Guidance

Interim operational instruction 07/2026: care and management of age-disputed individuals in immigration detention (accessible)

Updated 2 September 2026

Introduction

This interim operational instruction provides guidance on the care and management of age-disputed individuals within the immigration removal estate, pending publication of the revised Detention Services Order (DSO).

Scope

This guidance applies to all Home Office staff and contracted service provider (CSP) staff working in immigration removal centres (IRCs) who may encounter, manage or support an individual who raises an age dispute claim while detained. It should be read and applied alongside DSO 02/2019 Care and management of post detention age claims, and IOI 10/25 issued by Detention Services. This instruction does not replace the DSO or wider age assessment policy. It provides clarification of the operational approach to be followed in IRCs pending publication of updated substantive guidance, which will supersede this instruction and the previous version of the DSO.

This instruction applies to the period during which an individual remains in an IRC after raising an age dispute claim and before a decision on age is made or transfer to Local Authority care, including where the individual has raised the dispute with the Local Authority directly. It does not set out the full age assessment framework, which remains governed by the Home Office’s published Assessing age guidance, nor does it amend wider detention policy or case-working responsibilities.

Policy

The Home Office has a statutory duty under section 55 of the Borders, Citizenship and Immigration Act 2009 to ensure that immigration, asylum, nationality and certain customs functions are discharged having regard to the need to safeguard and promote the welfare of children in the United Kingdom. In the detention context, staff must therefore be alert to any age dispute raised in detention and must take immediate steps to safeguard the individual where there is doubt as to whether they may be under 18.

Immediate actions when a claim is raised

Notification

Where an individual in detention claims that they are under 18, or where staff have reason to doubt that the individual is an adult, the matter must be treated as an immediate safeguarding issue and responded to without delay.

As soon as a claim is raised, the member of staff receiving the claim must notify the CSP on-duty manager and ensure that the Home Office Compliance Team and Detention Engagement Team (DET) are informed, within 2 hours. The DETs are responsible for notifying case-working teams who will progress the dispute by arranging the initial age decision.

Out of hours, this must be escalated to the on-call Compliance manager in line with existing out-of-hours arrangements. The claim must be treated as a priority from the point it is raised, and staff must not delay protective action while awaiting age assessment or case-working direction.

Safeguarding

Immediate safeguarding measures must then be put in place within the centre. This must include a prompt Detainee Custody Manager (DCM)-led initial assessment, within 3 hours of the claim, of the individual’s welfare needs and vulnerabilities, using a multi-disciplinary approach where practicable, and the opening of the Age Disputes Care Plan (ADCP) without delay (Annex A). The initial assessment should consider the individual’s accommodation, required level of observation and interaction, any healthcare or welfare concerns, interpreter needs, access to regime, and any other safeguarding measures required to reduce immediate risk while they remain in detention. If, in exceptional circumstances, it is not possible to conduct the risk assessment within 3 hours of the claim, as a precautionary measure the individual must be moved into a single occupancy room and only have supervised access to activities.

Pending a decision on age (initially through a Home Office initial age decision, and/or a brief enquiry conducted by a local authority or an abbreviated age assessment conducted by the National Age Assessment Board), the individual must be accommodated in a way that safeguards their welfare, including single room occupancy where required by the risk assessment. Staff must ensure that all reasonable interim measures are put in place as the person may be a child. All actions taken, decisions made and interactions with the individual must be recorded clearly on the ADCP, Atlas, and CSP systems.

Once notified, the relevant Home Office teams must progress the case urgently in accordance with existing age dispute processes, including referral and liaison with case working colleagues including the Age Dispute Resolution Team who will engage with the Local Authority as appropriate. While that work is ongoing, CSP staff remain responsible for maintaining the agreed safeguarding measures, reviewing them regularly as per the ADCP, and ensuring that the individual’s immediate welfare is monitored until the case is resolved or the individual is released from the centre.

Ongoing safeguarding and welfare measures pending Local Authority release

Accommodation

Following a decision on age where an individual is to be treated as a child, pending release into Local Authority care, the individual must be accommodated in a way that safeguards their welfare and reduces the risk of bullying, harm or inappropriate association. This must include consideration of single room occupancy and any other accommodation adjustments identified through the initial assessment and the ADCP. Where the risk assessment identifies that additional safeguards are required, these must be implemented without delay and kept under review until the individual leaves the centre or their age dispute is otherwise resolved.

