Written evidence submitted by Hibiscus Initiatives (RTS4616)

1. Hibiscus Initiatives (‘Hibiscus’) Hibiscus is a feminist, anti-racist and intersectional women’s organisation that has delivered high-impact advocacy and advice services to Black and minoritised migrant women in contact with the Criminal Justice and Immigration systems We have been active in this field for nearly forty years. Between April 2024 and March 2025, Hibiscus supported 654 women from 82 countries. 95% of them identified as Black and minoritised women and 40% came from the Global South. The information in this response is drawn from our own caseload and discussions with our frontline practitioners.
2. Hibiscus currently works with women in the Greater London area. We partner with women through specialist casework support, advice and advocacy; group information and therapeutic workshops; and engaging them to transform the immigration system and CJS.
3. Our response to this call for evidence is based on the insights and lived experience of our service users and learned experience and observations of our frontline colleagues.
4. We are responding to this call for evidence as we are concerned that the government’s proposed changes to the pathways to settlement will have a significant negative impact on migrant women living and working in the UK. In addition, we believe that they will have a disproportionately negative, and in many cases devastating, impact on Black and minoritised migrant women.

Section 1: Potential impact of changes to pathways to settlement 

What evidence is there on the effect that pathways to settlement have on immigration and rates of settlement? What is the likely impact of longer routes and stricter requirements for settlement on migrant households already in the UK?

5. It is unclear what effect the proposed changes will have on immigration and rates of settlement. Whilst the government openly intends harsher immigration policy to decrease migration to the UK, this is supposition based on broad assumptions.
6. The women we support migrate or are forced to migrate to the UK for a range of reasons, largely unrelated to the prospect of settlement in the long-term future. This includes fleeing violence and persecution, being trafficked to the UK and choosing to stay for safety and to recover, violence against women and girls (VAWG), migrating to be with family, education, and employment.
7. What is certain is that the proposed changes to immigration policy will make life harder for many, including those already living in, and contributing to, the UK.
8. 59% of the women we support in our community service have no recourse to public funds (NRPF), which prevents them from accessing benefits, housing and some childcare support. In many cases, the result is that they are pushed into poverty, making them vulnerable, making it much harder to leave abusive relationships, and increasing risk of exploitation and homelessness.
9. We believe this needs to change to ensure that all migrants receive the support they need to avoid increasing their risk of abuse and exploitation. Increasing the length of time migrants are made to wait before applying for settled status and tying ‘financial contribution’ to the application criteria, will increase mean that Black and minoritised migrant women are made more vulnerable and for longer.
10. It is also highly likely that the proposed changes will have a disproportionately harsh impact on those who face marginalisation in society, such as Black and minoritised migrant women. These impacts may include:
1. More years living with uncertainty and much higher costs before settlement
2. Less freedom to leave exploitative jobs or relationships
3. Greater and intergenerational vulnerability to precarity, exploitation and abuse
4. Avoidance of use services essential for survival, including accessing benefits
5. Delayed or denied family stability
6. Mental health impact
7. Deepened existing economic and social inequalities
11. The current immigration system works to bar Black and minoritised migrant women, including victim/survivors of VAWG and human trafficking, from obtaining ILR, whilst creating and exacerbating vulnerability. The proposed changes will amplify this.
12. Further to this, we know that the current immigration rules, fear of enforcement, and the way some protections (e.g. the MVDAC and DVILR, or access to refuges) are applied often result in Black and minoritised migrant women being trapped in abusive relationships or are forced to stay with those exploiting them. This is because they face barriers to the support they need and because they know that they may be criminalised by the system if they encounter the police or immigration authorities. This is reflected in the fact that they are less likely to report domestic or sexual violence and less able to access safe refuges and services.
13. The proposed changes to routes to settlement will further entrench this.

What potential effect could changes to eligibility for settlement have on integration? 

