Guidance

Names: aligning names on foreign documents

Updated 22 October 2025

Version 30.0

His Majesty’s Passport Office guidance on how to deal with passport applications when the name a customer applies in does not match the name on their foreign documents

1. About: Names: aligning names on foreign documents

This guidance tells His Majesty’s Passport Office operational staff how to deal with customers when the name on their passport application does not match the name on their foreign documents. It tells staff:

• what the customer must do (before we issue them a passport)

• when we will consider issuing a passport using the name on a passport application (even if it does not match the name on the customer’s foreign document)

This guidance makes references to foreign documents and foreign passports. In this guidance, both foreign documents and foreign passports refers to non-British passports and national identity cards (for example, German citizens who have personal identity cards).

1.1 Contacts

If you have any questions about the guidance and your line manager or senior caseworker cannot help you or you think that the guidance has factual errors then email the Guidance team

If you notice any formatting errors in this guidance (broken links, spelling mistakes and so on) or have any comments about the layout or navigability of the guidance then you can email the Guidance team.

1.2 Publication

Below is information on when this version of the guidance was published:

• version 30.0

• published for Home Office staff on 16 October 2025

1.3 Changes from last version of this guidance

This guidance has been updated:

• in the section

  • ‘The administrative fairness test’, to expand the administrative fairness test for customers who would be put at risk if we add an observation

  • ‘Cultural naming conventions’, to tell examiners what to do when the customer’s foreign document includes an ‘also known as’ name

  • ‘Names observations for disputed territories’ to remove Palestine following the recognition of the State of Palestine (Palestine (Gaza) and Palestine (West Bank))

• to add new sections:

  • ‘Patronymic naming conventions’, to tell staff how to deal with patronymic naming conventions

  • ‘Name difference: names in a different order’, to tell examiners to check the Machine Readable Zone (MRZ) before asking the customer to align their foreign document

  • ‘Customer’s name change ordered by court’, to add an exception to name alignment for a child holding a foreign document, where there is a court order in place preventing disclosure of the child having a previous name

  • ‘Adding observations for name differences’, to add a name alignment observation table

• throughout to:

  • review and restructure the contents of the guidance

  • make terminology changes

  • change terminology from ‘connection from abroad’ to ‘international connection’ to align with the DAP Comms Builder

  • tell examiners to check previous applications for evidence of name alignment issues before contacting the customer

2. Aligning a name on a foreign document

This section tells His Majesty’s Passport Office staff about our ‘use of names’ policy and why we ask customers to align their name during a passport application when a customer applies for a passport in a name that does not match their name on their foreign document.

Our policy about aligning names on foreign documents, follows the Home Office policy on the use and change of name.

Customers applying for a British passport, must:

• tell us about any other valid (or expired) passports they hold including other British nationalities or foreign passports (see Declaring foreign passports)

• use the name they use for all official purposes (the name they use for going about their daily lives)

• make sure their official documents match the name they want to be known by, including their foreign documents

• make sure any spelling errors on their documents have been corrected. If the name cannot be corrected, they must enclose a full explanation of the difference

We must check the customer’s name on their foreign documents match the passport application.

If a customer has not declared another passport when making their application, see declaring another passport when a customer makes an application.

2.1 Why customers must align their documents

We will not issue the customer a passport if we cannot confirm they use one name for all official purposes. For example, when the customer applies for a passport and they:

• provide a national identity card in a different name to the one on their passport application

• declare a foreign or other British passport (for example, a British National Overseas passport) in a different name to the one on their passport application

This is because, we:

• must protect the security of the British passport (by preventing, disrupting, and identifying those who change their name to commit crime or avoid detection)

• cannot accept documents that allow a customer to apply for a foreign passport, travel document or identity document in a different name

Customers may send us a passport application in a name that does not match their foreign documents. Unless it meets one of our exceptions, we expect customers to align their foreign document to match their passport application before applying.

You, the examiner, must establish which name the customer uses and make sure all documents are aligned to show that name. These documents include any foreign passports, travel document or identity documents.

2.2 Declaring foreign passports

The UK allows its citizens to hold dual nationality. Although we do not tell other countries if a customer has dual nationality, we still ask them to declare any valid or expired passports when they apply for a British passport. We do this:

• for security reasons

• to help us:

  • decide if the customer is entitled to a British passport

  • confirm the customer’s identity

  • identify any vulnerability concerns

• because we need to consider if the customer can apply for another foreign passport

Regardless of how the customer makes their passport application, we ask them to declare any other valid or expired passports at the time of application.

It is a criminal offence if a customer does not declare another passport. If we find they have not:

• they may be subject to prosecution

• we may cancel their British passport (if they have one)

We will also investigate the reasons and decide whether to refer them for a criminal investigation.

3. DAP: name alignment

This section tells HM Passport Office operational staff how to deal with applications on DAP (Digital Application Processing) which have a foreign passport name alignment task to examine, as the customer holds a foreign passport.

You, the examiner, may identify the customer holds a foreign passport if:

• DAP (Digital Application Processing) creates a Foreign passport name alignment task, because the customer has applied on DCS (Digital Customer Service) and declared their foreign document

• the customer did not declare a foreign document on their application, but information provided by the customer, or previous case notes, show they hold a foreign document

DAP will not create a Foreign passport name alignment task, if the customer:

• applies using a paper form, (you must check section 3 of the paper application form to see if the customer has declared a foreign passport)

• does not declare a foreign passport in their application

Where DAP has not created a foreign passport name alignment task you must follow this guidance, and case note your actions and decisions using another task.

3.1 DAP: if the customer holds a foreign passport

If the customer holds a foreign passport, travel, or identity document, you must check:

• if we have received the documents (originals or colour photocopies)

• if the customer’s name on their foreign documents matches the name on their British passport application

Where the name does not match, you must check:

• if you can proceed without asking for the foreign document to be aligned because:

  • of a minor change due to a hyphen, space or apostrophe

  • an exception applies and you will issue the British passport with an observation

  • Knowledge Base shows there are naming conventions or restrictions on changes

3.2 DAP: foreign passport name alignment task

For applications made online, the Foreign passport name alignment task will ask you ‘Can you confirm the names align’ or ‘is there an allowable exception?’’. To process the task, you must add a case note to explain the actions and decisions you made and select:

• Yes, if the customer sent us their foreign document (or colour photocopy where this guidance says it can be accepted) and:

  • the name on it matches the one on the application

  • the name does not match but you can apply an exception that means they do not need align their name

  • the name does not match but you are using the administrative fairness test and decide they do not need to align their name

• No, withdraw application, if the customer sent us their passport or document, and their name does not match the one on their application and you are withdrawing their application because either:

  • you cannot apply an exception and the customer will not align their name

  • the customer will not provide evidence for the administrative fairness test

• No, need new documents, if you need to send an email (using the Comms builder) to the customer because:

  • they did not send us their foreign document and you need to see it to check their names

  • they need to align their name on their foreign document and you are returning the original to them, from the DHU

  • you need to tell the customer to align their name on their foreign document (if we have only received a copy of their document)

  • their names do not align, and you need to tell the customer to provide evidence so you can use the administrative fairness test

• Delay decision on this task, if you cannot deal with the task right now (because you need to email the customer as part of another task)

• Refer for investigation (after you have completed additional checks) if you have fraud concerns

Selecting No, withdraw application will withdraw the application. You must:

• send the customer an email using Comms builder explaining the reason for withdrawing the application (for example, because the customer will not provide the evidence we need or refuses to change their name)

• update the handling instructions in ARD if you need to retain the customer’s British passport (see Customer refuses to change name: renewal and replacement applications).

