Written evidence submitted by Southall Black Sisters and Latin American Women’s Rights Service (RTS5786)

Introduction

1. Southall Black Sisters (SBS) and the Latin American Women’s Rights Service (LAWRS) welcome the opportunity to submit evidence to the Home Affairs Committee’s Inquiry on Routes to Settlement.

2. As specialist by and for organisations working at the frontline of violence against women and girls (VAWG), modern slavery, immigration advocacy, and racial justice, we support thousands of Black, minoritised and migrant women each year, including those facing domestic abuse, gender-based violence, labour exploitation, trafficking, and extreme poverty.

3. Drawing on extensive frontline experience, casework evidence, and decades of policy engagement, this submission outlines our grave concerns about the May 2025 Immigration White Paper (Immigration White Paper hereon) and subsequent changes to the immigration rules outlined in the Earned Settlement Proposals[1]. We highlight the disproportionate harm these proposals pose to Black, minoritised and migrant victim-survivors, particularly those with insecure immigration status[2] and subject to the No Recourse to Public Funds (NRPF) condition, and those dependent on abusive partners or exploitative employers.

4. We also set out recommendations for a rights-based, safety-focused and humane settlement framework that meets the UK’s equality, safeguarding and human rights obligations.

About Southall Black Sisters

5. Southall Black Sisters (SBS), founded in 1979, is a pioneering Black feminist organisation dedicated to empowering Black, minoritised and migrant women and girls, particularly those fleeing VAWG.

6. For over four decades, SBS has been a trailblazer in advocating for the rights and safety of some of society’s most marginalised women and girls, addressing barriers rooted in racism, sexism, and socio-economic inequalities. SBS’s mission is dismantling the structural injustices which harm Black, minoritised and migrant women and girls while fostering global solidarity to build a future rooted in equity, justice, and empowerment.

7. Renowned nationally and internationally, SBS provides holistic support by combining crisis intervention services, advocacy, and counselling, with long-term campaigning and strategic policy work. Grounded in frontline experience, we challenge structural inequalities and harmful cultural practices that perpetuate VAWG. Our services respond to the complex and intersecting needs of Black, minoritised and migrant women, addressing domestic abuse, forced marriage, honour-based abuse, and transnational marriage abandonment-often compounded by insecure immigration status, homelessness, and mental health challenges.

8. Our leadership across London and the UK has driven systemic change and delivered life-saving support to countless women. Each year, SBS responds to over 5,000 cases and enquiries. In 2023-2024 alone, we handled 5,472 helpline calls and supported 706 individual cases, 60% of which involved victim-survivors with NRPF. Our Investing in Safety model demonstrates that specialist by and for support saves the state over £18,000 per woman over 3 years, through reduced use of emergency, health, social care, housing and criminal justice services[3]. This evidences both the economic and social value of our work. 

9. SBS’s frontline work has driven key reforms across immigration, civil and criminal law. Our advocacy led to the reform and eventual abolition of the criminal law on provocation through the landmark Kiranjit Ahluwalia campaign and contributed to the introduction of the Forced Marriage (Civil) Protection Act 2007. We also successfully campaigned for the introduction of the Domestic Violence Indefinite Leave to Remain (DVILR) rule and the Sojourner pilot project, which later evolved into the Destitute Domestic Violence Concession (DDVC), now known as the Migrant Victims of Domestic Abuse Concession (MVDAC).

10. Together, the DVILR-MVDAC model provides eligible migrant victim-survivors with temporary access to public funds while they apply to regularise their immigration status in the UK as victim-survivors of domestic abuse. SBS also fought to end the one-year probationary period for those on spousal/partner visas, which directly endangered women’s lives, and in 2010 we launched a legal challenge against attempts to revoke legal aid for women with NRPF. For further information, please visit our website: https://southallblacksisters.org.uk/

About Latin American Women’s Rights Service (LAWRS)

11. LAWRS is a human rights, feminist organisation run by and for Latin American migrant women living in the UK. We support women who are exposed to violations of their fundamental human rights, including VAWG, exploitation in low-paid sectors, trafficking, and/or enduring severe poverty and deprivation.

12. We also advocate for women’s rights, migrants’ and ethnic minorities’ rights at local, national and European Union (EU) levels, working with sister organisations in the women, anti-trafficking, immigration and racial justice sectors, to challenge the multiple layers of discrimination faced by Latin American women. Between 2023 and 2025, LAWRS provided services to 2,731 Latin American women, of which 45.2% had insecure immigration status.

13. Between 2024 and 2025, the VAWG team at LAWRS supported 78 women with limited leave to enter or remain - 40 in 2024 and 38 in 2025. Financial abuse was disclosed in the majority of cases (70.5%), and nearly half of the women (48.7%) were subject to the NRPF condition. A smaller proportion required immigration-related support: 15.4% were assisted to apply for settlement under the domestic violence rules, (DVILR or EUSS Retained Rights), and 19.2% were supported to lift their NRPF condition via MVDAC or a Change of Conditions application. Together, these interventions accounted for 39.5% of service-users who had both limited leave to remain and NRPF.

14. During the same period, LAWRS supported 62 undocumented women (33 in 2024 and 29 in 2025), including those recorded as overstayers, those never granted leave, and those on immigration bail. Financial abuse was again highly prevalent (67.7%), alongside widespread immigration abuse (61.3%). Additionally, 11.3% disclosed experiences of exploitation, including sexual exploitation, labour exploitation, and domestic servitude. For further information, please visit our website: www.lawrs.org.uk

15. End Violence Against Women Coalition, Hibiscus, LAWRS and the Step up Migrant Women Coalition, and SBS released a joint statement outlining major concerns about the May 2025 Immigration White Paper and its disproportionate impact on Black, minoritised and migrant victim-survivors[4]. In October 2025, these organisations held a demonstration outside the Home Office calling for the Immigration White Paper to be scrapped.

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? 

16. Evidence from our frontline support provision demonstrates that the current and proposed pathways to immigration and settlement in the UK as outlined in the Immigration White Paper and in the changes announced ever since, create significant instability, uncertainty and harm for migrants, particularly women, single mothers, and victim-survivors of domestic abuse and gender-based violence.

