Guidance

Complexity application routing solution (family migration) (CARS(FM)) (accessible)

Published 10 April 2025

Version 1.0

About this guidance

This guidance sets out the arrangements which Marriage and Family Operational Teams must follow from 03 April 2025, when routing and processing applications from customers applying for a visa in a marriage and family route (CARS (FM)).

CARS(FM) must be used in all marriage and family operations decision-making centres (DMCs).

CARS(FM) processes all entry clearance applications that are considered by Marriage and Family Operational Teams. These are considered against the following sections of the Immigration Rules:

• Appendix Adult Dependant Relative

• Appendix Adoption

• Appendix Gurkha and Hong Kong military unit veteran discharged before 1 July 1997

• Appendix Child staying with or joining a Non-Parent Relative (Protection)

• Appendix FM: family members

• Appendix HM Armed Forces

• Part 8: family members

All marriage and family applications are routed through CARS(FM) to determine the likely complexity of the application. There are 4 possible outcomes of the routing:

• Non-complex:

  • NCXDR - Single person centric attribute non-complex (NCX) direct routing (DR)

  • NCXPCA - Multiple person centric attribute (PCA) non-complex

• Complex

  • CXDR - Single person centric attribute complex (CX) direct routing (DR)

  • CXPCA - Multiple person centric attribute complex (CX)

All applications routed through CARS(FM) can be assessed by Executive Officer Decision Makers (EODMs), but only applications routed NCX may be assessed by Administrative Officer Decision Makers (AODMs).

In this guidance single and multiple PCA NCX applications are referred to as NCX, and single and multiple PCA complex applications are referred to as CX.

Reference to decision makers can be an AODM or EODM, reference to a senior decision maker can be an EODM, Entry Clearance Manager or Operations Manager.

Contacts

If you have any questions about the guidance and your line manager cannot help you or you think that the guidance has factual errors, then email VSI Central Services Team (CST).

If you notice any formatting errors in this guidance (broken links, spelling mistakes and so on) or have any comments about the layout or navigability of the guidance then you can email the Guidance Review, Atlas and Forms team.

Publication

Below is information on when this version of the guidance was published:

• version 1.0

• published for Home Office staff on 03 April 2025

Changes from last version of this guidance

This is new guidance.

Approach to routing

This guidance outlines how Marriage and Family Operational Teams are required to route and allocate applications for processing depending on their likely complexity.

CARS(FM) is a semi-automated routing system that differentiates between complex (CX) and non-complex (NCX) applications so that the application can be allocated to an appropriate grade of decision maker - an AODM or an EODM - or for directive enrichment where the application is routed as CXDR. This facilitates an efficient and effective routing process directing work to the most appropriate grade of decision-maker based on declared applicant attributes, but it does not remove the need for individual decision makers to consider all the relevant information for an application against the Immigration Rules.

Decision makers at all grades must continue to assess each application on its individual merits against the relevant marriage and family routes taking into consideration the supporting documents and any other factors relevant to the application at the date of decision.

Decision makers at all grades must consider the suitability and eligibility requirements of the relevant Immigration Rules and must be satisfied that they are met in order to issue a visa. AODMs will only be able to issue visas for applications routed as NCX if they are satisfied the requirements of the Immigration Rules are met. AODMs are not permitted to refuse applications. Where an AODM has concerns that the requirements of the rules are not met, they must re-route the application to an EODM for further consideration. See Re-route as Complex (RCX).

Applications which are direct routed as complex may require additional checks or assurance, for example enrichment, such as interviewing the applicant or sponsor.

Where an application is routed as CX, the application may be subject to additional checks or assurance, and these will be defined by the direct routing or determined by decision makers or enrichment teams in line with the VSI Cross Cutting Enrichment SOP.

Equality Impact Assessment

The CARS(FM) system has been considered under the Equality Act 2010 and the Public Sector Equality Duty. Equality impact assessments (EIAs) have been made covering the CARS(FM) process, as well as the use of bulk data tables and each person-centric attribute in the routing process.

The EIA considers the impacts on protected characteristics and ensures that the system does not include direct discrimination unless there is objective justification (in relation to age).

CARS(FM) does not differentiate on the basis of race (nationality) and any indirect discrimination is justified in the accompanying EIA. The EIA also ensures that any indirect impact is justified and is a proportionate means of pursuing the legitimate aim of ensuring the overall integrity of the immigration system.