3.3 DAP: foreign passport name alignment process

This table is a summary of the DAP process steps shown above:

Does DAP show a name alignment task?	Has the customer sent their foreign passport, travel, or identity document?	Do the names align?	Add a case note, to record your actions and decisions and:
Yes	Yes (or a colour photocopy that this guidance says we can accept)	Yes	Select yes in the task
Yes	Yes (or a colour photocopy that this guidance says we can accept)	No	Select yes in the task if you decide the customer does not need to align their name because: • the country guidance in Knowledge Base confirms alignment is not possible and you are applying an exception • you have used the administrative fairness test You may need to add an observation to show the customer holds a foreign passport in another name
Yes	Yes (colour photocopy or original documents handled by the DHU)	No	Select no, need new documents and use Comms Builder to tell customer to update name on foreign document (and send us their new document or a colour photocopy where its acceptable in this guidance, when it is changed) Update ARD (Application Receive Domain) to return the original passport so the customer can align their name.
Yes	Yes	No	Select no, withdraw application in the task if you cannot apply an exception and the customer will not align their name, or they will they not provide evidence for the administrative fairness test
Yes	No	Not known	Select no, need new documents and contact the customer using Comms Builder to send latest foreign document
No	Yes	Yes	Case note in another task, to show the names align
No	Yes	No	Case note in another task, if you decide the customer does not need to align their name because: • the country guidance in Knowledge Base confirms alignment is not possible and you are applying an exception • you have used the administrative fairness test You may need to add an observation to show the customer holds a foreign passport in another name
No	Yes (colour photocopy or original documents handled by the DHU)	No	Select no, need new documents in another task and contact the customer using the Comms builder, telling them to update name on foreign document
No	Yes	No	Select no, withdraw application in another task if you cannot apply an exception and the customer will not align their name, or they will not provide evidence for the administrative fairness test
No	No (but we find out the customer does hold a foreign document during examination)	Not known	Select no, need new documents in another task and contact the customer using Comms Builder to send latest foreign document

4. Checking for name differences

This section tells His Majesty’s Passport Office operational staff how to deal with passport applications when a customer applies for a passport in a name that does not match their name on their foreign document.

Before contacting the customer to ask them to align their foreign document, you, the examiner, must check:

• if the name difference is due to the addition or removal of a hyphen, space or apostrophe

• Knowledge Base for information about:

  • cultural naming conventions

  • information about technical issues which may affect how a name is displayed on a foreign document

4.1 Name difference: hyphen, space, or apostrophe

We will not ask the customer to align their name when all the following apply:

• the only difference between the names is the addition or removal of a hyphen, space, or apostrophe

• the order of the name has not changed

• a surname has not become a part of a forename

• a forename has not become part of a surname

For example, we will accept the name difference if the customer’s:

• surname on their foreign passport is Jones-Smith and the surname on their passport application is Jones Smith (the hyphen has been removed)

• forename on their foreign passport is JohnPierre and the forename on their passport application is John Pierre (a space has been added)

• forename on their foreign passport is John’Pierre and the forename on their application is John Pierre (an apostrophe has been removed)

If we can accept the name differences because they only relate to a hyphen, space, or apostrophe, you must:

1. Accept the name.

2. Add a case note to show all your actions and decisions (see Names: name related case notes for what you must include in the case note).

3. Contact the customer to tell them you will add an observation to their new passport, due to the name difference (in line with How to contact customers by phone)

4. Issue a passport with full validity with an observation to show the customer’s name in their foreign passport. You must amend observation code OBTZ, according to the name alignment observation table.

You must not add an observation if the foreign document is in a different gender to the new British passport.

If a customer tells you that adding an observation that shows they have a foreign passport or document will cause them problems, you must:

1. Check Knowledge Base to find out if an observation will cause travel problems or put the customer at risk.

2. Refer to When observations may cause the customer problems.

4.2 Name difference: spelling errors

If the name is different due to claimed spelling errors on the documents, you must ask the customer to amend the name on the documents or provide evidence showing they meet an exception.

You must assess the evidence provided by the customer to establish which name the customer uses for all purposes.

Unless there is an exception in guidance due to mitigating factors, we will not issue a passport when there are doubts or inconsistencies between the name on the customer’s passport application and their supporting documents.

4.3 Name difference: names in a different order

If the name is different due to being in a different order, you must check the format of the customer’s name in the Machine Readable Zone (MRZ) of their foreign passport, before asking the customer to align the passport.

This is because the MRZ will show the correct format of a customer’s name, even if there are technical restrictions in the issuing country.

If the order of the name on the foreign passport’s MRZ matches the British passport application and the customer’s documents, you must accept this and issue a passport in line with current guidance.

4.4 Checking Knowledge Base

If the name difference does not relate to a hyphen, space, apostrophe or initials you must check Knowledge Base to see if the issuing country has any:

• legal, cultural, social, or technical restrictions, relating to:

  • name changes

  • gender changes

  • dual citizenship

  • the number of characters a foreign authority can use for the customer’s name, and if it is less than the British passport character limit

• cultural naming conventions (rules that say how a name must be shown) that may explain why the name is different (see Names: how to show uncommon names in passports)

When you check Knowledge Base, you must consider, if:

• a customer can change the name on their foreign document and if they cannot, what evidence you need to confirm this

• a customer can only change their name on a foreign document by travelling to the issuing country

• a customer can change the name on a foreign document without travelling to the issuing country, for example:

  • if a third party (such as friend, relative or solicitor) who lives in the country where the document is from, can change the customer’s name on their behalf

  • if a customer can change their name by contacting the relevant UK based embassy, consular office, or High Commission

  • a customer who holds both an internal and international passport for another country, can change their residency status which allows them to change the name from the UK

• the issuing country does not allow dual citizenship (customers must check with the foreign consulate or High Commission before deciding on their foreign citizenship)

• a customer tells us they cannot change their name, and provide evidence to confirm this (in line with The administrative fairness test)

4.5 Name difference: initials

If the name is different due to the use of an initial instead of the full name, for example, John P White, the customer must be asked to align the passport.

If Knowledge Base or evidence from the customer confirms that initial(s) have been used due to the character limit (not enough space for the full name to be shown), you must:

1. Accept the name.

2. Add a case note to show all your actions and decisions (see Names: name related case notes for what you must include in the case note).

3. Contact the customer to tell them you will add an observation to their new passport, due to the name difference (in line with How to contact customers by phone)

4. Issue a passport with full validity with an observation to show the customer’s name in their foreign passport. You must amend observation code OBTZ, according to the Observation table for name alignment

You must not add an observation if the foreign document is in a different gender to the new British passport.

4.6 Cultural naming conventions

If Knowledge Base shows the issuing country has naming conventions, you must consider if this is the reason their name is different.

You must check Knowledge Base to find out if the issuing country allows the customer to align their name. You may need to check previous applications to see if there is any information or case notes which explain why the name is different.

For example, a previous application submitted for a child will show parents details or a case note explaining why a customer holds a Japan passport in their mother’s surname, and a British passport in their father’s surname. Information on Japan’s naming conventions in Knowledge Base will confirm this.

If the country allows the customer to align their name, you must ask the customer to change their name on their foreign document, or provide evidence showing:

• the change cannot be done; or,

• the process of aligning their foreign document would cause them problems (see the administrative fairness test)

You must refer to Exceptions to name alignment requirements, if Knowledge Base shows:

• the country does not allow the customer to align their name

• the name change will fall outside of the naming convention

• there are no naming conventions in the country, but the customer provides official evidence that explains the difference in the spelling of their name is because of a naming convention

If the foreign document has an ‘also known as’ observation matching the British passport application, you must add observation code OTBZ, according to the name alignment observation table.

4.7 Patronymic naming conventions

You must check Knowledge Base to see if the name difference is due to the use of patronymic naming conventions in the issuing country. A patronymic naming convention is a system where a second forename is created using the father’s forename, often with a suffix indicating ‘son of’ or ‘daughter of’.

If the difference is due to the addition of a patronymic name on the foreign document, you must not ask the customer to align their foreign document. The British passport must be issued with an observation, providing a direct link to the name on the foreign document.

You, the examiner, must:

1. Accept the name difference.

2. Add a case note to show all your actions and decisions (see Names: name related case notes for what you must include in the case note).