17. Evidence from our frontline work also shows that it is extremely hard to escape abuse, live an autonomous life and plan for a stable future, within a constantly shifting and increasingly hostile immigration system. The proposed earned settlement framework, which replaces automatic five-year routes with a baseline 10-year qualifying period for Indefinite Leave to Remain (ILR), with even longer routes for many migrants, creates prolonged insecurity. For migrant women, particularly those experiencing domestic abuse, gender-based violence, and exploitation, this extended uncertainty translates into chronic anxiety, poverty and a heightened risk of destitution and homelessness. 

18. These proposals do not operate in isolation; they directly intersect with patterns of abuse and exploitation. By moving to a 10-year baseline for ILR, introducing  high income and “contribution” requirements, increasing the qualifying period for anyone who has ever been criminalised, accessed public funds or incurred debt, and substantially raising salary thresholds, the Immigration White Paper and Earned Settlement Proposals significantly increase the risks faced by victim-survivors, undocumented women and those dependent on partners’ visas (such as dependents of Skilled Worker holders) or tied to exploitative employers or landlords. These rules prolong women’s dependence on perpetrators and sponsors, effectively trapping victim-survivors in abusive relationships and exploitative work environments and leaving them unable to achieve independence or access basic protections such as healthcare, a stable income, benefits and safe housing. 

19. The dependency created by the UK’s extremely complex and expensive immigration system, combined with long waits to secure independent immigration status, actively enable perpetrators to exert immigration abuse. Women experiencing financial abuse or subject to the NRPF condition lack the financial independence needed to renew their visas and avoid becoming undocumented, forcing them to rely on abusers for their survival. The growing complexity and cost of the immigration system drives new forms of abuse alongside existing ones; for example, SBS’s service-users report perpetrators demanding immigration fees as part of dowry-related abuse.

20. Our frontline experience further shows that service-users with insecure immigration status and NRPF are frequently tied to unsafe, exploitative and discriminatory work arrangements. Dependence on employers and perpetrators for visa renewal prevents women from leaving abusive or harmful environments. For example, one SBS service-user, a victim-survivor of domestic abuse on a Skilled Worker dependent visa was subjected to racism and exploitation at work but could not leave for three years because her visa was tied to her sponsor and she was barred from accessing public funds. The restrictive visa rules and the NRPF condition left her trapped in dangerous, degrading and precarious conditions. 

21. Many migrants come to the UK seeking safety, stability and the chance to rebuild their lives.      The current five-year settlement route already presents severe barriers to safety, particularly when compounded by high visa fees, the lack of legal aid, limited refuge spaces and the NRPF condition. Extending this route to ten years and even longer for many migrants under the proposed framework will deepen these barriers. Prolonged uncertainty exposes women to greater risks, entrenches financial precarity and denies them the basic protections essential for escaping abuse. Instead of safeguarding migrant women, the proposed framework increases the likelihood of poverty, dependence and vulnerability to exploitation.

22. The system ultimately fails to uphold even the most fundamental human rights: the right to safety, security, family life and freedom from degrading treatment. Rather than enabling women to rebuild their lives, the extended settlement framework institutionalises instability, making long-term safety, autonomy and recovery almost impossible.

23. Ongoing uncertainty, rapid policy shifts and increasingly complex immigration requirements also make it extremely difficult for frontline organisations including specialist by and for services such as SBS and LAWRS, to recruit and retain skilled staff. Many of our specialist staff come from the very communities we support, bringing essential cultural, linguistic and lived experience-based knowledge and expertise. Restrictive visa rules, increased income thresholds and prolonged settlement rules directly threaten their ability to remain in post, undermining workforce stability and the continuity and quality of our specialised advocacy, negatively affect our communities as they will have fewer options for life-saving support. (See points 25-37 for more details)

24. Taken together, restrictive and prolonged pathways to settlement including doubling the qualifying period for ILR, increasing thresholds, and adding new barriers will not only harm individual migrants and migrant victim-survivors but will also jeopardize the sustainability of frontline services. By denying stable, secure and humane routes to settlement, current and proposed policies deepen precarity faced by migrant communities and reinforce harmful narratives that scapegoat migrants for wider social and economic issues. These measures entrench insecurity, increase vulnerability to abuse, and weaken the support systems that victim-survivors depend on.

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

25. Research from the Domestic Abuse Commissioner shows that 67% of Black and minoritised victim-survivors prefer by and for[5] specialist services. As by and for organisations led, governed and staffed by Black, minoritised and migrant women, we rely on a specialist workforce drawn from the very communities we serve. Our staff bring a specialised understanding of the cultural and linguistic aspects of our service-users’ lives and an inherent lived-experience based understanding of the immigration and asylum systems that cannot be replicated through generic recruitment, and which is essential for building trust with women facing multiple layers of marginalisation. As stated above, more than 60% of SBS’s service-users have insecure immigration status and are subject to the NRPF condition, meaning culturally competent advocacy rooted in lived experience is essential to their safety, protection and long-term recovery.

26. SBS is widely regarded as a sector leader in supporting victim-survivors with NRPF and Honour-Based Abuse (HBA). We provide training to the Police, Home Office and statutory agencies, operate a national helpline, and receive referrals from across the UK because of our specialist expertise. This expertise is grounded in lived-experience: many of our staff are themselves navigating or have navigated the UK’s exceedingly complex immigration and asylum systems, giving them insight into the barriers, fears and vulnerabilities faced by migrant women—insight that is critical to effective safeguarding and support.

27. The proposed extension of qualifying periods for settlement, combined with the increase in the minimum salary threshold to £41,700 per annum, will disproportionately affect sectors such as by and for services, the VAWG sector, social care and the wider charity sector. These sectors already operate under chronic funding constraints yet rely on highly skilled, trauma-informed and culturally competent staff.  Raising salary thresholds beyond sector norms effectively excludes migrant women from these roles and undermines the sustainability and quality of specialist services.
     
28. These impacts are compounded by the proposals to tie the qualifying period for ILR to income levels. Under the earned settlement framework, any professional earning below £50,270 would face a 10-year route to secure status. This threshold is far above both the national median salary and the realities of the charity, by and for and VAWG sectors, where pay scales reflect chronic underfunding rather than skill or societal value. As a result, migrant frontline staff —whose cultural fluency, linguistic skills and lived experience are essential to supporting victim-survivors— would be pushed to leave the sector in search of higher-paid work simply to meet immigration requirements. For organisations like SBS and LAWRS, who cannot offer salaries near this level, these rules risk deepening the existing recruitment and retention crisis and destabilising the specialist, trusted services that victim-survivors rely on for safety and recovery.

