Written evidence submitted by Institute for Public Policy Research (RTS5639)

1. The government is introducing a new set of reforms to the process of acquiring indefinite leave to remain (ILR). Under the earned settlement proposals, the default qualifying period for ILR will increase from 5 years to 10 years (or 15 years for Skilled Workers sponsored for below-graduate level jobs). This default period can then be shortened or lengthened depending on a range of factors, based on an individual’s economic and social contribution to the UK.

2. IPPR (Institute for Public Policy Research) is an independent charity and research organisation. IPPR has a long history of research on migration and integration policy. This submission summarises IPPR’s assessment of the earned settlement reforms and their potential impacts. We have based our assessment on the consultation document published in November 2025.

• What evidence is there on the effect that pathways to settlement have on immigration and rates of settlement?

3. The evidence base on the impacts of pathways to settlement is relatively limited. Changes to rules on pathways to settlement should have a direct impact on settlement rates, given they will affect the numbers eligible to apply. The impacts on immigration and emigration levels are harder to determine. The Home Office has provided an illustrative analysis of the impacts of extending the qualifying period for ILR, estimating a 10-20% deterrent effect on affected inflows. This gives an estimated reduction in immigration of 12,000-24,000 per year.[1]

4. Past reforms to settlement rules were not associated with significant changes in immigration levels. In April 2006, the government tightened settlement rules for work-related migration, extending the qualifying period from 4 to 5 years.[2] The below chart based on Home Office entry clearance data does not suggest a significant change in applications on the main work routes following the rule change. However, it is worth noting that the lengthening of ILR to 5 years was much less considerable than the proposed changes under the earned settlement policy.

Note: main applicants only

Source: IPPR analysis of Home Office data[3]

5. International evidence suggests that restrictions on permanent residence do not have a deterrent effect on asylum arrivals. A study of asylum flows to EU15 countries found that the ease of obtaining permanent residence was not an important factor behind asylum seekers’ destination choice.[4]

6. The earned settlement policy could have an impact on emigration. In particular, Skilled Workers on a default 15-year route to settlement – due to being sponsored for an occupation below graduate level – may struggle to maintain an employer sponsor for the full 15-year qualifying period for settlement and so may choose to leave the UK. This could affect a large share of recent arrivals on the Skilled Worker route – according to the Home Office, 53 per cent of Skilled Workers (main applicants) issued visas in the year ending June 2024 were sponsored for below-graduate roles.[5]

• What is the likely impact of longer routes to settlement on businesses and employers, including international recruitment of higher-skilled workers?

7. Based on the outline proposals in the earned settlement consultation, we expect that most main applicants on the Skilled Worker visa sponsored for graduate level roles are likely to be eligible for ILR after five years, in line with current policy. This is because those sponsored for graduate level jobs will have a default 10 year wait, which they will be able to reduce to five years if they earn taxable income of £50,270 for the three years prior to settlement. Home Office analysis suggests that the median adjusted earnings for Skilled Worker main applicants issued entry clearance visas in 2023/24 was £56,600 – and this number is now likely higher due to recent increases in skills and salary thresholds – so most Skilled Workers who have a default 10-year wait should be eligible for a 5-year reduction.[6] Others may instead be able to reduce the qualifying period for ILR through volunteering in the community or working in a public service role.

8. There will, however, be some lower-paid workers who have to wait longer. In those cases, employers could incur significant costs, particularly if they pay for their employee’s visa/extension application fees, settlement fee and the immigration health surcharge. Given these are often treated as taxable benefits by HMRC, the costs are significant. Ian Robinson from Vialto has estimated that the cost for a medium-large employer for sponsoring a Skilled Worker for 10 years could vary between £36,987 and £45,811, depending on whether the employee is a basic or additional rate taxpayer. (If the employer also pays for dependants, then these costs could be considerably higher).

9. Moreover, under the new settlement policy, dependants will be assessed without reference to the main applicant. This could make it significantly harder for dependants to gain settlement. For instance, the proposed mandatory requirements for adults to settle include annual earnings of more than £12,570 for at least 3-5 years. Where adult dependants are not working in the UK – for instance, due to childcare responsibilities – they will in effect be prohibited from settling. This is largely out of line with international norms. While it is difficult to accurately estimate the impacts of this policy, there is a significant risk that the measures for dependants could make the UK a less attractive destination for high-skilled workers.

• What is the likely impact of longer routes and stricter requirements for settlement on migrant households already in the UK?

10. We can assess the likely impacts of longer pathways to settlement by looking at the UK’s existing 10-year Family Life and Private Life routes. These are routes to settlement for people who do not qualify for shorter routes but who are able to stay in the UK on human rights (Article 8) grounds. Applicants must apply for extensions to their leave to remain every 30 months (2.5 years) until they are eligible for settlement after 10 years. In general, people on the route are ineligible for public funds (though they can apply for a change of conditions in certain circumstances).

11. In 2023, IPPR, together with Praxis and Greater Manchester Immigration Aid Unit, conducted a study of more than 300 people with experience of being on the 10-year route.[7]

12. The survey found that significant numbers of people on the 10-year route were under financial pressure. When asked about the overall impact of the costs of applying for or renewing their leave to remain on their household finances, just under half (47 per cent) said they found it hard to afford everything they needed and had to borrow money to pay for their application, and a further 17 per cent said they had been pushed into severe debt by paying for their application and so were unable to afford essential living costs. Sixty-two per cent of survey respondents said that they struggled to meet the cost of utilities and 57 per cent said they struggled to meet the cost of food.

13. Survey respondents also highlighted a wider set of impacts of the 10-year route. Twenty-eight per cent said that the need to continually reapply for status every 2.5 years had made it harder to keep their job. More than half said that their physical and mental health had been negatively affected by their experience on the route. Around three fifths said that their children’s wellbeing had suffered as a result of the uncertainty of the route (excluding those to whom the question was not applicable).

14. The evidence from our study therefore suggests that longer routes to settlement can place pressure on household finances and wellbeing by creating an extended period of insecure status.

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

15. The evidence from our study above suggests that integration outcomes can be harmed by lengthening routes to settlement.

16. International evidence also suggests that stricter requirements for settlement can undermine migrant integration. In Denmark, efforts to tighten permanent residence requirements in 2007 – including new conditions relating to an applicant’s employment history and language proficiency – led to lower employment levels, the opposite of the reform’s intention.[8] The study’s authors concluded that if new requirements for settlement are too stringent then they can be ineffective at encouraging integration, or even counterproductive if individuals already struggling with their integration outcomes become disincentivised.

17. Studies find that permanent status is associated with stronger labour market outcomes. For instance, in Canada, a panel study found that, for open work permit holders, securing permanent residence resulted in a bump in employment rates and earnings.[9] A US study found that permanent residency led to greater job mobility for migrants who were previously tied to their employers, which in the case of male employees improved their earnings.[10]

18. One recent Swedish study points in a somewhat different direction. Focusing on a change in policy in 2013 which granted permanent residence to all Syrian asylum seekers, it suggests that Syrians with temporary residence had stronger labour market outcomes, at least in the short-term, than those granted permanent residence. However, permanent residents were more likely to spend time studying, which indicates that their long-term labour market trajectory may be more positive.[11]

19. Another recent Swedish study sheds light on the implications of settlement rules for individual wellbeing. The study focused on a law change in 2016 which restricted permanent residence for people granted international protection (subsequent to the 2013 change referred to above). It found that Syrian refugees who received only temporary status reported greater stress about their status and lower subjective wellbeing than those granted a permanent residence permit.[12]

20. There is currently a lack of evidence in the UK on the experiences and impacts of settlement. IPPR is looking to conduct further research on this important issue. We recommend that the Home Office works with external academics and researchers to develop a stronger evidence base on the economic and social impacts of settlement, which will help to inform future government policy.

• How should “long-term contribution” to the UK be defined and quantified, when considering pathways to settlement?

21. The government’s earned settlement consultation sets out a number of ways in which people can shorten their qualifying period for ILR. These include: English language proficiency, taxable income, employment in a specified public service job, and volunteering (or working ‘in the community’). These are a justified set of criteria which account for a range of ways in which people can make an economic and/or social contribution.

22. However, the government also include ways in which someone’s pathway to settlement can be lengthened. This includes receiving public funds (ie most mainstream benefits), arriving in the UK illegally, and overstaying for at least 6 months. The penalties for these actions are high: they can add between 5 and 20 years on to the default qualifying period for ILR. There is a risk, based on the evidence above, that excessive requirements and lengthy waiting periods for settlement will backfire and undermine integration outcomes.

• What exemptions should there be to the new rules?  

23. The earned settlement policy is likely to have wide-ranging impacts across different immigration routes. As IPPR has previously outlined, our view is that the new policy should not apply retrospectively and that the qualifying periods for settlement should not be excessively onerous.[13] Within this, there are some specific exemptions which we think are important to note. We do not consider all potential exemptions and vulnerable groups here, but we highlight a few cohorts which we think are worthy of attention.

24. First, the consultation document proposes that adult dependants will be subject to mandatory earnings requirements for settlement. Our view is that in some cases it would not be justified to require dependants to earn more than £12,570 for 3-5 years. This includes individuals with a long-term illness or disability, those with caring responsibilities, those on maternity leave, or those in full-time education. We therefore think the government should consider sensible exemptions for this group (or replacing the earnings requirement with a self-sufficiency requirement that can be met in multiple ways – eg through household savings).

25. We also suggest whether it would be possible for main applicants and dependants to ‘share’ attributes – for instance, where a main applicant fulfils multiple attributes for reducing their qualifying period for ILR, they could use some of these attributes to reduce the qualifying period of their dependant(s) instead.

26. For dependent children, in general the qualifying period should align with that of the main applicant. Further consideration is needed to account for when children turn 18 during their journey to settlement. For instance, it would be unjustified to immediately expect them to be subject to the income criteria in the earned settlement framework, not least because the mandatory requirement for earnings above £12,570 for 3-5 years would be inappropriate for the first few years of their adult life.

27. Second, there should be exemptions for individuals who apply for a change of conditions to access public funds due to a child becoming destitute (or other reasons relating to a child’s welfare). On the face of it, the earned settlement policy will penalise parents/carers on eligible routes who apply for a change of condition to lift their NRPF status, on account of their child’s wellbeing. Individuals who subsequently make use of public funds could wait up to an extra 5-10 years for settlement. There is a risk that parents/carers will be deterred from making change of conditions applications due to these penalties (one such case was recently reported).[14] In order to prevent an increase in child poverty, an exception to the benefits rule should be made for parents/carers with children who are on immigration routes which are eligible for a change of conditions application (ie family or private life routes).

28. Third, there should be exemptions from additional penalties for people sponsored for adult social care worker roles who lost their status due to unethical practices on the part of their employer. Many adult social care workers on the Health and Care visa have become ‘displaced’ because their employer’s sponsor licence has been revoked. Significant numbers have faced exploitation and abuse. It would be unjust to penalise these care workers for overstaying their visa – potentially resulting in a 35 year wait for ILR – because they lost their status through no fault of their own.

29. This document comprises our initial assessment of the earned settlement policy. We will produce further analysis ahead of the closing date of the consultation in February 2026.