3. Translate the patronymic name from Cyrillic characters (if the patronymic name is shown in Cyrillic characters) using the ICAO Transliteration table.

4. Issue a passport with an observation showing the customer’s transliterated name on their foreign passport, by amending observation code OBTZ, according to the name alignment observation table.

4.8 When Knowledge Base shows restrictions on aligning names

You must refer to the exceptions guidance, if Knowledge Base shows the country where the document is from, has legal, cultural, social or technical restrictions, relating to:

• name changes

• gender changes

• dual citizenship

• the number of characters a foreign authority can use for the customer’s name, and if it is less than what we can put in the British passport

4.9 Knowledge Base shows there are no restrictions on name alignment

If Knowledge Base shows the country does not have legal, cultural, social or technical restrictions, there are no naming conventions or the difference does not relate to a hyphen, space or apostrophe, you must the Comms Builder to tell the customer:

• you have identified a difference between the name on their foreign document and their passport application

• the Home Office has a ‘use of one name for all purposes’ policy

• to confirm the name they use for all official purposes and to provide evidence

• they must change the name on their foreign document to match the name on their passport application

• you cannot issue them a British passport until they do, or they can provide evidence from the foreign authority showing they cannot change the name on their foreign document

You must tell the customer to align the name on their original foreign document and continue to deal with the application by following the Returning documents on live applications guidance.

When processing the application, you must:

1. Add a case note to show all the actions and decisions you made (see Names: name related case notes for what you must include in the case note).

2. Wait for the customer to send the updated foreign document to you. You may accept a colour photocopy of the document (by post or email) for a renewal application. For any other application type, you can only accept a colour photocopy when you have already seen the original.

If you have any concerns, you must ask for the original document.

If the customer does not respond or you lose contact with them, withdraw the application (see passport application withdrawals).

If the customer tells you it is too difficult for them to change their name, you must refer to the administrative fairness test.

When the foreign document has been updated (and you have no concerns), you must check if the customer’s name matches the name on their passport application. If it:

• does, and you have no other concerns with the application, you must:

  • issue the customer a passport (in line with current guidance)

  • add a case note to show all actions and decisions you have made, (see Names: name related case notes for what you must include in the case note)

• does not, you must check Knowledge Base to find out if any local naming conventions mean the name is presented differently, for example, where a Latin spelling changes the spelling of a name. If a naming convention shows this, you must:

  • accept the foreign document

  • issue the customer a passport (in line with current guidance), with an observation to explain the difference in spelling

If the customer’s name does not match the name on their passport application and you cannot find any details of local naming conventions on Knowledge Base, you must:

• not issue the customer a British passport

• return the foreign document to the customer and ask them to change the name or provide evidence that shows why they cannot (see exceptions to name alignment requirements)

If the customer:

• does not respond, you must withdraw the application (in line with the passport applications withdrawal guidance)

• refuses to align their name, you must refer to customer refuses to change their name

• gives you evidence that they cannot change their name, you must check:

  • the evidence is from an official source (for example, a government website or issuing authority)

  • if the reason meets one of our exceptions to name alignment requirements

• tells you it is too difficult for them to change their name, you must refer to the administrative fairness test

4.10 Customer gives information not shown in Knowledge Base

If we do not hold information on Knowledge Base to confirm that a customer cannot change their name on a foreign passport, you must ask the customer to give us evidence from an official source to confirm this.

The official source can include:

• an official government website

• a credible website, for example, the:

  • United Nations International Children’s Emergency Fund site

  • European Asylum Support Office site

• an email from an official authority (for example, the Embassy or Consulate of the country of issue, that clearly shows they sent it)

• a letter from an official authority (for example, the embassy or Consulate of the country that issued the document)

If the information is not already in Knowledge Base, you must:

1. Email the Guidance team with the information that needs updating.

2. Include a copy of the evidence the customer gave you.

The Guidance team will update Knowledge Base with the new information.

You must not contact or respond to any email from an embassy or foreign authority. Only the International liaison team are authorised to deal with foreign authorities. You must send the email to the International liaison team who will respond on your behalf.

5. Name alignment: adopted children

This section tells His Majesty’s Passport Office operational staff how to deal with a passport application where an adopted child’s name does not match the name on their foreign document.

You, the examiner, must deal with applications for adopted children in line with the adoptions guidance. If an adopted child’s name on a passport application does not match the name on their foreign document, we:

• must check Knowledge Base, to find out if there are any reasons why the adoptive parents cannot align the child’s name on the foreign document

• expect the adoptive parents to change the child’s name on the foreign document, to match the name on the passport application

• will not accept the child’s name is different because the adoptive parents want the child to maintain a cultural link with their country of birth

In most cases, the parent can change the child’s name on the foreign document by contacting the correct UK based embassy, High Commission or consular office.

You must not:

• encourage adoptive parents to add an observation that allows us to issue a child’s passport in a name that does not match their name on a foreign passport (to provide a break with the old name)

• consider adding observations without evidence from the parents, showing they cannot change the name on the foreign document

5.1 Adding observations to passports for adopted children

Before you add an observation to a passport for an adopted child to show they have a passport in a different name, you must consider if:

• the adoption record is sealed (kept private) which the:

  • General Registrar Office (GRO) can confirm, if it is a UK adoption (see adoptions guidance, for details of the GRO for England and Wales, Scotland and Northern Ireland)

  • Department of Education can confirm, if the parent adopts a child from another country (see adoptions guidance, for details of the Department for Education)

• there are safeguarding (child protection) concerns

• the adoptive parents support the addition of an observation

Adoption record is sealed or you have safeguarding concerns

If the adoption record is sealed (or you are unsure if it is sealed) or you have safeguarding concerns, you must refer the application to the Quality, Examination Support team (QuESt). QuESt will decide if you can add an observation to show a child has a foreign passport in a different name (taking into account the parental rights of the birth and adoptive parents).

If you have safeguarding concerns, or believe the customer is at risk of harm, you must refer to How to safeguard a customer and a minor.

We do not usually add an observation showing an adopted child’s previous name when an adoption record is sealed or there are safeguarding concerns. This is so we can protect their safety, in line with:

• the disclosure of information in relation to a person’s adoption section of the Adoption and Children Act 2002

• section 15 of the Children, Schools and Families Act 2010

• overseas adoption laws (if it is on overseas adoption)

Due to the sensitivity of these applications, you must raise a guidance query and include all supporting evidence, if either the:

• adoption record is sealed

• adoptive parents agree to add an observation to the child’s passport, showing the name on their foreign passport (unless their name has changed, and the courts have noted it as ‘the name to be known as’ in the adoption agreement)

Adoption record is not sealed and no safeguarding concerns

You may add an observation to an adopted child’s passport to show they have a foreign passport in a different name, when all the following apply:

• the adoption record is not sealed

• you do not have safeguarding concerns

• adoptive parents agree to add an observation to the child’s passport, showing the name on their foreign passport

• the reason the child cannot align the name meets one of our exceptions or you decided the customer does not need to align the passport in line with the administrative fairness test

6. Exceptions to name alignment requirements

This section tells His Majesty’s Passport Office staff about when we will exceptionally issue a passport in the name on the passport application, even though it does not match the name on a customer’s foreign passport, travel document or identity document. It also explains when they must add an observation to show the customer has a foreign passport or document in a different name.

Customers must apply for a passport using the name they use for all official purposes and must match the name on their foreign documents. Although we expect the customer to change the name on their foreign document to match the name on their passport application, some customers may not be able to.

