06.08.2026

Home Office accepts some IMA recommendations on EUSS delays inquiry — but rejects key recommendations

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The Independent Monitoring Authority for the Citizens’ Rights Agreements (IMA) has welcomed the Home Office’s acceptance of three recommendations made following its inquiry into delays in deciding some EU Settlement Scheme (EUSS) applications.  

The IMA is disappointed that the Home Office has rejected other recommendations, particularly in relation to strengthening data and oversight. However, the IMA welcomes the Home Office’s response, which acknowledges many of the issues identified by the inquiry.  

Under the Withdrawal and Separation Agreements (the Agreements), decisions must be taken within a reasonable timeframe in each individual case. The IMA’s inquiry identified a systemic breach of the Agreements’ requirement for decisions to be taken within a reasonable timeframe.  For some applicants, particularly those in complex or vulnerable situations, ongoing delays had a significant impact on their lives. 

The Home Office has accepted recommendations to improve processes for deciding applications, strengthening escalation mechanisms with international partners, and enhancing communication with citizens. These improvements should provide greater clarity and better responses for citizens. 

It has also described measures introduced during the period of the inquiry or under development in several areas where recommendations were not formally accepted at the time of the publication of the report. 

These measures have the potential to improve the efficiency and transparency of the system. The IMA recognises the time which has passed since we launched our inquiry. 

The IMA notes that several recommendations aimed at strengthening oversight, data use and stakeholder engagement were not accepted. The IMA remains of the view that systematic data collection and analysis assist the public to understand perceived or real experiences when applying to the EUSS. It also enables greater scrutiny and assurance that delays are not disproportionally impacting some groups. 

The IMA recognises that the Home Office depends on information from other organisations, including UK public bodies and safeguarding partners. The IMA remains of the view that strengthening oversight, to ensure that information effectively supports decision-making, can improve both the timeliness of application decisions and the experience of citizens applying to the EUSS. 

While arrangements are in place, in the IMA’s view stronger monitoring and clearer accountability could help ensure that delays in complex cases are minimised and that vulnerable applicants are not adversely affected. 

Miranda Biddle, Chief Executive of the IMA said: “We welcome the positive steps the Home Office has taken in response to our inquiry.  

“We will continue to engage with the Home Office, including reviewing how data and oversight can be strengthened in the future as we believe assurance is strengthened when data is in the public domain. 

“The IMA will now commence monitoring progress against the recommendations to ensure that compliance with the UK’s obligations under the Citizens’ Rights Agreements continues to be met.” 

Read the inquiry report on the IMA’s website and the Home Office response on GOV.UK.  

About the recommendations

The IMA’s inquiry made seven recommendations to the Home Office. The following were accepted: 

  • Recommendation 2: Steps to improve processes for deciding EUSS applications in areas where delays have occurred. 
  • Recommendation 4: Strengthening escalation mechanisms with international partners. 
  • Recommendation 7: Enhancing communication with applicants. 

The following recommendations were not accepted: 

  • Recommendation 1: More systematic data collection and analysis to assess whether delays are having a disproportionate impact on particular groups of applicants. 
  • Recommendation 3 and 5: Monitoring arrangements with other agencies to ensure timely responses, and communication with relevant public authorities in cases involving children, vulnerable adults and safeguarding concerns. While existing arrangements are in place, greater transparency and consistency in how these operate would help ensure that delays, especially in complex cases, are minimised and that vulnerable applicants are not adversely affected. 
  • Recommendation 6: Engagement with stakeholders and advocacy groups. The Home Office recognised the importance of stakeholder engagement but did not accept the recommendation to reconsider its existing arrangements. The IMA remains of the view that effective engagement with stakeholders and advocacy groups is essential to understanding the lived experience of applicants and identifying emerging issues. In light of recent changes to the support landscape, the IMA considers that regular review of engagement mechanisms can help ensure they continue to provide meaningful insight and support continuous improvement.