Written evidence submitted by Dr Ilona Pinter, Research Associate, University of Glasgow (RTS5791)

Background

I work as a Research Associate based at the School of Social and Political Sciences, at the University of Glasgow on a mixed-methods study – Family Finances - which investigates the difference that the Scottish Child Payment makes to families on low income.[1] I also work as a Research Officer at the Centre for Analysis of Social Exclusion (CASE), at the Department of Social Policy, London School of Economics and Political Science, on a project aiming to better understand child poverty among migrant households in the UK, using Family Resources Survey data.[2] I have worked as a researcher and policy analyst within academia and civil society over the last 15 years, focusing on children, young people and families within the UK’s asylum and immigration system. This evidence submission is based on research and analysis that I have conducted in recent years.

I have focused my evidence on the following question:

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

The earned settlement reforms announced in November 2025 aim to reduce the number of individuals and households accessing settlement in the coming years. This involves several reforms including increasing the baseline qualifying period for settlement to 10 years for most households; increasing the baseline period to 15 years for those on lower pay; introducing penalties for those accessing benefits for an addition 5 to 10 years; and implementing measures to remove access to public funds for those who have permanent residence rights.

Extending the routes to settlement is intended, in part, to delay the point at which households already living in the UK (as well as those coming here in the future) can access social security benefits, leaving more households subject to ‘no recourse to public funds’ (NRPF) restrictions for longer. This will also mean that more individuals and families will be left without any access to social security benefits, including most income-based benefits like Universal Credit, Child Benefit, Housing Support, and homelessness assistance. The social security system not only provides a vital safety net in times of financial hardship and crisis following family separation, bereavement, domestic abuse, unemployment, illness and disability. But as highlighted in the government’s Child Poverty Strategy, the social security system plays a key role in supporting families on a low income. Household income has been shown to have causal effects on children’s outcomes, including health, education, development and economic outcomes.[3] Recent research has shown that cash transfers directed at children and families on a low income can help reduce food insecurity and child material deprivation. Findings from a mixed-methods comparative study showed that parents in Scotland who received the Scottish Child Payment (SCP) for the children in their household, were better able to meet their family’s essential needs for nutritious food, clothing and utilities while also investing in items and experiences that supported their children’s education, physical, psychological and social development.[4] However, alongside Universal Credit and Child Benefit, the vital support provided by SCP is not available to children whose parents have no recourse to public funds (NRPF) regardless of their income level. Under the earned settlement proposals, SCP and other vital support will continue to be unavailable to many children throughout their childhood, regardless of their needs or income shocks that they face.

Numbers affected

Despite efforts to obtain this type of information for many years[5], the government does not publish any precise data on the number of children and families currently affected by NRPF restrictions or corresponding demographic information, showing which categories of protected characteristics are most affected. In the absence of other data, we have used Home Office Migrant Journey data, which gives the number of individuals who have limited leave to remain or a visa at the end of each year and we estimate the overall numbers by selecting those in visa categories that usually come with NRPF conditions. Our analysis of Migrant Journey data at the end of 2024 showed that there were an estimated 3.67 million individuals, including over half a million (578,954) children (recorded as under 18 at the initial visa grant[6]) who had a type of visa or limited leave to remain, which generally comes with NRPF conditions.[7]

Of these, the vast majority - 86% or 498,871 children - were on a visa route that allows for settlement.[8] Figure 1 below highlights how these numbers are broken down by different visa categories (e.g. Work, Family, Study, Hong Kong BNO routes, etc.).

Figure 1 Number of children[9] with valid leave to remain, which generally comes with an NRPF condition (excluding ILR) at the end of each year, for those issued leave from 2004 onwards, by leave type category

Source: Author’s analysis of Migrant Journey data from years 2016-2024 (summary tables MJ_07)

The number of children on a work visa (likely to be dependents) increased significantly after 2021. Although Home Office quarterly statistics do not provide an age breakdown of new arrivals, they do show a significant increase in the number dependents granted entry clearance from 2021 under the Health and Social Care visa route[10].