There are exceptions when we will issue a passport in the name a customer has applied in, even though it is different to the name on their foreign document. We will consider:

• the legal, cultural, social and technical restrictions of other countries that stop customers from aligning their foreign document

• if the customer’s foreign passport is lost or stolen

• if the customer does not wish to renew their expired foreign passport, or replace a missing foreign passport

• if the customer is already in the process of aligning the name on their foreign passport

• if there is no reasonable way for a customer to change their name on a foreign document

• if there is a court order showing we must not disclose a customer’s previous name (for example a court order showing a child’s name change which must not be disclosed for safeguarding reasons)

6.1 Exceptions: legal, cultural, social and technical

Customers who hold nationality of more than one country are called dual nationals and may hold identity cards, travel documents or passports for each of those countries. They may not be able to change the name on their foreign document to meet the Home Office name alignment policy due to the legal, cultural, social and technical restrictions of the issuing country.

The restrictions that stop the customer from changing their name on the foreign document are when, the:

• law in the issuing country does not allow a change of name or only allows a partial change of name (see country does not allow a change of name)

• issuing country does not allow dual nationality (country does not allow dual nationality)

• customer can only change the name by travelling to the issuing country, but would be placed at risk if they did (see FCDO advice shows there is a risk of travelling)

• customer has changed their name because they have changed gender and the law in the issuing country does not allow or recognise a change of gender (see country does not allow or recognise a change of gender)

• foreign authority that issued the document used a shortened version of the customer’s name, because it was too long to fit on the foreign document (see technical restrictions mean full name is not on the passport)

• issuing country will not issue a new document to show the name change until we have issued a British passport in the customer’s new name

If Knowledge Base or official evidence (for example, from an official government website or issuing authority) shows a customer meets an exception, we will issue them a passport using the name on their application, even though it is different to their foreign document. In this case, an Observation must be added to link the names.

Country does not allow a change of name

We will issue a passport in the name the customer has applied in and add an observation to the British passport, if:

• Knowledge Base or official evidence from the customer (for example, an official document from an embassy, consulate or High Commission) shows the law in the issuing country does not allow a change of name or only allows a partial change of name

• there are no other concerns with the application

The information may also be shown on an official government website. We will accept this as evidence if it clearly confirms the customer cannot change the name because of the law in the issuing country. You must not contact or respond to any email from an embassy or foreign authority. Only the International liaison team are authorised to deal with foreign authorities. You must send the email to the International liaison team who will respond on your behalf.

You must:

1. Tell the customer you will issue them a passport with an observation to show they have a foreign passport in another name.

2. Add an observation in the passport to show the customer’s name on their foreign document. This includes if a customer holds a foreign passport which includes an ‘also known as’ name, due to local variations (see Knowledge Base profiles).

3. Amend observation code OBTZ, according to the name alignment observation table.

4. Add a case note to show all the actions and decisions you have made (see Names: name related case notes for what you must include in the case note).

5. Make sure any evidence the customer gave you is permanently scanned on the system (see scanning supporting documents).

6. Issue the passport.

We will only issue a passport without an observation, when:

• the customer provides evidence showing they have changed the name on their foreign document (to match the name on the passport application)

• the customer provides evidence showing they may be at risk of harm if an observation is included on their passport

• they send us a fully completed passport application

• their foreign document is in a different gender than the new British passport

If a customer tells you that adding an observation showing they have a foreign document will cause them problems, you must refer to When observations may cause the customer problems.

Country does not allow dual nationality

The constitution or legislation of some countries deliberately stops their citizens from holding the nationality of another country. In most cases, you can find this information in the Knowledge Base.

You must not tell a customer to give up another country’s nationality or cancel their foreign passport, as they must decide themselves whether to tell an overseas authority about their British nationality. Before they do, they must check with the consulate or High Commission about the effect of giving up their nationality.

If the customer tells you they will give up the other country’s nationality and cancel their foreign document, you must tell them:

• it is their decision and they should check with that country’s consulate or High Commission about the effect of cancelling their nationality

• they must give you official evidence that shows they gave up (or lost) the other country’s nationality and the foreign authority has cancelled their foreign passport

If the original foreign document is held in the DHU (Document Handling Unit), you must use ARD (Application Receive Domain) to return the original document to the customer by secure delivery, then follow the steps below.

You must:

1. Write to the customer using letter 344 to tell them they must give you official evidence.

2. Wait for the customer to respond. If you do not get a response, withdraw the application (see withdrawal of passport applications guidance).

3. Check the evidence received from the customer using Knowledge Base as there may be different types of evidence you can accept, depending on the country.

4. Check the document is scanned onto the system as a permanent record (see Document scans).

5. Add a case note to show all the actions and decisions you have made (see Names: name related case notes for what you must include in the case note).

6. Issue the customer a passport (in line with current guidance).

If the customer decides they do not want to tell the overseas authority about their British nationality, they must change their name on the foreign document to match the name on their British passport application, in line with this guidance. You must not contact or respond to any email from an embassy or foreign authority. Only the International liaison team are authorised to deal with foreign authorities. You must send the email to the International liaison team who will respond on your behalf.

Customer must travel to the issuing country

In most cases, customers can change their name on a foreign document, by contacting the:

• relevant UK based embassy

• High Commission

• consular offices

If Knowledge Base shows the customer must go to the issuing country, and no other exceptions apply, you must tell them, to:

• visit the issuing country to align the document; or,

• confirm in a written statement, why they cannot travel to the issuing country to change their name

While we try to reduce the impact travelling has on a customer, it is outside of our control, as we must protect the security standards of the British passport.

If a customer tells you that travelling to the country where the document is from will put them at risk, you must check the country’s Foreign, Commonwealth & Development Office (FCDO) website, for:

• travel related advice

• general security advice

FCDO advice shows there is a risk of travelling

If Foreign Commonwealth & Development Office (FCDO) advice shows there is a risk of travelling to that country, we will consider issuing the customer a passport, with:

• restricted validity (RV) using the name the customer applied in (if FCDO advice confirms the risk of travelling is likely to be short term)

• full validity, using the name the customer applied in (if the FCDO advice confirms the risk of travelling is likely to be long term or it does not show how long the risk will last)

We cannot list every situation where the risk of travelling is likely to be short term. However, an example may be when there has been an earthquake and FCDO advice is to avoid travel in the short term.

The Quality, Examination Support team (QuESt) will consider if you need to issue an RV or fully valid passport. You must:

1. Raise a guidance query and include all supporting evidence with your query.

2. Put the application on hold while you wait for a response.

QuESt will review the evidence and may contact Passport Policy for advice. If QuESt confirms you can issue the customer an RV (or fully valid passport) and there are no other concerns with the customer’s application, you must:

1. Add a case note to show all the actions and decisions you have made (see Names: name related case notes for what you must include in the case note).

2. Add observation code OBTZ, according to the name alignment observation table, to show the customer’s name in their foreign document.

3. Add observation code OBTU to show you have issued an RV passport (if you are issuing an RV passport).

4. Issue an RV or fully valid passport, depending on what QuESt tells you to do.

We will only issue a passport, without an observation, when:

• the customer provides evidence that they have changed the name on their foreign document, so it matches the name on their passport application

• the customer provides evidence showing they may be at risk of harm if an observation is included on their passport

• they send us a fully completed passport application

• the foreign document is in a different gender than the new British passport

If a customer tells you that adding an observation that shows they have a foreign passport or document will cause them problems, you must:

1. Check Knowledge Base to find out if an observation will cause travel problems or put the customer at risk.

2. Refer to When observations may cause the customer problems.

FCDO advice shows there is no risk of travelling

If Foreign Commonwealth & Development Office (FCDO) advice shows there is no risk of travelling, you must refer to the administrative fairness test guidance.

Customer has previously been granted asylum or refugee status

Customers granted asylum or refugee status in the UK may be at risk if we ask them to align their foreign document. You must check if they will be put at risk if they contact the foreign authority to align the documents.

If the customer, or information in their application, indicates they were previously granted asylum or refugee status, you must check UK Visa and Immigration (UKVI) systems to:

• confirm the customer was granted asylum or refugee status

• check the reason they were granted asylum or refugee status

The customer may have been granted asylum or refugee status for protection from the state (or bodies associated with the state), and this could mean they may still be at risk if they contacted those authorities. For example, because that government is still in power. If the customer may still be at risk, you must:

• not ask the customer to align the foreign passport, travel document or identity card

• issue the British passport in their new name

• include an observation referring to the foreign document unless:

  • the customer tells you an observation may cause them problems

  • it is in a different gender than the new British passport.

