Guidance

Complexity application routing solution: Family Reunion (Protection) (CARS(FR)) (accessible)

Published 8 April 2025

Version 1.0

About this guidance

This guidance sets out the arrangements which VSI (Visa, Status and Information Services) Family Reunion operations must follow from 02 April 2025, when routing and processing applications from customers applying for a visa under Appendix Family Reunion (Protection).

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 Family Reunion (Protection)

These applications are routed through CARS(FR) to determine the likely complexity of the application.

There are 2 possible outcomes of the routing:

• Single person centric attribute (PCA) non-complex direct routing (NCXDR)
• Single person centric attribute (PCA) complex direct routing (CXDR)

All applications routed through CARS(FR) 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 PCA NCX applications are referred to as NCX, and single PCA complex applications are referred to as CX.

Reference to caseworkers can be an AODM or EODM, reference to a senior caseworker can be an EODM, Entry Clearance Manager or Operations Manager.

Contacts

If you have any questions about the guidance and your line manager or senior caseworker 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 02 April 2025

Changes from last version of this guidance

New guidance.

Approach to routing

This guidance is to be used by all VSI Family Reunion entry clearance operations. It covers arrangements for dealing with applications made under Appendix Family Reunion (Protection) of the Immigration Rules.

This guidance outlines the way that Family Reunion operations are required to route and allocate applications for processing. CARS(FR) is an 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 Administrative Officer Decision-Maker (AODM) or an Executive Officer Decision-Maker (EODM). This facilitates an efficient and effective decision-making process, 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 Immigration Rules and in accordance with the  Family reunion guidance, and by making decisions based on the information provided by the applicant, supporting documents and any other factors relevant to the application at the date of decision. and by making decisions based on the information provided by the applicant, supporting documents and any other factors relevant to the application at the date of decision.

Decision makers at all grades must consider the validity, suitability and eligibility requirements of the rules and must be satisfied that they are met in order to issue a visa. AODMs will only be able to issue visas if they are satisfied the requirements of the Rules are met. They are not permitted to refuse applications. Where an AODM has concerns that the requirements of the Rules are not met, they must reroute the application to an EODM for further consideration. For further information see the Re-route as Complex (RCX) section of this guidance.

More rigorous scrutiny (or more in-depth assessment) can include any or all of the following - enrichment (additional checks), referral to a senior caseworker for case consideration or mandating a decision assurance check. A decision maker can also consider referral to other departments and/or request additional information through evidence or clarification from the Applicant/Sponsor in question. The appropriate scrutiny will be determined by decision makers or enrichment teams in line with guidance.

The CARS(FR) system has been considered under the Equality Act 2010 and the Public Sector Equality Duty. An Equality Impact Assessment (EIA) has been carried out covering the CARS(FR) process, as well as the use of 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 supported by a Ministerial Authorisation (MA) (in relation to race / nationality), or there is objective justification (in relation to age). 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, and if they identify any equality or discrimination issues, they must raise them without delay with the Central Services Team (CST) for further consideration.

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

Related content

Related external links

• Immigration Rules Appendix Family Reunion (Protection)

• Family reunion guidance

Complexity

CARS(FR) will identify 2 possible complexity outcomes:

Non-Complex (NCX)

Single PCA (SPCA) – 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 Appendix Family Reunion (Protection). For example, an applicant who has declared they are the spouse of someone with protection status, and who was previously mentioned in either the statement of evidence (SEF), witness statements, asylum interview or any evidence from that protected person’s legal challenge (where applicable) to a decision to refuse their initial asylum application would give a strong indication that they have formed part of the pre-flight family unit. It is likely the decision maker would be able to more easily verify that information, which will form part of the key considerations in determining the application. As such it is considered to be appropriate for such applications to be routed as NCX (more 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 a more in-depth assessment for a decision maker to determine whether the applicant meets the requirements of the Appendix Family Reunion (Protection) (less straightforward).

NCX applications would normally be processed by an Administrative Officer Decision-Maker (AODM), although where Family Reunion operations have no or insufficient AODMs to assess all NCX applications, an Executive Officer Decision-Maker (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(FR) routing process steps

All Family Reunion operations must ensure that relevant Family Reunion (Protection) applications are routed using these process steps to determine the complexity outcome.

Step 1: Bulk data tables

All applications covered by this guidance will be considered under Step 1.

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

Where an application matches a bulk table data, it must be recorded as single person centric attribute (PCA) complex direct routing through the abbreviation complex direct routing (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 a more in-depth assessment as defined in the section on 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.

Family Reunion operations can submit entries for inclusion in the bulk data table to Central Services Team (CST) with an accompanying profile document setting out the evidence and justification for including the entry. CST will consider whether to approve the entry. A centralised bulk table has been created for use by Family Reunion operations.

When CARS(FR) identifies a match to bulk data information, the application must be routed to the enrichment team for additional checks who must confirm the match. If CARS(FR) incorrectly identifies a match to a bulk data table, the enrichment team must not enrich the application and must route the application to an Executive Officer Decision-Maker (EODM).