Accommodation decisions must be informed by the individual circumstances of the case, including any vulnerabilities identified, the physical layout of the centre and the practical options available locally. Staff must record the accommodation decision and the reasons for it on the ADCP and relevant local systems, including any later changes made following review.

Regime, activities and restrictions

While an age dispute remains unresolved, the individual should continue to have access to the normal centre regime unless a specific restriction is assessed as necessary to safeguard their welfare or the welfare of others. Any restriction must be based on an individual risk assessment, must be proportionate, and must be clearly recorded with the justification for it on the ADCP and any supporting local documentation. Modifications to the regime may include, but are not limited to:

• Restriction of access to age-restricted goods, eg. vapes
• Monitoring access to age-appropriate media
• Adjusting association with others, e.g. supervised association
• Adjusting access to activities or areas of the centre.

Any such arrangements must be tailored to the individual case and reviewed regularly to ensure they remain necessary and proportionate.

Wherever possible, proactive steps should be taken to avoid use of force, the use of restraints during escort, and removal from association in relation to age-disputed individuals. Where a risk assessment identifies concerns that may ordinarily give rise to consideration of force or separation, staff may consider the necessity for increased supervision, enhanced welfare observations, and, where necessary, arrangements to enable separate access to regime activities in a manner that preserves safety without imposing restriction or isolation.

For centres in England, Detained Duty Advice Scheme (DDAS) appointments must continue to be facilitated for age-disputed individuals while their age remains unresolved. Only when either the Home Office or the Local Authority has assessed the individual as a minor should they no longer have access to DDAS.

Care plans, risk assessments and record keeping

An ADCP must be opened without undue delay (within 3 hours) when the age dispute claim is raised, and must be used as the primary record of the safeguards, support measures and review activity in place for the individual. The immediate action plan must be completed by a manager and should involve a multi-disciplinary approach where practicable. The parties involved in the multi-disciplinary approach will be dependent on the circumstances and needs of the individual and may include, for example, the contracted service provider, caseworker, DET, Compliance team, the Faith team, Healthcare, Welfare staff and the detained individual. The ADCP must remain open until the individual is either released into Local Authority care or determined to be an adult and their detention maintained.

The ADCP must be used to record the individual’s vulnerabilities, accommodation arrangements, agreed observation and interaction levels, healthcare or welfare input, regime adjustments, and any other measures put in place. All interactions with the individual, decisions taken, actions completed and review outcomes must be recorded clearly and factually on the care plan and relevant systems so that there is a clear audit trail and continuity of safeguarding.

CSP managers (DCM or above) must ensure that the care plan is reviewed every 72 hours and that all relevant departments are invited to contribute where appropriate, including healthcare, welfare, activities and Home Office colleagues. Where circumstances change, the ADCP and any associated risk assessments must be updated promptly to reflect the current position and any revised safeguarding measures. The ADCP must be made available to the Home Office upon request.

Appointments with the Local Authority

Where the Local Authority arranges to attend the centre in connection with the age dispute, including to conduct a brief enquiry or to take the individual into their care, the appointment must be treated as a priority and facilitated without avoidable delay. Staff must ensure that the individual is made available for the appointment, that necessary access arrangements are in place, and that any relevant internal teams are notified in good time.

Centres must work cooperatively with Local Authority representatives and with caseworking teams to support timely progression of the age dispute. This includes ensuring that agreed appointments are not impacted by avoidable delays at reception or release stage, and that communication is maintained where operational issues arise. Any missed, postponed or delayed appointment, and the reason for it, must be clearly recorded and notified via the relevant case-working team inbox.

Healthcare

Healthcare must be informed when an age dispute is raised and must be given the opportunity to contribute to the initial assessment, the ADCP and any ongoing review where relevant. Healthcare input should be considered in light of the individual’s presentation, vulnerabilities, any immediate welfare or mental health concerns, and any issues relating to medication, treatment or support needs while the individual remains in detention.

Where a specific healthcare concern arises, or where healthcare input is required to support safeguarding decisions, this must be sought promptly and recorded on the ADCP and relevant systems. Staff should not assume that the standard adult treatment pathway will always be appropriate for this cohort, and any uncertainty about healthcare arrangements should be escalated to the centre healthcare manager.

