Legislation Monitoring Reports

What is Legislation Monitoring?

The IMA has a duty, under the legislation that created it, to ensure that laws in the UK and Gibraltar reflect the rights of citizens under the Citizens Rights Agreements. One of the ways we do this is through our legislation monitoring work.

Watch our video to find out more.

Legislation currently under consideration by the IMA

This following legislation is currently being considered by the IMA for the purpose of legislation monitoring.

Legislation Monitoring Reports

This section contains links to the reports of all legislation monitored by the IMA.

Our reports explain whether any legal changes are compatible with the Citizens’ Rights Agreements. They help citizens to better understand their rights and can highlight where things may have gone wrong to assist public authorities to avoid similar issues.

Statement of Changes to the Immigration Rules: HC 259 9 July 2026

Date Legislation considered: 7 August 2026

Date Legislation in force: 30 July 2026 – for the purposes of the changes considered in this report

Potential Right(s) Affected: Residence

Statement of Changes to the Immigration Rules: HC 1691 5 March 2026

Date Legislation considered: 16 April 2026

Date Legislation in force: 29 April 2026 – for the purposes of the changes in relation to Appendix EU
8 April 2026 – for the purposes of the changes in relation to Appendix EU (Family Permit)

Potential Right(s) Affected: Residence

Housing Allocation Scheme Rules 2026

Date Legislation considered: 06 January 2026

Date Legislation in force: 07 January 2026

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Article 12/13 – Right of residence, Article 23/24 – Equal Treatment

Immigration and Asylum Bill

The Immigration and Asylum Bill has now been laid before Parliament. The Bill is relevant to the Withdrawal Agreement and the rights it sets out for EU and EEA EFTA citizens and their family members in the UK. Amongst other things the Bill proposes creating an Independent Immigration Appeals Body who will decide immigration cases included EU citizens rights cases.

Earlier this year, the IMA submitted a response to the Home Office’s Call for Evidence on proposals for a new appeals body. In that response, we highlighted a number of issues requiring consideration in relation to Withdrawal Agreement rights.

These included questions around access to justice, independent and impartial decision making, and how any new appeals system would operate for citizens whose rights are protected under the Agreements.

The IMA will analyse the Bill as part of its legislation monitoring processes, with a particular focus on its implications for citizens’ rights under the Withdrawal Agreement.

We expect to publish our assessment later this summer.

Our consultation response to the Home Office Call for Evidence is available here.
The Immigration and Asylum Bill (interim report) – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 28 August 2026

Date Legislation in force: Not yet in force. The Bill was introduced in the House of Commons on 30 June 2026.

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence

2025 Legislation Monitoring Reports

Statement of Changes to the Immigration Rules: HC 1491, 9 December 2025 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 5 February 2025

Date Legislation in force: 30 December 2025

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Right of residence
The Winter Heating Assistance (Pension Age) (Scotland) Amendment Regulations 2025 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 28 November 2025

Date Legislation in force: 11 October 2025

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Article 30 of Title III of Withdrawal Agreement, Article 29 of Title III of EEA EFTA Separation Agreement. The above provisions cover social security coordination
Statement of changes to the Immigration Rules: HC 1333, 14 October 2025 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 4 December 2025

Date Legislation in force: 11 November 2025 – for the purposes of changes considered in this report

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence
The Social Fund Winter Fuel Payment Regulations (Northern Ireland) 2025 No.142 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 27 November 2025

Date Legislation in force: 15 September 2025

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Article 30 of Title III of Withdrawal Agreement, Article 29 of Title III of EEA EFTA Separation Agreement, The above cover social security coordination
The Social Fund Winter Fuel Payment Regulations 2025 No.969 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 27 November 2025

Date Legislation in force: 15 September 2025

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Article 30 of Title III of Withdrawal Agreement, Article 29 of Title III of EEA EFTA Separation Agreement, The above cover social security coordination
The Immigration (EU Exit) Regulations 2025 and The Immigration (EU Exit) Amendment Regulations 2025 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 12 December 2025