VSI staff are required to continually review the impact of policies and processes. If they identify any equality or discrimination issues, they must raise them without delay with CST for further consideration.

While CARS(FM) uses complexity indicators to reach a complexity outcome, it is not automated decision making or machine learning. CARS(FM) will identify the complexity level so that the application can be routed to a relevant decision maker grade.

Related content

Re-route as Complex (RCX)

Related external links

Immigration Rules

Complexity

CARS(FM) will identify 2 possible complexity outcomes:

Non-complex (NCX)

Single PCA – NCX direct routing (NCXDR): where an application matches a positive attribute which has been identified as a strong indicator that the applicant is likely to be able to easily demonstrate they meet the requirements of a marriage and family route. For example, an applicant who is applying as a spouse of a serving member of HM Armed Forces is likely to be able to demonstrate that the income and accommodation requirements of the rules are met (because both will be provided by the British Army). The application is considered to be appropriate for NCX routing (most straightforward) because a decision maker should be able to easily verify that information, which will be a key factor in determining the application.

Multiple PCAs – NCX (NCXPCA): where an application matches multiple positive attributes which have each been identified as an indicator that the applicant is more likely to be able to demonstrate that they meet the requirements of a family migration route. As these attributes are not as strong as the single PCAs, an application must match all 11 attributes to be routed as NCX (straightforward).

Complex (CX)

Single PCA – CX direct routing (CXDR): where an application matches a bulk data table entry or a PCA which has been identified as a strong indicator of complexity, such as answering ‘yes’ to any criminality question, this indicates that the application is likely to require more rigorous scrutiny for a decision maker to determine whether the applicant meets the requirements of a marriage and family route (least straightforward).

Multiple PCAs – CX (CXPCA): where the application does not match all 11 positive attributes this means a more detailed assessment will be required. The application should therefore be routed as complex for consideration by an EODM (less straightforward).

NCX applications would normally be processed by an AODM, although where Marriage and Family Operational Teams do not have a sufficient number of AODMs to assess all NCX applications, an EODM should make the decision to avoid processing delays.

An AODM is only permitted to assess NCX applications, but an EODM can assess applications of either complexity.

CARS(FM) routing process steps

Marriage and Family Operational Teams must ensure that relevant marriage and family applications are routed using these process steps to determine the likely complexity of the application.

Step 1: Bulk data tables

All applications covered by this guidance will be considered in line with Step 1.

CARS(FM) will automatically identify applications which match a bulk data table entry by checking information contained in the visa application form against a table listing the attributes or known harm data strings.

Where an application matches a bulk data table entry, it must be recorded as single PCA complex direct routing through the abbreviation CXDR. The complexity case marker is not part of the decision-making process but is used for routing purposes only.

An application marked as CXDR must be routed for additional checks or assurance as defined in the section Approach to routing.

Step 2 does not apply where an application is routed CXDR in step 1.

Bulk data tables

Bulk data tables are used to identify applications that include data, such as email addresses and telephone numbers, that have been identified as having been used in previous fraudulent applications.

Marriage and Family Operational Teams can submit entries for inclusion in the bulk data table to CST with an accompanying profile document setting out the evidence and justification for including the entry. CST will then consider whether to approve the entry.

When CARS(FM) identifies a match to bulk data information, the application must be routed to the case preparation team for additional checks or assurance who must confirm the match. If CARS(FM) incorrectly identifies a match to a bulk data table, the case preparation team must not enrich the application and must route the application to an EODM.

For example, a telephone number can be added to the application form in more than one format. Customers may choose to include (or not) international dialling codes, for example:

• a UK telephone number could be presented as 00 44 7999 111 111 or +44 7999 111 111 or 07999 111 111 - where CARS(FM) identifies a match to the final 9 digits, in this instance 999 111 111, a decision maker must check that the telephone number matches in full the information in the bulk data table (in this instance dialling code if applicable + 7999 111 111)

Step 2: Single PCA direct routing

CARS(FM) uses PCAs that have been identified as strong indicators (‘single PCAs’) either that an applicant is likely to be able to easily demonstrate that they meet the Immigration Rules or that an application is likely to require more detailed assessment.

