Policy paper

Response to an inspection of the Home Office's management of fee waiver applications

Published 20 March 2025

The Home Office thanks the Independent Chief Inspector of Borders and Immigration (ICIBI) for this inspection report on the management of fee waiver applications between August and November 2024.

We have already taken steps to address some of the issues raised by the ICIBI in this report and will continue to work to improve the system.

The ICIBI identified several areas for improvement and has made eight recommendations.  The Home Office has accepted five recommendations (2, 3, 5, 6 and 7b) and partially accepted three (1, 4 and 7a).

Recommendation 1

Develop a workforce plan for in-country fee waiver applications that reflects forecasted application volumes, plus productivity and quality targets, and ensures enough trained and fully competent staff are dedicated to the processing of applications to avoid backlogs necessitating large-scale staff loans to reduce them.

Partially accepted – will be part of the annual Capacity Planning process

The Home Office recognises the need to plan the in-country fee waiver recourses as part of a wider plan across Asylum and Human Rights Operations (AHRO) to resource all its casework areas.  The AHRO annual plan will reflect forecast application volumes, productivity and quality targets across all service lines.  Flexible deployment of our workforce is a central element to our planning and enables us to meet the challenges of fluctuating demand in different workstreams.

Recommendation 2

Formalise regular (at least quarterly) meetings of senior managers and caseworkers from the three fee waiver teams to share information and promote ‘best practice’ and consistency, and to flag and manage risks. Agendas should be circulated in advance, Minutes taken, and Action Points recorded and tracked. Standing items should include: Guidance (including how to assess ‘affordability’); Training; Productivity (including Benchmarks); Performance (including Quality Standards); Safeguarding (including the identification and prioritisation of vulnerable applicants); and Stakeholder engagement.

Accepted – implementation from 1st April 2025

The In-Country fee waiver team will lead this and include all relevant parties and agenda items.  This may not always include all of those listed in the recommendation at every meeting.  Co-ordinated engagement with external stakeholders will be arranged and managed via the AHRO Logistics Team on behalf of all three of the fee waiver areas.

Recommendation 3

Create a more exacting ‘quality score marking’ system for use with fee waiver caseworkers that reinforces the importance of eliminating all errors, giving more weight than hitherto to correct spelling, grammar and content of correspondence, alongside correct decision outcomes. The same system, operating to the same rules, should be used by all three fee waiver functions.

Accepted – 31/10/2025

We have created two casework hubs to improve focus on and add greater control of cases to build expertise, identify efficiencies and provide consistency of decision making for our customers. The AHRO quality assurance team will work with the Passports, Citizenship & Civil Registration (PCCR) and Visas, Status & Information Services (VSIS) operational and quality assurance teams and the Central Customer Operations Support Service (COSS) assurance team to undertake further work to bring consistency and improve reporting mechanisms including fee waiver considerations and quality markings and standards.

Recommendation 4

Overhaul how the quality and consistency of the work of fee waiver caseworkers (not solely decision outcomes) is managed, defining the roles and responsibilities of line managers, ‘technical specialists’, and quality standards assessors in setting expectations, providing advice and support (including feedback), and maintaining standards, ensuring that these are co-ordinated and complementary.

Partially Accepted – 31/10/2025

The AHRO, PCCR and VSIS operational and quality assurance teams will work together to review the opportunities to deliver on this recommendation.  There may be instances where different approaches or staff roles are necessary and appropriate to be consistent with the wider working practises of the specific Directorate.  The three Directorates will work with COSS to provide advice and set expectations on assurance, consistency and quality standards and whether targeted assurances are needed.

Recommendation 5

Review and document the lawful basis for storing Equifax reports on Home Office systems, including the retention of such reports beyond the point where a fee waiver decision has been issued, and with particular regard to third-party data that is unconnected with the fee waiver application.

Accepted – estimated summer 2025

We are grateful to the ICIBI for bringing this issue to our attention. The contract with Equifax has now ceased and financial checks are conducted through our new provider, Experian. Operational staff have been trained on the use of the new system, and processes have been updated to ensure such reports are no longer saved or stored on Home Office platforms. Relevant Data Protection Impact Assessments (DPIAs) have been drafted and we are working closely with the Data Protection Practitioner network to ensure customer information is handled and processed appropriately.

Work is also underway to remove all previously affected cases where reports were stored, with this expected to be completed in the next three months. Guidance (in the form of Standard Operating Procedures for fee waiver teams) will also be produced and circulated to ensure staff are aware of the necessary steps to take should they identify a case which has a credit check report stored in future.

Recommendation 6

Ensure that where significant changes to fee waiver policy and processes are proposed, including but not limited to the triaging of applications by cohort or 29 characteristic(s), these are subject to an Equality Impact Assessment (EIA) to ensure that they are compliant with the Home Office’s Public Sector Equality Duty, and determine whether Ministerial Authorisation should be sought to cover instances of direct discrimination.

Accepted – Immediate

We will operate compliantly with the Home Office’s Public Sector Equality Duty, following the appropriate guidance and seeking the advice of the central Home Office team.

Recommendation 7

• From April 2025, introduce a service level agreement (SLA) for child citizenship and overseas fee waiver processing times, taking account of the fact that both have been relatively stable for at least 12 months in terms of application volumes, resourcing, and decision times, and there are no reasons to think that this will change.
• Commit to introducing an SLA for in-country fee waivers when the in-country fee waiver backlog has been reduced to a frictional level and processing times have been stable for six months.

Partially Accepted

• We intend to introduce a Customer Service Standard on Out-Of-Country and Child Citizenship Fee Waiver applications. Prior to introducing a service standard, we will need to ensure that we have the necessary reporting and workflow tools tested and in place to facilitate its delivery, and we will also need to ensure that any data meets the necessary assurance standards for publication within Home Office statistics. This will ultimately govern how quickly a service standard can be introduced. We expect this to be in place by the end of 2025 for Child Citizenship and 1 July for overseas.
• Prior to introducing a service standard, we will need to ensure that we have the necessary robust reporting and workflow tools tested and in place to facilitate its delivery, and we will also need to ensure that any data meets the necessary assurance standards for publication within Home Office statistics. This will ultimately govern how quickly a service standard can be introduced.  We expect this to be introduced by the end of 2025.

Recommendation 8

Develop an external stakeholder engagement strategy that covers in-country, child citizenship and overseas fee waivers.

Accept – April 2025

The AHRO central engagement team will develop a strategy in partnership with the appropriate teams from PCCR and VSIS.