For example, a telephone number can be added to the application form in more than one format. Applicant’s may choose to include (or not) international dialling codes, for example a UK telephone number could be presented as:

• 00 44 7999 111 111
• +44 7999 111 111
• 07999 111 111

Where CARS(V) identifies a match to the final 9 digits, in this instance 999 111 111, a caseworker must check that the telephone number matches in full the information in the bulk table data (in this instance dialling code if applicable + 7999 111 111).

Step 2: Single PCA direct routing

CARS(FR) 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 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 Appendix Family Reunion (Protection). For example, an applicant who has declared they are the spouse of someone with protection status and who was previously mentioned in either the statement of evidence (SEF), witness statements, asylum interview or any evidence from that protected persons legal challenge (where applicable) to a decision to refuse their initial application would give a strong indication that they have formed part of the pre-flight family unit.  It is likely the caseworker would be able to more easily verify that information which will form part of the key considerations in determining the application. As such it is considered to be appropriate for such applications to be routed as NCX (more 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 a more in-depth assessment for a decision maker to determine whether the applicant meets the requirements of the Appendix Family Reunion (Protection) (least straightforward).

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

You can find full descriptions of these indicators in the Complex Single PCA Table.

CARS(FR) identifies responses made by the applicant in the visa application and routes the application as single PCA non-complex (NCXDR) or single PCA complex (CXDR) based on the responses to the relevant PCA questions.

End of process outcomes

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

See: Illustration of the CARS(FR) process.

Family Reunion operations 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 ‘change complexity’.

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

If a Family Reunion operation 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.

Person-centric attribute (PCA) framework

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

CARS(FR) outcomes are determined by single PCAs, as explained earlier. 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)

A key consideration for applications in the Family Reunion (Protection) route is whether the applicant meets the requirements of these Immigration Rules. Further to this, the Family reunion guidance sets out a number of factors that can be considered by decision makers that may assist their decision-making process.

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(FR) 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 outcome as a basis for their assessment of an application.

Family Reunion operations are encouraged to provide feedback to aid in the ongoing evaluation and development of CARS(FR). Any additional attributes must be agreed by the Central Services Team (CST) and will require a full EIA.

Applications 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 rules or that an application is likely to require a more in-depth assessment. 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 Executive Officer Decision-Maker (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 a more in-depth assessment for a decision maker to determine whether the applicant meets the requirements of the rules.

For further detail see the Single person-centric attributes table below.

These applications are assessed in accordance with the Immigration Rules and Family Reunion guidance, and the decision maker must conduct a full subjective assessment in order to be satisfied whether, on the balance of probabilities, the requirements of the 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.

For further detail see the Single person-centric attributes table below.

These applications must still be assessed in accordance with the Immigration Rules and Family reunion guidance; however, a decision maker may be satisfied, on the balance of probabilities, 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. It may not be necessary to verify all the information given.

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Decision making

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

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

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

Re-route as complex (RCX)

Administrative Officer Decision-Makers (AODMs) must re-route a non-complex (NCX) application to complex (RCX) if:

• an application is subject to an adverse UKVI Operating Mandate match
• no evidence, other than the application form, is presented with the application
• they are unable to assess the application in full because, while some evidence has been submitted to enable a consideration to take place, some information is missing
• the application includes evidence which, following consideration, indicates irregularities, and the caseworker considers that further analysis or checks are required to confirm the veracity of the information submitted
• a previous application has been refused on suitability grounds (refusal under Part 9 of the Immigration Rules or, prior to 1 December 2020, refusal under part V3 of Appendix V, paragraph 320 of the Immigration Rules)
• 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
• they have identified that the applicant has raised Article 8 European Convention on Human Rights (ECHR) or leave outside the rules (LOTR) grounds to be considered
• they have identified that the application is fee paid or there is a linked application being considered under another route

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 documents and any other information provided. AODMs must not refuse applications, or draft refusal notices for Executive Officer Decision-Makers (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 must be completed in line with Family Reunion operations practices, but this would normally be done using the ‘Defer – Other’ event note and change the complexity rating in Proviso changed from NCXDR 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 applicant 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 NCX applications, and EODMs may assess all applications regardless of their category or routing.

Decision assurance

Decision assurance requirements are set out in the Family Reunion Review to Risk strategy, dated November 2024, which is compliant with OPI 1468 published on 11 March 2024.

Training

All decision makers receive the following training:

• Confirmation Bias
• Safeguarding Awareness
• Introduction to Family Reunion
• Introduction to Asylum
• Operating Mandate
• Mandatory Checks Process
• Endorsement Training
• Proviso training

Executive Officer Decision-Makers (EODMs) also receive the training in the following areas:

• Travel Document familiarity
• Considering Article 8 and Leave Outside the Rules (LOTR)
• Refusing and application

New AO decision makers should not be used to assess non-complex (NCX) applications until they have completed the above and met the required standard under the Administrative Officer Decision-Maker (AODM) Foundation Training course.

Existing operational AODMs, who have previously been trained and met the required standard, must read this guidance before continuing to assess NCX applications. Training also includes the latest update on the CARS tool and how AODMs assess their NCX decisions or re-route them as complex (CX).

Illustration of the CARS(FR) process

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