29. At SBS, 17% of our staff are currently on Skilled Worker visas that we sponsor. These roles form the backbone of our specialist, frontline services, delivering life-saving support to Black, minoritised and migrant women facing violence, destitution and immigration insecurity. Higher salary thresholds and prolonged settlement routes will severely restrict our ability to recruit and retain this specialist workforce. As one SBS staff member noted: 

30. “For the work we do as a by and for organisation in the VAWG sector, it is essential that our frontline workers share similar backgrounds and lived experiences with the women they support. This connection fosters trust, understanding, hope and ensures that victims-survivors can see themselves reflected in those working alongside them. However, under the current rules, it is simply impossible for us to offer an advocate a salary of £41,700.”

31. Under the new and proposed immigration rules, our ability to maintain a specialist workforce is under serious threat. As one manager at SBS explained:  

"Recruitment has become more challenging because, whereas we previously had access to a wider community of candidates, we are now limited by the salary levels we can offer. Because visa sponsorship can only be considered for certain pay scales, we will be missing out on brilliant women from Black, minoritised and migrant backgrounds, the very people our organisation is here to represent and support." 

32. The proposed minimum salary threshold of £41,700 to sponsor a Skilled Worker Visa, and £50,270 baseline salary to qualify for ILR in 5 years bears no relation to actual pay structures within the VAWG charity sector[6], where roles across frontline advocacy, casework and support work fall significantly below this level. Even managerial roles rarely reach the required threshold. As a result, nearly all frontline roles in the VAWG sector would be rendered ineligible for sponsorship, effectively excluding migrant women from the workforce and undermining the sector’s ability to meet the needs of its communities. Please see a breakdown of average salaries below:

33. The consequences for by and for organisations are especially severe. Specialist advocacy cannot be delivered by a generic workforce: it depends on cultural fluency, lived experience of immigration systems, linguistic skills and a deep understanding of structural inequalities. There is no alternative labour pool capable of providing the same level of expertise. Yet under the new salary rules, almost every frontline and specialist role in the VAWG sector falls below the sponsorship threshold, despite being highly skilled and essential to safeguarding migrant women. This makes it impossible for organisations like SBS and LAWRS to sponsor skilled migrant women for these essential roles, directly undermining the availability of culturally competent, trauma-informed support. In practice the policy will drain the sector of the very staff who are most qualified to support migrant victim-survivors, weakening provision nationwide.

34. The immigration rule changes were announced on 1st July 2025 with just three weeks’ notice.  This abrupt timeframe created significant operational strain for small organisations like ours, forcing immediate reviews of staffing, budgeting, sponsorship eligibility and compliance processes. For charities operating on short-term grants and limited funding streams, the sudden administrative and financial burden diverted essential time and resources away from frontline support. 

35. The increased risks associated with sponsoring Skilled Worker visas fall especially heavily on charities like ours. Sponsorship obligations require extensive reporting, monitoring and compliance processes, and any inadvertent errors, including those arising from sudden changes to rules risk fines, license suspension and the sudden loss of staff. Unlike larger employers, small charities do not often have in-house legal or HR teams to absorb these pressures, leaving them disproportionately exposed.

36. Longer qualifying periods for settlement also increase costs for both employers and migrant workers. Visa renewals, including application fees, legal advice and the Immigration Health Surcharge cost from around £9,900 to approximately £16,900 for a single worker without dependents. This places financial strain on both employers and employees. In sectors such as social care, education, and VAWG advocacy, where salaries fall below the new minimum threshold,[8] these repeated costs deepen precarity and undermine workforce stability.

37. Taken together, these rule changes risk creating a charity and care sector that is less diverse, less representative, and significantly less capable of delivering high-quality, life-saving services. Migrant expertise, cultural competence and lived experience are essential to supporting marginalised communities; removing pathways for these workers weakens the entire safeguarding infrastructure.

38. In conclusion, the Immigration White Paper and proposed Earned Settlement proposals will systematically exclude the professionals best equipped to work with and support victim-survivors of abuse and gender-based violence. By limiting their ability to work and remain in the UK, the Government is dismantling an essential layer of protection for migrant women and undermining the capacity of frontline specialist services.

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

39. Ultimately, longer routes to settlement will increase and prolong migrant women’s experiences of precarity and instability. Research consistently shows that without secure legal status; social and economic integration becomes significantly harder.[9]  Even the government acknowledged in its Immigration White Paper that “settlement is (…) an important step in integrating” into the UK. Making settlement harder to obtain therefore risks undermining the very policy goals the Government claims to pursue, namely stability, safety and integration, while placing migrant women and their children at heightened risk of harm, insecurity and exclusion.

40. Some of the general impacts of longer routes and stricter requirements for settlement on migrant victim-survivors and their households already in the UK include:

1. Increased precarity for migrant victim-survivors and their children.
2. Prolonged dependence on perpetrators, increasing exposure to harm and abuse.
3. Increased risk of falling into destitution and/or becoming undocumented as immigration rules become more complex and welfare safety nets become increasingly difficult to access.
4. Increased vulnerability to labour exploitation.
5. Increased strain on local authorities and charities as more migrant victim-survivors become destitute and homeless.

41. The stated aim of reducing public expenditure may therefore be a false economy, as more women rely on emergency support and crisis payments. 

1. the financial and economic impact, including access to benefits

42. Being subjected to prolonged insecurity and the financial burdens created by longer and more restrictive settlement routes have a severe economic impact on migrant victim-survivors and their households. Doubling the qualifying time-periods for settlement and tightening eligibility requirements deepen poverty, increase financial dependence, and significantly limit women’s ability to rebuild their lives after abuse.

43. Longer and more restrictive routes to settlement entrench financial insecurity and prolong dependence on abusive partners or exploitative employers. Women make up the vast majority of immigrants (68%) who rely on another person for their right to live and work in the UK.[10] For women with NRPF, there is often no option but to remain tied to their partners or employers, effectively trapping them in cycles of control and coercion.

44. In households where the perpetrator has access to public funds and the victim-survivor does not, the NRPF condition creates an extreme imbalance of power. Perpetrators frequently weaponise their entitlement to benefits or childcare support as tools of coercive control.

