Transparency data

6 September 2022: Future Border and Immigration System (FBIS) Programme Accounting Officer Assessment

Updated 6 December 2024

Background and context

It is normal practice for Accounting Officers to scrutinise significant policy proposals or plans to start or vary major programmes, and then assess whether they measure up to the standards set out in Managing Public Money. From April 2017, the government has committed to make a summary of the key points from these assessments available to Parliament when an Accounting Officer has agreed an assessment of projects within the Government’s Major Projects Portfolio.

Summary

The Future Border and Immigration System (FBIS) programme is delivering on HMG’s strategy for legal migration and border control and is underpinned by a clear ambition to put in place the world’s most effective and secure border system: one that enables and supports growth and prosperity for the UK; one that is simple to understand and operate; and one which prioritises public protection, by making our borders more secure. Our transformation of the border will provide benefits for all our customers, the public, industry and visitors.

Overall, our main challenge is to continue to deliver at pace, on time and on budget using the foundations we have put in place to good effect. Our top issue remains scope creep and we continue to manage this carefully to ensuring that impacts of changes in scope are well understood and that delivering major transformation remains our priority.

Given the low level of risk and uncertainty set out in this advice, as well as successful delivery to date, I consider that the FBIS programme conforms to all four Accounting Standards of regularity, propriety, value for money and feasibility.

Regularity

The FBIS Programme is funded in accordance with the Supply and Appropriation Act and the annual vote to implement government policy.

The FBIS programme relies on existing primary legislation, and in particular the Immigration Act 1971 provides the basis for the regulation of entry and stay in the UK. The Immigration Rules, which are laid before Parliament under section 3 of that Act, set out the practice that will be followed. Changes to the scope and operation of the immigration system are made through the Immigration Rules and a framework of secondary legislation as required.

We ensure there is a fit for purpose UK immigration system following the UK’s exit from the European Union and the ending of free movement for EEA nationals through the Immigration and Social Security Co-Ordination (EU Withdrawal) Act 2020. Biometrics, in relation to applications to come to the UK, are collected under the UK Borders Act 2007 and the Nationality, Immigration and Asylum Act 2002.

We have regular Ministerial meetings to discuss policies, design and delivery – this ensures that Ministerial approval is sought for key elements of the Programme.

We have robust governance and assurance in place including approval of the Programme Business Case (PBC) by the Home Office Finance and Investment Committee, the Major Projects Review Group (MPRG), regular interactions and reviews by the Infrastructure and Projects Authority (IPA). FBIS is a part of the Government Major Projects Portfolio (GMPP) and reports quarterly to the IPA.

Internally, we have a clear structure of Programme and Project Boards and a Finance and Workforce Committee that meet regularly to monitor delivery, manage dependencies, mitigate risks and ensure compliance with financial management requirements.

The Programme is not considered novel, contentious or repercussive, so HMT approval has not been sought on that basis. HMT have approved the FBIS PBC.

Affordability

Funding for the programme over the next three years (2022/23 to 2024/25) was provided as part of the Department’s Spending Review 2021 settlement. Remaining years investment will be considered as part of subsequent Spending Reviews.

Refer to Value for Money section for further information on costs.

Regularity summary:

Regular engagement with Ministers and OGD ensures our strategy, key design and delivery components are approved and set out in public facing published strategy documents. There is a framework of legislation underpinning the regulation of immigration, in particular the Immigration Act 1971 (which the Immigration Rules are laid under), the Immigration and Social Security Co-Ordination (EU Withdrawal) Act 2020 and the Nationality and Borders Act 2022.

Funding for the Programme up to 2024/25 was approved and provided as part of the Department’s Spending Review and we expect the variances to be manageable within the Programme’s budget.

I therefore consider it to conform to the Regularity Accounting Officer standard.

Propriety

FBIS is underpinned by clear Ministerial and governmental ambition to put in place the world’s most effective and secure border system:

• one that enables and supports growth and prosperity for the UK;
• one that is simple to understand and operate; and
• one which prioritises public protection, by making our borders more secure.