Figures 1 and 2 (below) highlight that overall, the numbers of individuals including children likely to be subject to NRPF conditions on their leave to remain or visa, were far lower in 2016, when 1.14 million individuals, including 142,496 children had limited leave to remain or a visa, in these same categories. Figure 2 below shows the overall figures of all age categories by visa groups.

Figure 2 Number of people with temporary leave to remain in the UK generally subject to NRPF conditions - from years ending 2016-2024 who applied for an initial visa from 2004 onwards (including main applicants and dependents)

It is important to note that children are affected by NRPF restrictions not because of their own status, but because of their parents’ ineligibility to be welfare claimants. Therefore, we would need to know how many parents facing NRPF restrictions had child dependents living within their household, in order to be able to make more accurate estimates. This would also provide us with an idea of how many British citizen children are affected by NRPF conditions on their parents. As children arriving in the UK generally get leave in line with their parents, and some will be living in mixed-status households, the true figure of the number of children affected by NRPF restrictions is likely to be higher than those who have a visa or limited leave to remain.

Poverty rates among children in migrant families

While not all children who are subject to NRPF conditions or whose parents have these restrictions on their visas, will be living on a low income. However, migrant children are at a disproportionately higher risk of poverty, including severe poverty and material deprivation, than both their British peers and migrants in other age groups. This is why children should be a particular concern for this inquiry.

We know from the existing analysis of national survey data that children with foreign-born parents are at a higher risk of poverty and material deprivation. For example, analysis by CASE colleagues of government Family Resources Survey (FRS) data has highlighted that children with non-UK-born parents are at a higher risk of poverty than their peers with UK-born parents: in 2019/20, relative poverty rates for children with foreign-born parents who had been in the UK for 10 years or less, and those who had been in the UK for over 11 years were estimated to be 49.6% and 47%, respectively compared to 25.8% for children with UK- born parents (after housing costs). Children with foreign-born parents were also three times more likely to be in severe poverty (10%) as compared to their peers with UK-born parents (3.1%).[11]

An earlier separate analysis of FRS data for 2011-14, which compared poverty rates among foreign-born individuals living in the UK across different age groups, showed that foreign-born children faced both higher rates of poverty than working-age adults and pensioners who were foreign-born as well as a bigger poverty gap to their UK-born peers.[12] More recent analysis by IPPR has shown that these disparities remain.[13]

Other survey data shows that children in migrant families are also at a high risk of destitution: of the one million children estimated to have experienced destitution in 2022, a third (34% - 355,900) were migrant children. This represented a 155% increase for migrant children (with no complex needs) since a similar survey was conducted in 2019.[14]

Although FRS data do not provide information on individuals’ immigration status, the findings nevertheless show that children living in migrant families in the UK are disproportionately affected by poverty and this warrants further focused attention.

Disproportionate financial pressures on families with children

While children are not themselves benefit claimants and are not directly restricted by NRPF conditions, they are detrimentally affected by their parents’ immigration status. Furthermore, given children’s higher risks of being in poverty as shown above, they will likely be disproportionately affected by an extended ban on access to important benefits, including those specifically directed at children, such as Child Benefit, Scottish Child Payment, the Healthy Start Scheme and most childcare support.

Increased routes to settlement will also mean that families will have to pay more in settlement fees, as the rates take little account of the resources available to families with children, who of course cannot earn income. In previous research on children and families affected by NRPF conditions on the current ten-year route to settlement, we calculated that a single parent with two children starting their settlement journey in 2012 would have had to pay £23,375 over a ten-year period to acquire Indefinite Leave to Remain. A family of two adults and three children would have had to pay £39,180 over a ten-year period.[15] Updated analysis suggests that had these families started their journey five years later in 2017, these overall fees would have increased to £27,182 and £45,560, respectively, given increases to both Home Office application costs and the Immigration Health Surcharge.[16] This is equivalent to an additional cost of £76 per person per month over a ten-year period and does not account for fee increases since 2024 or citizenship fees. Importantly, these are unique fees that migrant families pay on top of the taxes and National Insurance contributions paid through employment.

