Written evidence submitted by Citizens UK (RTS5276)
About Citizens UK
Citizens UK is the UK’s biggest, most diverse, and most effective people-powered alliance, bringing together everyday people and local organisations to build a better, fairer society.
We have a proven track record of working with successive governments on the issues that our communities care about the most. From enabling access to Free School Meals for children and families with No Recourse to Public Funds (NRPF), providing a safe passage for thousands of children to arrive safely in the UK, to our Living Wage campaign, winning over £2 billion back into the pockets of low paid workers, we know what can be achieved when government and communities work together.
Having organised communities for more than two decades, we know that there are many people who have made their life in the UK but are facing barriers to work, family and democratic participation due to lack of status, settlement and citizenship.
Through a six-month listening campaign, we went deep into this issue with over 2,000 people in local community institutions across the UK – in schools, faith communities, charities and civic associations - from September 2023 to February 2024. In one-to-one meetings and small groups, people who have put down roots in the UK shared their aspirations to become British citizens and described in vivid detail the barriers to getting settlement and citizenship and the problems created when you are stuck without it.
We published our ‘Unblocking the Pathways to Citizenship’ report in November 2024 (MARO Report), which details problems in the UK settlement and citizenship system, with recommendations for reform. Our campaign recommendations have grown over the last year in response to the White Paper, as we are informed and led by communities on the impact of immigration reforms and opportunities for change.
Citizenship is a foundational issue in our listening; it impacts long-term integration, social cohesion, and equality. We call on the government to facilitate integration and cohesion for those who have put down roots in the country by making the pathway to citizenship shorter, cheaper, and fairer. Our key asks are:
Introduction
We are deeply concerned that the new proposals risk moving in the wrong direction and making the pathway to citizenship longer and more complicated than it already is, harming migrants' ability to lead stable lives. Longer pathways to settlement for risk indiscriminately impacting the most vulnerable groups of migrants and families, which will have serious implications for integration, child poverty, and growth.
We encourage further consideration of the earned settlement model, to ensure it is fair and compassionate to all migrants and refugees making the UK their home. Many communities are confused and anxious about whether earned settlement will be applied retrospectively, and what the ‘transitional arrangements’ will be. We are urging the government not to apply the changes retrospectively, as it is only fair that people remain on the settlement pathway they expected, especially since many have made life plans based on a reasonable expectation of that commitment.
Up and down the country, our communities are filled with people who have migrated to the UK and made this country their home. They have put down roots and work, study, worship and volunteer here. Though almost all are on a pathway to citizenship, this pathway is unnecessarily long, costly, and unfair.
Rather than encouraging people to settle and become citizens, the design and delivery of the proposed earned settlement policy actively prevents people who have made the UK their home from settling in the UK, and becoming British Citizens. In the current system, it can often be more than a decade and tens of thousands of pounds before people can finally have the security of permanent residency and access to citizenship. People are often left to live in limbo, with constant stress from visa applications, waiting times and ever-increasing fees and charges. Whilst on the pathway, most people will be denied access to basic services and support and some will as a result face poverty and destitution. This disproportionately impacts black and racialised communities.
“For all of my life, the UK has been the only home I've known. I was born here and grew up being on a pathway to citizenship. As a child, I had to get my head around the reality that even if this was home, I had to wait years and pay thousands to formally belong here. I didn't understand why I couldn’t do the same things my classmates could. I would often see my parents attempt to hide the extortionate fees we had to pay and the suffering that came with not having status from me and my siblings.
My parents were on a longer pathway than me; always hiding the fear and uncertainty that came from not having the security of citizenship. Over 20 years of growing roots and making the UK home, immigration policies still affect where we can go as a family, the jobs my loved ones have access to, and even the places we can live in. More than two decades of the UK being home, some in my family have status and some don't.” (Community leader and member of Citizens UK Migrant & Refugee Organising team)
The potential impact of the earned settlement changes will exacerbate the challenges we are already hearing across the communities we work with. For many of the most vulnerable groups, longer and stricter settlement requirements will lead to prolonged periods of limbo and place even greater financial and psychological pressure on migrant and refugee households.
The earned settlement proposals outline a baseline qualifying period for most migrants that will increase from 5 years to 10 years, with a starting point of 20-years for some people recognised as refugees. There will also be minimum mandatory requirements that all people must meet in order to be granted settlement. The government suggests that the qualifying period can be adjusted, upwards or downwards, based on 4 core pillars of: Character, integration, contribution, and residence. In respect of contribution, the policy document states:
The reformed system will reward individuals who have made a sustained and measurable economic contribution to the UK, on the principle that any accelerated path to settlement should be earned through active participation in the economy. (Home Office consultation template, page 20)
In most EU countries, the US, Canada and New Zealand, temporary residents have the right to become permanent residents after five years (Permanent Residence | MIPEX 2025). In the UK currently, certain groups must wait much longer - ten, twelve or even thirty years. An estimated 170,000 people are already on the 10- year route to settlement. They have leave to remain because of their family or long-term ties to the UK but must accrue 10 years of continuous residence before they can apply for Indefinite Leave to Remain (ILR), and a further year before becoming eligible for citizenship (A punishing process': Experiences of people on the 10-year route to settlement | IPPR).