The FBIS strategy statement New Plan for Immigration: Legal Migration and Border Control was published in July 2022 alongside the Border Force review as part of a wider focus on the Home Secretary’s commitment to securing our borders. The system ensures we are an attractive global destination for highly skilled people that help the UK to prosper.

To ensure our new system is simple to understand and operate, we are putting the customer at its heart, ensuring it is easier to navigate and digital by default. It is a global system that treats its customers as individuals, making it fairer and simpler while continuing to ensure that the opportunities for legal migration to the UK are not abused. This includes transformation of our sponsorship system for employers and educational establishments.

Many of our customers already benefit from a fully digital journey, including over six million applications to the EU Settlement Scheme (EUSS). The changes we have already made enabled us to quickly adapt to meet the needs of those impacted by major international events such as the Covid-19 pandemic and the ongoing Russian invasion of Ukraine. We want to go further, with customers experiencing a slick digital interface akin to their daily interactions with businesses or services.

Our system will prioritise public protection, by making our borders more secure and transforming the border with visible changes to security measures, queue times and passenger experience. We will achieve this by understanding more about people coming to the UK before they travel, enabling us to manage flow and interventions at the border based on individual circumstances and reduce queues. We will maximise the use of pre-travel interventions to prevent harmful people reaching our border in the first place. Most people crossing the UK border will experience an eGate style arrival using automation as their only point of contact at the border. Eventually we want the border experience to be contactless for the majority of people.

These principles ensure that UK citizens and others who are in the UK legally have confidence in the effectiveness and efficiency of our system. We are committed to openness and transparency in understanding the impact of the points-based system and published a revised Equality Impact Assessment in February 2022.

We continue to review equalities impacts in relation to the new system. Robust evaluation will continue ensuring our approach to policy and delivery is led by the evidence. To protect the vulnerable, we also continue to engage with those working to tackle modern slavery, including the Independent Anti-Slavery Commissioner. Modern slavery and human trafficking have absolutely no place in our society. We are committed to fortifying our immigration system ensuring victims are protected and offenders prosecuted.

Governance structure

We ensure outcomes are delivered through a structured approach to enable the Programme to run consistently and successfully. The governance structures that support FBIS delivery and performance provide for external and internal challenge. The Boards are listed below:

• Government level: Number 10/Cabinet Office/MPRG. There are deep dive challenges on FBIS delivery including manifesto/public commitments.
• Ministerial Level: The FBIS Ministerial Board provides challenge on delivery, Chaired by the Minister for Future Borders and Immigration.
• Home Office Corporate level: The Finance & Investment Committee (FIC), which holds delegated responsibility from the Home Office Executive Committee (ExCo) for securing delivery of the Home Office portfolio of programmes.
• Group level: The Migration and Borders Transformation Board provides challenge on delivery of agreed FBIS programme scope and performance in line with the vision for the end state architecture. This is currently attended by Home Office NED, who acts an independent critical friend to the FBIS programme
• FBIS Programme Board – deep dives on strategic or cross cutting topics e.g. scope, data, communications and stakeholder engagement with attendance from an IPA critical friend.
• Finance & Workforce Committee – SRO’s monthly review of financial performance with key members of the programme.
• Delivery Boards – Delivery Directors holding Project Managers to account.
• Change Forum – a forum to ensure key changes are adequately challenged and impacts are assessed by key stakeholders.

Financial management

Funding for the programme was provided from HMT as part of the Spending Review. Our funding is then allocated via FIC, who also approve our business cases and provide a level of scrutiny and challenge to ensure the programme is aligned with Ministerial commitments.

Our annual allocation (budget vs forecast) is monitored at the monthly Finance & Workforce Committee (FWC) meetings. The FWC oversees, reviews, and endorses all the Programme’s finance and workforce planning activities, promoting a joined-up way of working.

The SROs review financial performance and our future financial plans with the Delivery Directors, Project Managers and key stakeholders to ensure FBIS remains within departmental expenditure limits. This ensures Finance and the FBIS Programme are aligned, and that forecasts, assumptions and dependencies are robust and accurate.

The SROs are ultimately accountable for the allocated budget for the Programme.

