family life in many ordinary cases, and will significantly harm children’s wellbeing, schooling and mental health (documented across multiple reviews). NGOs and legal bodies warn that longer waits and tighter family reunion rules exacerbate family separation and have clear negative welfare effects. (Equality and Human Rights Commission)

• Care workers and their families are net contributors rather than drains: sector and MAC/independent analyses show many migrant workers (especially in health & care) are net fiscal contributors and essential to service delivery; making settlement harder risks losing these contributors and raising recruitment/agency/operational costs. (GOV.UK)

1) What evidence exists on the effect of settlement pathways on immigration / settlement rates?

• Direction of effect. Shorter, predictable routes (e.g. 5 years to ILR) encourage migrants to remain, invest in skills, and plan family/housing decisions; longer, uncertain routes reduce settlement rates and raise return migration or “churn”. This is a finding repeated in policy analyses and the Home Office consultation debates.

• Behavioural responses. Evidence shows migrants respond to both (a) direct incentives (time to permanence, access to benefits), and (b) indirect effects (labour mobility, risk of family separation). Evaluations of UK skilled routes and international literature find mobility decisions are sensitive to route length and rights attached to status (e.g., ability to change employer, access benefits, opportunities to learn and getting promoted, finding better salary and work life balance.).

• Fiscal/aggregate effects. Independent analysis (MAC and others) indicates skilled migrants contribute more on average to public finances; making settlement harder for such migrants risks reducing long-term fiscal gains.

2) Likely impact of longer routes to settlement on businesses and international recruitment

Main channels of impact:

1. Recruitment pipelines & employer attractiveness. Employers use the promise of settled status to attract talent and was one of the main promises when all the tier 2 skilled migrants, especially carers with low salary, was recruited. Longer routes make UK jobs relatively less attractive vs. comparator labour markets (Canada, Germany, Australia), increasing recruitment costs and time to fill roles — worst for graduate/early-career pipelines and for sectors with long training cycles (medicine, engineering). Evidence from Skilled Worker route evaluations and employer briefings stresses this.

2. Retention & turnover. If migrants expect a much longer wait for permanence, retention falls (higher churn), reducing firm-specific human capital and raising recruitment/training costs. Sectors with acute shortages (NHS, care) are particularly exposed. Not only that, once the settlement period is extended, it raises the question that what assurance is there that the new settlement period won’t be extended or abolished when a new government is elected or even when the settlement period is reached, even the current government ,if still in governance, can move the goalpost further, which is against ECHR and most migrants consider it as deception to what they have been promised during recruitment. (NHS and employer organisations have flagged operational risks when settlement becomes less predictable).

3. Wage and bargaining effects. When settlement depends on continued employment or employer sponsorship, migrants can be less or not able to switch jobs — depressing mobility and possibly wages. There are also ongoing evidence of employers exploiting this by taking money from skilled migrants, to extend their visa, means them renumber of extensions are needed, whatever they earn goes into extension and also employers getting opportunity to exploit the inability of the skilled worker, especially carers, who have no options other than paying the employer and extend the visa or leave the country, which also completely demolishes their chances of promotion, employer switching for better roles or salary              his also affects their parners,as partner’s life and work is solely relied on the non flexible and long working hours, the sponsor imposes on the skilled worker, affecting child care, financial gains, career growth and so on. Conversely, removal of near-automatic settlement could push migrants to accept lower job security to retain qualifying conditions. (This is consistent with labour economics literature cited in policy reviews.)

4. Compliance and admin burden. New contribution rules, points, or periodic assessments increase HR/compliance costs for sponsors — especially SMEs without immigration teams. Legal and compliance advice costs will rise. (Raised repeatedly in industry commentaries.)

           Let’s put above into facts and figures

Modelling — explicit assumptions and calculations

A. Inputs (explicit)

• Care worker posts (FTE basis): 905,000 (Skills for Care). (Skills for Care)
• Migrant share of care-worker roles: 32% → migrant care workers = 905,000 × 0.32 = 289,600. (The Week)
• Median hourly pay (FTE): £12.00/hour. FTE hours = 37/week × 52 weeks ⇒ annual pay per FTE = £12 × 37 × 52 = £23,088. (Skills for Care)
• Fiscal yield assumed on wages (conservative blended rate): 25.8% of gross wages (13.8% employer NIC + ~12% employee NI/tax estimate). (Note: employer NIC has been subject to policy changes and could be 15% in later years — see sensitivity note). (House of Commons Library)

B. Behavioural (retention shock) scenarios modelled

Because the exact share who would leave or be deterred is uncertain, I model three illustrative scenarios (reasonable policy-modelling practice):

• Conservative scenario — 10% of migrant care workers leave or do not come because ILR extended.
• Moderate scenario — 25% leave / deterred.
• Severe scenario — 50% leave / deterred (extreme but useful upper bound).