Non-complex (NCX)

Single PCA – NCX direct routing (NCXDR): where an application matches a positive attribute which has been identified as a strong indicator that the applicant is likely to be able to easily demonstrate they meet the requirements of the relevant Immigration Rules. For example, an applicant who is applying as a spouse of a serving member of the armed forces is likely to be able to demonstrate that the income and accommodation requirements of the Immigration Rules are met (because both will be provided by the British Army). As a decision maker should be able to easily verify that information, which will be key factors in determining the application, the application is considered to be appropriate for NCX routing.

Complex (CX)

Single PCA – CX direct routing (CXDR): where an application matches a bulk data table entry (as per step 1) or a PCA which has been identified as a strong indicator of complexity, such as answering ‘yes’ to any criminality question, this indicates that the application is likely to require additional checks or assurance for a decision maker to determine whether the applicant meets the requirements of the relevant Family Migration rules.

Where an application matches one of these single PCAs they will be routed as NCXDR or CXDR, as appropriate, and allocated to either an AODM (NCXDR only) or EODM.

You can find full descriptions of these indicators in the Complex Single PCA Table and Non-Complex Single PCA Table

CARS(FM) identifies responses given by the applicant in the visa application form and routes the application as single PCA non-complex (NCXDR) or single PCA complex (CXDR) based on the responses to the relevant PCA questions or a bulk data table match.

Step 3: Multiple PCA routing

There are a further 11 multiple PCAs (person-centric attributes)) which will be applied to applications by CARS(FM) where there is no routing under steps 1 and 2.

These PCAs are positive attributes which have each been identified as an indicator that the applicant is more likely to be able to easily demonstrate that they meet the requirements of the relevant Immigration Rules, if other positive attributes are also met.

CARS(FM) identifies responses given by the applicant in the visa application form and routes the application as multiple PCA complex (CXPCA) or multiple PCA non-complex (NCXPCA) based on the responses to the relevant PCA questions.

Where all 11 multiple PCAs are met the application must be recorded as NCXPCA. In all other cases the application must be recorded as CXPCA.

End of process outcomes

At the end of the step process CARS(FM) will provide a routing outcome.

There is an illustration of the CARS(FM) step process at the end of this document.

Marriage and Family Operational Teams must ensure they classify application complexity by using ‘Change risk rating’ in Proviso and selecting the appropriate complexity routing. The user must record the change reason as ‘outcome of streaming tool’.

The complexity codes are used to route applications to the appropriate decision maker grade. Marriage and Family Operational Teams can generate management information (MI) using the Business Activity Monitoring (BAM) overview or the Proviso ‘Event Note Search’.

If a Marriage and Family Operational Team wishes to introduce any sub codes to be added to the spare code to assist workflow efficiency, they may do so but only after consultation with CST.

Related content

Complex Single PCAs table

Non-Complex PCAs table

Multiple PCA Table

Person-centric attribute (PCA) framework

The aim of PCAs is to indicate the likely complexity of an application in order to allocate it to the appropriate decision maker for assessment.

CARS(FM) outcomes are determined by single PCAs, as explained earlier, and multiple PCAs, as follows later. Each outcome is given a complexity rating (see the Complexity section for descriptions of these outcomes):

• single PCA - non-complex direct routing (NCXDR)

• single PCA - complex direct routing (CXDR)

• multiple PCA – non-complex (NCXPCA)

• multiple PCA – complex (CXPCA)

A key consideration for applications under a marriage and family route is whether the applicant meets the Immigration Rules, and the guidance sets out a number of factors that can be considered by decision makers that may help in making that assessment. As well as considering all the relevant Immigration Rules for the application route, decision makers must also consider the application against Part 9: grounds for refusal of the Immigration Rules.

Some applicants will be able to demonstrate that they meet the requirements of the Immigration Rules more easily than others. For example, some applicants will be able to point to objective evidence that links to factors which are relevant to the rules assessment – such as sponsor is employed by the British military. Others, however, may have to declare criminality which may be a ground for refusal.

The PCA framework identifies attributes that are relevant to the assessments that decision makers need to make and that are common either to applications which are considered complex or to applications which are considered non-complex. The visa application form includes questions which enable applicants to provide the relevant information and CARS(FM) matches those responses to the identified attributes.

Once an application is assigned to a decision maker, based on its complexity outcome, the decision maker must assess it on its individual merits. Decision makers must not use the complexity routing as a basis for their assessment of an application.

Marriage and Family Operational Teams are encouraged to provide feedback to aid in the ongoing evaluation and development of CARS(FM). Any additional attributes must be agreed by CST and will require an amendment to the CARS (FM) EIA.