Risk Management

We have developed and implemented a comprehensive risk and issue management strategy that aligns with the Government Functional Standard for Project Delivery.

Programme level risks and issues are updated monthly and reviewed by the FBIS Programme Board and Ministerial Board to ensure that focus is on the right risks and to ensure good progress on mitigations to drive down risk scores in line with risk appetite.

Key FBIS risks are highlighted in the feasibility section of this document.

Propriety summary:

In summary, I consider FBIS strategy and direction aligns with Government commitments. I believe there is adequate governance in place to adhere to the principles documented in Managing Public Money and conform to the Propriety Accounting Officer standard.

Value for Money

Delivery of the FBIS programme outcomes will provide the United Kingdom with significant financial and non-financial benefits. The latest PBC provided a detailed assessment against our preferred option. The Net Present Social Value (NPSV) of FBIS is £12,180m (over 10 years, rounded to the nearest £100m, 2021/22 prices). A significant proportion of the quantified benefits come from the fiscal benefits attributable to the introduction of new routes.

As per the latest PBC, including optimism bias (OB), FBIS requires £937m of implementation costs over the life of the programme and ongoing running costs of £3,037m (2021/22 to 2030/31). Future benefits forecasted for FBIS totals £3,290m (2021/22 to 2030/31) including OB. Any sunk cost or realised benefits have not been included as per HMT Greenbook requirements.

FBIS delivers on Ministerial commitments, external recommendations, and Departmental objectives. It also delivers significant value to society with monetised and non-monetised benefits to the Home Office.

Key cashable benefits include:

• Income due to new routes and Electronic Travel Authority (ETA);
• Reduction in use of Biometric Resident Permits (BRP) and vignettes;
• Commercial cost savings; and
• Operational efficiencies.

Quantified wider benefits include:

• Fiscal benefits and additional tuition fee revenue for the introduction of the Graduate route.
• Other quantified wider benefits include additional fiscal benefits arising from a speedier sponsorship system and reduced admin burden for sponsors.

Analysis was also developed to quantify wider benefits that are however not included in the NPSV because they are attributable to migrants rather than to UK residents. These benefits include:

• Benefits to migrants due to not having to attend a UK VAC for in-country visa applications. This benefit has been quantified by estimating the value of saved travel time, in the form of saved travel costs and increased customer leisure time.
• Benefits from reduced waiting time at the border for non-UK passengers from the introduction of ETAs. By allowing new cohorts of passengers to use eGates to pass through the border, the introduction of ETAs is expected to bring a welfare benefit from reduced queuing time for these passengers.

Non-quantified benefits

The following benefits could not be quantified due to difficulties in baselining or assessing the impact quantitively:

Efficiency and Effectiveness

More efficient case working and checking procedures should result in reduced time working on refused applications as well as the reduction of costs in Other Government Departments (OGD) e.g. having accurate and up to date information to inform their decisions. This may include less money lost by not giving access to services (such as public funds and free NHS treatment) to applicants who have no entitlement.

Security & Criminality

FBIS is also expected to generate wider benefits from improved security and reduced criminality risks. Increased automated and digital checks will make it harder for illegal migrants to continue to live in the UK, and act as a deterrent to those who would otherwise seek to abuse the system.

The ETA scheme, by which visitors to the UK will request advance digital permission before arriving at the border, will enable the HO to build a better intelligence picture of those arriving in the UK and identify those who overstay. This will also lead to more accurate data to support operational planning especially towards high harm individuals and inform decisions about who should be given permission to travel to the UK.

Strengthening data systems will enable better targeting of enforcement interventions leaving teams better able to identify and disrupt organised criminals and those who commit serious crimes of violence and protecting victims.

Customer experience/outcome

FBIS will deliver tools to improve customer experience, reduce failure rates and reduce customer contact centre demand will ensure a user-friendly system, that attracts the brightest and the best from around the world.

Increased use of biometric information will result in increased user convenience as customers do not have to attend a VAC whilst continuing to maintain high levels of security. Providing a quick and easy way for migrants to understand and establish their entitlements should improve their experience and make it easier for them to be compliant with the restrictions placed on their leave and entitlement.