C. Calculations (annual figures)

(Working from inputs above: migrant care workers = 289,600; annual pay per FTE = £23,088.)

I computed (precise values shown; rounding in text):

1) Conservative (10% exit/deterrence)

• Workers leaving = 28,960. (Skills for Care)
• Lost gross wages to England per year = 28,960 × £23,088 ≈ £668,628,480 (≈ £0.67 billion).
• Lost fiscal receipts (25.8% on wages) ≈ £172,506,148 (≈ £0.17 billion) per year.

2) Moderate (25% exit/deterrence)

• Workers leaving = 72,400.
• Lost gross wages per year ≈ £1,671,571,200 (≈ £1.67 billion).
• Lost fiscal receipts ≈ £431,265,370 (≈ £0.43 billion) per year.

3) Severe (50% exit/deterrence)

• Workers leaving = 144,800.
• Lost gross wages per year ≈ £3,343,142,400 (≈ £3.34 billion).
• Lost fiscal receipts ≈ £862,530,739 (≈ £0.86 billion) per year.

(All numbers shown are annual UK-earnings losses to England’s social-care wage bill and corresponding lost tax/NIC receipts, on care workers alone. (Skills for Care)

What these figures mean in practice

• The lost gross wages are not “lost to individuals” globally (migrants often re-employ elsewhere) — but are lost to the English economy (reduced spending, VAT, local services), and represent reduced taxable earnings in England. Lost tax/NIC receipts are immediate fiscal effects (shown above). (Migration Observatory)

• There are also knock-on costs not modelled above: higher vacancy/agency costs for providers; increased pressure on remaining staff (overtime, burnout); potential closure of care places; and higher public spending in other areas (e.g., hospital delayed discharges) if care capacity falls. These can exceed direct wage/tax losses. (Sector analyses warn of operational risk if migrant pipeline shrinks.) (The King's Fund)

3)Human-rights, children & dependent partners — evidence & likely impacts (qualitative + example citations)

1) Human-rights framing

• The UK must respect Article 8 ECHR (right to respect for private/family life). Policies that make family reunification or settlement de-facto unattainable for long periods can be challenged under Article 8 where refusal/long delay causes “unjustifiably harsh” consequences (this is the legal test applied by UK case law and Home Office guidance). NGOs and legal bodies (RAMFEL, Refugee Council, Citizens Advice) have repeatedly argued recent restrictive family/settlement changes raise Article 8 concerns. (Equality and Human Rights Commission)

• Where children are involved, UN Convention on the Rights of the Child principles (best interests of the child) are engaged — prolonged separation or insecurity can be incompatible with these standards in practice. NGOs warn of this explicitly. (Safe Passage)

2) Impacts on children & dependants (evidence summary)

• Mental health: long waits and precarious status are linked with higher risk of depression, PTSD, anxiety in children and parents (multiple reviews & studies). Protraction of settlement (10–15 years) magnifies these risks. (PMC)

• Education & school stability: prolonged legal limbo can lead to disrupted schooling, barriers to access, and poorer educational outcomes — reports show displaced young people often experience stress and school disruption. (Office for National Statistics)

• Economic security & poverty: delayed settlement reduces access to some benefits/supports and increases poverty risk for families that are low paid, which harms child development outcomes (income + parental stress are consistent risk factors in UK evidence). (appgmigration.org.uk)

• Family separation & care giving: if partners or parents cannot secure settlement or family reunion for many years, children face parental absence, single-parenting pressures, increased risk of homelessness or instability. Multiple UK reports document harms of family separation on children’s wellbeing. (Amnesty UK)

3) Specific human-rights violations that could be engaged

• Potential Article 8 breaches where the policy outcome is disproportionate (e.g., forcing long family separation when the public interest does not justify it). Domestic guidance recognises that “unjustifiably harsh consequences” for children or partners can require grant of leave. NGOs already report many referral successes on these grounds. (GOV.UK)

• Children’s rights under UNCRC: policies that systematically reduce children’s access to family life, to social security supports, or harm their best interests may raise compliance questions under the UNCRC. Charity/advocacy reports document these concerns. (Safe Passage)

Evidence on the contribution of care workers & families (facts & figures)

• Care workers pay & contribution: median FTE pay ≈ £12/hr → £23,088/year FTE (see modelling). Care workers pay income tax & NI and consume locally — they are net contributors in the longer term when they are in work and not claiming benefits. Sector & MAC analyses stress skilled and working migrants typically contribute net positive fiscal amounts. (Skills for Care)