14. It is likely that the long-term lack of certainty and security that would be created by the proposed changes would have a negative effect on integration. This is because it would remove the incentive for migrant people and families to form meaningful relationships and networks in their communities. Living on immigration limbo would create a sense of them not be part of society.
15. Delaying settlement prolongs precarious visa statuses, making it harder to for those subject to immigration control to plan for the future, including, housing, education, family life. This instability disproportionately affects migrant women with families, undermining their sense of belonging, ability to integrate, and long-term security.

Section 2: How the new earned settlement rules could work 

How should “long-term contribution” to the UK be defined and quantified, when considering pathways to settlement? This could include how the following elements should be defined and weighted:

16. The emphasis on ‘long-term contribution’ is problematic due to the term’s subjectivity and inherent bias, as well as the unequal opportunities that more marginalised applicants may have to ‘contribute’. It attempts to judge the value of individuals through criteria that are likely to be far more relevant to members of ‘dominant’ groups within society. E.g. white men. Those experiencing trauma would likely not be able to ‘contribute’ financially or socially in ways valued by the Home Office which are determined by economic factors with no trauma-informed understanding.
17. Black and minoritised migrant women are disproportionately represented among workers in lower-paid but essential jobs, including care, health, social care, domestic work. These are roles that the new proposals target for much longer settlement routes.
18. The effect of this will be to penalising low-paid, essential work, disproportionately impacting Black and minoritised migrant women and their families.
19. The emphasis on 'contribution' through continuous employment, will mean that those in low-paid, part-time, or precarious work will face an additional barrier. This type of work is particularly common among women balancing caring responsibilities, meaning that the increased emphasis will compound existing economic inequalities.
20. Furthermore, the requirement for continuous work and no benefits effectively penalises breaks in employment, including for parental leave, childcare, and caring responsibilities, all of which are disproportionately shouldered by women. This, again, will result in a disproportionately negative impact on women.
21. The same unpaid labour, including childcare, eldercare and community support, also does not appear to have been taken into account in the ‘contribution-based' model. The result of this is that women’s contributions to society will account less than men’s, further embedding this systemic gender inequality.
22. This criterion should not be included. If it must be, it must be expanded to include the true contribution that all migrant people make to society. This could include activities such as childcare, attending women’s centre events or accessing specialist services.

What exemptions should there be to the new rules?

23. If the government chooses to proceed with the proposed changes to immigration policy, there must be exceptions for:
1. Victim/survivors of human trafficking and modern slavery
2. Victim/survivors of VAWG
3. Refugees and those with protection under human rights grounds
4. Those already in the UK
24. For many Black and minoritised migrant women, especially victims/survivors of human trafficking and modern slavery, VAWG, and other forms of violence and persecution, the extended uncertainty over migration status means prolonged dependency and vulnerability.
25. The longer and more conditional route to settlement will increase their vulnerability, putting them at higher risk of further abuse and creating an additional barrier to support.
26. The proposed emphasis on ‘clean’ criminal and immigration history will also impact those with convictions directly or indirectly linked to their experiences of abuse and exploitation. For example, those trafficked into criminal exploitation, or who resort to shoplifting whilst experiencing VAWG. These are issues known to disproportionately impact Black and minoritised migrant women, meaning the effect of the policy will also be felt particularly harshly by them.

Conclusion

27. The current immigration system, including the hostile environment policies that remain in place, have produced disproportionate harms to Black and minoritised migrant women. This includes increased vulnerability, mental health harms, barriers to accessing essential services, employment, and justice. This system must change to ensure that migrants receive the support and protection that they need, particularly Black and minoritised migrant women who face additional marginalisation.
28. There must be a thorough review of the potential impacts of this policy before it is implemented. This must include detailed consideration of any disproportional or discriminatory impacts, such as that on Black and minoritised migrant women and victim/survivors of VAWG and human trafficking.
29. The 'contribution' test should be removed as it is clear that the potential risks associated with it, and systemic disadvantage it will create, will be significant.
30. Exemptions must be created for victim/survivors of human trafficking and modern slavery, victim/survivors of VAWG, refugees and people with protection needs, and long-term residents already in the UK. Exemptions must be clear, with a low evidentiary burden and trauma-informed assessment processes.

Dec 2025