Improving the customer experience will improve the reputation of the Home Office and the UK as a place to visit. This will meet the Home Office’s strategic aim of providing a modern, simple, high quality immigration system with the aim of attracting high quality applicants.

Non-quantified costs and disbenefits

Any change could result in unintended behavioural consequences. Tightening one route can always lead to uncompliant behaviour in a different form. For example, travellers may be displaced into other routes rather than being deterred i.e. from air passenger routes to tourist maritime and rail routes.

A further potential behavioural impact is the potential for visitors to be deterred through the introduction of an ETA fee. While Home Office research on the evidence of a price elasticity of demand for visas has found the demand for visas to be relatively inelastic to changes in its price, the introduction of ETAs has the potential to work against some of the positive behavioural response expected from making the customer journey more attractive.

Benefits delivered to date

The total benefits FBIS has delivered to date includes income benefits related to new and amended routes as well as commercial savings relating to the decommissioning of certain Foreign, Commonwealth and Development Office Services (FCDOS) services. At Q3 2022, the cumulative income to date was £159.4m and the cumulative FCDOS SLA saving was £2.6m.

Sensitivity analysis

As part of the PBC October 2021, we have undertaken extensive modelling of the costs and benefits and have conducted sensitivity analysis across various assumptions of Visa Demand Volumes, Electronic Travel Authority Fees, COVID19 impact on Graduate route, contingency levels and delays to implementation. The analysis showed the range of outcomes were unlikely to significantly impact the NPSV.

Value for Money summary:

FBIS is based on a combination of process and policy transformation which result in a strong positive net present social value to the UK. This option delivers monetised and non-monetised benefits, meets the Government’s manifesto commitments and 2025 Border Strategy, and is strategically aligned to proposals set out within our Ministerial commitments.

Taking account the assessment provided, overall, I consider FBIS is a sound use of public funds that will deliver significant financial and non-financial benefits to the United Kingdom and that it conforms to the Value for Money Accounting Officer standard.

Feasibility

Successes to date

We have achieved a significant amount since the first tranche of activities where we implemented a single points-based system as transitional arrangements ended on 31 December 2020 following the UK’s exit from the EU.

Below are some of the key FBIS achievements since completion of our first tranche:

• Over 20 new routes rolled out including the Skilled Worker Route, Global Talent, Student, Graduate and Scale-Up routes. In addition, new safe and legal routes, such as the Hong Kong British Nationals (Overseas) route, Afghan Citizens Resettlement Scheme, various Ukrainian Schemes and supporting Chagossians.
• Simplifying our Immigration Rules to cut through the complexities and make the Rules clear, consistent and accessible.
• A digital application form for the vast majority of our customers and millions of applicants can now upload their facial biometrics using a smartphone removing the need to visit a VAC.
• Many people now receive an eVisa – a digital version of their immigration status which they can access via an online account.
• Foundations have been laid for ETAs and e-visas by piloting real time information sharing with carriers
• Launched a new intuitive and interactive tool - the Skilled Worker Eligibility Checker which makes it easier for both workers and employers to understand if a particular job is eligible.
• We have a dedicated Resolution Centre, which is open seven days a week for telephone and email enquiries. The centre now provides telephone and email support to customers with an eVisa or using the online immigration status services.

Although we have achieved the above, this also included delivery of additional scope to respond to international events and supply chain issues. This included deliverables such as the BN(O) routes, temporary routes for poultry workers, HGV drivers and pork butchers in late 2021. Most recently we have implemented a range of Ukraine Schemes (Ukraine Family Scheme, Homes for Ukraine, Ukraine Extension Scheme, Ukraine Eligible Minors Scheme) which are now fully digital and constitutes one of the fastest implemented and biggest visa programmes in UK history.

