No More NRPF

Our Submission to the APPG on Migration's Call for Evidence

"The Home Office has ignored this and unnecessarily, clearly chosen fees over people when both can co-exist"

On the 14th of April, we submitted to the All-Party Parliamentary Group on Migration’s Call for Evidence. The APPG were looking for new evidence focused on the potential impact of recent changes and proposals to UK immigration and asylum routes on poverty in the UK – a question they had asked previously in April 2024.

In their guidance, the APPG asked for an analysis focusing on changes introduced in or following the Labour Government’s May 2025 “restoring control over the immigration system” white paper, with a specific ask for actions and their consequences that affect their April 2024 findings and those that address any of the four following areas: ‘Access to social security and welfare‘, ‘Access to public services and housing‘, ‘Employment and wages‘ and ‘Communities and integration

Our submission addressed two specific proposals using existing research. The evidence is made up almost exclusively of research published after the APPGs’ first call in April 2024.

First, the White Paper states on page 69: “This expansion of the Point-Based System will increase the standard qualifying period for settlement to ten years”. Second, the consultation “A Fairer Pathway to Settlement” (November 2025) states on page 25: “Under this option, new migrants granted settlement would continue to be unable to access specified benefits in line with existing visa conditions.” 

Both policies seek to increase and/or expand the usage of the No Recourse to Public Funds (NRPF) condition. In the former, doubling the length of the default route to settlement, which most people experience with NRPF as a condition of their limited leave, and the latter, adding the NRPF as a condition of settlement, also known as indefinite leave to remain (ILR), which was previously the first point at which migrants could access public funds. 

Use the toggle below to work through our analysis of the two proposals and how they interact with the relevant thematic areas and how they interact with the 2024 report.

The UK already operates a 10-year route to settlement for certain family and private life cases. The first proposal tabled wants to make this the standard route to settlement, replacing the current 5-year route. Throughout this entire period, migrants on the 10-year route are subject to NRPF, which bars them from accessing most ‘public funds‘; meaning no universal credit, no child benefit, no housing benefit, and no homelessness assistance, regardless of how dire their circumstances become.

Evidence from the existing decade-long route is stark and clearly warns against any move to make it the new norm. During the 10-year route, migrants must apply for a limited leave to remain every 2.5 years until they complete 10 years of continuous residence, which provides four opportunities for the slightest discrepancy to throw individuals and families off the wagon and into periods of stay without immigration permission. The 2024 APPG report found that over half of those already on this 10-year route struggle to afford bills and food, and nearly half go into debt to pay visa fees. IPPR research found that the route made it harder to find work, heightened insecurity about living in the UK, and harmed children’s prospects. The existing 10-year route already imposes significant financial strain: the Migration Observatory estimates that a migrant on a 10-year route pays around £16,900 in fees alone, compared to £9,900 for a 5-year route, which already represents a substantial financial burden. Colin Yeo predicts that a family of four on the ten-year route faces total costs exceeding £50,000, rising to over £70,000 under the new proposals.   

The proposal to extend the 5-year route to 10 years for all settlement applicants would not necessarily create a novel problem. Still, it would rather dramatically expand an existing, well-documented one, as shown above. The “no benefits at settlement” proposal then removes the endpoint entirely. Under this, migrants would be unable to access public funds until they become citizens. A process that, much like the route to settlement itself, is financially gatekept and available only to those wealthy enough.    

Social services support, which is not a public fund and is one of the few avenues for support for migrants with NRPF, albeit with incredibly high thresholds and very specific circumstances, has experienced unparalleled surges in demand, manufactured by policies like those proposed here, and only set to move in one way should proposals become policy. We found that expenditures on NRPF-related social services amongst Scottish local authorities have tripled in the 2020s. This spending stands in the face of the available evidence, research from the Centre for Analysis of Social Exclusion at LSE which makes the case that repealing NRPF would generate a net benefit of £872m over a decade in London alone and the Trust for London’s scathing review of the policy against its intended outcomes, yet the government is moving in the opposite direction. 