Applications under this guidance where single PCA direct routings will be used

Single PCAs are strong indicators either that an applicant is likely to be able to easily demonstrate that they meet the Immigration Rules or that an application is likely to require more rigorous scrutiny. These will be allocated to the appropriate grade of decision maker based on the single PCA direct routings.

Allocation directly as complex (CXDR)

Single PCA CX direct routing applications must be assessed by an EODM.

These applications are considered to be the least straightforward to assess. Applications directly routed as CX include an attribute that indicates that the application is likely to require additional checks or assurance for a decision maker to determine whether the applicant meets the requirements of the Immigration Rules.

See the Complex Single Person-Centric Attributes Table below.

These applications are assessed in accordance with the relevant marriage and family route rules and guidance, and the decision maker must conduct a full assessment in order to be satisfied whether the requirements of the Immigration Rules are met.

Allocation directly as non-complex (NCXDR)

This routing – NCXDR - can only apply to applications that are not routed as CXDR.

These applications are considered to be the most straightforward to assess. Applications directly routed as NCX include at least one single PCA attribute that is a strong indicator that the applicant is likely to be able to easily demonstrate they meet the requirements of the Immigration Rules.

See the Non-Complex Single Person-Centric Attributes Table below.

These applications must still be assessed in accordance with the relevant marriage and family route Immigration Rules and guidance; however, a decision maker may be satisfied that the requirements of the rules are met by verifying the statements made in the application against the supporting evidence and any other information provided. As the evidential requirements for the relevant marriage and family route are set out in Appendix FM-SE: family members specified evidence, decision makers will be required to validate all the information provided to be satisfied the applicant meets the requirements of the rules.

Applications under this guidance where multiple PCA outcomes will be used

As set out above, single PCAs are strong indicators that an applicant is likely to be able to easily demonstrate that they meet the Immigration Rules or that an application is likely to require more detailed assessment. These will be allocated to the appropriate grade of decision maker based on the single PCA direct routings.

Applications that have not been directly routed as CX or NCX through a single PCA will be considered against a further set of PCAs to determine likely complexity. CARS(FM) uses 11 attributes for the multiple PCA outcomes. These are positive attributes that indicate that an application is less likely to be complex, but as they are not as strong as the single identifiers described above an applicant must meet all of these attributes to be considered appropriate for routing as NCX to an AODM.

The 11 multiple PCAs are shown in Multiple Person Centric Attributes Table. These attributes are reliant on information provided by the applicant or third party within the visa application form.

To meet the threshold for routing to NCXPCA, all PCAs must be met. If at least one attribute is not met the application will be routed CXPCA.

Meeting the multiple PCAs threshold means that an applicant has 11 positive attributes. In combination this is likely to mean that the applicant can readily demonstrate they meet the requirements of the of the relevant marriage and family route rules and the decision making will be NCX.

If the multiple PCA threshold is not met it means that the applicant does not have sufficient indicators of non-complexity, and it is not possible through the routing process to determine the complexity of the application. It is therefore appropriate to assign these applications a CX outcome and refer them to senior decision makers.

Applications meeting the threshold for routing to NCXPCA must still be assessed in accordance with the relevant marriage and family route rules and guidance. However, a decision maker may be satisfied that on the balance of probabilities the requirements of the rules are met by verifying the statements made in the application against the supporting evidence and any other information provided. It may not be necessary to verify all statements made.

Where an application does not meet all 11 multiple PCAs, the application will be routed as multiple PCA CX (CXPCA). Multiple PCA NCX (NCXPCA) outcomes can be assessed by an AODM, but multiple PCA CX (CXPCA) outcomes must be assessed by an EODM.

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Minor children

In the case of minor children (under the age of 18) travelling in a family group, we should reasonably accept the outcome of the parents or lead applicant’s attributes as being relevant to the child. In these cases, minor children should be recorded as having the same complexity outcome as their parent or lead applicant.

In the case of an accompanying adult who is not a direct relative of the main applicant the application complexity will be determined by CARS(FM). Marriage and Family Operations should link the applicants within Proviso to aid in allocation and preventing the applicant being assessed separately from the main group.

Related content

Complexity section

Step 1

Decision making

Marriage and Family Operational Teams must maintain a clear distinction between CARS(FM) routing and decision making and ensure that the routing of a case does not influence the decision on an application. The routing based on the outcome of CARS(FM) must only be used to indicate the likely complexity and subsequent handling.