Date Legislation in force: 6 October 2025

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Article 12/13 – Right of residence, Article 17/18 – Issuance of residence documents
Gibraltarian Status and Immigration (Amendment) Bill 2025 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 14 November 2025

Date Legislation in force: Not yet in force

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Article 12/13 – Residence Rights
The Disability Assistance (Scottish Adult Disability Living Allowance) Regulations 2025 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 29 May 2025

Date Legislation in force: 31 March 2025

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence, Social security co-ordination
Statement of changes to the Immigration Rules: HC 733, 12 March 2025 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 24 July 2025

Date Legislation in force: 9 April 2025 – for the purposes of the changes considered in this report.

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence
Statement of changes to the Immigration Rules: HC 836, 24 June 2025 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 30 June 2025

Date Legislation in force: 16 July 2025 – for the purposes of changes considered in this report

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence
The (Draft) Social Security (Cross-border Provision, Case Transfer and Miscellaneous Amendments) (Scotland) Regulations 2025 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 3 July 2025

Date Legislation in force: 6 November 2025 (subject to regulation 1(3).

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence
The Immigration (Citizens’ Rights Appeals) (EU Exit) (Amendment) Regulations 2025 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 7 July 2025

Date Legislation in force: 25 June 2025

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence
Border Security, Asylum and Immigration Bill – Clause 42 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 3 June 2025

Date Legislation in force: 2 months after the Act receives Royal Assent

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence

2024 Legislation Monitoring Reports

The Winter Heating Assistance (Pension Age) (Scotland) Regulations 2024 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 13 November 2024

Date Legislation in force: 20 November 2024

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Article 30 of Title III of Withdrawal Agreement, Article 29 of Title III of EEA EFTA Separation Agreement. The above covers social security coordination
The Social Fund Winter Fuel Payment Regulations (Northern Ireland) 2024 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 12 November 2024

Date Legislation in force: 16 September 2024

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Article 30 of Title III of Withdrawal Agreement, Article 29 of Title III of EEA EFTA Separation Agreement, The above covers social security coordination
The Funeral Expense Assistance (Scotland) Amendment Regulations 2024 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 31 January 2025

Date Legislation in force: 02 December 2024

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Non-discrimination, Equal treatment, Social security co-ordination
Social Fund Winter Fuel Payment Regulations 2024 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: September 2024

Date Legislation in force: 16 September 2024

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Article 30 of Title III of Withdrawal Agreement, Article 29 of Title III of EEA EFTA Separation Agreement. This covers social security coordination regimes.
The Education (Student Support, etc.) (Amendment No.2) Regulations (Northern Ireland) 2024 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 30 September 2024

Date Legislation in force: 14 August 2024

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence, Discrimination, Equal-treatment
The Education (Student Support, etc.) (Amendment No.2) Regulations (Northern Ireland) 2024 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 19 April 2024

Date Legislation in force: 26 February 2024

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence, Discrimination, Equal-treatment
The Disability Assistance for Older People (Scotland) Regulations 2024 No.166 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 26 July 2024

Date Legislation in force: 21 October 2024 (but Regulation 53 and Part 5 of the schedule come into force on the 7 June 2024)

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Social Security
The draft Immigration (Leave to Enter and Remain) (Amendment) Order 2024 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 24 April 2024

Date Legislation in force: In accordance with article 1(2) – the day after the Order is made

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence
The Education (Student Fees, Awards and Support) (Amendment) Regulations 2024 SI 2024/85 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 15 April 2024

Date Legislation in force: 15 February 2024

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence, Discrimination/Equal Treatment
Statement of Changes in Immigration Rules HC 590 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 21 May 2024

Date Legislation in force: 04 April 2024

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence
Illegal Migration Act 2023 (Amendment) Regulations 2024 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 2 August 2024

Date Legislation in force: 23 July 2024 (subject to regulation 1(3))

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence
Interim Report Statement of Changes in Immigration Rules HC 217 – Independent Monitoring Authority for the Citizens’ Rights Agreements

