Policy paper

Home Office response to the ICIBI's report: An inspection of the Border Force operation to deter and detect clandestine entrants to the UK

Published 25 March 2025

The Home Office thanks the Independent Chief Inspector of Borders and Immigration (ICIBI) for this report. The inspection examined the Border Force operation to deter and detect clandestine entrants at the juxtaposed controls in Northern France, focusing on resources, technology, and partner engagement. The inspection also examined the operation of the Clandestine Entrant Civil Penalty Scheme (CECPS) and Civil Penalty Accreditation Scheme (CPAS) which seek to encourage greater vehicle security to prevent the carriage of clandestine entrants.

The Home Office is pleased that the ICIBI reported findings of positive, professional relationships with stakeholders and staff who were generally committed, enthusiastic and focused on success. The Home Office acknowledges the need for a co-ordinated approach to tackling the clandestine threat. The newly established Border Security Command (BSC) will deliver a major overhaul and upgrade in law enforcement marking a significant step forward in the fight against illegal migration and criminal smuggling gangs. The BSC will coordinate the work of all our law enforcement and intelligence agencies and work closely with European counterparts to address organised immigration crime, evolving over time to wider threats to border security including clandestine entry across modes of entry.

Data is a recurring theme in inspections and the Home Office continues to improve the way it captures and analyses data whilst also exploring technologies that can contribute capability to supporting our mission at the Border. The UK’s investment in border security and technology enables many lives to be saved each year, that would otherwise be in danger of being lost as a result of these criminally facilitated crossings. More specifically, the Border Force data cell has a dedicated team analysing immigration and clandestine data. They work on maximising the reporting capability of the current system and work with operational partners to address Data Quality issues. New provisions have also been introduced in the new Border Security, Asylum and Immigration Bill enabling partner agencies to share data in specific circumstances – for example, UK trailers, an area of interest to CECPT and which may be used for people smuggling or goods, may be more easily identified.

Work is already underway to modernise the way the Home Office manages the civil penalty system and since the inspection, the Integrated Platform Management (IPM) system, referenced in the report, was successfully launched in February 2025, updating working practices and driving efficiencies and improvements.

All redactions of material from the inspection report, are for reasons of national security and have been made by the Home Secretary in accordance with the UK Borders Act 2007.

The ICIBI identified several areas for improvement and has made seven recommendations. Work is already underway to deliver some of these recommendations. The Home Office has accepted recommendations one and five; partially accepted recommendations two, three, six and seven; and not accepted recommendation four.

Recommendation 1

Designate a Home Office-wide ‘owner’ for clandestine entry, with overall responsibility for the efficiency and effectiveness of the Migration and Border System’s efforts to deter, detect, and manage clandestine entry to the UK, including responsibility for ensuring that recommended improvements are implemented and embedded.

Accepted - October 2026

The Home Office (HO) agrees with the overall ambition of this recommendation and is of the view that the newly formed Border Security Command (BSC) will ultimately provide the structure to support this role, and the Border Security Commander, Martin Hewitt, will provide the personal ownership and responsibility proposed. Whilst the BSC’s initial focus is on tackling organised immigration crime (OIC) and reducing irregular migration to the UK, its remit will evolve to tackling wider threats including clandestine entry across all modes.

The BSC was established in July 2024 to increase the Government’s capacity to disrupt irregular migration and other border security threats by drawing together organisations across the Border Security landscape to work together to reduce border security risks. It will lead the system to further enhance its efforts to reduce clandestine entry. Work has already begun to cohere system partners, and significant international engagement with key counterparts to deter this shared issue upstream.

We believe it would be appropriate to assess progress on those wider elements of the BSC remit, and implementation of this particular recommendation, two years on from Martin Hewitt taking up his role, in October 2026.

Recommendation 2

Review the range of analyses, assessments and intelligence products dealing with clandestine entry that are currently produced and check (at least quarterly) with ‘end users’ that these support strategic and tactical decision-making, including decisions about resources, investments and operational deployments. This should include:

a) revisiting ICIBI’s previous recommendation to “Produce a detailed monthly analysis of clandestine entry attempts detected at the juxtaposed controls and at UK ports, and ‘failures’ (vehicles later identified in connection with ‘lorry drops’), and the factors over which Border Force had control, including staffing levels, targeted vehicles, and search techniques used, (ensuring that the information provided by frontline staff is specific and complete).” As a first step, to supplement the revised CLEAR report, conduct a series of shorter, more-focused exercises to capture this information would enable Home Office Intelligence and front-line teams to review and refine what is required, how it is best reported, and to identify particular gaps and any sticking-points.

b) specifying what information the Home Office requires from partner agencies, including those conducting checks prior to the UK control zone, and UK police forces, in order to create a better overall understanding of and response to clandestine entry and supporting them to provide it (including through regular dialogue and feedback, and by creating easy reporting mechanisms).

c) commissioning research into the reasons why illegal migrants choose particular methods of entry to the UK, with a view to assessing the likely effects of the successful disruption of specific methods and routes, including displacement.

Partially accepted - March 2026

The Home Office is committed to producing the right products to help guide and inform the business areas in relation to Clandestine Entry and will continue to build on existing reports, reviewing and refining the capture of front-end data, identifying gaps and working across business areas to make dynamic adjustments to reporting. However, we do not accept the need to commission additional research, given the assessment processes already in place, and for this reason the recommendation is only partially accepted.

The Home Office agrees the need to specify the information it needs from partner agencies and can confirm this is core activity already undertaken. Home Office Intelligence (HOI) routinely issues intelligence requirements to a range of partner agencies. The Clandestine Commonly Recognised Intelligence Picture (CRIP) is an assessment which includes intelligence gaps and requirements and so specifies the information HOI requires.

The Home Office agrees that an understanding of the effects of successful disruption of specific methods and routes adds value to the intelligence picture around illegal migrant entry to the UK and this assessment is already undertaken negating the need for a specific research commission on this issue. HOI already monitors modes on a routine basis and participates in the Home Office Early Warning Index (EWI) meeting led by Home Office Analysis & Insight (HOAI). The EWI monitors methods of entry to the UK to provide an early warning on new trends and/or displacement activity.

Recommendation 3

Overhaul training provision for front-line Border Force officers at the juxtaposed ports to ensure that they are as far as possible multi-functional and can be deployed flexibly, in particular:

a) providing IFC2 training within three to six months of completion of IFC1

b) extending the training to enable all IFC2-trained officers to make S31A referrals (first reissuing guidance on the exercise of discretion not to refer incidents to the CECPT)

c) including in the training for vehicle searching briefings on the roles and responsibilities of the contractors working alongside Border Force and how best to work with them

d) ensuring that the level of Personal Safety Training (PST) required to fulfil specific roles is clearly documented, that staff are trained and certificated to the correct level, and that officers do not go ‘out of ticket’ because they have not been able to access PST refresher training

e) encouraging officers to acquire French language skills, for example by granting them study time and identifying opportunities to use the language

Partially Accepted - March 2026

The Home Office recognises the need to overhaul training provision for frontline officers to maximise flexibility in deployment and therefore accepts many elements of this recommendation. We do not agree to the imposition of strict timelines for IFC training delivery. Any provision must also meet individual needs, with staff only being offered IFC-P2 training within three months of IFC-P1 training if their learning has been sufficiently embedded. In addition, training will only be offered where there is a business need to have more staff trained to a higher level. Further to this, while we will also explore options for French language learning provision for staff, as an organisation we cannot commit to granting staff paid study time without first assessing the operational impact. For these reasons, the recommendation is only partially accepted. All other elements b) to d) are accepted. Work to improve training provision is already underway in many areas. A learning needs analysis (LNA) has commenced to assess S31A referral training requirements which will then inform improvements to the current learning offer. In addition, work to review the public and personal safety training (PPST) has begun, with a commitment to continue to deliver PPST delivery to any Border Force (BF) staff who require it for their role, tracking expiry dates and arranging refreshers as needed.

The Home Office has progressed activity to better define the FSLO role and improve contractor collaboration. Updated training material has been created and guidance circulated to staff and contractors. In addition, a Border Force conference took place in January 2025, bringing together fifty FSLO trained staff from across Northern France and contractor teams to work together on more clearly defining this role. This included presentations from contractors to outline their responsibilities and an opportunity to meet and discuss challenges. Border Force staff assisted in producing training materials which they are now using to cascade training to staff across juxtaposed ports. We are also reviewing local freight training courses to ensure all further training and refresh training covers these elements.

Recommendation 4

Install an integrated ANPR system linking the juxtaposed controls at Calais, Coquelles, and Dunkerque, enabling real-time checking of all vehicles arriving in the UK control zones against Home Office watchlists and the sharing of vehicle information between the three ports and with UK ports.

Not Accepted

We fully appreciate and accept the rationale behind this recommendation, and if money was no object, we would regard an integrated ANPR system of the kind suggested as a welcome addition to Border Force capabilities. However, given the difficult financial situation the Government has inherited and the need for each department to target any additional spending on the activities and programmes that will make the greatest difference to its core objectives, it would be difficult to justify prioritising a new integrated ANPR system over other potential uses of the same money, in terms of the benefits it would provide over and above the existing processes at the juxtaposed controls.

As ICIBI have detailed in their report, Calais, Coquelles and Dunkerque already have systems in place which enable real-time checking of vehicles in the UK control zones against Home Office watchlists and there are processes to share information across the three ports. Despite systems differing, we do not believe the significant investment required for their integration would deliver a sufficiently commensurate improvement in border security or create efficiency savings.

Any proposal to install an integrated ANPR system would therefore require further evidence that it would be an effective, efficient, deliverable, legally compliant and value for money option, over and above any current systems in place, over and above other options which may be considered to address the same risks, and over and above the other demands on spending required to deliver the Home Office’s priorities on border security.

Recommendation 5

Within three months of the introduction of the new Integrated Platform Management (IPM) system, conduct a root and branch review of the Clandestine Entrant Civil Penalty Team (CECPT) working practices and processes to eliminate duplication and maximise efficiencies, with a view to re-setting staffing levels and revising structures so that the CECPT is sufficiently resourced to manage all of its functions concurrently, consistently, within deadlines and to an acceptable standard, including: casework (processing referrals, issuing penalties, responding to new information and appeals), accurate record-keeping, routine quality assurance, and stakeholder engagement. This review should include identification of the training and guidance documents CECPT staff require to perform their role, including training in the use of the Home Office finance system (Metis) and guidance on the application of discretion and exceptionality.

Accepted - March 2026

The Home Office fully accepts this recommendation. Since the inspection, the Integrated Platform Management (IPM) system has been successfully launched. While it will take time for the benefits of the IPM to be realised, Border Force is committed to full delivery of the system and to ensuring that Clandestine Entrant Civil Penalty practices are reformed to take best advantage of the potential efficiencies and improvements IPM offers.

The Home Office has already commenced a programme of work to modernise and align the administration of Border Force civil penalty schemes, to streamline processes and identify best practice. As part of this, a cost-benefit analysis for the CECP scheme will be undertaken to identify the most effective activities and their impact on compliance, appeals and resourcing. Results will inform a Border Force civil penalty strategy, including stakeholder engagement, to drive overall improvements to the civil penalty framework. Any findings or recommendations relating to discretion and exceptionality would be subject to ministerial authorisation.

As IPM is intended, over time, to be the case management system for all civil penalty schemes, a review of record keeping processes and assurance will also be conducted, and alongside this a time and motion study will complete the IPM benefits assessment and further inform resourcing levels. Training and guidance will be included as part of this review. Given the complexity of the review, it is expected this will take six to nine months to complete. A Target Operating Model was agreed in 2022-23, with an ambition to integrate all finance administration into a dedicated team, trained in accounts management including the Home Office Metis system. This work is ongoing.