This route disproportionately affects black and racialised communities. Analysis of Home Office data showed that all but one country in the top 10 nationalities forced to use this route were those with predominantly non-white populations. The top five were Nigeria, Pakistan, India, Ghana and Bangladesh. Overall, 86% using the route were from Asian or African countries, while 6% were from Europe. (Home Office urged to scrap long, expensive and ‘racist’ visa route | Immigration and asylum | The Guardian)
The new earned settlement proposals could contribute to further inequalities by disproportionately targeting;
From our previous findings, a family of two adults and two children on the 10-year route to settlement in the UK must pay application fees of over £5,000 every two and half years, health surcharges of over £3,500 per year, and fees of over £11,500 to apply for Indefinite Leave to Remain after ten years. Citizenship costs a further £5,600 in fees, plus £50 for the ‘Life in the UK’ test and the cost of English language tests with approved providers for the adults. This is a cost of over £37,000 in fees alone, and over £73,000 including health surcharges. Families have to pay legal fees on top of this. These fees will significantly increase if families are on routes to settlement for more than 10 years.
Longer and stricter requirements are of particular concern for families with NRPF and will push children into deeper poverty, especially if families face consequences for claiming public funds and are put on a longer qualifying route to settlement. Today, over 2.6 million people in the UK are thought to be affected by NRPF, including hundreds of thousands of children who are growing up in poverty because of the condition. Families subject to NRPF often face impossible choices between rent and food. Many are pushed into homelessness, informal and exploitative work, or prolonged cycles of debt.
The link between NRPF and child poverty is clear. Children in NRPF households are more likely to:
The contradiction between NRPF and the UK’s obligations under the Children Act 1989 is stark. While the Act requires local authorities to safeguard children in need, NRPF places these same families outside the formal safety net, forcing councils to pick up the pieces and often without the necessary funding. This policy doesn’t just harm children; it places unsustainable strain on local services.
Through our community listening, we have heard stories of parents with British children being on a 10-year route to settlement with NRPF, being driven to borrow money from friends, or use bank overdrafts to cover immigration application costs. We have heard about the severe impact this has on their mental health, emotional well-being, and financial stability. Parents have shared the devastating impact on children when they cannot adequately provide for them or struggle to offer meaningful opportunities. For these families, there is no safety net to fall back on.
The proposed earned settlement changes will place greater pressure and strain on families who are already navigating a deeply unfair system. As we know from research on NRPF, this is likely to increase child poverty, while also limiting social integration and hindering children’s positive development into adulthood.
In our listening, we have also heard of families being forced to make harrowing choices prioritising the visas of certain family members over others. Complex and inaccessible fee waivers mean people can’t access their rights. Desperate to stay on the pathway, people have been driven to debt and destitution. High and rising costs have meant that some ended up relinquishing their rights to citizenship, or getting caught in a cycle of limited leave to remain visas without being able to afford ILR, for which there is no fee waiver available. We foresee this being exacerbated through the earned settlement contribution model.
We know that the standard qualifying period is proposed to rise from 5 to 10 years, with 15 years proposed for ‘lower-skilled’ workers, which will negatively impact people on a health and care visa route. We are concerned that extending the qualifying period will disproportionately and indiscriminately affect migrants in essential roles, primarily due to their lower salaries.
We have heard endless stories from migrant care workers who work long hours in poor and in many cases exploitative conditions, to survive and provide for their family. Careworkers do the essential work of caring for vulnerable people in our communities. We have heard 100s of stories of care workers who have been exploited by care companies. Some are recognised as victims of modern slavery and can access support through the National Referral Mechanism. However, many more do not reach this threshold and are stuck in exploitative and dangerous situations, unable to speak out for fear of reprisals or the impact on their immigration status.
Migrant care workers came to the UK on visas to provide essential work and fill the gaps in the UK’s care system, and yet instead of valuing and protecting them, the settlement proposals would lead to greater harm and instability. We view being a care worker as a long-term contribution to the UK, which should be valued properly with a fair pathway to settlement.
. 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:
. social and community contributions; and
. fiscal and economic contributions.