You must ask the customer to align the name on their foreign document if they were previously granted asylum or refugee status, but it does not appear they would be at risk if they contact the authorities. For example, they may not be put at risk by contacting the authorities if:

• they claimed protection from a family member

• they claimed protection from groups in their society

• the situation they fled from no longer exists

You, must raise a guidance query to QuESt if:

• UKVI systems do not:

  • confirm the customer was granted asylum or refugee status

  • show the reason for the asylum or refugee status

• you ask for the document to be aligned and the customer feels they would still be at risk

QuESt will advise you what name a passport can be issued in, or what further evidence is required.

Country does not allow or recognise a change of gender

We expect customers who change their name because they have changed gender, to change the name on their foreign document to match the name on their passport application. However, if Knowledge Base (or acceptable evidence from the customer) shows the issuing country does not allow or recognise changes to gender, we will issue a passport using their name on the application.

Before you apply this exception, you must consider the passport application as a whole and make sure you are satisfied with the evidence the customer has provided (in line with the gender guidance).

If you are satisfied with the evidence, you must:

1. Add a case note to show all the actions and decisions you have made (see Names: name related case notes for what you must include in the case note).

2. Issue the passport (if you have no other concerns with the application).

3. Only enter details of a foreign passport as an observation in the customer’s new British passport if it is in the same gender as their new British passport. This is because disclosing an identity in a previous gender, breaches the Gender Reassignment Legislation and the Adoption Act.

If you are not satisfied with the evidence, you must raise a guidance query and include all supporting evidence.

Technical restrictions mean full name is not on the passport

If the name in the foreign passport is different because it has been shortened, you must:

• check Knowledge Base to see if there is information that shows the issuing country has a character limit less than ours

• ask the customer for official evidence (for example, from an embassy, government authority, consulate or High Commission) showing the name has been shortened to meet the character limit on the foreign document (if Knowledge Base does not show it)

If the name has been shortened on a foreign document because of a character limit, and you have official evidence to confirm this (from Knowledge Base or the customer) you must:

1. Add a case note to show all the actions and decisions you have made with reasons (see Names: name related case notes for what you must include in the case note).

2. Check the document is scanned onto the system as a permanent record (see Document scans).

3. Issue a passport with full validity and an observation to show the customer’s name in their foreign document. You must amend observation code OBTZ according to the name alignment observation table.

We will only issue a passport without an observation when the customer:

• provides evidence showing they have changed the name on their foreign document (to match the name on the passport application)

• the customer provides evidence showing they may be at risk of harm if an observation is included on their passport

• sends us a fully completed passport application

• has a foreign document in a different gender than the new British passport

If a customer tells you that adding an observation showing they have a foreign passport or document will cause them problems, you must:

1. Check Knowledge Base to find out if an observation will cause travel problems or put the customer at risk.

2. Refer to When observations may cause the customer problems.

6.2 Customer’s foreign passport is lost or stolen

If the customer tells us their foreign passport is lost or stolen, you must ask them to provide evidence from the issuing foreign authority that shows what name:

• was on the lost or stolen passport (so you can check it matches their current passport application)

• is shown on their registration system (some countries have a central registration record that all official documents align to)

You must tell the customer to get a replacement foreign passport in the name shown on the British passport application, if the evidence shows their foreign passport was in a different name. However, you must also consider if there are other exceptions that stop the customer from changing the name on their foreign passport.

Customer provides a replacement passport

You must check if the name on a customer’s replacement foreign passport matches the name on their British passport application (in line with this guidance).

Customer gives evidence of name on lost or stolen passport

In some cases, the issuing authority can only provide evidence of the customer’s name on the central register (from which they issue the passport).

When you get evidence from the issuing authority showing the customer’s name on their lost or stolen passport (or from the central registration records), you must check if it matches the name on their British passport application.

Evidence from issuing authority show the names match

If evidence received from the issuing authority confirms the names match, you must continue to deal with the application (in line with current guidance).

Evidence from issuing authority show the names do not match

If the evidence from the issuing authority shows the names do not match, you must:

• check if there are any other exceptions stopping the customer from changing their name with the foreign authority (to match their British passport)

• ask the customer to get a replacement passport in the name shown on the British passport application (if there are no other exceptions that stop the customer from changing their name)

You must deal with the application in line with this guidance, if:

• there are other exceptions that stop the customer from changing their name to match the name on their British passport

• the customer provides a replacement foreign passport (to check the name on it matches the name on the British passport application)

6.3 Customer does not wish to renew their expired foreign passport

If the customer does not want to renew their expired foreign passport, or replace their missing foreign passport, and there are other exceptions that stops them from changing their name, you must:

1. Add a case note to show all the actions and decisions you have made (see Names: name related case notes for what you must include in the case note).

2. Add the OBTO observation to the passport, according to the name alignment observation table, to show the customer is also known by another name (unless the foreign passport is in a different gender).

3. Issue the passport in the name on the British passport application.

If the customer does not want to renew their expired foreign passport or replace their missing foreign passport, and there no other exceptions that stop them from changing their name, you must tell them:

• they must apply to change their name with the foreign authority

• to provide evidence from the foreign authority showing they have applied to change their name on the central registration system (to match their British passport)

When you get the evidence, you must:

1. Check the evidence is from an official authority (for example, from an embassy, government authority, consulate or High Commission).

2. Check the document is scanned onto the system as a permanent record (see Document scans).

3. Add a case note to show all the actions and decisions you have made (see Names: name related case notes for what you must include in the case note).

4. Issue the passport in the name on the British passport application.

6.4 Customer is in process of aligning their name

We will issue a British passport using the name on the passport application, if the customer has a foreign document in another name, but provides evidence showing they are in the process of changing it. Evidence we will accept includes:

• an official letter from an embassy, government authority, consulate or High Commission, which confirms:

  • the customer has submitted their foreign passport to change the name on it

  • what name will be shown on the new foreign passport (as we need to make sure it matches the name on their British passport application)

• a digital or paper receipt from an issuing authority, which shows:

  • the customer has applied to change the name on their foreign passport

  • what name will be shown on the new foreign document (as we need to make sure it matches the name on their British passport application)

This is because:

• it may take a long time for the foreign authority to issue the foreign document

• we will be satisfied the customer told them about their name (using the evidence they give us)

When you get the evidence, you must:

1. Not wait for the customer to send us their new foreign passport or document (to show they have aligned their name).

2. Check the document is scanned onto the system as a permanent record (see Document scans).

3. Add a case note to show all the actions and decisions you made, with reasons (see Names: name related case notes for what you must include in the case note).

4. Issue the customer with a passport using the name on their passport application (you do not need to add any observations to show they have a foreign passport in another name).

If you are dealing with an application where a customer is experiencing issues with the process of aligning their name due to an ongoing crisis, you must consider any specific crisis guidance with your OTL (operational team leader) or QuESt (Quality and Examination Support team).

6.5 Customer’s name change ordered by court

A customer may provide a court order which shows that the court instructs them to change their name (for example a court order showing a child’s name change which must not be disclosed for safeguarding reasons).

If the customer tells us they have a court order instructing them to change their name, you must:

1. Ask the customer to send the court order to us (if not already provided).

2. Check the wording in the court order to see if the order states the customer’s previous name or court proceedings should not be disclosed.

You must raise a guidance query and ask QuESt to ask for advice from Passport Policy if you are unsure from the wording in a court order, whether we can disclose a previous name.

If the court order does not specifically state the customer’s previous name cannot be disclosed, you must continue with the examination process, and:

1. Add a case note to show all the actions and decisions you have made with reasons (see Names: name related case notes for what you must include in the case note).