A ten-year employer-sponsored visa (which would become the norm under these proposals) ties a worker’s immigration status to a single employer for a decade. The Work Rights Centre notes that longer paths to settlement benefit employers who offer poor pay and conditions at the cost of a higher risk of exploitation, a population that the Home Office takes ‘immense pride’ in targeting and disrupting. The Work Rights Centre found that 65 per cent of migrant workers on similar routes disclosed an employment rights breach in the last twelve months; 39 per cent did not raise a complaint due to fear of employer retaliation, as migrant workers are at the behest of their employing sponsor, as when facing dismissal they have 60 days to find a new sponsor or leave the country.

The Public Accounts Committee documented widespread evidence of debt bondage, excessive hours, and exploitative conditions on the Skilled Worker route. In theory, these individuals should be protected by a robust sponsor licensing system which reduces the number of bad actors. Underscored by the Independent Chief Inspector’s findings that compliance visits in the health and care sector found 80% of sponsors failing to meet their duties.   

These experiences are unlikely to do anything but increase under prolonged periods of employer dependency associated with the proposed changes. NRPF-induced pressures do not simply evaporate when one enters their home; a place that is supposed to provide much-needed sanctuary. Prolonged periods of NRPF prevent access to childcare funding, trapping parents, particularly mothers, in low-paid, part-time work, a decision which purposefully suppresses wages and any possibility of upward mobility. The Migration Advisory Committee estimates that the 2022/23 Skilled Worker cohort (excluding Health and Care) will make a net lifetime fiscal contribution of around £47b. 

The evidence is overwhelming that these proposals will actively damage integration and community cohesion. Research from Switzerland and the Netherlands shows that secure residence status, which these proposals antagonise, is a prerequisite for social integration and should not be its culmination. The Migration Observatory finds that longer periods without the rights that come with permanent status and citizenship can hinder social and economic integration, concluding that “a longer and more difficult path to settlement brings a trade-off between short-run fiscal benefits and longer-term negative effects on integration”. Research from Praxis offers evidence that one-third of those on the existing ten-year route feel they do not belong in the UK.

Faith leaders have spoken with extraordinary clarity, and in a letter published in the Guardian, Bishops, rabbis, and imams expressed “grave concern” warning that “policies that make status more precarious and pathways more distant risk undermining” community cohesion. Sunder Katwala stated that “leaving people in limbo for a ten or fifteen-year period of ‘unsettlement’ will achieve nothing but damaging integration and community cohesion”.  

The pressures that individuals face are compounded when children are in the mix, as parents with NRPF are unable to access relevant public funds like child benefit – even if their child themselves is a British citizen. An extension of the NRPF period, whether for 10 years or at settlement, will have a stark impact on children and families. IPPR analysis suggests that upwards of 300,000 children already on routes to settlement could be affected by retrospective applications, with Pinter and Leon estimating that the total number of children currently affected by NRPF is close to ¾ of a million.

The Joseph Rowntree Foundation, amongst other organisations, has consistently found that the NRPF condition is massively detrimental to children. Their headline, regrettable finding, was that 80% low-income families with NRPF went without essentials like heating or suitable clothing, and almost half went hungry. Low-income families with NRPF were around twice as likely as other low-income families to go without essential travel (29% vs 14%), which snowballs into situations, including but not limited to being unable to attend doctors’ appointments or job interviews and for children being ripped away from the everyday social interactions that build friendships, trust, and a sense of shared belonging; situations which flagrantly violates Scotland’s intention to ‘Get it right for every child‘ and related commitments enshrined in the UNCRC (Incorporation) (Scotland) Act 2024.

The 2024 APPG report made two core recommendations that these proposals directly reverse: first, that no route to settlement should take more than five years (p. 23); second, that no one on a settlement path should have NRPF for more than five years (p. 25). The 2024 report found that the existing 10-year route already causes destitution, debt, and mental health crises. The proposals discussed are set to expand that misery to a growing population, of what is likely to be in the millions. Where the report found that tied visas enable exploitation, these proposals double the period of employer dependency. Where the report called for shorter routes to enable integration, these proposals create a decade or more of “permanent temporariness.” The retrospective application (applying new rules to those already on a five-year path who made life-altering decisions on that basis) adds a new layer of harm the 2024 report did not need to address head-on: institutional dishonesty  

Safety Exit