Date Legislation considered: 12 October 2024

Date Legislation in force: 8 October 2024 in respect of the changed to Appendix EU

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence

Retained EU Law (Revocation and Reform) Act 2023

The Disability Assistance (Miscellaneous Amendment) (Scotland) Regulations 2023

Date Legislation considered: 12 January 2024

Date Legislation in force: 20 November 2023

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Social security co-ordination/Residence/Discrimination/Equal Treatment
Retained EU Law (Revocation and Reform) Bill (first report)

Date Legislation considered: 01 November 2022

Date Legislation in Force: Not yet in force

Potential Right(s) Affected: Residence/Discrimination/Equal Treatment/ Workers/ Social Security
Retained EU Law (Revocation and Reform) Bill (second report)

Date Legislation considered: 28 February 2023

Date Legislation in Force: Not yet in force

Potential Right(s) Affected: Residence/Discrimination/Equal Treatment/ Workers/ Social Security
Retained EU Law (Revocation and Reform) Act 2023 (third report)

Date Legislation considered: 30 June 2023

Date Legislation in Force:

The following provisions come into force on 29 June 2023

(a) sections 1 and 2; 25

(b) section 5(1), (2) and (4) to (7).

(c) section 7.

(d) sections 9 to 17 and Schedule 3.

(e) sections 19 to 21, section 22, section 23 and Schedule 4 and Schedule 5.

Section 18 will come into force on 29 August 2023. The other provisions of the Act will come into force on such day as a Minister of the Crown may by regulations appoint.

Potential Right(s) Affected: Residence / Discrimination/Equal Treatment / Workers / Social Security coordination

2023 Legislation Monitoring Reports

The Disability Assistance (Miscellaneous Amendment) (Scotland) Regulations 2023 – Independent Monitoring Authority for the Citizens’ Rights Agreements (ima-citizensrights.org.uk)

Date Legislation considered: 12 January 2024

Date Legislation in force: 20 November 2023

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Social security co-ordination/Residence/Discrimination/Equal Treatment
The Welfare Foods (Best Start Foods) (Scotland) Amendment Regulations 2023

Date Legislation considered: 26 January 2024

Date Legislation in Force: 26 February 2024

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence/Discrimination/Equal Treatment
The Recognition of Professional Qualifications and Implementation of International Recognition Agreements (Wales) (Amendment etc.) Regulations 2023

Date Legislation considered: 26 January 2024

Date Legislation in Force: 1 December 2023

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Recognition of Professional Qualifications/Discrimination/Equal Treatment
The Carers Assistance (Carer Payment Support) (Scotland) Regulations 2023

Date Legislation considered: 24 January 2024

Date Legislation in Force: In part 19 November 2023 and in full on 1 October 2024

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence/Discrimination/Equal Treatment/Social Security coordination
The Recognition of Professional Qualifications and Implementation of International Recognition Agreements (Amendment) Regulations 2023

Date Legislation considered: 25 January 2024

Date Legislation in Force: 1 December 2023

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Recognition of Professional Qualifications and Discrimination/Equal Treatment
Social Security (Widow’s Benefit and Retirement Pensions) (Amendment) Regulations 2023

Date Legislation considered: 24 January 2024

Date Legislation in Force: 31 December 2023

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s) : Residence, Social Security Coordination
Social Security (Widow’s Benefit and Retirement Pensions) (Amendment) Regulations (Northern Ireland) 2023

Date Legislation considered: 24 January 2024

Date Legislation in Force: 31 December 2023

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s) : Residence, Social Security Coordination
The Statement of Changes in Immigration Rules Presented to Parliament on 7 December 2023

Date Legislation considered: 22 January 2024

Date Legislation in Force: 16 January 2024

Potential Right(s) Affected: Residence
The Tribunal Procedure (Amendment No.2) Rules 2023

Date Legislation considered: 18 January 2024

Date Legislation in Force: 25 December 2023

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residency
Statement of changes to the Immigration Rules: HC 1780, 7 September 2023