2. Issue a passport with full validity with an observation to show the customer’s name in their foreign passport. You must amend observation code OBTZ according to the name alignment observation table.

7. Customer refuses to change their name

This section tells His Majesty’s Passport Office staff how to handle common scenarios, for example when the customer is using a foreign document for travel, is requesting an old passport to be returned, and when a customer refuses to align their foreign documents with their British passport application

A customer may refuse to change the name on their foreign document when asked to align. You, the examiner, must consider which name they use for all purposes before proceeding.

If the name on the foreign passport is not the name used for all official purposes, you must:

• not tell the customer to change their current name used on the passport application, to match their foreign document (for example, by deed poll)

• check if the customer has provided any new information that may meet our exceptions, or the criteria of the administrative fairness test

If the customer does not meet one of our exceptions or the administrative fairness test criteria, you must:

1. Tell the customer:

• you cannot issue them a passport, until they either change the name on their foreign document, or register the change of name with the relevant authorities to match their passport application

• that dual citizenship is allowed in the UK, and they must check with the relevant foreign authorities to find out about their laws on dual nationality

2. Send the customer a letter telling them what they need to do

3. Add a case note to show all the actions and decisions you have made (see Names: name related case notes for what you must include in the case note).

7.1 Customer refuses to change name: if you lose contact

If the customer does not respond after you asked them to change their name, you must withdraw their application and archive the supporting documents (in line with the withdrawal of passport applications guidance).

You must send any type of British passport or additional passport (held with the application) to long term storage.

If the customer has another type of British passport or additional passport and they still have it, you must raise a guidance query and ask the Quality and Examination Support team (QuESt) what to do about the other British passport. QuESt will assess this on a case by case basis and may contact Passport Policy team for advice.

If the customer later asks us to return their old passport, you must refer to when a customer asks for their old passport back.

7.2 Customer refuses to change name: if you are still in contact

The customer may refuse to align the name in their foreign passport. How you deal with the situation will depend on whether the application is for their first British passport or renewal or replacement of an existing one.

Customer refuses to change name: first time application

If you are still in contact with a customer who refuses to change their name on a first-time passport application, you must:

1. Discuss any concerns with your operational team leader (OTL), who may need to seek advice from QuESt. If you agree there are fraud concerns, you must:

• complete additional checks: and,

• select Refer for investigation

2. Withdraw the application (in line with the withdrawal of passport applications guidance).

3. Return the customer’s supporting documents.

4. Add a case note to show all the actions and decisions you have made.

Customer refuses to change name: renewal and replacement applications

If you are still in contact with a customer who refuses to change their name on a renewal or replacement application, you must check if the name on their old passport matches the name on their foreign passport.

If the name in the customer’s old British passport matches the name on their foreign document but not the name on the passport application (for example, because the customer changed their name since we issued their old passport) you must:

1. Discuss any concerns with your operational team leader (OTL), who may need to seek advice from QuESt. If you agree there are fraud concerns, you must:

• complete additional checks: and,

• select Refer for investigation

2. Withdraw the application (in line with withdrawal of passport applications and DAP name alignment task guidance).

3. Not physically cancel the old passport.

4. Return the old British passport to the customer (in renewal applications).

5. Return any other supporting documents to the customer.

6. Add a case note to show all the actions and decisions you have made.

If it is a renewal application and the name on the customer’s old passport does not match the name on their foreign document, you must:

1. Refer to When a customer asks for their old passport back, if the customer asks us to return their old British passport.

2. Add a case note to show all the actions and decisions you have made.

3. Withdraw the application (and deal with the DAP name alignment task).

4. Not cancel the old passport and retain it in storage using ARD.

5. Return any other supporting documents to the customer.

6. Raise a guidance query if the customer has other British passports, to ask QuESt what you should do with it – when you do, you must include:

• what type of British passport it is (including if it’s an additional passport)

• whether the customer sent it with their application

• any differences with the customer’s name between all their British passports and foreign documents

• if you find any visas in it when completing document validation checks

• if the customer tells you they are currently using the passport

7. Discuss the case with your OTL, who may need to seek advice from QuESt.

7.3 When a customer asks for their old passport back

If a customer refuses to change the name on their foreign document to match their passport application, we will have withdrawn their application and kept the old British passport, if:

• we lost contact with them during the examination process

• their name on the old passport did not match the name on the foreign document

If the customer asks us to return their old passport, you must:

• return it, if the:

  • name on the old passport matches the name on the foreign document

  • customer provides evidence that they are in the process of changing the name on their foreign document to match the name on their old passport

If the name in the customer’s old passport does not match the name on the foreign document, you must raise a guidance query with QuESt.

QuESt may consult with the Passport Policy team and will let you know if you can return the passport.

7.4 Customers who want to use their foreign passport for travel

It is the customer’s decision if they want to use their foreign passport for travel. If they do not have a British passport and want to use their foreign passport for travel, they may need a certificate of entitlement to prove they have Right of Abode in the UK.

Customers can find out more about certificates of entitlement on GOV.UK, including who can apply, how to apply and how much they cost.

8. The administrative fairness test

This section tells His Majesty’s Passport Office operational staff about the administrative fairness test and how it can be used in exceptional occasions when we will issue a passport in the name on the passport application, even though it does not match the name on a customer’s foreign document or meet an agreed exception.

An administrative fairness test allows us to make sure our processes and the decisions we make:

• are reasonable and fair, using discretion (when necessary)

• take in to account the customer’s circumstances (using the evidence they give us)

8.1 When we will use the administrative fairness test

We will use the administrative fairness test for a customer whose name on their passport application does not match the name on their foreign document and:

• who may be put at risk if an observation is added to their British passport

• whose reason they cannot change the name on their foreign document does not meet one of our existing exceptions, for example, due to transliteration regulations or the customer does not hold a current ID document as evidence to be able to update their foreign document

• who tell us they had (or will have) difficulty changing their name on their foreign document, for example, because the process to change it:

  • means they need to travel to the country where the document is from

  • means the customer may incur unreasonable costs if they were required to travel to update the document

  • would take a long time, for example, it may require the customer to travel and stay in the issuing country for an extended period

  • means they would need to get consent from someone else, but the customer cannot get it, for example, because it would put them at harm

  • is very difficult

8.2 How we will use the administrative fairness test

The administrative fairness test helps us decide if there is a reasonable way for a customer to change their name on a foreign document to match the name on their passport application. It also helps us decide what to do if the customer would be put at risk if we added an observation to their British passport. When using the administrative fairness test, we consider:

• the information and statement:

  • the customer gives us, showing why they cannot change their name and how they will be impacted if they were to change it)

  • in Knowledge Base

• the risk of customers using multiple identities

• if it is proportionate for a customer to align their foreign document (based on their individual circumstances)

If we decide that asking a customer to change the name on their foreign document is:

• unreasonable, we will:

  • issue them with a passport with full validity

  • add an observation that provides a link to the name in their foreign passport or document (unless the foreign document is in a different gender, or the customer provides a statement explaining they would be at risk of harm if an observation is added); and,

  • tell them we recommend they align their name before they renew their new British passport

• reasonable, we will tell them we cannot issue a passport until they:

  • change the name on their foreign document to match their British passport application; or,

  • give us evidence they have made an application to change the name on their foreign document

If the customer is unable to align the name on their foreign document or identity document, you must consider our exceptions and applying the administrative fairness test in these applications.

8.3 Making a decision using the administrative fairness test

Examiners must check Knowledge Base to see how a customer can update their foreign document and decide if the way that is done would have an unreasonable impact on them. For example, when a customer can only do it by travelling to the country where the foreign document is from and:

• doing so would have a significant impact on them; or,

• they have a medical condition that means they cannot travel

If it is not straightforward or you have doubts, you must discuss the case with your operational team leader (OTL). If there are still doubts, the OTL must discuss the case with the Quality and Examination Support team (QuESt).

The OTL (and QuESt) may decide an observation in the British passport, referring to the foreign document would be appropriate.