We view volunteering and community work as vital and pivotal roles throughout the country. Many of our members who are migrants are proud of the community work and contribution they make to the UK. In many cases, they are making significant social as well as economic contributions. That might be volunteering in their community, working in the public sector, or taking on community roles and responsibilities.
Systemic factors mean that not everyone has an equal opportunity to make an economic contribution. The earned settlement model is broadly based on earnings being the best means to objectively measure economic contribution. There is grave risk that this approach will penalise and exclude the many other ways in which people contribute to social integration and cohesion in the UK.
Our communities want to contribute over the long-term and work hard to demonstrate this sustained commitment to cohesion and integration. The earned settlement approach to contribution should be fair and inclusive, recognising the full spectrum of efforts and achievements that migrant communities work hard to attain.
In our listening, a community member told us that they have been in the UK for over 20 years, having studied and completed their Master’s degrees here. They had struggled with periods of being undocumented, during which time they had been unable to work, despite being highly qualified. The community member told us that they dedicated all their time to volunteering and serving the community at their local church, taking part in cultural and sporting events, and encouraging others who were struggling. This community member now has status and can work, but continues to dedicate their life to volunteering and has won awards for their services.
Defining contributions too narrowly, for example, as only economic, risks undervaluing and excluding other vital ways in which people make British society better and contribute to social integration and cohesion. Many migrants balance paid employment with civic engagement in community life.
We have heard stories of families balancing economic contributions and societal contributions, such as volunteering in community churches and supporting elderly people to remain socially active and engaged in community life. One migrant’s community work helped to reduce social isolation, support mental health, and strengthen intergenerational connections in the community, reducing strain on health and social care services. Despite this, we hear of families who remain with insecure status and will need to pay thousands more to stay in the UK, and eventually settle.
“The process leaves us with constant anxiety, financial strain, and a feeling of being temporary…”
The breadth of contribution that migrants make in their communities and to the country must be recognised within the earned settlement consultation process. Defining contributions more broadly, to include social as well as financial contributions, would ensure that the many dimensions of social cohesion aside from economic activity are acknowledged.
We heard from one community member that the earned settlement model has created a tick box exercise, where a person has to prove their profile is strong enough. The community member said that people want to build a life here and they want to contribute, but it has prevented this member from furthering their life in the UK. They gave the example of wanting to buy property but finding this challenging without settlement, as it can be very difficult to get a mortgage.
This ‘tick box’ exercise could undermine the voluntary nature of social contribution and, rather than enabling those who contribute to fast-track their settlement, it could be a necessary step in being able to reach settlement. Our listening has shown that migrants and non-migrants value the voluntary nature of social contribution and the government should design a system to preserve.
There was also concern shared about how earned settlement could impact women who have status in the UK and who are on the route to settlement; if a woman has a baby and she is out of work for a period of time, could this delay her qualifying for settlement?
We strongly encourage the government to consider the positive effects of implementing a broad definition of contributions, and we recommend more time is spent engaging with civil society organisations to understand how people contribute, as well as the barriers to contribution, to ensure the process is fair, humane, and does not penalise anyone. This would be particularly important in designing a system that is robust, has public trust, and isn’t vulnerable to gaming or fraud.
In the consultation policy document, the government raises the need for ‘transitional arrangements’ and ‘temporary measures’ to ease the impact of the new rules for those already in the UK and on existing pathways to settlement. We urge the government not to apply the earned settlement proposals retrospectively, so we can ensure that all migrants and refugees in the UK with leave remain on their current route to settlement.
R has never claimed benefits, and he has been working since coming to the UK. He has had no issues with the police, and his record is completely clean. But he doesn’t know if the rules will impact him retrospectively and he is worried about the decision of his settlement application.
“It feels like a punishment, I truly don’t have any words. I have been working all my life to have some stability. Now, I am on my new journey studying law to become a solicitor. I feel it is pushing me in the other direction. I am halfway through my studies, and I feel completely threatened. The UK is my home now; I don’t know my country anymore”.
We are aware that the government is consulting on groups that should be exempt from the earned settlement proposals, and that the government is particularly interested to hear about people where extenuating circumstances might apply, and people that claim public funds. Our pathways to citizenship campaign urges the government to broaden its thinking in relation to immigration reform, particularly in relation to child and adult citizenship.
In light of our campaign, we would urge the government to give particular attention to children and young people who have grown up in the UK, who have made the UK their home, attend school, and become part of UK life and society. These children need stability and hope, on a pathway to citizenship that is fair, timely, and affordable.
From our listening, communities are also concerned that the earned settlement contribution model could negatively impact migrants and refugees in our community who are disabled, have poor mental health, carers for family members and children, especially women, and survivors of domestic violence and abuse. We hope that the government will explore exemptions to the new rules for all these groups.
Dec 2025