Date Legislation considered: 8 November 2023

Date Legislation in Force: 5 October 2023 – for the purposes of changes considered in this report

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residency
The Professional Qualifications Act 2022 (Commencement No. 3 and Savings and Transitional Provisions) Regulations 2023

Date Legislation considered: 24 November 2023

Date Legislation in Force: 11 October 2023

Potential Right(s) Affected: Recognition of Professional Qualifications and Discrimination/Equal Treatment
The Immigration (Citizens’ Rights Appeals) (EU Exit) (Amendment) Regulations 2023

Date Legislation considered: 27 May 2023

Date Legislation in Force: 08 May 2023

Relevant Withdrawal Agreement/EEA EFTA Separation Agreement Right(s): Residence
Second Report in respect of the Statement of changes to the immigration rules: HC1496 presented to Parliament on 17 July 2023

Date Legislation considered: 09 August 2023 (initial consideration)

Date Legislation in Force: 09 August 2023

Potential Right(s) Affected: Residency
EEA and Registered European Lawyers and Lawyer’s Practice (Revocation etc.) (EU Exit) Regulations 2023 (Gibraltar)

Date Legislation considered: 24 October 2023

Date Legislation in Force: 27 July 2023, but regulation 3(2) came into force on the 01 September 2023

Potential Right(s) Affected: Recognition of Professional Qualifications, Discrimination/Equal Treatment
Interim Report in respect of the Statement of changes to the immigration rules: HC1496 presented to Parliament on 17 July 2023

Date Legislation considered: 09 August 2023

Date Legislation in Force: 09 August 2023

Potential Right(s) Affected: Residencey
The Agriculture (Student Fees) Regulations (Northern Ireland) 2023

Date Legislation considered: 18 August 2023

Date Legislation in Force: 01 September 2023

Potential Right(s) Affected: Residence/Discrimination/Equal Treatment/ Workers/ Social Security
Education (Fees and Student Support) (Miscellaneous Amendment) (Scotland) Regulations 2023

Date Legislation considered: 20 July 2023

Date Legislation in Force: 01 August 2023

Potential Right(s) Affected: Residence
National Health Service (Charges to Overseas Visitors) (Amendment) Regulations 2023

Date Legislation considered: 10 February 2023

Date Legislation in Force: 18 February 2023

Potential Right(s) Affected: Residence/Discrimination/Equal Treatment
National Health Service (Charges to Overseas Visitors) (Amendment) (Wales) Regulations 2023

Date Legislation considered: 10 February 2023

Date Legislation in Force: 01 February 2023

Potential Right(s) Affected: Residence/Discrimination/Equal Treatment
The Education (Student Fees, Awards and Support) (Amendment) Regulations 2023

Date Legislation considered: 14 March 2023

Date Legislation in Force: 16 February 2023

Potential Right(s) Affected: Residence/Discrimination/Equal Treatment
The Education (Student Finance) (Miscellaneous Amendments) (Wales) Regulations 2023

Date Legislation considered: 31 March 2023

Date Legislation in Force: 22 February 2023

Potential Right(s) Affected: Residence/Discrimination/Equal Treatment
Immigration (Restrictions on Employment etc) (Amendment) (EU Exit) Regulations 2023

Date Legislation considered: 08 February 2023

Date Legislation in Force: 02 February 2023

Potential Right(s) Affected: Residence/Discrimination/Equal Treatment/Social Security Coordination
The Statement of Changes in Immigration Rules presented to Parliament on 09 March 2023 (HC 1160)

Date Legislation considered: 12 May 2023

Date Legislation in Force: 12 April 2023

Potential Right(s) Affected: Residencey

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What is Legislation Monitoring?

Legislation currently under consideration by the IMA

Legislation Monitoring Reports

Immigration and Asylum Bill

2025 Legislation Monitoring Reports

2024 Legislation Monitoring Reports

Retained EU Law (Revocation and Reform) Act 2023

2023 Legislation Monitoring Reports

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