Like rent, utilities and food, these fees are essential costs for families because if they are unable to pay, their status becomes irregular with significant consequences for children and parents’ welfare. The pressure of having to save up and pay visa renewal application fees every 30 months to comply with UK immigration policy can take its toll on migrant parents as well as children. Our research with parents on the ten-year route to settlement in 2020, found that families struggled to meet basic needs and accumulated significant debt to stay afloat, with some parents having to take multiple loans to cover Home Office fees. For example, Emanuel – one of the parents interviewed for our research on NPRF conditions explained:

“[this is] driving people into debts, it’s driving people into misery. Some diseases are kicking in. Insomnia. At one point I was unable to sleep because I was thinking. And it’s caused by all this. If you are not able to make your ends meet. If you cannot have basics, five years, basic things that you can attend to, it’s very difficult in life.”

Another parent Tiana – a single mum who had lived in the UK for 17 years, had a British child and was on the ten-year route to settlement - was forced to take out multiple payday loans to support her day-to-day costs like rent, gas and electricity. She had always worked in social care, including in nursing homes and for the NHS and had accrued debts of £15,000. Her wages from her part-time job all went towards paying off her debts, and she described herself as feeling trapped in an endless cycle of debt and borrowing.[17]

Our findings also highlighted the detrimental impact of their family’s financial circumstances on children’s material deprivation levels and diminished well-being. Paying Home Office fees and the IHS takes away important resources that parents could otherwise invest in children’s nutrition, education, development and to support their family’s housing stability. These financial pressures on children and parents are likely to increase with longer routes to settlement of between 10-20 years in some cases, given with the five- and ten-year penalties facing those who will need to take up social security support in a financial crisis. Extending routes to settlement for families with children could further diminish any investments or savings that parents are able to make for their children’s well-being, leading to worse outcomes during their childhood as well as later in adulthood.

Unequal nature of NRPF restrictions and settlement reforms

In its consultation, the government acknowledges that the fiscal contribution of migrants varies across different migrant cohorts, influenced by factors such as employment rate, income level, age, and their propensity to use different types of public services. However, there is limited evidence available on what this will mean in practice, particularly for those with protected characteristics and children. The government has not yet published an Equality Impact Assessment or Child Rights Impact Assessment, which would help to better understand these risks.

As I have highlighted in previous research, although NRPF restrictions are currently applied to most migrants’ visas, not all households are affected equally.[18] Households with higher incomes and assets that provide a sufficient personal safety net would be ineligible for means-tested benefits like Universal Credit and are therefore materially unaffected by NRPF restrictions. Families without children would be ineligible for Child Benefit, while those who do have children in the household, even on higher incomes, miss out on this support, which most of their peers receive in recognition that families have additional costs related to raising children.

NRPF restrictions are particularly detrimental for families on low incomes and with additional needs, who are prevented from accessing both means-tested and non-means-tested support through the ‘blanket ban’ that these restrictions represent.[19] This also means that those already at greater risk of poverty – such as families with children, single-parent households, minority ethnic households facing labour market discrimination, households where family members have a disability or illness – are more likely to be negatively affected. For example, various data sources have highlighted the disproportionate effects of existing NRPF restrictions on minority ethnic households. While the Home Office does not generally collect or publish ethnicity data, its Policy Equality Statement on the NRPF policy in 2015 showed that most applicants (79 per cent) on the ten-year route to settlement in 2014 – among the hardest hit by this policy because of the long-term ineligibility to social security benefits – were of nationalities from African and Asian regions.[20] Our own analysis of Home Office data in 2020 showed that the majority of those granted extensions to their leave to remain applications on the ten-year route to settlement between 2012–19 were from former British colonies, namely Nigeria, Pakistan, India, Ghana, Jamaica and Bangladesh. The same top six countries were highlighted in data on families with NRPF supported by local authorities between 2015 and 2019.[21]