Customer tells you they will be put at risk

In a small number of cases, customers may be at risk if their British passport has an observation showing they hold a foreign passport. For example, someone travelling to Russia may be at risk if we add an observation acknowledging they hold a Ukraine passport.

You, the examiner, must always consider if issuing an RV (restricted validity) passport, without an observation, is appropriate (for example, in time limited situations where the risk only exists for one specific trip) and where the difference in the name meets one of the exceptions in this guidance.

When a customer tells you that an observation showing they have a specific foreign document will put them at risk, you, the examiner, must consider:

• the reason for travel, for example, travelling from Russia to Ukraine, travelling from Israel to an Arabic country or any other conflicts (see When observations may cause the customer problems)

• any personal risk to the customer, for example, religious beliefs, political beliefs or refugee and asylum status

• if an RV (restricted validity) passport could be issued for a limited time or a single journey

You must ask the customer for a written statement if the observation would put them at risk (the statement must be scanned onto the system).

If you decide the customer’s evidence is acceptable, you must:

1. Check the evidence is scanned onto the system as a permanent record (see Document scans).

2. Add a case note to show all the actions and decisions you have made (see Names: name related case notes for what you must include in the case note).

3. Issue a full validity passport, in the name on the British passport application, without adding an observation.

Customer tells you the process to change names is difficult

If a customer tells you the process to change the name on their foreign document is difficult, you must check Knowledge Base, to see if it confirms this. For example if it shows the customer must travel to and stay in the issuing country. If Knowledge Base:

• does not show the process of how they can change their name, or the process does not appear difficult, you must send letter 344, to ask the customer for:

  • evidence to show how difficult the process is to change their name in the issuing country

  • a statement showing how they will be impacted if they followed the name alignment process with the issuing country

• shows the process to change the name and it appears difficult, you must send letter 344, to ask the customer for a statement that shows:

  • the process they would need to follow to change their name (we do not need official evidence)

  • a statement showing how they will be impacted if they followed the name alignment process with the issuing country

Evidence to show difficulty changing a name

We may need evidence from the customer that confirms the process to change their name in their foreign document is difficult. Examples of evidence showing the process is difficult includes written instructions from a consulate, embassy or foreign authority or information from an official government website that shows the:

• process to change a name is long or complex

• customer must travel to (or stay in) the issuing country

• customer cannot ask someone else to change their name (on their behalf)

You must not contact or respond to any email from an embassy or foreign authority. Only the International liaison team are authorised to deal with foreign authorities. You must send the email to the International liaison team who will respond on your behalf.

Statement to show how the customer will be impacted

Customers must provide us with a signed statement telling us how they will be impacted (by carrying out the name alignment process). For example, they may be adversely impacted if:

• they have caring responsibilities

• they have a medical condition or disability that would make travelling difficult

• it will be unreasonably expensive for them (this is expenses outside of their foreign document application, for example, if they need to travel to the country where the passport is from)

• they are working or enrolled in education and cannot take time off

• their safety would be at risk

• they have claimed asylum from the country where the foreign document is from

We do not need evidence of the impact on the customer as:

• we do not expect customers to send us evidence of their circumstances (for example, financial situation or caring responsibilities)

• we will consider what the customer tells us in their statement

• the impact on one customer may be different to the impact on another customer

When you get the evidence and statement

When a customer provides you with evidence of the process to change their name and a signed statement confirming how it will impact them, you must consider:

• all potential risks to the customer if you add an observation showing details of a specific foreign document

• the process the customer would have to follow to change their name (using the evidence they gave and Knowledge Base) and how reasonable it is, for example:

  • how long it takes

  • do they need to travel to (or stay) in the issuing country

• if the reason the customer cannot change their name already meets one of our other exceptions

• if there are other reasonable ways for the customer to change their name, for example:

  • do they have a friend or relative they can stay with, while they change their name

  • do they regularly travel to the country where the foreign document is from (as they may be able to change their name when they next travel)

  • can someone else change the name on their behalf (for example, a friend, relative or solicitor)

  • can they change their name on a foreign document by contacting their local embassy, consular office of High Commission

• if a customer has previously been granted asylum or refugee status

You must also consider if exceptional circumstances apply that may prevent the customer from being able to travel or stay in the country where the passport is from, for example:

• they would need to travel or stay away from home and this would be considered unreasonable, for example if:

  • the trip would incur unreasonably expensive costs, if they must travel to (or stay) in the issuing country

• they have employment, family or education commitments

• they have a medical condition or disability

• there are safety risks if they travel to the issuing country (in cases where FCDO (Foreign, Commonwealth & Development Office) advice shows there is no risk of travelling)

If exceptional circumstances apply and the customer is unable to travel or stay in the issuing country, you must ask them to provide a signed statement which explains this.

You must ask the customer for more evidence if you do not have enough information to decide.

If it is clear from the evidence the customer gave you the only way they can change their name is:

• reasonable, you must refer to You decide a customer can change their name

• unreasonable, you must refer to You decide a customer cannot reasonably change their name

If it is not clear from the evidence whether it is reasonable to change their name on their foreign document, you must discuss the case with your OTL (operational team leader), taking into account the customer’s circumstances, evidence and statement.

Where doubts continue or a customer gives different information to that shown on Knowledge Base, you must raise a guidance query. The Guidance team will update Knowledge Base with the new information when they confirm the information is correct.

8.4 Administrative fairness test: when you have made a decision

You must decide, based on all the information available to you, whether the customer can or cannot be reasonably expected to change the name on their foreign document.

You decide a customer can change their name

If you decide the only way for a customer to change their name is reasonable, you must:

1. Send letter 345 to the customer, to tell them:

• you have considered their circumstances and evidence and that you cannot issue them a passport (until they align their foreign document)

• to send you any other evidence that shows they cannot change their name

• to send the foreign document back to you when they have changed their name (or a colour photocopy for any application where you have seen the original document already and it is recorded as a scanned document on the application)

2. Check if the customer has sent in the original foreign document, or a copy of the foreign document.

3. If the customer has sent in a copy of the foreign document, you must tell the customer to get the name on their original foreign document updated and continue to deal with the application

If the customer has sent in the original foreign document, you must:

1. Update ARD (Application Receive Domain) to return the original document to the customer by secure delivery

2. Add a case note to show all the actions and decision you have made (see Names: name related case notes for what you must include).

3. Wait for the customer to respond.

4. Check the:

• customer’s name on the foreign document matches the name in the passport application when they send the new foreign document

• new evidence provided if the Customer tells you the process to change names is difficult

You must withdraw the application (in line with the Withdrawing passport applications guidance) if the customer does not respond or refuses to change their name.

You decide a customer cannot reasonably change their name

If you decide the only way a customer can change their name is unreasonable, you must:

1. Send letter 346 to the customer, to tell them you:

• have considered their circumstances and that you will issue them a passport with fully valid passport

• the passport will have an observation to show they have a foreign passport in another name

• can only issue a passport without an observation when their name aligns

• recommend they align their name before their new British passport expires

2. Add a case note to show all the actions and decisions you have made with reasons (see Names: name related case notes for what you must include in the case note).

3. Check the document is scanned onto the system as a permanent record (see scanning supporting documents).

4. Issue a passport with full validity with an observation to show the customer’s name in their foreign document (unless the customer provides a statement explaining they would be at risk of harm if an observation is added). You must amend observation code OBTZ according to the name alignment observation table.

If the foreign document is in a different gender, you must:

• issue the passport without an observation

• amend letter 346 to remove the references to observations

If a customer tells you that adding an observation showing they have a foreign passport or document in another name will cause them problems, you must refer to Customer tells you they will be put at risk.

9. Adding observations for name differences

This section tells His Majesty’s Passport Office staff when we will exceptionally issue a British passport with an observation to account for a difference in the name on a customer’s foreign passport, travel document or identity document. It also tells examiners what to consider when an observation may cause a customer problems.