45. The high rates of financial abuse among victim-survivors with insecure immigration status demonstrate the level of economic precarity they face. Many have no financial safety net to flee, forcing them into impossible choices—incurring significant debt to survive, falling into destitution or homelessness, or remaining with their abuser. SBS and LAWRS repeatedly see women return to perpetrators because they have become destitute or street homeless, placing them at significant risk of fatal harm.

46. Government support and protection for victim-survivors of domestic abuse and gender-based violence does not extend to women on temporary routes such as Skilled Workers visa, Graduate visas, Student visas, Health and Care Worker visas, or to those who are undocumented. As a result, most migrant women with insecure status are excluded from accessing welfare support, emergency accommodation, crisis payments and long-term support. The UK-wide Support for Migrant Victims (SMV) fund remains the only national mechanism available, providing up to 12 weeks of rent and subsistence support.  However, it is capped at just 475 women per year[11] and cannot meet demand —which the Domestic Abuse Commissioner estimates to be at least 32,000 victim-survivors. The fund is also only guaranteed until March 2026, with no clarity on renewal or extension. At a time when more women will require help due to prolonged and increasingly stringent settlement routes, as well as extended periods under NRPF, this limited provision leaves thousands without any access to safety or subsistence support.

47. The cost of visa renewals, including application fees, legal advice and the Immigration Health Surcharge, places an unbearable financial burden on migrant households. For victim-survivors of domestic violence, abuse and exploitation, these high costs directly prevent women from fleeing or rebuilding their lives. Many of the women we support face impossible choices between buying food, paying their rent or meeting visa costs[12]. Extended periods under NRPF further block access to benefits, trauma-informed support and basic healthcare.

Case study: Catalina

48. Catalina*[13] is a LAWRS service-user. She was granted pre-settled status under the EUSS as the spouse of a settled person, giving her limited leave to remain in the UK. She fled severe domestic abuse including non-fatal strangulation and threats to her life. Left homeless and with NRPF, she became destitute. Her former partner repeatedly weaponised his access to benefits, telling her she had “no rights” and withholding money for their child unless she complied with his demands.

49. Every time Catalina gained employment, her ex-partner would stop working to trigger the loss of childcare support, causing her to lose multiple jobs and fall back into destitution. Despite the statutory duty under Section 17 of the Children Act 1989 to support children in need regardless of their parents’ immigration status, a social worker threatened to remove Catalina’s child on the basis of her NRPF status. This not only reflects a serious misunderstanding of legal duties, but also demonstrates how migrant women with insecure immigration status face discriminatory decision-making and punitive responses from safeguarding professionals, further eroding trust in public services.

50. Following the Immigration White Paper, the Health and Care Worker visa route to new overseas recruits in the adult social care sector was closed. This will disproportionately impact Black, minoritised and migrant women who make up a significant proportion of the social care workforce[14] and are already concentrated in highly demanding, low-paid, insecure roles. The precarious position of migrant women in these roles is illustrated by the experience of an SBS service-user.

Case study: SBS service-user

51. She arrived in the UK on a care worker visa, after being promised employment in a care home; however, no work was provided on arrival. Having fled domestic abuse from her husband and in-laws in India, she needed to secure an income but was restricted to 20 hours’ work a week under her visa conditions. Despite actively seeking full-time employment, she was unable to secure it, leaving her financially insecure and highly vulnerable to further abuse and exploitation. Furthermore, she was also approached by prospective employers who illegally demanded up to £30,000 in exchange for sponsorship, which demonstrates how current and proposed policies embolden exploiters and increase risks for migrant victims-survivors.

52. Faced with these restrictions, she was pushed into an impossible choice: take unsafe informal work paid cash-in-hand, risking loss of her immigration status and further abuse, or survive on 20 hours of permitted employment, which did not cover her basic needs. She chose the latter and as a result, she now struggles to meet her basic living costs, including rent, which is often paid cash in hand, putting her at a higher risk of exploitation by her landlord.

53. Attempts to re-match her to another care home have been delayed for eight months, trapping her in extreme poverty while she remains unable to return to her country due to threats from her abuser. Low sector salaries also fall well below thresholds proposed in the Immigration White Paper, meaning she, and many in similar roles, would never meet the income required to progress towards settlement. This creates a cycle where migrants are pushed towards poverty, exploitation, destitution and loss of status.

54. These experiences are not isolated. Many SBS and LAWRS service-users on temporary or tied visas face similarly severe consequences. One SBS service-user was unable to access NHS care during a high-risk pregnancy due to unaffordable upfront charges. Her repeated requests for treatment were denied, and she later miscarried. This demonstrates how NRPF restrictions, discrimination, and financial barriers directly endanger women’s health and lives.

55. No consideration has been given to the financial impact of these policies on migrant households during a cost-of-living crisis. This is particularly alarming given the well-established link between NRPF, destitution and child poverty, disproportionately affecting migrants and racially minoritised households.

56. Frontline workers report that the combination of visa restrictions, high renewal costs, longer and more restrictive settlement routes and lack of welfare support pushes migrant women into deep poverty. Many are left with no realistic way to sustain themselves, secure safe housing, or achieve economic independence. These pressures fall most heavily on households headed by Black, minoritised and migrant women, who already face structural inequalities in the labour market.

57. The Earned Settlement proposals treat prior debt, access to public funds and criminalisation as markers of reduced “deservingness”, increasing an applicant’s qualifying period for ILR. This is deeply concerning for victim-survivors whose debt, criminal records and reliance on public funds are often direct consequences of coercive control, financial abuse and structural inequalities. Penalising these experiences, rather than recognising them as evidence of harm, represents a profound erosion of migrant women’s ability to seek safety and stability. Under the proposal:
1. Use of public funds for less than 12 months increases the qualifying period by 5 years.
2. Use of public funds for more than 12 months increases it by 10 years. 
3. Overstaying, entering as a visitor or irregular entry may add up to 20 years.

These measures disproportionately punish Black, minoritised and migrant victim-survivors who face poverty, coercion, domestic abuse, exploitation and structural barriers that limit lawful routes to safety.

58. The Earned Settlement Proposals introduce a ‘Time Adjustment Model’, where settlement timeframes are extended or reduced depending on income, compliance, occupation, English language, integration and access to public funds. This creates a system that rewards high-earning, stable migrants while penalising those in situations of economic insecurity or abuse.