• Work without claiming benefits: Most migrant care workers work full-time and do not claim out-of-work benefits; their family members (where present) often also work or are in school — together this reduces welfare spending and adds tax receipts. NGO and sector briefings emphasise that portraying care migrants as a “drain” ignores payroll/NI and service value. (UNISON National)

• Systemic dependency: the social care sector filled ~1.60m roles and has historically relied on overseas recruitment to fill vacancies (tens of thousands of recruits in recent years). Removing or delaying the settlement promise risks long-term workforce shrinkage and higher agency costs. (Skills for Care)

Sensitivity & caveats (important for policy use)

1. Behavioural uncertainty: the % who would leave/ be deterred is not directly observable — I used 10%/25%/50% scenarios to show scale. Real behaviour depends on alternative country opportunities, visa rules in practice, family circumstances, and whether exemptions/fast-tracks exist. (Economic literature shows migrants respond to settlement certainty, but elasticity vary by occupation & pay.) (GOV.UK)

2. Fiscal rate uncertainty: I used a blended 25.8% for employer employee contributions; actual lost public receipts depend on precise earnings distributions, tax thresholds, and whether left workers are replaced by UK-born workers (which would reduce long-run revenue loss). Employer NIC rates have changed (15% possible) — this raises potential lost receipts if employers pay more in future years. (Sage)

3. Scope limitation: the modelling here only covers care-worker roles — the government’s proposals affect many other sectors (NHS nurses, doctors, hospitality, tech). Aggregating across the whole migrant workforce would raise the scale of fiscal & operational risks substantially. MAC/OBR work shows skilled migrants generally make positive net fiscal contributions. (GOV.UK)

4. Non-fiscal harms: not modelled numerically: hospital discharge delays, increased agency staffing costs, impacts on continuity of care, local economic multipliers (lost spending), and the social cost of child mental-health deterioration — each can be large but are harder to quantify without sector-level modelling.

Quick policy-oriented takeaways (from the figures & evidence)

• Even modest retention losses (10%) among migrant care workers produce meaningful annual revenue and wage shortfalls (~£0.67bn wages, ~£0.17bn tax) and much larger operational risks for the sector. (Skills for Care)

• Longer waits (10–15 years) raise real legal and child-welfare risks (Article 8 and UNCRC considerations), and increase poverty/mental-health harms for children and partners. NGO reports and academic reviews document these effects. (RAMFEL)

• If the policy objective is to ‘earn’ settlement, a multi-axis, transparent system that credits employment, NI contributions, English/community engagement and family ties — with explicit exemptions for critical sectors (NHS/care) and a strong family-reunion safety valve — will reduce the negative labour-market and human-rights outcomes suggested above. (Design detail is available from cross-country lessons.) (Skills for Care)

4) Likely impact on migrant households (financial/economic & personal/social)

Financial & economic

• Delayed access to benefits/housing: If benefits or social housing eligibility are postponed until citizenship or much later ILR, many households (esp. those with care giving needs or unstable incomes) face cash flow stress, higher poverty risk, and difficult trade-offs (work vs. caring). Past UK research into entitlement restrictions shows loss of entitlements raises destitution and reduces access to services. (compas.ox.ac.uk)

• Increased household costs: Longer routes increase insecurity about housing and family planning (childcare, schooling decisions), may raise remittances home, and can increase use of short-term credit.

• Labour market effects: Some migrants may take precarious or longer hours to meet earnings thresholds — with knock-on effects on health and family life.

Personal & social

• Mental health & family stability: Evidence and stakeholder submissions indicate prolonged temporary status increases stress, reduces sense of belonging and life planning, and can harm integration. Sense of belonging through ILR is the best way to increase integration, not vice versa. (community ties, civic participation). The IPPR and civil society commentaries highlight risks of prolonged ‘limbo’. (IPPR)

• Children & education: Children in households facing long uncertainty may see disrupted schooling decisions, and families may be less likely to invest in long-term assets (home, local networks).

• Access to services: Tighter residence rules can restrict access to some public services or benefits, complicating healthcare and social support uptake despite need.

5) Potential effect on integration

• Integration is time- and rights-dependent. Access to settlement and associated rights (welfare safety net, ability to switch jobs, family reunion) are strongly correlated with better labour market integration, civic participation and language acquisition. Policies that create long limbo periods — or link settlement chiefly to income — risk undermining social integration (less volunteering, lower trust). Migration Observatory and think-tanks warn the reforms could worsen integration unless designed to reward community engagement and employment. (Migration Observatory)

• Conditional integration incentives: A contribution-based system can incentivise positive behaviours (English, volunteering, stable employment) but only if the rules are transparent, the scoring predictable, and support is provided (language training, recognition of qualifications) — otherwise it becomes punitive.