All decision making in CARS(FM) routed applications must be made in accordance with the relevant Immigration Rules and guidance.

Decision makers are required to conduct operating mandate checks on all applications.

Re-route as complex (RCX)

AODMs must re-route a NCX application to complex (RCX) if:

• an application is subject to an adverse match in line with the UKVI Operating Mandate

• no evidence, other than the application form, is presented with the application

• if a piece of evidence is missing, which the AODM believes the applicant can provide and which will then lead to the application being issued, the AODM can request the evidence without marking the application as complex (however, if multiple pieces of evidence are missing, and it is unclear whether the application will meet the requirements of the rules, then the application should be re-routed as complex)

• the application includes evidence which, following consideration, indicates irregularities, and the decision maker considers that further analysis or checks are required to confirm the veracity

• a previous application has been refused on suitability grounds (previous suitability grounds under any application route should be considered a complex indicator)

• they have any concerns about modern slavery or safeguarding.

• they have any other doubts about the evidence presented

• they have any other concerns that the Rules might not be met

Complex and non-complex decision making

AODMs are primarily trained to make administrative decisions, where the statements in the application can normally be verified by checking against the supporting evidence and any other information provided. AODMs must not refuse applications, or draft refusal notices for EODMs. These are skills for EODMs, who receive additional training and guidance on considering refusals and drafting refusal notices.

When an AODM ‘re-routes as complex’ (RCX) an application to an EODM, they must complete a full case note in Proviso explaining the reasons and defer the application in the Proviso system. The deferral event note should be completed in line with the Marriage and Family Operations practices, but this would normally be done using the ‘Defer – Other’ event note and change the complexity rating in Proviso from NCXDR or NCXPCA to RCX to aid workflow routing and MI counting for the number of cases which are being re-routed.

EODMs must assess each application against the Immigration Rules and each application will be decided based on the information provided by the customer and any other relevant factors at the date of decision. There must be no presumption that an application will result in a particular outcome based on it being routed to or re-routed to an EODM.

AODMs may only assess single PCA NCX applications, and EODMs may assess all applications regardless of their category or routing.

Decision assurance

Decision assurance requirements are set out in the Marriage and Family Review to Risk strategy, which is compliant with OPI1468, published on 11 March 2024.

Training

The Marriage and Family Entry Clearance training package is divided into 3 separate modular training packages to account for the complexity of different case types. This also includes a comprehensive operating mandate course which requires an assessment to be completed and an acknowledgement of the operating mandate guidance to be signed.

Once initial classroom-based training is completed, a period of focussed mentoring support and quality assurance of new cases then takes place. The training material is reviewed regularly to account for policy updates, operational instructions and procedural changes that need to be accounted for. A training team comprising of specialist decision makers, led by an entry clearance manager retains overall responsibility for the delivery of these training courses.

Candidates are not placed onto the second and third modular training until the first module has been successfully passed. Refresher training for experienced decision-makers is completed where there is an operational need to do so, for example, in the event of significant changes to the Immigration Rules.

Enrichment

Enrichment is one of the types of additional checks and assurances that can be applied to an application. Examples of enrichment include, document verification, requests for further evidence and interview of the applicant and/or of a sponsor.

The framework will have 3 levels of checks:

• UKVI Operating Mandate checks

• bulk table and directed routed applications (where applicable) – where an application has matched an entry in a bulk data table or directly routed complex as a result of a match to a single person centric attribute

• decision maker directed checks – where a decision maker identifies any irregularity in the information or evidence provided the application may be referred for enrichment on a case-by-case basis.

Operating Mandate checks must be conducted on all applications.

Applications routed CX or RCX could be subject to additional enrichment which may include an interview. This would be at the discretion of the decision maker and is covered below.

AODMs would not normally commission any enrichment checks as the type of activity requiring a check for an NCX application is likely to require to be re-routed to complex (RCX) in line with the relevant marriage and family route guidance. Any referral for enrichment should be agreed with a senior decision maker.

In some circumstances a senior decision maker may enable an AODM to conclude an NCX application, that the AODM has raised a concern about, without it being re-routed or additional checks being completed. The senior decision maker must have considered the wider evidence and must be satisfied that a decision can be reached on the basis of that information. In these circumstances, the senior decision maker must justify their decision in an event note in Proviso before enabling the AODM to proceed.

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Related content

Re-routed as complex

Illustration of the CARS (FM) process

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