Reductions are offered for:

1. High earnings (£50,270 - £125,140)
2. Employment in public service occupations (RQF 6+)
3. Volunteering or community work

These reductions are largely inaccessible to low-paid, part-time or precarious workers, especially Black, minoritised and migrant women in feminised essential sectors, or those navigating domestic abuse and exploitation. As a result, the model structurally excludes the very women most in need of secure settlement routes.

59. The Earned Settlement proposals fail to clarify whether vital protections for migrant victim-survivors will continue. There is no indication of how the MVDAC which provides up to 12 weeks of access to public funds for victim-survivors with NRPF will interact with new penalties for “immigration breaches” or use of public funds. It is also unclear whether domestic abuse victim-survivors will be exempt from retrospective punitive increases to the qualifying period for settlement. This uncertainty places migrant victim-survivors, particularly Black and minoritised women, in life-threatening precarity, and undermines by and for services across the VAWG sector, who cannot guarantee safety or secure pathways for service-users under the proposed changes.

60. The Earned Settlement Proposals also suggest extending the NRPF condition even to those with settled status, shifting access to public funds to citizenship rather than ILR. This would overturn long-standing principles that settlement confers security and stability. Removing access to public funds to those with ILR would dramatically increase destitution, hardship and exploitation among migrant women and contradict the stated goals of integration and community cohesion.

61. Far from “reduce[ing] pressure on public services”[15], extending the qualifying period for settlement and delaying access to public funds will increase demand on local authorities, homelessness services and specialist charities. Women will be forced into crises, requiring emergency accommodation, subsistence support, safeguarding intervention or NHS care, before they qualify for any state assistance, causing significant and long-term harm to women and children.

62. When women are forced to choose between safety and status, between abuse and deportation, the system becomes complicit in sustaining violence. These policies not only deny victim-survivors access to protection but also legitimise and reproduce the very conditions that trap women in abusive relationships or exploitative work. The fear of losing immigration status, coupled with financial hardship, cultural isolation and systemic exclusion, leaves many Black, minoritised and migrant women unable to escape and/or seek help. In practice, the UK’s current and proposed immigration frameworks are not only gender-blind but also violence-enabling, reinforcing the structures of dependency and control they claim to dismantle.

ii. the personal and social impact. 

63. The personal and social consequences of extended settlement routes are profound. They affect every aspect of migrant victim-survivors’ and their children’s lives, deepening fear, instability and dependence while undermining their physical safety, mental wellbeing and ability to integrate into society.

64. Black, minoritised and migrant women are disproportionately affected. Visa dependency and the NRPF condition trap women in unsafe relationships and exacerbate exposure to violence. Studies show that women with insecure immigration status are three times more likely to experience VAWG[16]. The proposed changes will intensify these risks by prolonging the period during which migrant women remain dependant on partners, employers and sponsor for their status and livelihood.

65. Many of the women with insecure immigration status that we support disclose that the process of visa renewal process often triggers an escalation of abuse. The high costs of visa applications are routinely weaponised by perpetrators as a form of coercive control, with many victim-survivors reporting debt bondage and financial dependence when perpetrators pay visa fees.

66. The Earned Settlement proposals also treat any breach of immigration rules — such as overstaying, illegal entry — as a deliberate act that increases the qualifying period ILR by up to 20 years. This approach entirely overlooks the reality of coercive control, immigration sabotage by abusive partners and exploiters, and the systemic barriers that prevent victim-survivors from securing timely legal advice. As a result, the proposals would disproportionately punish Black, minoritised and migrant victim-survivors whose insecure status is often a direct outcome of abuse, pushing them into even deeper precarity and danger. 

67. Existing protections for migrant victim-survivors-such as the DVILR and the MVDAC are lifesaving but extremely limited, applying only to a narrow cohort of women. Even for those who qualify, accessing these entitlements is often exceptionally difficult due to complex processes, limited awareness of rights, the civil legal aid crisis, and the absence of specialist by and for support organisations. The Earned Settlement proposals bring into question the longevity of this model and would further increase complexity and insecurity within the system. Without clear guarantees that protections like the DVILR-MVDAC pathway will be preserved and expanded, more victim-survivors risk being locked out of the very mechanisms intended to safeguard them, leaving them without routes to life-saving support.

Case study: Leonor*

68. Leonor[17], a LAWRS service-user from Latin America, came to the UK on a spousal visa and is subject to NRPF. She experienced physical, emotional and financial abuse. Her husband repeatedly threatened to revoke her dependent visa if she reported him to the police and sought protection. Visa costs were also a trigger for physical violence.

69. After fleeing the abuse, Leonor was advised by a private solicitor to apply for the MVDAC. She applied successfully but was given no information about her options for settlement. Her MVDAC expires in three months, yet she cannot afford the private solicitor fees to lodge her DVILR application. She is ineligible for legal aid because her income slightly exceeds the threshold, despite being £5000 in debt. 

70. LAWRS secured a solicitor willing to support her on a payment plan. However, even with temporary access to Universal Credit through the MVDAC, legal fee instalments left Leonor unable to afford essentials and LAWRS had to provide emergency food vouchers. Her experience shows how temporary concessions provide short-term safety but fail to dismantle the structural barriers that prevent long-term security.
71. Service-users on the MVDAC report significant distress and uncertainty as the 3-month cliff-edge approaches. The concession provides only temporary leave and access to public funds, and only a very small cohort of women, specifically those on spousal/partner visas, can progress to settlement through the DVILR route. The vast majority of migrant victim-survivors have no equivalent pathway. If women are unable to access specialist immigration advice, gather evidence or afford application fees within the three-month period, they reach the end of the concession with no viable immigration application to submit and therefore fall out of status, becoming undocumented. This leaves them at immediate risk of becoming homeless or forced back to perpetrators for survival.

72. Beyond the immediate pressures of the MVDAC cliff-edge, women with insecure immigration status face wider structural barriers to securing immigration representation. Many fall into a “legal aid gap”: they earn too much to qualify for legal aid but cannot afford private representation. As a result, women are forced to choose between destitution, paying legal fees instead of food or rent, or remaining with perpetrators until they become eligible for settlement, all of which place them and their children at significant risk of further abuse, exploitation and harm.

73. Similarly, of LAWRS’ service-users with limited leave to remain and the NRPF condition, only 39.5% could apply to lift their NRPF condition in 2024-25 (through either the MVDAC or Change of Conditions application). Many of the women who could not apply were ineligible for the MVDAC based on their visa but not yet destitute enough to meet the Change of Conditions threshold. As a result, they were caught in limbo: unable to afford to flee, unable to access a financial lifeline, and unable to progress their immigration route without first experiencing destitution.

74. Delays in responses to settlement and visa applications further trap women in dangerous situations. While waiting for decisions that determine their ability to access public funds or secure lawful status, many are unable to flee abuse, secure safe housing, or meet basic needs. This prolonged instability creates significant distress and prevents victim-survivors from rebuilding safe and independent lives.

75. These harms are also experienced by migrant frontline workers within SBS who themselves are navigating insecure immigration routes. One recently sponsored employee on a Skilled Worker visa reported that the new salary thresholds exceed what can be met within existing organisational pay scales, and that rules are changing so rapidly that long-term planning feels impossible. Even where staff currently meet the threshold, constantly shifting requirements and compliance obligations create a persistent sense of precarity.

76. Questions such as "Will I be able to build a future here?" illustrate the daily anxiety, fear and precarity faced by migrant women with lived experience who work in frontline services. This ongoing sense of being “othered” undermines their sense of belonging and stability in the UK, even as they provide essential, life-saving support to victim-survivors of abuse.

77. Despite the scale of these harms, there has been no meaningful consideration of the impact of these changes on migrant households in general, or on migrant victim-survivors of VAWG and exploitation in particular. The House of Lords Secondary Legislation Scrutiny Committee has repeatedly criticised the Home Office for introducing major immigration changes without consultation, without adequate evidence, and without properly assessing their consequences for those most affected.[18]

78. By increasing the qualifying period for settlement and making immigration rules more complex and punitive, the Government will significantly increase both the financial and personal burdens on migrant women. These policies heighten dependency, delay access to protection, exacerbate the risk of abuse and exploitation, and undermine women’s ability to secure long-term safety, stability and integration in the UK.

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

79. The UK’s integration landscape cannot be separated from the wider climate of anti-immigrant rhetoric, racism, and rising far-right mobilisation. In recent years, xenophobic narratives have increasingly shaped political discourse and public attitudes, culminating in violent attacks against asylum accommodation and racially minoritised communities since August 2024 and henceforth. In this context, restrictive changes to settlement eligibility further legitimise exclusionary attitudes and deepen divisions, reinforcing the message that migrants do not belong.

80. The hostile immigration system and the settlement proposals outlined in the Immigration White Paper and Earned Settlement Proposals exacerbate existing social and economic inequalities. Migrant single mothers who are victim-survivors of domestic abuse, and those subject to NRPF, are particularly vulnerable, as prolonged settlement routes increase the risk of poverty, homelessness and pressure to leave the UK. By privileging high-earning migrants and excluding low-paid workers, dependents and victim-survivors, the proposed settlement framework limits opportunities for integration undermining both individual wellbeing and social cohesion.

81. Discussions about integration often focus narrowly on race and religion, overlooking the central role of class inequality and its intersections with race and gender in shaping belonging and participation. The proposed settlement rules intensify class-based exclusion, while failing to address the socio-economic investment needed to support genuine community cohesion.

82. Our frontline data shows that poverty, immigration insecurity and restricted access to public funds or healthcare significantly undermine migrant victim-survivors’ ability to integrate. Single mothers who are victim-survivors of domestic abuse and violence, already face deep financial hardship and isolation, and extended settlement routes will worsen these challenges by prolonging instability and preventing access to the foundations needed for integration.

83. The Earned Settlement proposals assume that all migrants have equal access to stable, well-paid work, English language learning opportunities, high-quality legal advice and safe, violence-free living conditions. In reality, Black, minoritised and migrant women face systemic labour-market exclusion, structural racism, gendered inequality, immigration barriers and high rates of abuse and exploitation. These intersecting disadvantages mean they are the least able to "earn" settlement under the proposed model. Instead of supporting integration, the Earned Settlement proposals risk punishing women for circumstances shaped by inequality, coercion and structural discrimination.

84. Many SBS service-users cannot afford even basic participation in community or social life, such as travelling across London, due to the high cost of living, transport costs and precarious work.  Limited income and insecure status prevent women from building relationships, participating in civic spaces, or accessing opportunities that support integration and belonging.

85. Black, minoritised and migrant women working in low-paid sectors such as cleaning, healthcare, social care, and domestic work, face intensive and demanding workloads, low wages, and the additional burden of paying the Immigration Health Surcharge on top of tax contributions.[19] These pressures leave little capacity for social participation, volunteering or community engagement. The proposed settlement changes risk further trapping migrant women in cycles of overwork, economic precarity and immigration insecurity conditions fundamentally incompatible with meaningful integration.

86. The newly proposed increase in salary thresholds and the extension of settlement routes entrench a system that penalises low-wage, frontline and feminised labour while rewarding higher earners. By linking settlement eligibility to economic worth, the proposed ‘earned settlement’ framework reinforces classed, racialised, and gendered inequalities. It positions low-paid migrant workers, women and victim-survivors as less deserving of belonging, thus marginalising and rendering them invisible.

87. This rhetoric ties belonging to narrow frames of economic contribution, fostering exclusion rather than integration. It implies that those in undervalued or feminised roles, roles disproportionately performed by migrant women, are of lesser societal value. This deeply racialised and gendered framework tells migrant women and people of colour that they must earn their right to belong, while simultaneously denying them the structural means to do so.

What evidence is there from other countries on the above issues? 

88. International evidence demonstrates that countries with more human rights-centred immigration and settlement policies achieve better integration, stronger economic outcomes and higher public support for migration. By contrast, restrictive and punitive systems with prolonged and precarious routes to settlement, such as those proposed in the Immigration White Paper and the Earned Settlement proposals, are associated with greater precarity, exploitation and social division.

89. These examples underline the importance of a human rights-based approach to immigration, built on the recognition of the inalienable rights of all individuals, regardless of immigration status. Such an approach enshrines safeguards and protection for migrants, acknowledges the harm and vulnerability caused by punitive and hostile systems, particularly to migrant victim-survivors of abuse, and extends rights and security to all those currently deprived of them.

90. Canada offers a strong example of more holistic good practice. Its immigration framework[20] facilitates the transition from temporary to permanent residence and ultimately to citizenship.[21] It supports family reunification, and is complemented by government-funded settlement services, including targeted programmes such as the Racialized Newcomer Women Pilot, which provides racialised newcomer women with mentorship, work placements and women-only employment counselling[22] to improve labour market access and progression. These measures are integral to Canada's immigration strategy and enable newcomers, especially racialised women, to integrate economically and socially while fostering a sense of belonging.