6) Evidence from other countries (what works and lessons)

Australia (points + tailored fast tracks): long experience with points-tested skilled migration and targeted pathways for graduates/needed occupations. Evidence/consultation documents stress that a clear, objective points test helps target skills, but the system requires regular updating (occupation lists, points) and regional/state coordination. Faster PR for targeted groups (graduates in skilled jobs) helps retention. (Department of Home Affairs Website)

Canada (Express Entry + bridging for temporary migrants): Canada’s two-stage approach (temporary stay → permanent pathways) supports retention of students and temporary workers. It shows advantages in integration outcomes for those who gain PR after Canadian study/work experience, but also shows that not all temporary residents transition to permanency — creating “leakage” if pathways are too restricted. (Canada)

Germany / EU Blue Card: EU Blue Card and German settlement rules give accelerated routes for highly paid/highly qualified workers and reward language competence — showing that conditional concessions (language + contributions) can speed settlement while encouraging integration (language). (Make it in Germany)

Key cross-country lessons

• Predictability and transparency matter more than complexity: simple, well-explained scoring/predictable timelines encourage retention.
• Fast-track routes for in-demand sectors (health, STEM) preserve essential labour supply.
• Linking settlement to outcomes (employment, language) can support integration — but only when access to training and qualification recognition is enabled.

7) How “long-term contribution” could be defined & quantified (practical framework)

Design principles: measurable, administrable, non-discriminatory, and supportive of integration goals.

Suggested multi-axis scoring model (example weights — illustrative only):

1. Fiscal & economic contribution (40%)
• Years of paid employment / NI contributions in the UK (per year points).
• Average taxable earnings (with thresholds or bands).
• Taxes/NI paid (or employer-reported contributions).
• Evidence: payroll records, P60s, employer attestations.
2. Labour market stability & skills (20%)
• Employment in shortage occupations or qualifications recognition.
• Career progression / promotion evidence (employer reference).
3. Social & community contribution (20%)
• Verified volunteering hours (trusted charities), community service, or civic engagement.
• Longstanding membership of community organisations, or evidence of local leadership roles.
4. Integration markers (10%)
• English language level (CEFR) – higher points beyond basic threshold.
• Participation in accredited integration or civic programmes.
5. Family & dependants considerations (10%)
• Length and legal status of family ties in the UK (children in UK schools, partner with settled status) — to avoid family separation harms.

8) What exemptions should exist

• Humanitarian/refugee protections: standard refugee protection rules and accelerated integration for those with vulnerability.
• Victims of crime/trafficking: safeguard routes with protection and support.
• Children born or educated in the UK / long-term family ties: avoid perpetuating childhood insecurity.
• Essential public-facing workers (e.g. NHS clinical staff, social care ,health care assistants and senior care workers brought to the country on tier 2 visas ,in shortage roles) — tailored faster routes or lower thresholds to avoid service collapse. (NHS Employers)
• Those with strong local integration but low earnings — carers, single parents — allow weight for community contribution and family ties so rules are not purely monetary.

9) How have other countries applied contribution-based systems?

• Australia & Canada: points tests that reward human capital (age, language, education), work experience in host country, and sometimes regional or occupation-based bonuses. They aim to pick migrants expected to provide high long-term economic value; systems are regularly adjusted. (Department of Home Affairs Website)
• Germany (EU Blue Card): faster settlement for highly qualified workers and reduced residence time if language proficiency is higher — a de-facto contribution + integration reward. (Make it in Germany)

10) Practical recommendations for UK policymakers (concise)

1. Predictability & grandfathering: If changing routes, grandfather existing cohorts or offer transitional protection to avoid legal challenge and sudden churn. (Stakeholders emphasise this repeatedly in submissions.) (Financial Times)

2. Targeted fast-tracks: Keep or create explicit fast routes for critical sectors (health, STEM, teachers) to protect supply. (NHS Employers)

3. Design score not solely on earnings: Use multi-dimensional scoring (fiscal + community + integration) to avoid penalising carers, part-time workers, and those in public service roles.

4. Admin simplicity & data systems: Use PAYE/NI data and employer attestations to minimise documentation burdens; invest in digital checks to limit delay.

5. Support for integration: Fund language, recognition of foreign qualifications, and volunteering pathways so migrants can meet contribution criteria.

6. Impact monitoring: Commit to transparent monitoring (retention, fiscal impact, family outcomes) and a regular review mechanism.

11) What we still don’t know / further evidence needed

• Precise elasticity of settlement/return migration for each sector in the UK (how many nurses, doctors, tech staff would leave under different qualifying periods).
• Micro-evidence on family wellbeing under benefit/eligibility changes in the new proposals — useful for calibrating exemptions.
• Administrative cost estimates for different models (pure points system vs. blended earned settlement).

Nov 2025