Key future deliverables

Using the current structures in place and solid foundations from the past few years, we remain on track to deliver our plans to achieve the following:

• We have started work on more simple and tailored guidance on gov.uk for users. We intend to use more ‘how to’ videos to show step by step how the system works and help users successfully complete tasks such as applying for an ETA, proving their identity or registering as a sponsor.
• Reforms to the sponsorship system including streamlining processes for sponsors, applicants and case working. The online management system will allow quicker decision making as sponsors are able to make changes to their account and automated data checks will be introduced by 2025.
• A seamless, fully digital, end-to end journey for customers interacting with the immigration system by 2025. This includes enabling more people to use a smartphone to provide facial biometrics to establish or verify their identity and enabling reuse of fingerprint biometrics that have previously been captured.
• This, along with the introduction of eVisas/ETA, will further reduce the need for people to go to a Visa Application Centres (VACs) to give biometrics or collect a physical visa.
• Using what we know about people to inform flow and interventions at the border, better informed “counting in and counting out”.
• Increasing the use of e-gates through piloting use of the gates for those under 12 years old through a proof of concept exercise.
• Innovative technology increasing automation for everyone travelling to the UK across all modes of transport to allow piloting of “contactless travel”.
• We are developing chatbot and ‘voice-bot’ functionality with a view to launching this digital support from 2023, giving customers the means to resolve their queries effectively, without needing to wait to speak to an agent.

Delivery confidence

Delivery of FBIS remains on track. As a major project, FBIS is registered with the IPA for inclusion in the GMPP and submits quarterly returns on IPA recommendations.

In January 2021, a Gateway 0 review of subsequent delivery plans resulted in ‘amber-red’. However, the most recent AAP review in July 2021 resulted in an ‘amber’ delivery confidence rating reflecting the successful delivery of the programme to date, but some of the scale and complexity of future change.

The two recommendations from the AAP review included:

1. A review of the strategic intent for one area of the programme and the role in driving customer experiences; and,
2. Documentation of plans for transition of completed projects into the business as usual operating environment.

We have addressed both recommendations and have put in the appropriate clarifications and documentation.

Our delivery confidence rating as of July 2022 for the whole of the programme (not just 2022) is amber. The confidence aligns with the last IPA review (July 2021) but also reflects the level of risk and complexity in the baseline plan for 2022 and beyond.

Key Risks

Like any programme, there are key risks associated with the Programme. The top 3 risks and high-level mitigations are described below.

• Scope – potential radical scope change to the Programme due to changes in the political climate, immigration requirements and/or further reforms from other government departments. Meetings via the Ministerial Board to discuss potential changes to scope and delivery will help mitigate this risk.
• Business design and technology capacity - the Programme plan may not be delivered to agreed timescales, quality and cost if the limited resources within DDaT and design are diverted to support delivery of Home Office demands/priorities outside of the Programme. We have recently procured consultants to increase the capacity within the design team.
• Management Information (MI) resource capacity – the team providing MI data on new/amended FBIS routes may not be able to meet requirements and/or timescales of the FBIS programme due to capacity constraints. We have ramped up the MI discovery team to mitigate this risk.

Lessons Learned

FBIS conducted a comprehensive ‘lessons learned’ exercise at the end of its first tranche of delivery. The outputs were then collated and used to produce a series of recommendations for change which were implemented. We continue to undertake lessons learned sessions at key delivery points. This is fundamental to ensure we continue to learn and improve delivery as we approach our milestones.

Feasibility summary:

Although there is a continued risk around further scope creep that may require FBIS to deliver, we manage this risk by highlighting the impacts that these new initiatives will have our current delivery roadmap and re-prioritising as necessary.

Our delivery milestones and key risks are tracked weekly, and our current delivery confidence remains “amber”. Therefore, the proposal above meets the AO test of feasibility as we remain on track to deliver FBIS outcomes.

Conclusion

As the Accounting Officer for the Home Office, I considered this assessment of FBIS, which conforms to the four accounting officer standards of regularity, propriety, value for money and feasibility and approved it on 31 August 2022. This document sets out the key points which informed my decision. If any of these factors change materially during the lifetime of this project, I undertake to prepare a revised summary, setting out my assessment of them.

This Accounting Officer Assessment will be published on the government’s website (GOV.UK). Copies will be deposited in the Library of the House of Commons and sent to the Comptroller and Auditor General, and the Treasury Officer of Accounts and the Chair of the Public Accounts Committee.

Matthew Rycroft CBE

Permanent Secretary for the Home Office

6 September 2022