91. Evidence from Canada also illustrates the benefits of accessible settlement and integration pathways. Canada’s immigration framework facilitates the transition from temporary visas to permanent residence and citizenship, with clear pathways that support newcomers’ integration into the labour market and society. The Immigration, Refugees and Citizenship Canada’s 2024 - 25 Departmental Plan[23] shows the proportion of newcomers employed increased from 70% in 2020 - 21 to 78% in 2022 - 23, exceeding the target of 65%. Similarly, the percentage of immigrants and refugees reaching the middle-income range or above rose from 56% to 63%, highlighting how accessible settlement and integration pathways directly improve economic outcomes. As Canada’s immigration approach measures integration beyond employment, the results show that 90% of immigrants and refugees report a strong sense of belonging, while volunteer participation remains above 20%, demonstrating active social participation[24].

92. New Zealand has also taken steps to remove barriers to settlement and integration. Recent 2025 reforms[25] removed the median wage threshold for most work visas, reduced the required years of work experience, extended visa lengths, and granted full work rights to migrants on interim visas. These changes explicitly aim to reduce exploitation risks and provide stability for migrant workers transitioning between employers or visa categories. By recognising that rigid salary thresholds and stringent employer-dependence create precarity and vulnerability, New Zealand's model promotes continuity, protection and stronger integration outcomes.

93. On the contrary, the UK's proposed direction, outlined in the Immigration White Paper and the Earned Settlement Proposals, runs directly counter to global best practice. Measures such as extending qualifying periods, raising salary thresholds, restricting rights, and penalising the use of public funds, debt or past criminalisation will trap migrant women in exploitative worker-employer relationships and deepen their vulnerability to underpayment, exploitation, abuse and coercion. These proposals also entrench  gendered and racialised inequalities that place Black, minoritised and migrant women at heightened risk of domestic abuse, gender-based violence and sexual violence.

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: 

social and community contributions; and 

fiscal and economic contributions.

94. We strongly oppose any model that ties migrants’ rights or eligibility for settlement to quantified measures of “contribution”. The premise of “earning” settlement reinforces anti-migrant narratives and embeds racist, classed and gendered hierarchies. For this reason, contribution should not be used as a criterion for accessing settlement at all.

95. Contribution-based models reproduce a harmful and unfair distinction between so-called "high-skilled" and "low-skilled" migrants, privileging those who already benefit from structural advantage while devaluing the labour of those concentrated in feminised, racialised and low-paid sectors. These hierarchies obscure the systemic barriers faced by Black, minoritised and migrant women and legitimise exploitation and exclusion.

96. Our frontline experience shows that it is structural inequality and not a lack of willingness that restrict migrants’ participation in the labour market and civic life. As one frontline SBS worker stated:

"The [White Paper] policy [on salary thresholds] is racist and classist. The Home Office is basically saying that if you want to be a migrant, you have to be a high-earning migrant, with no consideration for women or domestic abuse victim-survivors. It fuels division and hostility.”

97. All individuals, regardless of income or immigration status have inalienable rights to safety, dignity and belonging. Tying these rights to perceived economic worth undermines the UK's human rights obligations and erodes the foundations of equality and social cohesion.

98. Migrants, and in particular migrant women, contribute in countless invisible, frequently unpaid and unmeasured ways: through care work, community resilience, solidarity networks and the everyday labour that sustains families and public services. To attempt to measure these would be practically impossible, and to disregard them within a system that considers contributions as a key part of settlement and integration, would be unfair and discriminatory.

99. Migrant women in low-paid care and domestic and frontline roles are essential to the UK’s social infrastructure, yet they are among the most excluded from settlement opportunities. Women constitute over two-thirds (68%) of all migrants on family and dependant visas and are therefore disproportionately affected by visa dependency. While one in five (20%) migrant women hold work visas, many more contribute through family and student routes, structurally undervalued.

100.                     Many migrant women work in key but low-paid and insecure sectors such as cleaning, domestic work, social care, and hospitality roles that are foundational to the UK’s economy yet chronically undervalued. Migrants make up 16% of the adult social care workforce providing essential labour that sustains hospitals, care homes and community settings. Despite this critical contribution, migrant women’s employment rate is 66% lower than the 72% rate for women born in the UK. This disparity reflects the structural and economic barriers they face, including NRPF restrictions, limited access to free childcare, employer discrimination and precarious working conditions. These barriers drive financial dependency on partners or employers increasing vulnerability to exploitation, coercive control and gender-based violence and abuse.[26]

101.                     These structural inequalities mean that migrant women cannot meet “contribution” thresholds, not because they lack commitment or ability, but because the system is designed to exclude them. Thus, even if the government wishes to understand “long-term contribution”, it must be approached through culturally sensitive, trauma-informed and human rights-based frameworks. Meaningful contribution cannot occur without safety, stability and the structural support that allows people to rebuild their lives. Migrants, refugees and asylum seekers escaping war, persecution, wider oppression or gender-based violence need systems that protect and empower them, not policies that punish vulnerability and perpetuate precarity and insecurity.

102.                     In summary, a settlement system based on “contribution” fundamentally misrepresents how migrants, and particularly women, contribute to the UK. It denies recognition to those who sustain families, communities, and essential public services under exploitative and undervalued conditions, while rewarding only those whose labour is already economically privileged. Such an approach deepens structural inequality and actively undermines integration, belonging and social justice.

What exemptions should there be to the new rules? 

103.                     Community-based frontline organisations, including by and for organisations and specialist charities, must be granted sector-wide exemptions from the new baseline salary thresholds for sponsoring migrant workers. Frontline workers in these sectors should also be exempt from minimum salary thresholds within the Earned Settlement framework. These services provide life-saving specialist support yet operate within chronically under-funded structures that make compliance with elevated salary requirements structurally impossible. Without exemptions, the new thresholds will  destabilise the VAWG sector, and undermine culturally competent, trauma-informed support, and disproportionately harm migrant women, particularly those facing VAWG and exploitation.

104.                     Victim-survivors of domestic abuse and modern slavery and vulnerable Black, minoritised and migrant women on temporary visas must be provided with accessible and secure pathways to settlement. Under the new earned settlement system, prolonged qualifying periods, income thresholds and contribution requirements, and the extension of the NRPF condition-alongside penalties for past debt, criminalisation and use of public funds-will further entrench women’s dependence on perpetrators and heighten their exposure to harm.

