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A complete shake-up of the Home Office system for submitting visa and citizenship applications is taking effect this month, revealed in a series of last-minute announcements that have left many confused.

A preliminary announcement of the changes was followed by several months of silence, until last week when UK Visas & Immigration (UKVI) suddenly published multiple pages of information that answer some questions but leave many, many others unanswered.

The New System

In short, UKVI is aiming to do away with paper applications. In the near future, all applications will have to be completed and paid for online. The immigration health surcharge and biometrics enrolment fee will also have to be paid at this time.

Applicants will no longer be able to print and post their form and supporting documents to UKVI. Instead, after making payment, they will be transferred to a third-party website where they must book an obligatory appointment at a new service centre.

Applicants are asked to attend these appointments within 5 days if possible but can apparently book appointments up to 28 days in the future.

During this appointment, applicants will have their biometrics enrolled. They will also have their documents scanned and returned to them, so they can keep these while the application is being processed. Those with access to a scanner and a lot of time on their hands can apparently choose to upload all their documents in advance of the appointment.

This new system is called the UK Visa Citizenship Application Service (UKVCAS)

UKVI Appointment Centres

UKVI is opening a series of new centres around the country, outsourced to a third-party, Sopra Steria. These centres will broadly be divided into three categories.

Most people will either use one of six Core Centres, which will be free to use, or 50 Enhanced Service Centres, which it seems applicants will have to pay to use. It is not clear how much they will have to pay. The enhanced centres will also offer additional services applicants can pay extra for, such as translation and document checking.

Early next year, the UKVI will open Service and Support Centres, with complex circumstances, such as those applying for family reunion, those making further submissions or those applying for a fee waiver.  The ‘full’ list can be found here, although it still far from complete – it is not clear what kind of family applications would need to be made using this route. Reading between the lines, I believe it may refer to those applying under Appendix FM for the first time (either because they have no leave or because they are switching into a family route) but this is speculation.

I assume (also speculation) that these SSCs will be run by UKVI staff rather than Sopra Steria due to the presumed complexity of the applications.

The existing Premium Service Centres will remain in full use until 29 November, for anyone able to secure an appointment.  From 30 November until early January, it seems some appointments will still be available at PSCs for those applying on the basis of family or private life for the first time, either with or without leave. At this point, they will presumably transition to SSCs.

UKVI

 

Who will not be able to use the new system?

Applications made under the EEA Regulations will not be covered by the UKVCAS. In other words, all applications based on an EEA right to reside (e.g. Registration Certificates, Residence Cards, Permanent Residence Cards etc.) will still need to be made by post.

The other exception will be those applying for a certificate confirming right of abode.

Will everyone have to use the new system?

This is not clear yet. My preliminary reading is that as of 30 November 2018, the UKVCAS will be obligatory for most applicants, meaning they will no longer be permitted to make postal applications and will no longer have the choice of using PSCs.

I am not yet certain if SSCs will be obligatory for all those eligible to use them or whether they are an optional extra. Give the stated aim of moving all applications online, it seems likely that they will become obligatory eventually, assuming they are not immediately so in early January.

Timing

The appointment booking system is already in operation, although neither I nor any of my colleagues have used it as yet. You can only make a booking after payment and submission of an online application form.

The first of the centres opened on Monday 5 November and the rest will open their doors in stages over coming weeks, with all open by the end of the month.

From now until 29 November, applicants will be able to choose between the current system or using the new centres.

The PSCs will close to most applicants on 29 November 2018, although a limited number of family applications can still theoretically be made through a PSC in December 2018 and early January 2019. However, our experience at present is that it is impossible to get PSC appointments at that time (presumably because the number of caseworkers has been radically reduced).

Priority Service?

It is not clear (at least to me or any of my colleagues) what options will be available for priority decision-making. I am fairly confident that same-day decisions will no longer be an option, given that the centres will be run by third-party Sopra Steria employees with no involvement in UKVI decision-making.

There is no mention of any priority service on the website list of paid for additional services. However, I find it hard to believe there will be no such option at all. Reading between the lines, it seems that there will almost certainly be some kind of priority service but no further information is available as yet: how much it will cost, what the turnaround times will be or what kinds of application will be able to use the service.

Presumably, this will become clear only after going through the complete online application process, once it comes to payment at the end stage.

Final Thoughts

I have a lot of preliminary concerns at this stage, such as

  • The fact the submission process now seems to require a lot of additional work, including two whole new stages of booking and attending an appointment
  • The hassle of online forms, which usually require you to complete a section before moving forward
  • The difficulties of using an online form which only allows for yes / no answers, when many people’s situations are more complex than this
  • The extra time and hassle for clients being forced to take time off work to attend centres when they could previously submit by post
  • The availability of appointments – I suspect many people will be forced to use the so-called enhanced service centres, for which there is a fee attached, simply to secure an appointment
  • The limited number of core centres – as above, this will be another factor that either forces people to travel long distances simply to submit a free application or else backs them into a corner when they have no choice except to pay
  • The apparent abolition of the same-day decision making service, which has been a lifeline for people who need to travel or for people whose employers do not wish to keep them on unless they can see a valid visa
  • The difficulties for people with babies or childcare problems in having to attend a centre for several hours
  • Fears around how applications will be handled from people without any leave – forcing them to attend a centre to submit an application is likely to create considerable anxiety and stress. The Home Office has made much of the fact that people will have their passports and documents returned to them while a decision is under way but I struggle to see how this will benefit most applicants. The majority will not be able to travel on their passport if the Home Office is still making a decision on their applications, as they would not be able to re-enter the UK with an expired visa. The only categories who could travel while an application is pending are citizenship applicants and EEA nationals. However, EEA residents are excluded from the new service so will gain nothing, while citizenship applicants can already use the local authority Nationality Document Return Service, which allows them to keep their passports. In other words, without clarity on priority decision-making, the return of a passport seems to offer minimal benefit to most people, for whom the process will simply create added stress and complications. However, perhaps I am being unfair and perhaps it is the case that people coming to the system with no prior experience may well find it more “streamlined”, “intuitive” and “easy-to-use” as the Home Office keeps claiming. I remain unconvinced at present. In fairness though, it is simply impossible to reach any kind of firm conclusions on this new service at present, when so much information is still missing or unclear.

For advice on making a visa, immigration or nationality application or in relation to immigration matters more widely, please contact Karma or another member of our Immigration Team on 020 7631 4141 or email immigration@bishopandsewell.co.uk.

Karma Hickman Associate Solicitor   +44 (0)20 7091 2879


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