Recommendation 6

Produce and publish an ‘engagement plan’ for industry stakeholders, which includes seeking regular feedback about the impacts that the Clandestine Entrant Civil Penalty Scheme (CECPS) is having on drivers, owners and hirers of vehicles, and starting with ‘quick wins’, including:

a) publishing a telephone number and email address for the Clandestine Entrant Civil Penalty Team (CECPT) to receive and answer queries from anyone notified of liability to a civil penalty

b) improving the information provided to drivers, owners or hirers of vehicles stopped at a port for a suspected Section 31A or Section 32 incident, providing the driver with written notification that they may be liable to a civil penalty (that they can share with the owner, hirer, or operator, as appropriate), setting out the reasons why, and including the date by which they can expect to receive the notice of liability (form IS11D or IS11E)

c) producing, and keeping up-to-date in light of clandestine entrant incidents, a training ‘toolkit’ and guidance on the minimum standards Border Force expects in terms of the measures drivers and hauliers should take to secure vehicles against clandestine entry

d) clearing the backlog of Civil Penalty Accreditation Scheme (CPAS) applications and starting processing all new applications to join the CPAS within 30 days of receipt

Partially Accepted - March 2026

The Home Office acknowledges the need to improve engagement with industry stakeholders but is only able to partially accept this recommendation due to the specific nature of some of the timescales and practical considerations of implementation.

With regard to points a. and b. the Clandestine Entry Civil Penalties Team (CECPT) contact details are available on gov.uk and will also be included in a newly designed initial notification leaflet. CECPT will work to introduce this notification by June 2025, informing the driver they have been involved in an incident and advising them to inform their employer. This leaflet will state that incident details have been referred for civil penalty consideration and that an IS11D/E will follow shortly. However, a commitment to updating drivers within set timescales is not deliverable due to the constraints of international postage systems. Nor is it feasible to provide full reasons for liability as this would require full assessment against the regulations, which takes time to consider following referral.

As part of a wider engagement strategy, options for developing more targeted training guidance and collaboration opportunities with hauliers and drivers will be considered. This work cannot commence however until wider improvements to the operation of CECP regime are realised.

CECPT are conducting a local review of processes required for the Civil Penalty Accreditation Scheme (CPAS), due to complete in April 2025. The Home Office is therefore unable to commit to the proposed actions of clearing the backlog and processing all new applications within 30 days of receipt until the review has been completed and its impacts understood.

Recommendation 7

Produce and publish an annual report on how the Clandestine Entrant Civil Penalty Scheme (CECPS) is working, informed by the feedback received from drivers, owners and hirers of vehicles (not limited to industry stakeholders), and including:

a) data about the numbers of vehicles searched, number of clandestine entrant incidents, number of clandestine entrants detected, number of goods vehicles found not to have been adequately secured, plus any other relevant data

b) the level of penalties imposed, numbers of successful and unsuccessful challenges to a penalty and the reduction in penalties imposed, the amounts of collected and uncollected debt

c) an assessment of the deterrent effect of the scheme

d) planned amendments and improvements, with dates

Partially Accepted - March 2026

The Home Office (HO) recognises the importance of assessing the effectiveness of the Clandestine Entrant Civil Penalty Scheme (CECPS) and will make all efforts to collect and report the data outlined in this recommendation. However, the production and publication of annual reports or similar for such an area does not align with current practice and this level of administrative activity is not considered the most effective use of resource. The HO is also unable to commit to publishing planned amendments or improvements to the scheme. As with any activity undertaken by the HO, its effectiveness is consistently reviewed and amended or improved as required but other than appropriate consultation when required, a public commentary on such work is not undertaken.

As per the response to Recommendation 1, in due course the Border Security Command will have the lead on clandestine entry. This will include responsibility for understanding the threat and introducing measures to improve the UK response which will necessarily include considerations as to the management information (MI) which best supports this activity and the appropriateness of its publication.

Until that time, Border Force (BF) will seek to achieve the data collection set out in a. and b. The HO already publishes Migration Statistics data on a quarterly basis (Immigration system statistics data tables – gov.uk) which include part of what is suggested in point a. (number of clandestine entrants encountered in the UK and number of migrants encountered broken down by location) and consideration is already being given to extend this information.

Separately, the CECPT locally collect much of that listed in point b. and the HO recognises the value in corralling and professionalising its Management Information on this subject. It will therefore continue internal discussions to consider what data is relevant, either for public consumption through existing publications, or for internal use to support the performance of the CECPS. An improved data management and reporting capability has already been introduced which will support this effort and BF are committed to a long-term solution.

Under the New Plan for Immigration (NPI), the CECPS seeks to increase vehicle operator compliance with vehicle security standards and an assessment of the effectiveness of the scheme will emerge from the data collected in a. and b.