Resources Reports Evidence Submission to the ICIBI Inspection on how the EUSS is working for vulnerable groups Download the evidence session Background JCWI has conducted extensive work on the EU Settlement Scheme (EUSS) since its inception, specifically focusing on its impact on vulnerable EU citizens and non-EU family members (EEA+ citizens) most at risk of slipping through the cracks in the scheme. We have called on MPs to reform the scheme in order to protect EEA+ citizens’ rights, worked with MP Kate Green to table a motion calling for automatic settled status for EEA+ citizens and called for changes to the Immigration and Social Security Co-Ordination (EU Withdrawal) Bill 2019-2021 during its passage through Parliament. Some of what is being asked is covered in our existing briefings EUSS FAQs, Immigration Bill 2020 Second Reading Briefing and Evidence to the Public Accounts Committee Inquiry into Immigration Enforcement. We would also recommend the ICIBI refers to reports outlining the risks of the EUSS for vulnerable EEA+ citizens including CORAM’s ‘Children Left Out’, Roma Support Group’s ‘Brexit, EU Settlement Scheme and Roma Communities in the UK’ and The 3 Million’s ‘Rights and Representation: What Young Europeans in London know and think about their rights and politics in the UK’. General concerns about the EUSS The design of the EUSS will create a significant new population of irregular migrants The way the EUSS is designed will force significant numbers of EEA+ citizens out of status and rights, and guarantees the creation of a new irregular migrant population overnight after the EUSS cut-off point. The EUSS as designed by the Government, is a ‘constitutive system’, which means that eligible people must apply by the deadline in order to secure their immigration status. Any EEA+ citizen who is unaware of the scheme, unaware that they are eligible, or are otherwise unable to apply in time will simply fall out of status. No comparable application system has ever succeeded in reaching 100% of the people it is targeted towards, and there is no reason to believe the EUSS will be the first to achieve it. Our research into EEA+ Care Workers’ experiences of the EUSS found that 17% of online participants and 31% of face-to-face participants either did not know or were not sure what the EUSS was. This is a worryingly high proportion with absolutely no awareness about the scheme, especially considering that care workers are not perceived as a group of people at risk of slipping through the cracks. Even more concerningly, we found that 31% of online participants and 94% of face-to-face participants did not know or were not sure when the EUSS deadline was. The EUSS is failing because worryingly high numbers of EEA+ citizens have not heard of it, and a vast number of those who have do not understand what they need to do in order to secure their status and rights in time. Even EEA+ citizens who are aware of the EUSS and know when the deadline is will not be protected if they do not also understand how to apply and have access to support if they need it. We found that 28% of online survey participants and 54% of face-to-face survey participants reported had not made an application to the EUSS. We recommend that this inspection investigates: What evaluation / prediction has been made of the scale and nature of the population of EEA+ citizens likely to fall out of status as a result of the design of the scheme? How has the Home Office ensured it is prepared for this new population of irregular migrants? EEA+ citizens who are unable to apply on time will become criminalised and vulnerable to Hostile Environment policies EEA+ citizens who are unable to apply by the deadline and subsequently fall out of status will become criminalised and vulnerable to the Home Office’s Hostile Environment, a set of policies designed to make life unliveable for migrants without the right documentation. People who have been living, working and building lives in the UK for years will be prevented from working, driving, accessing vital healthcare, and could face detention and removal. Landlords and employers will face fines for renting to or employing EEA+ citizens without status. The Home Office has stated that anyone who misses the EUSS deadline for a ‘good reason’ will be given a ‘reasonable further period’ in which to apply. However, it has yet to define what it means by ‘good reason’, and historically this threshold has been incredibly high, excluding almost anything short of being physically unable to leave hospital. We can safely assume it will not include people who simply did not realise they needed to apply or that they were eligible for the EUSS. Further, in October 2019 then Immigration Minister Brandon Lewis confirmed that EEA+ citizens who miss the deadline will face immigration enforcement controls including deportation. "It [the EUSS application] made me feel horrible, unvalued, cheated, used... I arrived in the UK legally and have made my life here, and was forced to apply to continue living here with my British husband. I am really angry. I fear that many vulnerable people will fail to apply and will face the Hostile Environment” (EU Care Worker) We encourage the ICIBI to consider and inspect: How will immigration enforcement controls be used against people who are unable to apply on time? What protective measures will be put in place to ensure eligible EEA+ citizens are not subject to Hostile Environment measures between the end of the transition period (31 December 2020) and the EUSS cut-off point (30 June 2021)? How will the Home Office decide who is eligible for applying after the deadline and how it will measure a ‘good reason’ for late