Among the proposals in the ‘earned settlement’ consultation, the penalties for households who claim benefits are particularly concerning. Families who receive any benefits for less than 12 months will face a penalty of an additional five years in settlement requirements while those who claim any benefit for over 12 months will face a penalty of ten years, resulting in 15 and 20 years of settlement respectively. This is also likely to fall unevenly, particularly on women and families with children, and those with significant needs resulting from disability. While the available data are limited, according to Home Office administrative data, female applicants made up 72% of all adult applicants who had Change of Conditions accepted on average between 2017 and 2025.[22] Change of conditions applications do not in themselves constitute benefit claims, but these figures suggest that women are likely to be overrepresented main benefit claimants and will therefore more likely face the additional year penalties. There may be particular reasons that women are more reliant on social security support, like having childcare responsibilities, being single parents, or facing gender and ethnicity wage gaps. Although we do not have a comprehensive picture of the children affected by these Change of Conditions applications, it is likely that both women and child dependents will be disproportionately exposed to these punitive measures. Therefore, as routes to settlement are increased, we are also likely to see a widening of inequalities with more families unable to access means-tested, children’s and disability benefits, leaving more at greater risks of poverty, destitution, debt and homelessness for longer.

Costs of NRPF restrictions

There are significant costs associated with child poverty and while the Home Office has focused on the fiscal costs of allowing families to access social security if they are eligible after being granted ILR or citizenship, there will also be wider economic and social costs of these restrictions. But there is little acknowledgement of these costs within the consultation, particularly for children.

Analysis by CASE and other LSE researchers commissioned by the Greater London Authority in 2021-22, on the social costs and benefits of lifting NRPF conditions for those on a visa or with limited leave to remain who were residing in the UK, found that this reform would bring parity so that families would be eligible for benefits under the same criteria as their peers. Our analysis found that lifting NRPF conditions for families with children with limited leave to remain would result in a positive net present value of £872 million over a 10-year period. The main costs of lifting conditions would be for Universal Credit and Child Benefit, while the biggest gains would come from enabling better housing stability and improvements to children’s education and development.

Using Home Office Migrant Journey 2019 data and other sources, we estimated that 106,000 households with dependent children would benefit if NRPF conditions were lifted. We assumed that most households with children (96,713 or 91%) would become eligible for and would take up Child Benefit given it is currently available to most children, but that only 9,000 households would receive Universal Credit based on current eligibility criteria and existing take-up patterns.[23] Better housing stability and improvements to children’s education and development are key drivers of health and wellbeing. Even short periods of poverty and insecurity can severely negatively affect children’s life chances. There would also be high gains from access to better-quality, less crowded, or more affordable housing, and from relief of problem debt. As our analysis highlighted, unsuitable housing can have long-term effects on health, and the financial burden of high housing costs can push families into poverty. We also noted that problem debt has profound social, emotional and productivity impacts, as well as effects on physical and mental health. As well as the financial protection of social security, lifting NRPF conditions would enable families to access employment-related support, such as work coaches, and childcare provision, most of which is currently restricted for those who are subject to immigration control, even when they are working.[24] This could enable families, particularly migrant women whose employment rates tend to be lower,[25] to increase earned income.

This analysis closely aligns with the costs that the Prime Minister highlighted in his foreword to the Child Poverty Strategy:

“There are those who would say that we cannot afford to act on poverty. This Labour government believes that it is the cost of inaction that our country, society, economy, and future generations cannot afford. When children grow up without the things they need to be happy, healthy and to achieve, they are less likely to do well at school, college, or university. They are less likely to get a job when they leave education. And they are less likely to have good mental or physical health. The cost in poorer health, worse educational attainment, lower skills and lower earnings is high. That is terrible in human terms, expensive in financial terms, and damaging in economic terms.”

This is no less true for children facing poverty as a result of immigration policies, which restrict access to social security protection and impose significant additional household costs for children and families whose homes are already in the UK.