We add observations to British passports to provide a direct link to the customer’s foreign passport and other name when a customer cannot align their foreign passport. This includes if a customer is unable to change the name on their foreign document until we have issued a British passport in their new name.

We have the right to add observations to help confirm the customer’s identity. It is up to the customer to tell us during the application process if an observation about their foreign passport will cause them problems.

Although we may issue a passport with an observation, we expect the customer to align the name on the foreign documents before their next British passport application.

You, the examiner, must:

• always check Knowledge Base before adding an observation to a customer’s passport

• not add an observation if the foreign document is in a different gender to the new British passport application

9.1 When observations may cause the customer problems

We may add observations to passports when a customer has a foreign document in another name. The observation shows the country where the identity document is from and what name the customer is using in the document.

Customers may tell us an observation will cause them problems, for example, when it:

• names a country that has political differences with another country, that a customer travels to

• shows they have a foreign passport in another name, and it will put them at risk when they return to their home country

When they do, you must:

• refer to The administrative fairness test before deciding whether to issue a British passport with an observation to reflect their foreign document (observation OBTZ), or without an observation (in line with Customer tells you they will be put at risk)

• refer to the additional passports guidance, to consider issuing the customer with an additional passport with restricted validity to cover the period of travel, that does not show the:

  • name of the country where the identity document is from (if the observation names a country that will cause the customer problems)

  • name that the foreign document is in (if the observation contains a name that will cause the customer problems)

  • observation (if the foreign document is in a different gender)

9.2 Names observations for disputed territories

A disputed territory is a territory claimed by more than one sovereign state. Disputed territories include:

• Crimea

• Taiwan

• Kurdistan region

• Northern Cyprus

The Occupied Palestinian Territories are now recognised as Palestine (Gaza) and Palestine (West Bank).

We must make sure the customer will not experience any issues when travelling because of the observation. If you need to add an observation that refers to a passport issued by a disputed territory you must raise a guidance query with QuESt (Quality and Examination Support team).

QuESt will contact Passport Policy to ask:

• how we must record the name of the disputed territory when we refer to it in the passport observation

• if the customer will experience any issues when travelling if we add the observation

You, the QuESt team member, must tell the examiner to add the observation in line with the FCDO’s advice.

9.3 Adding name related observations to other British passports

If we add an observation to a passport to show the customer has a foreign passport, travel document or identity document in a different name, we must add it to any other type of British passports they have (including additional passports).

Customers must submit applications and pay to have all British passports they hold renewed so we can add the correct observations to each passport. They must do this before we complete the current application and issue the passport.

You must raise a guidance query if the customer:

• does not submit and pay for an application for each of their British passports, or does not want to pay to renew their other British passport (for example, because it is not due to expire for some time)

• tells you they cannot submit their other passport (for example, as they are using it for travel)

QuESt will decide what to do about the other British passports, based on the guidance query response, and may contact the Passport Policy team for advice.

9.4 Observation table for name alignment

Observation code	Observation	When to use it
OBTZ	THE HOLDER HAS A [name of country] [passport, travel document or identity document], NUMBER [passport, travel document or identity document number], ISSUED ON [date], IN THE NAME OF [name on that passport, travel document or identity document]. THIS [passport, travel document or identity document] IS DUE TO EXPIRE / EXPIRED] ON [date]	If the holder’s forenames and surname are clearly recognisable and you need to account for their foreign document which cannot be aligned
OTBZ	THE HOLDER HAS A [name of country] [passport, travel document or identity document], NUMBER [passport, travel document or identity document number] IN THE FORENAMES OF [forename] AND THE SURNAME OF [surname], ISSUED ON [date]. THIS [passport, travel document or identity document] [IS DUE TO EXPIRE / EXPIRED] ON [date]	If you need to clearly show the customer’s forename(s) and surname(s) separately when accounting for a foreign document which cannot be aligned
OBTU	VALID FOR (INSERT FREE TEXT) MONTHS, MAY NOT BE REPLACED WITHOUT REFERENCE TO THE PASSPORT OFFICE	If you are issuing a restricted validity passport
OBTO	THE HOLDER IS ALSO KNOWN AS	May be used if the customer does not want to renew their expired foreign passport, or replace their missing foreign passport, and other restrictions prevent them from changing their name

10. Declaring foreign passports

This section tells His Majesty’s Passport Office operational staff how the customer declares a foreign passport, and how to deal with a customer who does not declare another passport.

When the customer applies for a British passport, they must tell us whether they hold any other passport. This includes any other British passports or foreign passports they hold.

If a customer tells us (on their passport application) they have another passport but does not give details, you must:

• ask them to send us the other passport (or colour photocopy of a foreign passport on renewal applications) so you can consider it as part of their application

• check the name on the other passport matches the name on their passport application (in line with this guidance)

10.1 Customer declares they do not have another passport

If the customer completes their passport application and states they do not have another passport, or submits a paper application without completing section 3, you must:

• take no action if it is a renewal or replacement application for a British passport, unless:

  • the customer has previously declared a foreign passport

  • case notes on a previous application refer to the customer’s foreign passport being submitted

• ask the customer to provide the document they used to travel, so you can consider it as part of their passport application (or a colour photocopy for renewal applications) if they:

  • currently live in a different country to the one they were born in and it is a first time passport application

  • originally stated they did not have a passport when making their application, but later declare they do when you examine their application

When you receive the customer’s document, you must check the name on it matches the name on their passport application and deal with any differences in line with this guidance.

10.2 Customer did not previously declare a foreign passport

During examination, you may find a customer did not declare a foreign passport when they made a previous application for a British passport. You might find this when they send:

• an application to renew or replace their British passport

• their British and foreign passport as part of a linked application. For example, when a parent sends them as part of their child’s connected passport application

You must check the customer’s application record and documents shown on ARD (Application Receive Domain) to see if they declared their foreign passport when they made an application for their own British passport.

If they did and the name matches the name on their British passport, you must:

• not take any action

• deal with their renewal or replacement application (or the connected application), in line with current guidance

Dealing with a passport when the customer did not previously declare a foreign passport

If you are dealing with a live passport application and you find a customer has not declared a foreign passport at the time applied for their current British passport, you must:

1. Send the customer letter 347 (using the Comms Builder) to ask them to send you:

• the foreign passport, if you do not already have it, (or a colour photocopy if a renewal application)

• a written statement to explain why they did not tell us about their foreign passport when they applied for a British passport

2. Add a passport note to the passport record if it is not a live application (for example, when the passport concerned is sent in support of someone else’s application), to show why the customer did not declare their foreign passport.

3. Check if the name on the foreign passport matches the name on their British passport.

If the names on the foreign and British passports match and there are no other concerns with the application, take no further action and deal with any other linked application (in line with current guidance).

You must raise a guidance query if the names on the foreign and British passport do not match, and you are considering cancelling the customer’s British passport, You must include in your query:

• all supporting evidence

• the reasons why you think we must cancel the British passport

• if the reason the names do not match is because it meets one of our exceptions

If QuESt tell you not to cancel the customer’s passport, you must follow their advice, and deal with the renewal, replacement or connected application (in line with current guidance).

If QuESt tells you to cancel the passport, you must:

1. Contact the customer by phone and tell them:

• you need to cancel their British passport because they gave us incomplete information when they applied

• to submit a new passport application, so you can conduct a full check on their identity and entitlement to a British passport

2. Use letter 349 to tell the customer:

• you will cancel their British passport because they did not disclose their foreign passport

• to return the passport to us (if they have not already sent it in)

• they can apply and pay for a new British passport by submitting a passport application

3. Send the British passport to the Lost, Stolen and Recovered passport team in Peterborough, so they can treat it as a recovered passport (if the customer sends it to you (see LSR examination: replacing lost, stolen and recovered passports guidance).

4. Add a case note to show all the actions and decisions you have made (see Names: name related case notes for what you must include in the case note).

If you have any concerns with the customer’s identity, you must complete additional checks and Refer for investigation if required.