application? What aftercare and support will be provided for those deemed eligible for late application? EEA+ citizens most at risk of falling out of status We know that it is the most disadvantaged people in society who face greatest risk of slipping through the cracks in the scheme, particularly older people, disabled people, looked-after children and people in precarious work or housing. Children: EUSS procedures mean that children automatically receive the same status as their parent, but for looked-after children and care leavers who are estranged from family, the process is significantly more difficult. Home Office estimates that there are around 5000 EU children in care in the UK, not including care leavers. Official government guidance for local authorities outlines that where the local authority has parental responsibility, they are duty-bound to ensure the EUSS application is made. However, for children accommodated under Section 20, authorities are only expected to raise awareness or signpost to support ‘where needed’. Children under Section 20 make up 73% of the looked-after children in England yet will be left with far less support.  In a study looking into children in care and care leavers in Manchester, the GMIAU found that none of the children they spoke to were able to make an application, due mainly to problems evidencing their residency and nationalities, despite the fact over half had lived in the UK for more than five years. Further, CORAM highlight an underrepresentation of EUSS applications from children. They found that some children who have tried to apply for status under the EU settlement scheme have been unsuccessful. Up to 31 March, 1790 applications by children have been withdrawn or rejected as ‘void’, and 520 were rejected as ‘invalid’. Disabled people: Disabled people and adults with limited mental capacity are another group of EEA+ facing significant barriers with the scheme due to difficulties navigating a wholly-digital system alongside a lack of adequate support. Further, disabled people may face discrimination and extra difficulty proving residency and thus obtaining status due to the scheme’s automated checking system, as the DWP data quality is low, which includes most of the disability benefits. It is notable that of the 57 Home Office funded organisations to work with vulnerable groups, only one is specifically for disabled people, framing in stark terms the impossibility of meeting the support needs of a community who otherwise will likely be unable to access the scheme. BAME people: Further, we know that Black, Asian, and minority ethnic (BAME) people face disproportionate socio-economic disadvantages which will make it harder for them to access the EUSS and thereby secure immigration status (e.g. because of lower levels of literacy, digital capacity and digital access). In a study into Roma communities and the EUSS, the Roma Support Group found that whilst the vast majority of people they spoke to knew about Brexit, they did not know how to apply to the EUSS, with only 3% able to submit an application completely independently. Roma people face disproportionate levels of illiteracy, limited digital capacity and insecure housing, which are all factors that could explain why they struggle with the EUSS. Older people: Applications from older people (over 65s) are significantly lagging behind the working age population. Age UK found that only 16% of over 65s had applied to the EUSS, compared with 30% of working age EU citizens. Older people face multiple barriers with the scheme caused mainly by limited digital capacity and greater social isolation, particularly for those in care homes, who are less likely to be reached by the Home Office’s EUSS communications or advertising. This is only going to be intensified by the current COVID crisis and the fact many older people are in complete isolation or shielding. We also know from speaking to EEA+ citizens and other practitioners that very long-term residents who are fully settled in the UK (many of whom already have Permanent Residence status) often do not realise they are expected to apply. Non-EU family members: Non-EU family members also face disadvantages and increased barriers with the scheme, whose cases are more complex and harder to reach. They are required to demonstrate their relationship to the EU family member as well as evidencing all other EUSS requirements, meaning that many who have experienced domestic violence and whose documents are possessed by their perpetrator, may be unable to apply and forced out of status. 33,092 EEA Family Permits were issued to non-EEA family members entering the UK in 2016 alone, with almost 283,000 issued between 2005-2016. British Future, The Migration Observatory and HASC all identify non-EU family members as an “at risk group” who may not be aware that the scheme applies to them, or that it is mandatory. Non-EU nationals also face a disproportionate burden of proof along with the “hidden costs” of the scheme. Workers: Our EEA+ Care Workers research, which highlights a significant lack of awareness and understanding about the EUSS amongst care workers, shows that it is not just extremely vulnerable people who are at risk of failing to apply by the deadline. The issues we have identified are not unique to care workers but will affect any EEA+ citizen who is simply unaware, unsupported, or unable to apply to the EUSS in time for the deadline. EEA+ citizens from all walks of life, but particularly those who work in sectors with poor working conditions, low pay and precarious employment arrangements, face additional risk of slipping through the cracks in the scheme and feeling the full force of the Hostile Environment. We have various concerns we would encourage the ICIBI to investigate: How much further money will be allocated for EUSS advertising, communications and outreach? What is the strategy for reaching ‘at risk’ people, including workers in sectors with high numbers of EEA+ staff? Will employers receive training on the Government’s arrangements for EEA+ citizens and the EUSS process? How will the Home office ensure they reach EEA+ citizens who are socially isolated in residential settings or due to COVID lockdown measures? Is the funding allocated to 57 front-line services enough to reach all vulnerable EEA+ citizens? Whether there is a need for funding for trade unions, local authorities and other bodies that support workers or other EEA+ citizens not eligible for front-line charitable support. Lack of information and support for EEA+ citizens The Home Office has stated that the EUSS is “simple and straightforward” for the “great majority” of EU citizens and their family members. However, our research suggests this is simply not the case. We found that 46% of EEA+ Care Workers we spoke to who had applied, reported they had received help with their application, of which 76% said this help was “very” or “quite” important. Considering that we spoke solely to working age EEA+ citizens in employment, this reveals it is not just extremely vulnerable people who require assistance with the EUSS, but EEA+ citizens across the board. Despite this clear need for support, the overwhelming majority of EEA+ care workers we spoke to face-to-face (93%) said they would not know where to find support if they needed it. This points to a concerning gap in information and support which will make the difference between remaining rights-holding residents and becoming subject to immigration enforcement controls for many EEA+ citizens. We encourage this inspection to consider: The take-up and success of the “Digital Assist Programme” The need for further assistance programmes suitably designed to reach all EEA+ citizens How will assistance be tailored to suit workers in different sectors with large proportions of EEA+ staff? The EUSS will devastate many key sectorsWe have seen during this pandemic that care workers and other keyworkers are responsible for keeping our vital services running, caring for those most in need and holding society together. Despite this, the Government has designed the EUSS in a way that will make the scheme harder to reach for workers from sectors with low pay, poor working conditions and higher levels of exploitation. We found that EEA+ care workers are feeling the sharp edge of the Brexit process and the Government’s arrangements for EEA+ citizens, which have dramatically altered how they feel about their lives and futures in the UK. 37% of online participants reported very negative emotions and/or experiences associated with applying to the EUSS. Feelings commonly included anger, anxiety about the future, exclusion, or injustice at having to apply to continue living in their own homes. "Meanwhile, we care for your seniors and vulnerable, pay taxes, leave our energy and skills. ...What will the UK give in return?" (EU Care Worker) Many reported that Brexit and the EUSS had left them feeling differently about the UK, with some telling us this was enough to make them want to move or return to their countries of origin. 30% of online participants told us they were either not planning on applying to the EUSS or not sure if they would apply. Britain without enough carers will see further cuts to vital services supporting so many of our loved ones, and an increase in deaths of society’s most vulnerable citizens. These disastrous impacts are entirely preventable, but the Government must act now before it is too late. “When Brexit happens I will ask myself the question of do I still want to be here? Because attitudes have definitely changed… So the narrative of blame Europeans because they stole our jobs and our money, the environment is so susceptive to that kind of narrative." (EU Care Worker) We encourage the ICIBI to investigate: What (if any) duties / responsibilities are there for employers to inform their EEA+ staff about the Government’s arrangements for EEA+ citizens? What (if any) follow up is carried out to check that large employers of EEA+ citizens have informed their staff about the EUSS process? Long delays for EUSS decisions The Home Office has stated that it will take a ‘flexible’ and ‘reasonable’ approach to EUSS applications and will be ‘looking to grant, and not reasons to refuse’. However, we know from speaking to practitioners from front-line organisations that non-EU family members and people affected by the criminal justice system are waiting very long periods for decisions on their EUSS application. Non-EU family members often have more complex cases and are required to provide additional evidence as they must also demonstrate their relationship to the EU citizen on whom their application relies. If the delays are being caused by difficulties with evidence, this suggests the requirements are too demanding. The Home Office has insisted that only ‘serious and persistent’ criminals would be excluded on the basis of suitability. However, we know anecdotally that people with very minor convictions are waiting months for a decision on their EUSS application, with many still having received no outcome. As of May 2020, there were 900 refusals (of which 2% were refused on suitability grounds) but just under 300,000 unresolved cases. Despites impressions of permissibility, we are concerned that the Home Office is in fact taking an overly tough approach towards criminality and simply pushing complex cases to one side, creating a backlog of potential refusals. We would advise the inspector to investigate: What proportion of unresolved cases have been waiting over 3 months for a decision? How many of the unresolved cases have issues of criminality or are non-EU family members? What proportion of refused or unresolved cases with issues of criminality could be described as “serious and persistent” criminals? Lack of physical documentation will lead to discrimination The Government has decided to deny EU citizens access to physical documentation as proof of their immigration status and we know this will lead to discrimination. All other migrants and British citizens can choose to obtain physical documentation to prove their status, but this right has been denied for EU citizens. According to the Government, a wholly digital system is ‘more secure and forward looking’, yet evidence suggests a lack of physical documentation leads to discrimination and difficulty in daily life. HASC, The House of Lords EU Justice Sub-Committee and the Exiting the EU Committee all agree that without physical documentation EU nationals are likely to find it difficult to access services, rent accommodation and find employment, and draw parallels with the Windrush scandal in which people could not evidence their status due to a lack of documentation. The HASC found that under ‘hostile environment’ measures, ‘if it is impossible to differentiate between these groups, the prospect is raised of EU citizens being discriminated against in areas such as employment or housing.’ We are already seeing instances of EEA+ citizens unlawfully being denied access to vital services because they cannot demonstrate their status and we know a digital only scheme will lead to further discrimination. This will be especially harmful for EEA+ workers in sectors with higher levels of work exploitation and employers who will be less likely to recruit people without physical papers, such as care, agriculture, manufacturing and construction. We would encourage this inspection to investigate: What assessment has been made of the potential for digital-only systems to cause discrimination? The main risks associated with a digital-only immigration checking system. The EUSS Policy Equality Statement The Home Office has still not published the long overdue Policy Equality Statement (PES) on the EUSS, which requires the Home Office to have due regard to the need to eliminate discrimination, advance equality of opportunity, and foster good relations when developing policies and delivering services. Over a year ago on the 11th June 2019, then Immigration Minister Caroline Nokes confirmed the existence of an unpublished PES. We requested a copy on the 29 August 2019, to which the Home Office responded on the 19th September 2019 that it did have the PES but refused to provide it because it was intended for future publication. Despite this commitment to release the statement, the PES has still not been published almost a year later. Without the PES, the Home Office has no way of identifying and tackling any discrimination enacted in the operation of the EUSS. We strongly recommend the ICIBI should investigate: How the potentially discriminatory impacts of the EUSS are measured? Why the PES has still not been published? When the Home Office will release the PES? Whether the refusal to publish the PES constitutes a breach in Public Sector Equalities Duties under the Equality Act. Non-monitoring of protected characteristics The Home Office releases monthly EUSS statistics that break down applications based on age, nationality and geography, but this is not enough to expose and tackle inequalities in the operation of the scheme. We know that one’s protected characteristics will shape their experience of the EUSS and create additional obstacles, particularly for BAME people, disabled people, and many women, yet the Home Office refuses to take responsibility for this. The Government risks breaching its equalities duties as it has no way of knowing who is slipping through the cracks in the scheme, and therefore cannot make adjustments to fix these problems. We would suggest the ICIBI should include the following in his investigation: How does the Home Office assess and evaluate which groups of EEA+ citizens are struggling to access the EUSS without monitoring protected characteristics? How is an EUSS outreach strategy constructed without knowledge of which EEA+ citizens are failing to apply? How funding for front-line organisations is allocated without knowledge of which EEA+ citizens are failing to apply? The Government cannot measure the effectiveness of the EUSS The Government has no way of measuring the effectiveness of the EUSS because it does not know how many EU citizens and non-EU family members are resident in the UK, or how many have applied to the EUSS. The Government has failed to conduct a meaningful calculation since the Brexit vote, and this is now impossible in the timeframe available until the EUSS deadline. Official figures estimate there are 3.4 million non-Irish EU citizens resident in the UK, but expert reports conclude this number is likely to be much higher, as it does not account for some groups such as people living in communal or residential homes and will undercount others, including dual-citizens. There is no official estimation of the number of non-EU family members resident in the UK, who make up a significant proportion of people eligible for the EUSS. Moreover, the Home Office publishes monthly EUSS statistics, but these include repeat applications - for example double-counting anyone who applied for pre-settled status and subsequently applied for settled status - and do not disclose the overall number of individuals who have made applications or been granted status. Whilst we welcome the fact a significant number of EEA+ citizens have applied to the scheme, Home Office statements that the EUSS is a ‘success’ because over 3.6 applications have been made are not conclusive and should not be overstated. Recommendations Grant all EEA+ citizens automatic settled status The Government must make the EUSS a declaratory scheme whereby all EU citizens and non-EU family members resident in the UK are granted automatic settled status. This is the only real and sustainable way to avoid hundreds of thousands of EEA+ citizens falling out of status overnight after the EUSS cut-off point. The creation of a new population of irregular migrants will enable greater work exploitation and further driving down of wages for all workers, especially in sectors such as care where there is a lack of bargaining power. Many people are making comparisons between what will happen to EEA+ citizens who do not apply to the EUSS and the life-ruining effects of Home Office decision making on the Windrush generation. During the Windrush scandal, those whose right to remain was under threat had legal status but were unable to evidence their rights due to lack of documentation, leaving them vulnerable to harmful and unlawful Hostile Environment policies. EEA+ citizens who do not apply to the EUSS will be left with no legal status whatsoever. After the EUSS far more people will fall out of status with similarly devastating real-life consequences as those faced by the Windrush generation. Granting automatic settled status is the only way to avoid this. Scrap the temporary and less secure ‘pre-settled status’ The Home Office is granting a temporary (five year) status to EEA+ citizens who can prove short periods of residence in the UK but cannot demonstrate that they have been here for five years or more continuously. Many people are being wrongly granted pre-settled status as they cannot evidence the entirety of their residence, especially people in the care system, cash-in-hand work, insecure housing or abusive relationships. Many of those granted pre-settled status are particularly vulnerable or in exploitative situations and will likely face these same problems in five years' time. Two care workers we met in during visits to care homes had wrongly received pre-settled status instead of settled status but did not realise the difference until they spoke to us. This is a small snapshot of the same potentially life-ruining mistake happening to many more EEA+ citizens. The Home Secretary has created a cliff-edge scenario and an arbitrary barrier to individuals remaining regularised, rights-holding residents. This is not what was promised by our Prime Minister and Home Secretary during the 2016 Leave Campaign when they committed to granting all EEA+ citizens automatic indefinite leave to remain’ and assured they would be ‘treated no less favourably than they are at present’. Increase funding and resources for EUSS communications, advertising and outreach Our research has shown that many EEA+ citizens are not aware about the EUSS and a significant number of those who are lack understanding about when and how to apply to ensure they remain regularised, rights-holding citizens. The Home Office must do more to reach EEA+ citizens - particularly those who are extremely vulnerable or work in ‘high-risk’ sectors including care - through increased funding and resources for EUSS advertising, communications and outreach. It is essential that specialist front-line charities, as well as trade unions, local authorities and large-scale employers of EEA+ workers, are allocated adequate funding to enable them to reach, inform and assist EEA+ citizens. This should include aftercare for people citizens who do not make an EUSS application in time, and those with pre-settled status who later need to apply for settled status. Provide all EEA+ citizens with physical documentation as proof of immigration status The Government must provide physical documentation as proof of status to all EEA+ citizens who successfully receive status through the EU Settlement Scheme. All other migrants and British citizens can choose to obtain physical documentation to prove their status but this right has been denied for EU citizens. We simply cannot rely on an untested online database as the only means of evidencing status and rights. Monitor protected characteristics of EUSS applicants We urge the Home Office to begin monitoring the protected characteristics of applicants to the EU Settlement Scheme with immediate effect. The Home Office releases monthly statistics that break down applications based on age, nationality and geography, but this is not enough to expose and tackle inequalities in the operation of the scheme. We know that one’s protected characteristics will shape their experience of the EUSS and create additional obstacles, particularly for BAME people, disabled people, and many women, yet the Home Office refuses to take responsibility for this. The Government risks breaching its equalities duties as it has no way of knowing who is slipping through the cracks in the scheme, and therefore cannot make adjustments to fix these problems. Without such monitoring, the EUSS will continue to cause discrimination and further existing inequalities. Release the EUSS Public Equality Statement It is crucial that the Home Office must release the long overdue PES, which has been written but unpublished for over a year. We know the scheme causes discrimination and is harder to access for certain individuals including older people, looked-after children and BAME communities. 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