105.                     These measures fail to recognise that debt, criminalisation and reliance on public funds are often direct consequences of abuse or coercion. Exemptions are therefore essential to ensure that      victim-survivors are not punished for the violence they have experienced, and that they can access safety, stability and legal protection.

106.                     However, exemptions alone cannot remedy a system built on racialised, gendered and class-based inequalities. SBS and LAWRS have long argued that migrant and refugee rights must never depend on income or immigration category. A rights-based framework centred on equality, protection and justice must replace all models that treat belonging as something to be earned through productivity.

107.                     Contribution-based criteria that tie immigration rights to economic output must be revoked. Such models are inherently discriminatory and incompatible with a human-rights framework. They reduce settlement to a narrow measure of income, despite clear evidence that structural inequalities, rather than individual effort, shape migrants’ economic position.      Applying contribution-based tests would entrench racial, gendered and class inequalities and exclude those whose labour is essential yet undervalued.

108.                     The government must reframe the immigration system so that it is grounded in human rights, social justice and equality, rather than economic productivity. Migrants enrich UK society in ways that cannot be measured by income levels, and the immigration system must recognise      the full social, cultural and economic contributions that migrant communities make.

109.                     There must be sustained, evidence-based public messaging that counters the harmful narratives surrounding migration. Positive communication     that reflects the realities, experiences and structural barriers faced by migrants is essential for rebuilding social cohesion and reducing hostility, misinformation and scapegoating.

110.                     Shorter, secure and accessible routes to settlement must be introduced. Stability is essential for migrant women’s safety, recovery from trauma, and ability to participate fully in community life. Prolonged insecurity traps women in abuse, increases exploitation and undermines integration.

111.                     The Immigration White Paper and Earned Settlement proposals should be scrapped. Its short-sighted proposals further entrench the hostile environment and would fundamentally restructure the immigration system around exclusion, insecurity and inequality. A comprehensive reset is needed, one that prioritises rights, safety and dignity and rejects punitive and contribution-based approaches.

How have other countries applied contribution-based systems?  

112.                     Many countries operate points or contribution-based immigration systems, assessing factors such as qualifications, work experience, language proficiency and salary.  However, countries such as Canada and New Zealand pair these systems with robust integration frameworks, recognising that settlement cannot be reduced to economic metrics alone. Their models demonstrate that contribution-based criteria only function effectively when embedded within a human-rights based, well-resourced settlement infrastructure, the opposite of the direction taken in the UK.

113.                     Canada's immigration framework provides a clear pathway from temporary visas to permanent residence and citizenship. Government-funded settlement services, including family reunification programmes, employment support and targeted initiatives[27] such as the Racialised Newcomer Women Pilot- ensure that migrant women can participate fully in economic and civic life. These programmes recognise that structural inequality, not individual merit, shapes migrants’ ability to “contribute”.

114.                     New Zealand's recent reforms to the Accredited Employer Work Visa (AEWV)[28] and Skilled Migrant Category removed rigid median-wage thresholds, extended visa durations and reduced work experience requirements. These changes were explicitly introduced to reduce exploitation, allow workers to move more freely between employers and provide more secure pathways to settlement, mitigating precisely the harms that the UK’s new settlement proposals will intensify. 

115.                     By contrast, the UK's current trajectory, including extended settlement periods of 10-20 years and over, punitive income requirements, dependency penalties, and the linking of settlement reductions to high earnings prioritises perceived economic worth over human rights. These rules disproportionately exclude low-paid, racialised and migrant women, including victim-survivors of domestic abuse and create conditions that heighten exploitation and VAWG. 

116.                     We support the elements of international practice that center rights, stability and protection. However, the shortcomings of contribution-based systems globally combined with the acute harms they produce in the UK underscore that this model is inherently discriminatory.  Migrants’ rights and belonging should never be conditional on income, productivity or employer dependence. UK migration policy must instead prioritise secure settlement, safety, equality and full social participation.

Our recommendations:

117.                     Clarify and guarantee the long-term continuation of the life-saving MVDAC-DVILR model, and extend it to all victim-survivors regardless of their immigration status or visa type.

118.                     Grant sector-wide exemptions from salary thresholds for community-based frontline organisations, particularly by and for specialist services, when sponsoring migrant workers. These staff must also be exempt from minimum income requirements for ILR, reflecting  the essential nature of their work and the chronic underfunding that makes compliance with the new thresholds structurally impossible. 

119.                     Provide accessible, safe and swift pathways to settlement for victim-survivors of domestic abuse and modern slavery, and vulnerable Black, minoritised and migrant women on temporary visas, including protections that reflect their heightened risk of exploitation.

120.                     End the contribution-based criteria that reduces migrants' rights to economic output, and the rhetoric that focuses on the arrival of new immigrants as the source of all economic, socio-political and cultural woes in the UK.

121.                     Reframe the immigration system around human rights, equality, safety and social justice, recognising that migrants enrich UK society in ways that cannot be captured through narrow economic indicators.

122.                     Foster a positive, evidence-based narrative on migration, reflecting the lived realities of those who seek to build their lives in the UK, acknowledging the structural barriers they face.

123.                     Introduce shorter, more secure and more humane routes to settlement, recognising that stability is essential for integration, well-being and recovery from trauma.

124.                     Withdraw the Immigration White Paper and Earned Settlement proposals. A fundamental reset of the immigration system is needed - one grounded in human rights rather than punitive, “hostile environment” logic. 

125.                     Scrap the NRPF condition. All victim-survivors of domestic abuse and gender-based violence, including those on work sponsored, dependent and temporary visas, and those who are undocumented must have access to public funds, healthcare, emergency accommodation and employment.

126.                     Extend the combined MVDAC-DVILR model to all victim-survivors, regardless of immigration status.

127.                     Introduce a firewall to prevent data-sharing between police, statutory services and Immigration Enforcement.

128.                     Provide ring-fenced funding for by and for organisations supporting victim-survivors of abuse, reflecting their proven role in safeguarding the most marginalised women.

129.                     Simplify sponsorship rules to reduce administrative burdens on small charities and ensure the retention of skilled migrant staff whose expertise is essential to frontline service delivery.

Dec 2025