CSP responsibilities and challenge

CSP staff must be alert to indicators that an individual entering detention may be a child and must not assume that a previous assessment or earlier decision removes the need for immediate safeguarding action where concerns remain live. Should staff have ongoing concerns about an individuals’ age or receive information giving rise to a concern that the individual is in fact a child, the IRC Centre Manager and the on-site DETs (on-call Compliance team out of hours) should be informed immediately.  

If a ‘significantly over 18’ initial age decision was made previously by the Home Office, any new evidence must be shared with the Age Disputes Resolution Team for the decision maker to consider whether this changes the Home Office assessment. The decision maker should consider all available information. Where a local authority or the National Age Assessment Board (LA / NAAB) have previously made an age assessment, any new evidence must be shared with them via the Age Disputes Resolution Team in order for the LA / NAAB to consider whether this changes their assessment. This must be done as a matter of urgency and the safeguarding actions detailed above should be taken immediately.

In some cases, an individual may have already been assessed as over 18 by the Home Office while in detention but has chosen to appeal that decision with the local authority. In these circumstances, the age dispute case must be reopened, and the steps in this instruction followed.

Annex A – Age dispute care plan (ADCP)

Plan REF Number (for local use only):

Individual’s Name

Insert individual’s picture:

ATLAS/CEPR:

Location:

Language/Comprehension of English:

English – Ability to speak/understand: (Good / Some / None)

First Language:

Interpreter required: (No / Yes - Details:)

Staff member opening the ADCP:

Date and Time opened:

CASE MANAGER Name and Grade:

Part C sent to DEPMU and DET?

Date and Time:

Sent to Case owner (DET only):

Date and Time:

Initial assessment and immediate action plan completed - Duty Manager:

Date:

Time:

Required frequency (day & night) of conversations and observations:

1. From [date]
2. From [date]
3. From [date]

Initial assessment and immediate action plan

The Immediate Action Plan must be completed by a Detainee Custody Manager (DCM) as soon as practically possible upon an age dispute being raised, and must involve a multi-disciplinary approach. This will determine any actions required and the correct level of support for the individual. A DCM must check the booklet daily to ensure the appropriate level of support is being maintained. The document will remain open until the individual is either released into the care of the local authority, or determined to be an adult and their detention maintained. When closing the document, an IS91 RA part C must be completed and sent to DEPMU for uploading to ATLAS, and the individual file updated by CSP. DET will send the Part C to caseworkers.

Individual’s Name

ATLAS/CEPR

Location

Case Manager:

Grade:

Date and time:

Signed:

Consulted: (Role, In person/Telephone/Email)

Healthcare Home Office Activities Other…………………

Observations of individual’s welfare and any vulnerabilities identified:

Will any amendments be made to the individual’s access to activities? Please specify, including the justification.

What kind of safeguards will be put in place for this individual? Please specify, including the justification. What monitoring arrangements have been put in place for those identified with vulnerabilities and welfare concerns?

Immediate care actions

Room Share Risk Assessment Review completed YES / NO

Personal Emergency Evacuation Plan needed? YES / NO

Individual’s location assessed and agreed YES / NO

Part C to DEPMU and DETs YES / NO

ACDT opened? Or review required? YES / NO

Individual’s regime access agreed YES / NO

Special arrangements required (expand above) YES / NO

Other………………….……

Other………………….……

Other………………….……

Multidisciplinary case review

Review number:

All departments who may be involved in supporting the individual must attend where possible, for example Home Office Compliance and DETs, the faith team, healthcare, welfare staff, activities and education etc. A verbal contribution may be obtained over telephone when they are not available to attend.

Detained Individual’s Name:

ATLAS/CEPR:

CSP Manager:

Other Attendees/Contributors:

Date and Time:

Have there been any changes in the individual’s circumstances?

Are they receiving the correct level of support?

Print Name:                                              

Position:                                                  

Date and Time:                                        

Signed:

Ongoing support monitoring

You should consider the following areas when preparing the support record:

• Does this individual have a disability?
• Does the individual need medical advice or support?
• Is the individual at risk of self-harm?
• Does the individual have friends or family to support them?
• Does the individual need faith support?
• Is the individual being safeguarded when accessing activities within the centre?

Review number:

Issues identified:

Actions required:

By whom and when:

Progress status:

Date completed:

Reviewing manager signature and date: