Research and analysis

Public body review of the Office of the Immigration Services Commissioner

Published 8 October 2025

Foreword

I am pleased to submit this report on the Public Bodies Review of the of the Office of the Immigration Services Commissioner (OISC) to the Home Secretary. This review was undertaken as a part of the Cabinet Office Public Bodies Review Programme, which considers how our public bodies are delivering their vital services to the UK efficiently and effectively.  

Public Body Reviews are one of the principal levers by which Ministers, departments, and ultimately the public, can influence and be informed about public bodies and their sponsorship. Proportionality sits at the heart of the Public Bodies Review Programme, meaning that the size, complexity, and function of a body will be considered when determining the scope of a review.

The OISC is a relatively small organisation with an important remit. They are responsible for registering and regulating individuals and organisations who provide immigration advice. They also have powers to take enforcement action against those operating outside of the legal framework. In this way, their work supports both the government’s priorities with regards to legal migration and in preventing illegal migration by taking action against those who breach legal requirements when providing advice. I value the insight gained through this review into the important work the OISC does to regulate immigration advisers, ensuring they are fit and competent and act in the best interest of their clients.

During the review, I spoke to teams across the OISC and the Home Office about their experience working together in driving forward the government’s aims efficiently and effectively. I found an agile organisation with strong leadership in the Commissioner. The organisation understands its remit and consistently seeks to improve how it operates, to best serve its customers while maintaining alignment with its remit and with governmental priorities. Its small size relative to other Home Office public bodies does mean that it is limited in its resilience and in the areas it could feasibly make the 5% cuts which underpin the review programme. However, it is clearly an organisation focused on its effectiveness and consistent internal reflection on how it could improve.

I wish to thank the Commissioner and his Office for the full and open cooperation with this review.

Kay Chauhan, Independent Lead Reviewer

Executive Summary

A Public Body Review focuses on the ability of an arm’s length body to deliver efficiency savings. This report should not therefore be read as a comprehensive assessment of all elements of the OISC’s performance.

The OISC is a small organisation with a big remit. In 2022/23, the OISC employed an average of 54.97 FTE (full time equivalent) staff, with a further 0.52 FTE agency staff. There have been significant changes to the immigration system and the advice sector since the OISC was established in 2000. Government is prioritising initiatives to manage immigration and the issue has high public salience. These issues are not within the scope of this review but are important context when considering the headroom available for efficiency savings.

The Home Office recently launched a public consultation on changes to the OISC’s fee structure charged to their advisers, in part in recognition of the ongoing changes to the sector and the OISC’s role within it. The outcome of this consultation is likely to have a significant impact on the OISC’s income and how any efficiency savings may be realised in the future.

The OISC has not been passive in the face of these changes. The current Commissioner and his team have initiated a wide-ranging transformation programme to modernise and improve the operation of the OISC. This programme is driven by analysis to determine where the OISC can most effectively target its activities in support of government objectives, aiming to disrupt illegal immigration advice activity and drive better quality and availability of regulated advisers. The review has been impressed with this analysis and the ways in which the OISC has sought to engage the Home Office in strategic conversations about its role.

The review recommends that the Home Office sponsorship function, which is split across a corporate sponsorship unit and sponsorship by the relevant policy area^{[footnote 1]}, builds on the support and challenge it provides to the OISC in this strategic engagement. There is a new senior sponsor for the OISC who is Head of the Human Rights and Family Unit and also a new Head of Unit for corporate sponsorship. This presents an opportunity for the Home Office to revise its outdated Framework Agreement with the OISC, and to ensure Ministerial priorities for the OISC as part of the UK government’s overarching response to immigration are clearly articulated.

The review recommends that the OISC and the Home Office ensure that appropriate governance, in particular as relating to the Deputy Commissioner role, is in place for the next period of the OISC’s operation. This could include learning from the ways in which other Corporations Sole across government have reinforced their governance and accountability. The current Commissioner and senior team are very effective individuals who have led much of the strategic policy conversation in their field. The Home Office must ensure that, despite this, it has a robust and effective framework in place to ensure the OISC is accountable, as individuals in post change over time and present different challenges. The establishment of a new Advisory Board is a positive step, and we encourage the OISC and the Home Office to take time to consider with an open mind what other options for constructive challenge might be helpful here.

There is work for the OISC to do as it continues its transformation journey. It is a small organisation which has taken a proportionate approach to the governance systems and controls it uses. However, it is now undertaking a dramatic series of changes to its operations to ensure it is fit for future challenges, and it is important that its systems and controls keep pace. The review recommends increased Home Office oversight to ensure effective benefits realisation processes are in place. Such oversight may have made it easier to document concrete and cashable savings from the transformation work already carried out by the OISC, particularly those that may have been available because of its new Estates strategy.

The OISC has recently moved its operations from central London offices to a fully remote model, with a new cloud-based IT system. As part of this, the OISC has established regional teams to better distribute its staff across the UK, and to support its attempts to encourage greater supply of regulated advice in the regions where there is greater demand. Such changes inevitably bring teething problems, particularly in small organisations, and the OISC has been open about the challenges of ensuring continued access to important legacy data and institutional knowledge within the new technology. The review recommends the OISC continues to improve the effectiveness of these new systems and begins to roll out their full capability to take full advantage of the opportunities for efficiencies.

The review was pleased to note the emphasis on efficiency running through the OISCs transformation plans and the series of LEAN reviews that are in progress. These have already identified opportunities to reduce manual casework handling and improve the adviser application customer experience. The Home Office has agreed CDEL (Capital Departmental Expenditure Limit) Funding to support these improvements to the OISC’s web presence and IT systems. The review recommends that the OISC continues to focus CDEL spend on projects with clear efficiency benefits, or on those which will enhance its financial governance capability.

The Home Office monitors actual and forecast spend on CDEL during existing regular finance meetings. The review recommends that this monitoring be extended to include the progress of project delivery against plans. This could be done by including a standing agenda item to analyse CDEL spend against delivery progress. Doing this will help to ensure collaborative working between HOSU and OISC delivers return on investment.

The Home Office should also do more to provide additional support, challenge, and direction to the OISC, particularly in areas where its relatively small size limits its resilience, such as in its finance function. This will help the OISC to manage any increased financial management responsibilities that result from the review of its fee structure, and without impacting its ability to deliver its mission. With such a small number of staff, any changes must be carefully planned and implemented. The review supports the decision to explore changes to the OISC’s fee structure to ensure this very capable and effective organisation is fit for the challenges it faces in the future.

Public Body Review Programme

Public bodies play a vital role in providing services on behalf of His Majesty’s Government. Their responsibilities and functions must be clear and necessary, and public bodies must be accountable and transparent in the interests of effective democratic debate. Reviews are one of the principal levers by which ministers, departments, and ultimately the public, can be informed about public bodies and their sponsorship.

The Cabinet Office Public Bodies Review Programme, launched in April 2022, is designed to promote the government’s vision of public bodies that are accountable, effective, efficient, and aligned to the government’s priorities.

Reviews are carefully scoped^{[footnote 2]} to avoid unnecessary expense, while providing assurance for the public and government that public bodies are effective and efficient.

Within the Home Office, reviews are managed by a public body review team that is independent of the department’s policy and public body sponsorship functions. Reviews are overseen by an independent lead reviewer appointed by the department.

Review Scope and Methodology

The review was conducted on behalf of the Secretary of State for the Home Department by Kay Chauhan, a senior official with the Cabinet Office, who is independent of the body and the sponsorship function. The review was supported by a small secretariat provided by the Home Office.

Prior to the start of the full review, a Self-Assessment Model (SAM) was undertaken as an initial step to help the body consider how it meets the four areas of consideration – efficacy, efficiency, governance and accountability. The SAM consists of a set of questions for departments and public bodies, also referred to as Arm’s Length Bodies (ALBs), to use as a ‘health-check,’ and to review the relationship of the ALB with the sponsoring department. This was completed by the OISC in consultation with Home Office Sponsorship Unit (HOSU). The results of the SAM, along with the Cabinet Office guidance for public body reviews, were drawn on to inform a Terms of Reference for the review (Annex A). This Terms of Reference was developed by HOSU, in consultation with the OISC, and agreed by Home Office Ministers.

While the core aspect of the Cabinet Office Review Programme is that each body should seek to make savings against their Resource Departmental Expenditure Limit (RDEL) of at least 5%^{[footnote 3]} against its 2022/3 spending review allocation^{[footnote 4]}, it is acknowledged that the relatively small size of the OISC budget – less than 0.001% of the Home Office departmental budget - leaves limited scope for cost savings.

The methods relied on for this review were a combination of desk research, interviews and observations.

Presentations from the OISC, reports and documents were examined to understand the OISC business and services. The review team also spoke with operational staff in the OISC to understand the complexity of work and the processes that support OISC services.

Interviews were conducted with key stakeholders and staff in the OISC and the Home Office. Within the OISC, those interviewed included the Commissioner, the Chair of the Audit and Risk Assurance Committee, senior staff across the business, and operational staff in both national and regional teams. Within the Home Office, interviews were conducted with those involved in sponsoring the organisation as well as with those working in the department’s policy, finance and commercial professions.

The review team also considered the founding legislation to assess the legal remit of the OISC and ensure that it was still operating within those powers, and the findings of the previous review of the OISC, which was published in 2017.

Oversight and guidance were provided by subject matter experts drawn from senior leadership within the Home Office. They provided support and challenge in the development of the review and recommendations. This advice was provided independently of the review secretariat, the OISC and HOSU.

Summary of Recommendations

1. Fees

Recommendation 1: The Home Office has launched a public consultation^{[footnote 5]} on the structure of the fees charged by the OISC to its registered organisations. Following the conclusion of this exercise, and subject to Ministerial approval, the Home Office must implement the preferred changes to the OISC’s fee charging regime as quickly as parliamentary time and priorities allow.

The new fee structure should move the OISC towards recovery of the full cost of regulatory activity. Ministers’ ambitions for the future operational scope of the OISC must be considered by the Home Office when deciding the extent to which additional fee income should be used to enable any reductions in grant in aid for the OISC in future years. All such decisions should be clearly recorded.

2. Estates, Levelling up and Places for Growth

Recommendation 2: The move from a central London office-based operation to fully remote and regional was a novel response to the challenges arising from the Covid-19 pandemic. The OISC has taken steps to ensure that the move supports the Levelling Up policy agenda. The changes have improved the distribution of staff across the country and created cost savings, but the full operational impacts cannot be fully assessed at this early stage.

The OISC must regularly review and assess the effectiveness of its regional model in the allocation of its resources, to ensure they are balanced to where they are most needed. This must include consideration of the location and structures chosen by its evolving regulated community of advisers, and the location of advice seekers.

3. Transformation Programme: Benefits Realisation

Recommendation 3: The Home Office must provide oversight to ensure that effective benefits realisation processes are in place for the Aspire programme, ensuring gross cashable benefits are identified and monitored.

Upon realisation of these benefits, the Home Office and the OISC must decide how to release these cashable benefits in line with the 5% efficiency aim of the Public Body Review (PBR) Programme. The PBR programme expects^{[footnote 6]} that proceeds from any savings identified will be used to support the delivery of departmental priorities; either within the body under review (i.e. the OISC) or in the wider department.

4. CDEL (Capital Departmental Expenditure Limit) Funding

Recommendation 4: The OISC has made successful bids for significant CDEL allocations to develop its ICT systems, and to review aspects of its operations to support the transition to a fully remote organisation. While these projects have made the digital transition possible, they have not yet been fully optimised to support further efficiencies within the organisation. The OISC plans to use 24/25 CDEL to develop the finance, HR and digital payments areas of its systems.

The OISC should focus its 24/25 CDEL funding on those projects which have a clear efficiency benefit, or which will support the OISC in fulfilling statutory reporting requirements, such as those related to financial reporting.

The Home Office monitors actual and forecast spend on CDEL during existing regular finance meetings. Monitoring should extend to the progress of project delivery against plans and the delivery of expected benefits.

5. Website optimisation

Recommendation 5: As part of its ongoing capital programme, the OISC should improve its website to respond to the needs of advice seekers, advisers, and other stakeholders. It should explore ways to make it easier for each category of user to navigate to relevant information.

The OISC should prioritise enabling integrated payment options for applications to join or renew membership of the adviser register.

The OISC should focus on optimising the system within GOV.UK in the first instance, as this is in line with government policy and is likely to be the most cost-effective option.

6. Automation of case handling

Recommendation 6: The OISC has reviewed its operations to identify where casework handling could be made more efficient through minimising manual intervention. The OISC must prioritise reducing manual handling as part of its ongoing capital works for IT system improvements and ensure this is fully implemented within 12 months of the publication of this review.

7. Workforce

Recommendation 7: The OISC should ensure it has a useful and meaningful sense of the resource required for different types of activities undertaken by its staff, and the consequent value of that work. As a regulatory and enforcement organisation, much of its value is difficult to quantify, but as the OISC gains more control over its income it will need to be able to analyse and assess the best use of those funds internally, and account for those to the Home Office and ultimately to Parliament.

The OISC must establish a more accurate understanding of the resource spend for different activities, including through the LEAN reviews funded by the Home Office for 2024/25.

8. System of Governance

Recommendation 8: The need to address the Deputy Commissioner issue and the forthcoming end of tenure for the current ARAC present useful opportunities for the Home Office to review the system of governance for this increasingly significant public body, and ensure it is fit for the future challenges it faces. The Home Office should act as quickly as is practicable to:

• Regularise the situation regarding the vacant Deputy Commissioner position. Options include appointing a new Deputy, legislative change to make the requirement for a Deputy discretionary, or removing the requirement altogether.
• Consider a range of options to secure robust governance and accountability for OISC, including learning from comparable corporations sole sponsored by other government departments, and mechanisms such as a formal non-executive function.

9. Framework Document

Recommendation 9: The Home Office and the OISC should work together to review and publish an updated Framework Document as soon as practicable, and no later than April 2025.

10. Strategic vision for the OISC

Recommendation 10: The Home Office must set out a clear strategic direction for the OISC based on Ministerial and Home Office priorities for the organisation and wider sector. This should be detailed in the annual letter to the Commissioner from the relevant Home Office Minister or Principal Accounting Officer (PAO) which should be sent in the Autumn of each year to ahead of the OISC’s business planning cycle.

The priorities agreed in this letter should then be reflected in clear and measurable KPIs used by the Home Office to assess the OISC’s performance as part of its regular assurance monitoring. The OISC should also regularly publish on its website data and reporting on KPIs it collects, unless there is a compelling reason not to do so.

11. Finance

Recommendation 11: The OISC must improve its finance systems and controls to ensure it has the capacity and capability to demonstrate best practice in financial governance. This is particularly important to prepare the OISC to assume additional and more complex financial management responsibilities if changes to its fee structure are agreed. Steps have already been taken by the OISC to improve processes, and the Commissioner should continue to report on improvements to the ARAC, Home Office, and external auditors (where relevant).

• a) The OISC is encouraged to take advantage of Home Office finance expertise to ensure it fully understands and proportionately implements expectations of required standards and practices, in line with the Government’s functional standard for finance.^{[footnote 7]}
• b) Improvements to the IRIS system should be prioritised under the current capital project, to best utilise the capabilities of the system to support effective and accurate financial reporting.
• c) The OISC should aim to submit its annual report and accounts to be laid in Parliament as quickly as possible after year end, and ideally prior to Parliamentary summer recess.

Overview of the OISC

The OISC was established under the Immigration and Asylum Act 1999 (IAA-99), as a Corporation Sole, appointed by the Home Secretary, to enable the Commissioner to discharge statutory functions under the Act.

The OISC’s statutory remit is to provide an effective system of regulation for immigration advisers and immigration services within the UK in a manner which promotes good practice by those who provide such services and/or advice. It is also charged with investigating illegal activity and enforcing the legislative framework.

The OISC is classified as Non-Departmental Public Body and operates at arm’s length from the Home Office. Its relationship with the sponsoring department is set out in a Framework Document. The OISC is operationally independent, with the ability to set its own KPIs, employ staff, determine applications for registration and make decisions concerning how and when to use the Commissioner’s power to investigate complaints and to prosecute those acting illegally^{[footnote 8]}.

The OISC plays an important role in regulating the provision of immigration advice and services throughout the UK. It assesses competence and fitness of immigration advisers and identifies and takes enforcement action against those organisations and advisers acting improperly. In addition, it holds a register of immigration advisers.

The OISC currently regulates over 3,000 individual immigration advisers and 1,600 organisations.

Governance

The OISC is led by the Immigration Services Commissioner, who is a Corporation Sole. The Corporation Sole structure means that all legal powers are vested in the Commissioner personally and he is responsible for all decision-making and governance. The enabling legislation also includes provision for a Deputy Commissioner, and both are Ministerial appointments. At present, the role of Deputy Commissioner is vacant, and has been since 2021.

The Commissioner was appointed by the Home Secretary for a period of five years, commencing on 8 July 2019. The reappointment of the Commissioner is currently being considered and it is expected that a decision will be made prior to the publication of this review.

The Home Office is the sponsoring department for the OISC, and the Senior Sponsor of the OISC is currently the Head of the Human Rights and Family Unit. In addition to the Senior Sponsor, sponsorship of the OISC is undertaken in part by the Home Office Sponsorship Unit (HOSU). This model of sponsorship with a Senior Sponsor based in the relevant policy area working closely with HOSU is the model for most Home Office sponsored bodies.

Within the OISC governance structure, the Commissioner is supported by an Audit and Risk Assurance Committee (ARAC) and an Advisory Board.

The ARAC is an advisory committee with four members, including the Chair, appointed by the Commissioner. The Committee provides independent advice and assurance on overall governance arrangements, financial and risk management, and internal audit arrangements. They provide an advisory function to the Commissioner and are not meant to replicate the function of a Board. The Home Office Senior Sponsor and representatives of the Home Office Sponsorship Unit (HOSU) typically attend the quarterly meetings of this committee as observers.

The Commissioner has also recently established an Advisory Board of four Non-Executive members which is also attended by the Home Office Senior Sponsor and HOSU as observers. The role of this Board is to have oversight of all OISC strategies and to provide advice to the Commissioner on where further investigation or action is needed. 

The present ARAC members are nearing the end of their second three-year terms, and the Commissioner has confirmed that he intends to conduct a recruitment campaign beginning in summer 2024 to recruit new members for the ARAC and Advisory Board. Currently, membership of both groups is similar, but the Commissioner intends to change this through the forthcoming recruitment exercise.

Home Office policy and sponsorship teams play key roles in the governance framework of the OISC. They hold the Commissioner to account through annual business planning and reporting, the Framework Document, and appointing and reviewing the performance of the Commissioner.

Registration of Immigration Advisers

The core remit of the OISC as defined in the enabling legislation is to register and regulate those individuals and organisations who provide immigration advice and services who are not members of other professional bodies noted in the Immigration and Asylum Act 1999. The OISC refers to this system as its “regulatory scheme”.

In addition, the OISC is empowered to act against individuals or organisations who act outside the legislative framework, where appropriate.

Immigration advisers must be qualified to provide advice and services in relation to the following:

• claims for asylum.
• applications for entry clearance or permission to enter/stay in the UK.
• Immigration employment documents.
• Unlawful entry to the UK.
• Nationality and citizenship.
• Removal or deportation
• Immigration bail applications
• Appeals or Judicial Review applications in relation to any decision made in any of the above list.

It is a criminal offence for a person to provide immigration advice or services in the UK unless their organisation is regulated by the OISC or is otherwise covered by the Immigration and Asylum Act 1999.

The 1999 Act specifies that immigration advice and services can only be provided by qualified persons. Qualified persons are those registered by the OISC, or those who are authorised to provide immigration advice and services by other regulators or professional bodies such as: the Solicitors Regulation Authority, the Law Society of Scotland, the Law Society of Northern Ireland, the Bar Standards Board (or Scottish and Northern Ireland equivalents), or the Chartered Institute of Legal Executives.

Fitness:

An individual or organisation will be considered fit to provide immigration advice or services if they can demonstrate to the Immigration Services Commissioner that there is:

• likelihood of compliance with the OISC’s regulatory scheme
• a history of honesty and legal compliance
• a history of financial probity

Competence:

An individual or organisation will be considered competent to provide immigration advice or services if they can sufficiently demonstrate to the Commissioner the necessary knowledge and skills required to meet the needs of clients seeking immigration advice or services at a specified advice level and category.

Advisers are authorised to provide immigration advice and services at one of three distinct levels:

• Level 1: Advice and Assistance.
• Level 2: Complex Casework, including asylum.
• Level 3: Appeals

Assessment

New Advisers and Organisations

Individuals and organisations wanting to provide immigration advice or services must typically apply for registration with the OISC unless they are members of the professional bodies listed above.­

Applications to the OISC are completed online and, at present, submitted via email. Instructions are provided on the OISC website^{[footnote 9]}. Once the applicant has submitted all the required information and documentation, the OISC will consider and assess the material submitted for compliance with their code of standards.

New advisers must also complete a competence statement and pass a standard DBS check. New advisers are then invited to sit a Level 1 competence assessment. Applicants may also sit an assessment at Levels 2 and 3 if they wish to progress to work at that level.

Online assessment events are held monthly for Level 1 and every three months for Levels 2 and 3. The delivery of assessment centres is contracted, and they have been held online since 2022. This means that participants no longer need to travel to London to attend an assessment. Despite this change, there has not been a substantial difference in pass rate, and there are systems in place to avoid cheating. During the 2022/23 FY, 16 such assessment centres were held.

Authorised advisers must be linked to an organisation which is “fit and competent”. The OISC must assess what “fit and competent” means in practise. Concerns about fitness could include, for example, a criminal record or assisting someone to break immigration laws. Each organisation on the register must have at least one individual adviser who has passed the relevant fitness checks.

The application process is detailed in the flowchart in Annex H.

Continued Registration

After an application is approved, an individual or organisation will normally be granted a registration period of 12 months. Each organisation intending to remain in the regulatory scheme is required to apply to the OISC on an annual basis.

Compliance and Enforcement

Enforcement action is taken to protect the integrity of the regulatory scheme and to protect those who suffer from such unlawful activity. The Commissioner seeks to maintain a consistent approach to those in breach of the Immigration and Asylum Act (IAA). The OISC’s Criminal Enforcement Policy^{[footnote 10]} sets out in detail the Immigration Services Commissioner’s duties to exercise his functions to prevent the provision of immigration advice/services by any person in contravention of section 84 of the IAA (as amended).

Regulation Through Complaints.

A key component of the work of the OISC is to stop unregulated advisers from providing immigration advice. This is achieved by offering advice seekers a forum for complaints about poor service.

Complaints procedure:

An advice seeker can complain about any adviser, solicitor or barrister based in the UK. The OISC deals directly with complaints about immigration advisers. The OISC passes complaints about immigration advice provided by designated professional bodies, such as solicitors, to their respective regulatory body, and monitors their complaints handling processes.

The complaints process is detailed on the OISC website, and they accept complaints by email or post. They publish complaints forms in a number of languages^{[footnote 11]}.

What happens next:

The OISC will acknowledge a complaint within 5 working days. The Commissioner has discretion to decide if a complaint should be investigated. The OISC will inform the complainant as soon as possible after receipt of their complaint and usually within 10 working days whether their complaint will be investigated. In most cases that are investigated, the complainant will receive a full written determination within 5 months of receipt.

Possible outcomes of a complaint:

The OISC may act against an adviser to prevent others receiving poor advice and services. This can include a range of steps from complaint remedies to legal enforcement action, and these may depend on the nature of the complaint and whether an individual or organisation is currently registered with the OISC or not.

The OISC may write a document to be shared with victims and those they are investigating setting out how they investigate potential illegal advice and outlining possible outcomes which might result. The OISC may choose to publish this document.

The Commissioner can accept a complaint about immigration advice or services from any source. Annex F shows how complaints received by the OISC are categorised and Annex G shows how those against an OISC registered organisation are handled.

The OISC also publish a complaints procedure for complaints made against the Commissioner or the organisation^{[footnote 12]}.

Other Activities and Objectives

The OISC also undertake other activities such as sector engagement and outreach. This work is largely targeted towards sharing advice and guidance for the benefit of advice seekers.

The OISC’s current engagement strategy aims to work with key stakeholders to better connect advice seekers to reliable, high-quality advice. Through this strategy, the OISC also expects to gain greater insights into advice seekers’ needs and increase data collection regarding illegal immigration advice.

To achieve this aim, engagement focuses on the four objectives identified in the OISC corporate plan:

• Key data and information is to be acquired from stakeholders through a three year programme of regional and national engagement.
• Regional Teams will each have detailed regional engagement plans.
• Memorandums of Understanding and partnership arrangements will be made  with stakeholders and updated in line with priorities.
• Stakeholder views and comments on major policy issues will be established through formal consultations. Immigration advisers and stakeholders will give regular feedback to the OISC through a programme of online, regional, and national seminars.

Engagement Metrics

There are several metrics key to measuring the success of engagement at the OISC. These are detailed in the OISC business plan and national engagement plan. Critical success factors include:

• recruitment of regional engagement officers
• clear, consistent messaging
• a system to record and report on engagement activity
• a process for capturing and reporting data

Quarterly reports will detail the outputs and outcomes of engagement activity. These are shared with senior leaders and operations teams to inform decision making. Annex C shows the OISC’s stakeholder mapping.

The OISC also undertakes campaigns to raise awareness of using regulated advisers, including a poster campaign in a range of languages. It maintains the register of advisers, which is a comprehensive list of all regulated advisers, and an Adviser Finder search tool, both of which are updated daily.

Finances

The OISC is funded by grant in aid (GIA) by the Home Office. The amount of GIA it receives is reviewed annually. Its Resource Departmental Expenditure Limit (RDEL) has been in a range between £3.8-£4.2 million per annum since 2009, in cash terms. In real terms, this amounts to an estimated 33% decrease in GIA since that time.

The OISC also received capital funding of £1.5m (22/23) and £2m (23/24).

For the 2024/25 fiscal year (FY), the Home Office expects that the budgeted RDEL allocation will increase from approximately £4.2m to £4.6m, but the CDEL budget will change from approximately £2m to £1m.

The OISC generates income from its work, including from registration fees and court settlements from cases it prosecutes. The OISC collected fees of c£1million in 2023/24, which was remitted as appropriate back to the Home Office.  

The fees were last amended in May 2022, increasing them in line with inflation. There has been no significant amendment to the structure of fee charging since the OISC was established in 2000, but there is a current consultation ongoing regarding options for moving towards cost recovery for regulatory activity.

There are regular meetings between Home Office finance and the OISC to monitor spend against forecasting and budgets. The OISC report on their finances annually in their Annual Report and Accounts.

Updates since the 2017 OISC Review

The previous review of the OISC was published in 2017^{[footnote 13]}. The report concluded that the OISC performed an important function for which there was an ongoing need. Of the 19 recommendations contained within the review, ten were directed towards the OISC and nine were for the Home Office.

Many of the recommendations of the review were either agreed and incorporated into the operations and sponsorship of the OISC or were superseded by subsequent events. Recommendations which were implemented include: reviewing the transition to digital applications, standing down the Commissioner’s Advisory Panel, undertaking work to assess customer satisfaction, and the Home Office Senior Sponsor attending ARAC meetings as an observer.

There were several recommendations made in that review which were not fully implemented. For example, there was a recommendation that the Home Office “should work with HM Treasury and the OISC as a matter of priority to minimise the cost to the public purse of financing the OISC by seeking to make efficiency savings with a view to continuing the current year on year reduction in the OISC’s grant from the Home Office and by maximising fee income with a view to getting as close as possible to full cost recovery by 2020”.

The Home Office and the OISC have continued to work towards finding efficiency savings. However, while fees were reviewed in 2022, this was an adjustment in line with inflation since the previous increase, ahead of a full review of the fee structure. A review has now taken place, and the Home Office are now consulting on proposals to amend the structure with the aim of moving the OISC closer towards cost recovery for the cost of regulation.

A full breakdown of the recommendations of the previous review can be found in Annex I.

Review Findings and Recommendations

Efficiency: Findings

The target outcome of the review is to “identify where savings to Resource Departmental Expenditure Limits (RDEL) of more than 5% in nominal terms as of 22/23 budgets can be made for an average review and go further where possible.” Given the relatively small size of the OISCs operational budget, it is acknowledged that the scope for efficiencies within the organisation is limited. For the OISC, 5% of 22/23 RDEL would be £192,850.

For the 2022/23 baseline FY, the OISC had a RDEL budget of £3,857,000 and a capital allocation (CDEL) of £1,500,000. Detail on the subsequent years can be found in the following table:

Year	RDEL Budget	CDEL	Total
22/23	3,857,000	1,500,000	5,357,000
23/24	4,266,169	1,980,000	6,246,169
24/25	4,619,647	997,393	5,617,040

The OISC does not appear to have not received any significant CDEL funding prior to the 22/23 FY. This funding is supporting an ongoing programme of transformational change across the organisation in response to the Places for Growth initiative and the Covid-19 pandemic.

The majority of the OISCs current financial spend (80-85%) is on salaries, indicating a limited scope for efficiency savings to be found from other aspects of the business.

Fee Review

The Immigration and Asylum Act 1999 (legislation.gov.uk) Paragraph 5 of Schedule 6, gives the power to specify fees for registration or continued registration. The structure and level of the fees is set in the Immigration Services Commissioner (Application Fee) Order 2011 (as amended).

All organisations who operate on a for-profit basis must pay a fee upon application for registration with the OISC and annually for continued registration. In 2014, amendments were made to the 2011 Fee Order. Since this time, the Commissioner has had the power to waive the fee for organisations that do not charge a fee themselves. There are different fees for the three advice levels, and the fees change depending on the number of individuals registered in a business. It has not been possible to ascertain the rationale behind the initial fee structure given the time which has passed since the OISC’s founding.

In line with Managing Public Money, the approach to setting charges for public services should seek to provide full cost recovery^{[footnote 14]}. The Home Office is currently consulting on an update to the OISC’s fee charging model aimed at moving the OISC towards recovering the costs of regulation.

There has been no significant amendment to the structure of fee charging since the OISC was established in 2000, despite significant changes to the immigration advice sector. For example, in March 2017, there were 701 advisers providing immigration advice and services within non-fee charging organisations regulated by the OISC. By February 2024, this figure had increased to 1,625 advisers within the non-fee charging space. Additionally, while there are fewer organisations providing immigration advice on a non-fee charging basis, these organisations have a larger number of individual advisers than the for-profit sector.

The 2017 review of the OISC recommended that the Home Office should work with the OISC and the Treasury to “maximising fee income with a view to getting as close as possible to full cost recovery by 2020”^{[footnote 15]}. Significant changes to the charging structure of the OISC are expected to require changes to primary legislation, meaning that the opportunities for a wholescale update to the fee charging structure have been limited since the previous review.

In 2022, the fees that the OISC charge to individuals and organisations were updated in line with inflation. This was the first time the fees had been changed to account for inflation since 2011. The current fee charging structure is as follows:

Application type	Cost 2011 to May 2022	Cost May 2022 to present
New Registration - individuals	£575	£733
Continued Registration - individuals	£575	£733
New Registration - organisations (1-4 Advisers)	£1,759	£2,232
New Registration - organisations (5-9 Advisers)	£1,960	£2,500
New Registration - organisations (10+ advisers)	£2,370	£3,023
Continued Registration - Organisations (1-4 Adviser)	£1,290	£1,646
Continued Registration - Organisations (5-9 Advisers)	£1,600	£2,041
Continued Registration - Organisations (10+ advisers)	£2,115	£2,698

This inflationary adjustment has not resulted in a significant change to income for the organisation thus far^{[footnote 16]}.

The fees charged by the OISC to regulated advisers and businesses at present do not cover the cost of the regulatory activity, which is estimated at £2.2m. For this to happen, fundamental changes are needed to the charging structure to reflect the operational model and costs of registration/continued registration.

In order to review the fee structure and look at the funding model and powers of the OISC, a joint Home Office/OISC project board was set up in Spring 2022. Following the inflationary increase to the fees charged to advisers, the project board has undertaken a review of the fee structure and developed proposals to amend it.

A public consultation on the proposed amendments to the fee structure was launched on 14 March 2024^{[footnote 17]}, and was open for responses until 5 June 2024.

The proposed amendments to the fee structure set out in the consultation include:

• introducing separate charging for organisations and individual advisers.
• introducing charges to non-fee charging organisations and individual advisers, with phased introduction of changes for the organisations.
• introducing additional fees/charges for other activities such as audit/competence assessments.
• if introduced, the third option would require changes to the primary legislation, whereas changes to the first two proposals can be introduced by changes to the Fee Order.

Increasing income generation will play an important role in the longer-term effective functioning of the OISC. Work has been done to model the effectiveness of the consultation proposals in moving the organisation towards cost recovery. One of the objectives of the consultation is to get a fuller picture of how the proposed changes will impact the sector and understand the make up and funding of the organisations registered with the OISC. This will be important in ensuring that the changes will not drive advisers to leave the sector or continue to offer advice without being registered. Implementation of the consultation proposals could also impact on the ability of the sector to cope with the current demand for immigration services. A significant decline in registered advisers and consequently in registration income, alongside ongoing limits to OISC’s grant in aid could result in the inability of the organisation to continue to function effectively. Nevertheless, change to the fee structure is needed to ensure the organisation can continue to carry out its work.

Efficiency: Recommendation

Recommendation 1:

The Home Office has launched a public consultation on the structure of the fees charged by the OISC to its registered organisations. Following the conclusion of this exercise, and subject to Ministerial approval, the Home Office must implement the preferred changes to the OISC’s fee charging regime as quickly as parliamentary time and priorities allow.

The new fee structure should move the OISC towards recovery of the full cost of regulatory activity. Ministers’ ambitions for the future operational scope of the OISC must be considered by the Home Office when deciding the extent to which additional fee income should be used to enable any reductions in grant in aid for the OISC in future years. All such decisions should be clearly recorded.

Estates and Levelling Up: Findings

The UK government aims to move 22,000 public sector jobs out of London by 2030 as part of its Levelling Up initiative. The 2022 Levelling Up White Paper^{[footnote 18]} established the principle that ALBs would be expected to relocate outside of London, with exceptions for essential operational requirements.

As a response to this initiative, the OISC considered options for moving out of its sole physical office location in Central London. A key concern was that this would result in staff leaving the organisation, and risk significant levels of institutional memory loss.

The Covid-19 pandemic pushed the OISC to adopt a temporary remote business model in 2020. In response to the Levelling Up initiative, a decision was taken that, with an initial investment in upgrading the Information and Communications Technology (ICT) infrastructure, the business would operate remotely as a permanent solution. The OISC subsequently took the decision, in consultation with the Home Office, to give up their London office and move to a fully remote model with reference to the Levelling Up and Places for Growth initiatives.

The OISC vacated its former offices in Bloomsbury Street, London in November 2022. This will result in annual savings of circa £600k on estates costs, offset in part by increased travel and subsistence to facilitate regular in-person meetings, and increased outgoings for a cloud-based IT system to enable remote working. Despite these increases, this move remains a significant cost saving over maintaining a physical office. The OISC has confirmed that savings from the move to a remote model have been reallocated to front line operations, but as these changes are recent, the impact on the business and the sector is not yet clear.

The move to remote and cloud-based operations gave the OISC flexibility to move from a central (London focused) to a regional model. There are now three operations teams conducting all regulation and enforcement activities on a regional basis. While individuals remain fully remote, they are recruited from and located in the regions they serve. In the view of the OISC, having people physically situated where they can relate and react to local issues is more beneficial than the previous London based centralised model.

In support of the move to home working, a capital project was undertaken to replace the extant IT database with a cloud based one. This incurred up-front costs, and there is ongoing work to continue to improve this database and make it more effective for the organisation. It is likely that, due to the age of the previous system, this work would have been necessary regardless of the decision to move to remote operations.

Estates: Recommendation

Recommendation 2:

The move from a central London office-based operation to fully remote and regional was a novel response to the challenges arising from the Covid-19 pandemic. The OISC has taken steps to ensure that the move supports the Levelling Up policy agenda. The changes have improved the distribution of staff across the country and created cost savings, but the full operational impacts cannot be fully assessed at this early stage.

The OISC must regularly review and assess the effectiveness of its regional model in the allocation of its resources, to ensure they are balanced to where they are most needed. This must include consideration of the location and structures chosen by its evolving regulated community of advisers, and the location of advice seekers.

Capital Projects/Aspire Programme: Findings

Initial IT Capital works

As a part of the move to full remote-working, the OISC moved its IT infrastructure from server based to cloud-based hosting. To do this, it developed and built a new system based on the Microsoft Azure platform, which its strategic partner manages.

Prior to this, three OISC staff ran and operated an aging database which was bespoke to the organisation. The system did not have external support and many functions needed to be completed manually by the developers.

That system was initially developed in 2010 through joint work between the OISC Senior Developer and external IT consultants. Since then, it has been maintained and further developed by the Senior Developer and an additional in-house Developer.

In 2021, the OISC secured capital funding to start to build a replacement to the existing system. Following a discovery phase led by the Home Office Digital, Data & Technology (DDaT) team, a ‘SalesForce’ software package was recommended as the best option to replace the existing database. The OISC scoped the new system, in collaboration with ‘BlueWave’ through a Request for Clarification on G-Cloud via Home Office Commercial.

The first phase of development resulted in a system which was essentially a like-for-like replacement of the existing system, but within a cloud-based environment. While this helped the organisation build resilience and limited the need for internal developers, the initial iteration of the system had many of the same limitations as the previous version.

Aspire Programme

The capital programme was subsequently expanded to take a wider view of how the work to improve the IT system could also be used to improve the efficiency of other functions across the business. This evolution of the capital programme is known as the Aspire Programme. Aspire is planned for delivery over a 2-year period beginning in 23/24 and finishing in 24/25. The expected high-level outcomes of the programme include:

1. LEAN reviews of all operational and corporate processes and the automation of external facing processes through the development of technology. This may include further developing IRIS, HR and finance systems to maximise productivity through automation. This may also include the integration and use of AI where appropriate.
2. Streamlining processes and better using tools and technology to work collaboratively remotely leading to quicker response and processing timeframes.
3. Improved processes which will free up staff to concentrate on the needs of the advice seeker rather than administrative overheads.
4. Increased staff morale and job satisfaction, improved individual and team performance through better engagement, inclusivity, individual support, and wellbeing.
5. Indirect benefits through improved customer experience, end user satisfaction and customer service.

The OISC intends to carry out LEAN Reviews across all its processes and, at the time of this review, aims to complete these by the end of FY 2024/25. Initial findings after reviewing two areas of the business (Oct 23) indicated considerable potential efficiency and productivity benefits of about £100k p.a. could be gained from modernisation of processes. This work shows how the organisation has taken proactive steps to assess its effectiveness and efficiency.

Capital was also allocated in 23/24 to develop and enhance the OISC’s ICT security.

Aspire – HR/Finance System

In 23/24 the decision was taken not to implement a new finance and HR system due to organisational capacity, the extended external financial audit, and because the new fees regime was expected, but had not yet been precisely determined. It is expected this work will be undertaken in 2024/25, given that these improvements will be important aspects of the implementation of the preferred new fee structure. In 2024/25 the OISC also hopes to further automate and streamline processes to realise benefits such as automated email tracking and responses, fee payment reconciliation, automation of proof of DBS, automated complaints triaging and responses.

Aspire – Rebrand

The OISC is considering its overall branding with the aim of better placing the advice seeker at the forefront of its activities. The organisation is looking at a rebrand including a potential name change to better describe its role for the user.

A total of £32,000 of capital was combined with an RDEL allocation of £101,000 to fund this rebrand. The allocated funds were also intended to develop materials to support the rebranding and enhance the website.

Aspire – Data Management

Progress was made in 23/24 to develop a data management capability within OISC that would enable the organisation to gather and analyse data in support of strategic decisions around how to allocate resources and support tactical decisions regarding illegal advice-giving activities.  

Approximately £40k of the capital delegation was used to identify potential systems suitable to meet OISC data handling and analysis needs for the future. This included procuring a reporting tool (Tableau) to analyse and present the information required to support business decisions, including the introduction of a balanced scorecard.

Some process improvements were achieved in 23/24 by utilising underspends from other areas. These included: the automation of workflows, webform decision making and engagement activities. The OISC has stated that significantly more funding will be required in 24/25 to fully automate and streamline processes and realise benefits. Some areas which could replace or improve on manual processes include automated email tracking and responses, fee payment reconciliation, automation of proof of DBS and automated complaints triaging and response.

Digital webforms mean the system can ingest data and automatically create cases, removing the need for manual data entry. Applying validation to the webforms has also helped improve the quality of the data being used.

A digital case management solution has improved the overall management of case work. Notification and alerts based on defined SLAs & KPIs supports progression of cases to agreed service levels. A robust, secure database solution supports data security and integrity; and performance to required standards.

Aspire – Website

The OISC website is hosted on GOV.UK^{[footnote 19]}. It contains guidance for prospective immigration advisers about how to become regulated, as well as hosting the database of advisers and corporate documents and reports.

The OISC considers that improvements could be made to the useability and functionality of the site to help advice seekers access information more easily. One way this might be achieved is through featuring clear pathways for different user categories (ie., Advisers, Advice Seekers), such as those found on the website of the Solicitors Regulation Authority (SRA)^{[footnote 20]}.

However, the OISC considers that making amendments to the website through GOV.UK processes presents them with significant challenges. There is also a view within the OISC that an independently badged website would support users by clearly signalling the distinction between the OISC and the Home Office. The OISC has therefore considered the potential for using capital funding from the Aspire programme to develop its website outside of the GOV.UK domain. Doing so would be outside of government policies encouraging the use of GOV.UK. In addition, procuring and developing an entirely new site may not be a cost-effective use of public money.

Prior attempts to secure an exemption from government policy for the OISC were declined due to insufficient user testing to justify an independent website and efforts have been focused on improving the existing website. Plans are in place to gather clear evidence to support an exemption application in the future. In the interim, the team aims to enhance the content on the homepage, reorganise the site map, and address administrative challenges with the Government Digital Service (GDS).

Capital Projects/Aspire Programme: Recommendations

Recommendation 3:

The Home Office must provide oversight to ensure that effective benefits realisation processes are in place for the Aspire programme, ensuring gross cashable benefits are identified and monitored.

Upon realisation of these benefits, the Home Office and the OISC must decide how to release these cashable benefits in line with the 5% efficiency aim of the Public Body Review (PBR) Programme. The PBR programme expects^{[footnote 21]} that proceeds from any savings identified will be used to support the delivery of departmental priorities; either within the body under review (i.e. the OISC) or in the wider department.

Recommendation 4:

The OISC has made successful bids for significant CDEL allocations to develop its ICT systems, and to review aspects of its operations to support the transition to a fully remote organisation. While these projects have made the digital transition possible, they have not yet been fully optimised to support further efficiencies within the organisation. The OISC plans to use 24/25 CDEL to develop the finance, HR and digital payments areas of its systems.

The OISC should focus its 24/25 CDEL funding on those projects which have a clear efficiency benefit, or which will support the OISC in fulfilling statutory reporting requirements, such as those related to financial reporting.

The Home Office monitors actual and forecast spend on CDEL during existing regular finance meetings. Monitoring should extend to the progress of project delivery against plans and the delivery of expected benefits.

Recommendation 5:

As part of its ongoing capital programme, the OISC should improve its website to respond to the needs of advice seekers, advisers, and other stakeholders. It should explore ways to make it easier for each category of user to navigate to relevant information.

The OISC should prioritise enabling integrated payment options for applications to join or renew membership of the adviser register.

The OISC should focus on optimising the system within GOV.UK in the first instance, as this is in line with government policy and is likely to be the most cost-effective option.

Application Process: Findings

The OISC has reviewed its operations to identify where casework handling could be made more efficient through minimising manual intervention. Increased automation would also help to minimise the impact of staff absence on the OISC’s productivity. These are sensible aspirations.

The IRIS system has moved the OISC’s legacy paper and server-based systems into the cloud. Immediate savings are negligible as reductions in IT staffing costs have been offset by the new costs of a cloud-based contract. The OISC does feel that the contract has delivered increased flexibility of management. The potential efficiencies of the new system will not be fully realised until it is used to enable different and more efficient approaches to the OISC’s work.

The OISC’s application processing team is not large, comprising two application receipt officers, one continued applications adviser, two administration officers and two executive officers. Both new applications and annual reapplications are processed by this team.

The OISC expects to process a level one application in 4 months. Around 700 to 800 individuals, working for around 1500 regulated bodies, submit individual applications each year. The OISC also receives around 250 new applications from businesses each year. These applications are more complex than those for individual advisers and require a business plan.

The OISC notes that each change to visa routes or other requirements by the Home Office results in an in increase in applications. Where a significant increase in applications occurs, the OISC has, on occasion, needed to amend its published processing time for applicants and flags this change on its website.

At present, applications are received online via a form which is downloaded, filled in and emailed by applicants. Once received, OISC staff manually copy information from the form into the IRIS database. This process has been somewhat streamlined in recent years and there is no longer a need to physically post a paper application.

The OISC intends to move to an integrated web form system as soon as possible, which will cut this processing time. The OISC also intends to take the opportunity to make the application process more efficient by ensuring the web form cannot be submitted until all required components, such as documents and evidence of fee payment, are present and complete. This will free up time currently spent by OISC staff processing incomplete applications.

It was noted during the review that certain steps of the application process could be changed to enable the OISC to process applications more efficiently. For example, individuals could pay to take an assessment prior to making an application. This would make approvals more straightforward and quicker to process because an applicant would have all the required data needed to complete the application (apart from the DBS check) prior to starting the application.

Application Process: Recommendation

Recommendation 6:

The OISC has reviewed its operations to identify where casework handling could be made more efficient through minimising manual intervention. The OISC must prioritise reducing manual handling as part of its ongoing capital works for IT system improvements and ensure this is fully implemented within 12 months of the publication of this review.

Shared Services: Findings

Government ambition is for all public bodies to be brought into a single shared system along with their sponsoring departments, which would realise considerable efficiency savings. This strategy will help deliver better service through modern systems at a lower cost. Bodies not joining a shared service centre in the immediate future are expected to progress with alignment to global processes and standards.

The OISC should therefore consider bringing its transactional processes for HR, finance, and procurement into closer alignment with those of the Home Office as part of its transformation programme. The implementation and business process impacts of changes to such systems are disproportionately costly for smaller organisations such as the OISC and should therefore only be made as part of a considered programme of transformation.

The OISC is taking broader and more innovative approach to shared services, looking beyond the typical back-office targets. For example, it undertook a review of its legal services provision in January 2023 which led to it considering collaboration with another arm’s length body (ALB) to improve its legal services provision. The OISC is now sharing legal services with the Security Industry Authority (SIA). By sharing this resource on a cost recovery basis, the OISC is accessing more targeted expertise than would typically be possible for an organisation of its size. This is a positive step which could be emulated among other Home Office sponsored bodies.

The OISC is also keenly aware of the importance of trusted working-level relationships between its staff and those in partner enforcement agencies. It intends to strengthen and deepen these connections, supplementing them with more formal and senior relationships where helpful, with an emphasis on Information Sharing Agreements to promote data exchange. This is aligned with the OISC’s broader ambitions for its intelligence capabilities, and with its pivot towards proactive disruption of illegal activity. This leveraging of the network of agencies working in the sector has the potential to generate considerable efficiencies for the OISC, and to deliver a less reactive and more preventative regime for the UK.

Workforce Benchmarking: Findings

The OISC directly employed an average of 54.97 people in 22/23, and also employed .52FTE agency staff. These figures are similar overall with those from 21/22, when they directly employed an average of 52.12, and 2.58FTE agency staff. They paid four exit packages totalling £168k.

The OISC currently has six operational teams overseen by the Director of Service Delivery, five corporate support teams overseen by the Director of Corporate Operations, an HR & OD function overseen by the Director of People, Culture & Programmes, and a Chief Staff Officer, reporting directly to the Commissioner, who also oversees the Communications & Engagement function.

The OISC’s data shows that there is currently an approximate 69%:31% split between delivery and non-delivery staff^{[footnote 22]}. When comparing to other organisations through benchmarking, this figure is higher than average for non-delivery staff. This may be due in part to the ongoing change programme, which includes 2.6 temporary posts in culture change and programme management, for which there is a clear rationale at present.

As the OISC is a relatively small organisation, these comparisons are limited in their applicability because there will be an irreducible minimum of staff needed to provide the function. For example, the OISC’s ratio is 1 HR team member per 36 staff. This is a higher proportion of HR staff than the published Civil Service ratio of 1:49 but a little lower than the average for small public bodies. The OISC’s ratio of communications staff to total staff is similar to that of other smaller public bodies.

Finance staffing is also similar to other small regulators. For digital staff, a high ratio to total staff is considered to indicate a more efficient organisation with higher automation. The OISC is therefore slightly higher than average, but for individual areas is in line with benchmarking from other small regulators. 

Workforce: Recommendation

Recommendation 7:

The OISC should ensure it has a useful and meaningful sense of the resource required for different types of activities undertaken by its staff, and the consequent value of that work. As a regulatory and enforcement organisation much of its value is difficult to quantify, but as OISC gains more control over its income it will need to be able to analyse and assess the best use of those funds internally, and account for those to the Home Office and ultimately to Parliament.

The OISC must establish a more accurate understanding of the resource spend for different activities, including through the LEAN reviews funded by the Home Office for 2024/25.

Governance: Findings

The corporation sole governance model vests organisational accountability in an individual, and it therefore tends to be more suited to smaller organisations. It is a relatively common model across government and is utilised where it would be disproportionate to adopt a chair and board model. This type of structure has fewer checks and balances and is therefore also more appropriate for organisations with limited responsibilities for public money.

Where such an organisation grows or takes on additional responsibility or funds, the structure is sometimes adapted by changing the relevant legislation to include provision for a chair and board. The review does not believe that immediate movement to a Chair and Board model for the OISC would be a proportionate use of public money at this stage.

Alternatively, in some cases across government, departments have taken steps to enhance an organisation’s governance arrangements through the Framework Document. Examples include: requiring that a corporation sole’s audit committee and/or advisory board has a majority of non-executive members; or that appointments to an audit committee and/or advisory board are made via the department’s public appointments process, or are subject to Ministerial approval, or involve a selection panel which includes a departmental representative.

The enabling legislation for the OISC requires both a Commissioner and a Deputy Commissioner. The Commissioner acts as corporation sole for the organisation. The Act requires the Deputy Commissioner to act in place of the Commissioner should he or she be unable to discharge their functions. There are no specific duties assigned to the Deputy role, but power is vested in the Deputy to undertake the duties of the Commissioner as and when required.

The previous Deputy Commissioner’s appointment ended in February 2021. A recruitment exercise began in mid-2020 but was paused during an in-depth consideration of all public appointments and ALBs under the 2020 spending review. Ministers agreed to increase the Commissioner from three to four days a week to help cover duties which had previously been delegated to the Deputy.

The OISC appears to be functioning suitably well without a Deputy, and the Commissioner has taken additional steps to bolster accountability, including setting up a Strategy Board which includes representation from the Home Office. This committee is a good step towards increasing the accountability of the organisation, but the Commissioner should seek to expand its membership and ensure it is empowered to provide both advice and challenge.

Governance: Recommendations

Recommendation 8:

The need to address the Deputy Commissioner issue and the forthcoming end of tenure for the current ARAC present useful opportunities for the Home Office to review the system of governance for this increasingly significant public body, and ensure it is fit for the future challenges it faces. The Home Office should act as quickly as is practicable to:

• Regularise the situation regarding the vacant Deputy Commissioner position. Options include appointing a new Deputy, legislative change to make the requirement for a Deputy discretionary, or legislative change to remove the requirement altogether.
• Consider a range of options to secure robust governance and accountability for OISC, including learning from comparable corporations sole sponsored by other government departments, and mechanisms such as a formal non-executive function.

Sponsorship and the relationship with the Home Office: Findings

The OISC is sponsored by the Home Office with a Senior Sponsor drawn from the relevant Policy Unit, and support provided by the Home Office Sponsorship Unit. Annex D explains the Home Office’s sponsorship structure in more detail.

The division of responsibility between the Home Office Sponsorship Unit and the Policy Unit should be made clear for the benefit of those teams and the corporate enablers working with the bodies. This is especially important at present, given that the both the Senior Sponsor and the Head of the Home Office Sponsorship Unit have each recently changed.

The Framework document sets out the ways in which the Home Office and the OISC work together. This document states that it should be updated whenever there is a new Commissioner or a new senior sponsor. The current document has not been reviewed since 2017, and in the period following, there has been both a new Commissioner appointed and a new senior sponsor. In addition, the Head of the Home Office Sponsorship Unit has also changed recently.

Accountability – Findings

Key Performance Indicators (KPIs) and Reporting

The work that the OISC does supports the Home Office’s departmental outcome delivery. Agreeing an organisational strategy and setting objectives are both important parts of aligning the work of the OISC to Home Office and governmental priorities. To effectively hold the OISC accountable, the HO must have a forensic understanding of the OISC’s performance data, to enable the HO to assess the impact of the OISC’s work and make informed decisions regarding funding and resource allocation.

The OISC must prioritise the production of baseline performance figures to measure its impact accurately. By showcasing the outcomes of its interventions, the OISC can demonstrate the value it adds to the immigration system. This information will not only enable the Home Office to evaluate the effectiveness of the OISC but will also support the effective allocation of funding. With sufficient financial support, the OISC could enhance its casework processes, making them swifter and more productive. This improvement would ultimately contribute to reducing illegal immigration and ensuring the provision of quality advice to those in need.

The OISC sets its own KPIs and reports against them in quarterly meetings, attended by the Home Office. The KPIs that the OISC measures are published in their annual Business Plan, and some are reported on in high level in their Annual Report.

In order to align the OISC’s KPIs with departmental priorities, the OISC and the Home Office should work together to consider in greater detail what should be measured and publicly reported on. This is especially important when thinking about those outcomes which impact the wider advice sector and end users. The Home Office could do more to help set and measure priorities, expectations and metrics for the OISC, such as through an annual letter from the responsible minister or delegated accounting officer.

The importance of this letter is noted in the Sponsorship Code of Good Practice, which applies to the sponsorship activities of government departments. Creating such a letter is an opportunity for policy and corporate sponsors within a sponsoring department to develop and then set out a common understanding of government priorities for the ALB, and how those will be measured by the Home Office over the coming year. Annex E provides relevant extracts from the Sponsorship Code of Good Practice.

Sponsorship Code of Good Practice

A shared sense of mission between department and ALB is essential for a mature sponsorship relationship. The ALB Sponsorship Code of Good Practice^{[footnote 23]} states that great sponsorship is delivered across six key capabilities:

• relationship management
• agreeing strategy and setting objectives
• outcome assurance
• financial oversight
• risk management, and
• governance and accountability

The Home Office and the OISC should prioritise improving the maturity of their relationship in relation to financial oversight and objective setting. The former is important to support both the Home Office and OISC to adapt to the outcome of the consultation on the OISC’s fees, moving towards a position of ‘open book’ engagement between department and ALB.

Departments should feel confident in setting clear expectations for financial reporting from their ALBs, and how these need to adapt to any changes within the ALB, and for ALBs to align with departmental interpretations of value for money and the prioritisation of resources.

Financial reporting

The Commissioner is Accounting Officer for the OISC and is responsible for safeguarding the public funds and reporting to Parliament on the organisational accounts. To support the Commissioner in fulfilling this role, the OISC has a financial accounting structure in place that includes reporting in quarterly meetings of the ARAC, quarterly organisational performance management meetings, external and internal audits and Home Office Finance/OISC monthly liaison meetings.

The 2022/23 Annual Report and Accounts (ARA) of the OISC was published in March 2024. This was due to a delay in the completion of the audit process. One reason given for this delay was that changes in key staff within both with the OISC and the audit team resulted in longer than expected intervals to complete checks.

Another key issue which contributed to the delay was the implementation of the new case management system. The previous system was able to provide the required information to the audit regarding adviser’s fees. After transitioning to the new system, which went live in March 2023, it was not immediately possible to process and report on the fees in the same way. This led to the OISC undertaking a manual process to reconcile the reporting between income and deferred income.

An update to the case management system is required to effectively automate this process. While ideally this would have been integrated into the initial design of the new system, there is an opportunity to utilise capital funding to adapt the system to report this information in future years.

The audit process and reporting to the ARAC indicated that there were other considerations which required amending the accounts, such as the way that the OISC reported on holiday accruals. The OISC has already taken steps to rectify these issues for future years.

Corporate Planning and reporting

The Corporate Plan is a longer-term strategic overview of how the OISC will achieve its statutory requirements while adapting to changes in the sector it serves. The plan is also an opportunity to set out how the OISC supports key strategic aims of the Home Office.

The OISC has recently reviewed its entire approach to enforcement and expects to significantly raise the profile and resources allocated to this work. It expects to shift the emphasis from relying on complaints to a proactive approach of seeking out and disrupting illegal activities. Home Office officials and Ministers have agreed in principle the need for a new funding model that enables OISC to expand its range of activities.

Sponsorship and the relationship with the Home Office: Recommendations

Recommendation 9:

The Home Office and the OISC should work together to review and publish an updated Framework Document as soon as practicable, and no later than April 2025.

Recommendation 10:

The Home Office must set out a clear strategic direction for the OISC based on Ministerial and Home Office priorities for the organisation and wider sector. This should be detailed in the annual letter to the Commissioner from the relevant Home Office Minister or Principal Accounting Officer (PAO) which should be sent in the Autumn of each year to ahead of the OISC’s business planning cycle.

The priorities agreed in this letter should then be reflected in clear and measurable KPIs used by the Home Office to assess the OISC’s performance as part of its regular assurance monitoring. The OISC should also regularly publish on its website data and reporting on KPIs it collects, unless there is a compelling reason not to do so.

Recommendation 11:

The OISC must improve its finance systems and controls to ensure it has the capability and capacity to demonstrate best practice in financial governance. This is particularly important to prepare the OISC to assume additional and more complex financial management responsibilities if changes to its fee structure are agreed. Steps have already been taken by the OISC to improve processes, and the Commissioner should continue to report on improvements to the ARAC, Home Office, and external auditors (where relevant).

• The OISC is encouraged to take advantage of Home Office finance expertise to ensure it fully understands and proportionately implements expectations of required standards and practices, in line with the Government’s functional standard for finance^{[footnote 24]}.

• Improvements to the IRIS system should be prioritised under the current capital project, to best utilise the capabilities of the system to support effective and accurate financial reporting.

• The OISC should aim to submit its annual report and accounts to be laid in Parliament as quickly as possible after year end, and ideally prior to Parliamentary summer recess.

Annex A: Terms of Reference

Terms of Reference: Office of the Immigration Services Commissioner Public Bodies Review

Background

1. The Office of the Immigration Services Commissioner (OISC) is a public body responsible for regulating immigration advisers and ensuring the provision of high-quality immigration advice and services to the public. The OISC seeks to protect consumers by ensuring the continuing fitness and competence of registered advisers and organisations, setting standards for registration and promoting good practice throughout the sector.

2. The OISC was most recently reviewed in 2014 (published in 2017) as part of the Triennial Review programme which aimed to ensure that non-departmental public bodies were still needed and complying with principles of good corporate governance. The review concluded that the OISC performed a necessary function and undertook its regulatory obligations with the aim of providing a good quality service. The review also noted that there were changes which should be made as to how the OISC did business to improve efficiency and reduce the burden on the public purse, with a view to the organisation getting as close as possible to full cost recovery model by 2020.

Scope and Purpose of the Review

3. The review of the OISC is part of the government’s commitment to continuously improve the effectiveness and efficiency of public bodies. The central purpose of the review is to consider how the OISC can deliver recurring efficiency savings on its Resource Departmental Expenditure Limit (RDEL) of at least 5% (in nominal terms), against its 2022/23 spending review allocation to be delivered within three years of the review. Actions to meet the efficiency target must be reflected in the review recommendations and recorded and quantified in the published review report.

4. The review will also consider aspects of the OISC’s compliance with government functional standards, including efficacy, accountability, and governance, to complement the findings set out in the Self-Assessment Model (SAM).

5. In addressing efficiency, the review will consider:

• What plans the OISC has to deliver more efficiently and effectively against the required 5% or more efficiencies target.
• Whether it is possible to identify opportunities for efficiency improvements through benchmarking against similar organisations.
• Consideration of whether efficiencies could be made through the digitisation and automation of processes, further streamlining of digital processes and/or the use of shared services.

• Consideration of how the recommendations of the OISC Triennial Review have progressed (where they have continued relevance). This will include recommendations in relation to the future funding model of the OISC connected to its fees and charges.

• Robustness of OISC’s financial management arrangements to sufficiently track progress towards achievement of key organisational objectives and efficiency improvements.

6. In addressing efficacy, governance and accountability, the review will focus on the following areas, in line with the outcomes of the SAM and the Government Functional Standards:

• Productivity and Efficacy – Whether the OISC’s performance metrics align with its strategy and annual business plan, are outcome focused and are supportive of the Home Office objectives to tackle illegal migration, remove those with no right to be here and protect the vulnerable.
• Governance – To consider whether the current governance arrangements are sufficient to enable the OISC to operate efficiently and effectively while minimising operational risks.
• Accountability – Whether the organisation’s accountability, in its use of public funding, to the Home Office, Parliament and the public is clear, transparent, and effective. This will include assessing the existing accountability arrangements between the OISC and the sponsoring department, such as the use of service level agreements, and the extent these agreements are clear and effective in maintaining organisational accountability.

Approach

7. The review will report to the Home Secretary.

8. The review will be led by Kay Chauhan through a combination of the following methods:

• a. Desk Research: This will include an analysis of published documentation, including the OISC Corporate Plan 2020-23, OISC Business Plan 2022-23 and Annual Reports. It should also include any draft Corporate and Business Plans that will reflect current strategic thinking, the SAM and any other relevant reports and publications. Analysis shall be undertaken on staffing levels, corporate functions and alignment with the shared services strategy, reliance on non-payroll resources, use of procurement, fraud and error rates, and digitalisation of services.

• b. Stakeholder engagement: The review may also seek feedback from stakeholders such as OISC staff, regulated advisers, service users, Home Office or other government officials, representative bodies and the devolved governments.

• c. Benchmarking: Comparing the OISC’s practices with other similar regulatory bodies to identify best practices and potential areas for improvement.

9. The Independent Lead Reviewer will be supported by an advisory panel, which will include individuals with expertise in the operations of Government and arm’s length bodies. This panel will provide advice on the programme of work, if required and can also be used to test emerging recommendations.

10. In conducting this review and making recommendations, the review will take account of the requirements of the Public Sector Equality Duty.

Timetable

11. The review will commence in Autumn 2023, after the Home Secretary formally appoints the Independent Lead Reviewer with a commencement letter.

12. The review is expected to report to the Home Secretary once complete and key findings and recommendations will be published on Gov.uk.

Annex B: Legislation

Immigration Services Act 2000 – Part V Immigration Advisers and Immigration Service Providers

The Immigration Services Commissioner 83 The Commissioner.

(1) There is to be an Immigration Services Commissioner (referred to in this Part as “the Commissioner”).

(2) The Commissioner is to be appointed by the Secretary of State after consulting the Lord Chancellor [F7, the Department of Justice in Northern Ireland] and the Scottish Ministers.

(3) It is to be the general duty of the Commissioner to promote good practice by those who provide immigration advice or immigration services.

(4) In addition to any other functions conferred on him by this Part, the Commissioner is to have the regulatory functions set out in Part I of Schedule 5.

(5) The Commissioner must exercise his functions so as to secure, so far as is reasonably practicable, that those who provide immigration advice or immigration services—

• (a) are fit and competent to do so;

• (b) act in the best interests of their clients;

• (c) do not knowingly mislead any court, tribunal or adjudicator in the United Kingdom;

• (d) do not seek to abuse any procedure operating in the United Kingdom in connection with immigration or asylum (including any appellate or other judicial procedure);

• (e) do not advise any person to do something which would amount to such an abuse.

(6) The Commissioner—

• (a) must arrange for the publication, in such form and manner and to such extent as he considers appropriate, of information about his functions and about matters falling within the scope of his functions; and

• (b) may give advice about his functions and about such matters.

[F8(6A) The duties imposed on the Commissioner by subsections (3) and (5) apply in relation to persons within section 84(2)(ba) only to the extent that those duties have effect in relation to the Commissioner’s functions under section 92 or 92A.]

Annex C: stakeholder mapping

OISC

Those to whom we are accountable

• Government - Home Office Ministers/SoS
• Government - Home Office - Policy

Those who lobby us

• Membership organisation
• Members of the public
• Community and voluntary sector - 3rd party support
• Legal professionals
• Courts and Tribunals
• Research organisations
• (Media)

Those we influence and advise

• Community and voluntary sector - advise
• Families of migrants
• General public
• Law clinics
• Regulators
• Government - Home Office policy
• Government - OGDs
• Government - Local Authorities
• Parliament - MPs
• Parliament - Lords
• Academia
• (Media)

Those we protect

• Advice seekers - asylum/refugees
• Advice seekers - economic
• Advice seekers - education
• Advice seekers - family
• Advice seekers - other
• Advice seekers - complaints/unregulated advice
• Migrant communities

Those we oversee

• OISC Regulated - fee
• OISC Regulated - non fee
• Designated Professional Bodies

Those we collaborate with

• Regulators
• Charities
• Devolved administrations - government
• Government - Home Office Policy/HOSE
• Government - OGDs
• Government - Local Authorities
• Internal - contractors/partners
• Membership organisation
• Enforcement partners
• Research organisations
• Courts and Tribunals
• Academia

Annex D: Home Office Sponsorship

Home Office sponsorship is delivered through a hybrid model.

The Policy sponsor acts as senior sponsor, and is typically a senior civil servant from the policy area most relevant to the work delivered by the ALB.

The Corporate sponsor role is conducted by the HOSU, a centralised division which is responsible for the relationship between department and ALB and undertakes most of the day-to-day contact.

This structure requires strong communication between policy and corporate sponsors to ensure ALBs experience coherent engagement with their department.

Home Office sponsorship of the OISC:

Policy Sponsorship	Corporate Sponsorship
Ministerial priorities	Objectives, Targets and Performance Monitoring
New policy requirements	Governance, Annual Reports and Accounts, Reviews
Relationships with policy teams in Home Office and other government departments	Relationships with government functional areas and professions such as Finance, HR, Commercial and Digital

Annex E: Extracts from the Sponsorship Code of Good Practice

Capability 2: Agreeing strategy and setting objectives.

Emerging

1. The responsible minister (or PAO, if delegated) does not communicate priorities to the ALB, for example via an annual chair’s letter or direct communication.
2. There is limited engagement between the department and ALB on what success looks like, how it can be delivered and how it is measured.
3. The senior sponsor has limited engagement with the ALB in the production of its annual business plan and multi-year corporate strategy and is unable to influence its direction.
4. The ALB is insufficiently responsive to departmental priorities, to change delivery through lack of awareness or inability to flex resources.
5. The ALB’s plans to deliver ministerial objectives are not clearly articulated in an annual business plan and multi-year corporate strategy.

Maturing

1. The responsible minister (or PAO, if delegated) clearly articulates the priorities for the ALB.
2. Senior sponsor engagement on the business plan and corporate strategy is limited to final review.
3. A vision of what success looks like, how it can be delivered and how it is measured is clearly articulated by the department to the ALB, but may be over or under stretching and not properly reflect ministerial priorities and/or the reality of the ALB’s operating context.
4. Priorities for the ALB from the department change frequently and can at times be inconsistent with the longer-term strategic direction and/or any statutory underpinning.

Advanced

1. The priorities for the ALB are set out in documents such as an annual chair’s letter issued by the responsible minister (or PAO, if delegated) sets SMART objectives for the ALB to deliver.
2. Outputs provide a stretching but realistic target that drives continuous improvement in effectiveness and efficiency for the ALB.
3. The department and the ALB engage collaboratively on an annual business plan that sets out how these SMART outputs will be delivered, underpinned by key performance indicators that are informed by timely management information. There is a constructive yet challenging dialogue between individuals at all levels that underpins this work.
4. This document makes up the first year of a multi-year corporate strategy that sets out how the ALB’s annual outputs contribute to the delivery of longer-term impacts.

Annex F: categorisation of complaints

Complaint received by the OISC

Yes

Who regulates the person who provided the Immigration advice or services?

• OISC registered Organisation/Adviser, Complaint dealt with under the OISC complaint scheme
• Other legal regulator, Designated professional body, Designated qualifying regulator
• Unregulated adviser/organisation complaint referred to the OISC intelligence and investigation team to consider.

No

• Complaint outside of the OISC’s jurisdiction e.g. not a relevant matter s.82 IAA 99

• Complaint against Home Office staff

Annex G: Process for handling complaints against OISC registered organisations

Complaint made to the OISC

Is it a ‘relevant complaint? If ‘relevant’ the complaint is recorded by the OISC. Commissioner considers whether to investigate.

If no

• Complainant informed
• No further action taken

If yes

• OISC investigation starts
• Statement of complaint issued to the registered organisation
• Response considered and further enquiries made if necessary.

Complaint determination made:

• Complaint not substantiated. All parties informed. No further action.
• Complaint not substantiated. Practice points issued. All parties informed.
• Complaint substantiated.

Commissioner’s options:

• Consider the complaint determination at the next relevant application for registration.
• Cancel immediately the registration of the organisation/adviser.
• Lay a disciplinary charge before the first tier tribunal (Immigration Services).

Annex H: Application Process

Complete an application form via the OISC website. Submit your application form to the OISC. The application will not be assessed until your application fee clears and we have received all requested documentation and information.

If your application is complete

It will be assessed. We will contact you if any further documentation or clarification is required.

You will be required to satisfactorily complete the OISC Competence Assessment.

You will receive feedback once you have completed the assessment.

You demonstrate the required level of competence in the assessment

Level 1 applicant

All information and documentation required has been received. A decision is made on your application. The decision will depend on whether you have demonstrated you are fit and competent. A decision to refuse the application in part or in whole carries a right of appeal to the First- Tier Tribunal (Immigration Services).

Level 2/3 applicant

You are invited to complete a Level 2 or Level 3.

You demonstrate the required level of competence in the assessment

All information and documentation required has been received. A decision is made on your application. The decision will depend on whether you have demonstrated you are fit and competent. A decision to refuse the application in part or in whole carries a right of appeal to the First- Tier Tribunal (Immigration Services).

You do not demonstrate the required level of competence in the assessment

All information and documentation required has been received. A decision is made on your application. The decision will depend on whether you have demonstrated you are fit and competent. A decision to refuse the application in part or in whole carries a right of appeal to the First-Tier Tribunal (Immigration Services).

If you application is incomplete

We will write to you giving you 10 days to supply the information and documentation.

If your application is still incomplete we will write to you giving you a further 5 days to supply the missing information and documentation.

If after the further 5 days you still have not supplied the missing information and documentation, your application will be refused. The application fee will not be refunded.

All information and documentation required has been received. A decision is made on your application. The decision will depend on whether you have demonstrated you are fit and competent. A decision to refuse the application in part or in whole carries a right of appeal to the First-Tier Tribunal (Immigration Services).

Annex I: Recommendations from Previous Review

Recommendations which are the primary responsibility of the OISC:

• The OISC should consider whether its current approach to monitoring CPD compliance is the most proportionate and appropriate one. A review of this approach should be completed and agreed with the Home Office within six months of the publication of this report, with any potential savings as a result of increased efficiencies clearly identified and built into future budget allocations.
• Building on the successful 2008-10 Reform and Remodel programme which streamlined the processes for new applications and re-registrations, the OISC should work with the Home Office to apply the same value for money principles to its other large-scale processes, most notably complaints and upward review. A revised, more risk-based process should be developed with efficiency savings clearly identified. This should include a robust cost benefit analysis of reduced caseworking time set against possible increased risk of appeals. The new process should be implemented within 18 months of the publication of this report so that any identified savings can be realised in the following financial year.
• The OISC should review its legal costs with reference to other organisations doing similar work within 12 months of the publication of this report and, if necessary, work with the Home Office to improve value for money in representation at appeals.
• The OISC should consider within 12 months of the publication of this report whether there is an appropriate light-touch way of assessing consumer satisfaction. This would have to be clearly distinct from the complaints scheme.
• The status of the Commissioner’s Advisory Panel should be clarified, either by making it more representative and having regular meetings, perhaps to discuss the findings of the advisers’ survey; or alternatively, if it serves no purpose, by discontinuing it.
• The OISC should keep under review mechanisms for engagement with registered advisers, whether via the Commissioner’s Advisory Panel or other routes, and also should consider engagement with the public.
• The Review recommends that the OISC should continue to consider how they can best meet Cabinet Office guidelines on transparency and open data.
• The OISC should assess trends in its own efficiency over time and should compare to other similar organisations, and publish this benchmarking activity in its Annual Report, starting with the next one.
• The Review recommends that the incoming Commissioner should provide his or her preferred option for rationalisation of the OISC’s management structure to the Home Office within 3 months of taking up post.
• The OISC should keep in touch with Government work on shared services so as to take advantage of any future opportunities for rationalisation. In addition, the OISC should consider the scope for sharing some services locally, for example with other occupants of the building they use at 21 Bloomsbury Street.

Recommendations which are the primary responsibility of the Home Office or another body:

• The Home Office should work with the OISC to ensure that its outcome-based objectives are appropriate for the organisation, and that the proposed data collection is adequate to support assessment of those objectives. A detailed set of performance indicators should be agreed within three months of the publication of this report and the data should be available to measure performance against these indicators by the end of Autumn 2017.
• The Home Office should, with the OISC, assess the impact of electronic applications in the year after they are implemented, and any necessary further changes or improvements should be agreed at that stage.
• The Home Office should work with HM Treasury and the OISC as a matter of priority to minimise the cost to the public purse of financing the OISC by
  • i) seeking to make efficiency savings with a view to continuing the current year-on-year reduction in the OISC’s grant from the Home Office and
  • ii) by maximising fee income with a view to getting as close as possible to full cost recovery by 2020.
• The Home Office should engage with the work being led by the Legal Services Board on the future of the framework for legal regulation, and ensure that proper consideration is given to the place of the OISC in any wider review, in particular considering whether the OISC could in due course become a qualifying regulator under the Legal Services Act 2007 if the devolution requirements could be dealt with.
• The Legal Services Board and the OISC should continue to work together to ensure that they are both effectively contributing to, and benefiting from, proactive sharing of experience and information with other regulatory bodies.
• The Home Office should consider whether there would be value in strengthening the governance framework, possibly by introducing a formal non-executive role.
• The Home Office Senior Sponsor should attend one meeting of the Audit and Risk Assurance Committee every year (or one meeting of the non-executive board if such a board is established in future).
• A new Framework Document should be drawn up by the Home Office and published on the OISC website as quickly as possible after the publication of this review and the appointment of the new Commissioner, and certainly within 6 months.
• This Review recommends that the Home Office works as a matter of urgency to ensure that targets for delivering electronic applications to the OISC are achieved in line with the implementation plan in place in early 2017.

1. Annexe D summarises the Home Office sponsorship structure and approach ↩

2. The OISC completed the Cabinet Office’s a self-assessment model (SAM). No areas of concern about the OISC’s delivery of its mission were highlighted. ↩

3. In nominal terms ↩

4. including any reduction in indicative budget allocation from the Home Office for 2023/4 ↩

5. Office of the Immigration Services Commissioner’s fee structure - GOV.UK (www.gov.uk) ↩

6. Paragraph 92 of Guidance on the undertaking of Reviews of Public Bodies - GOV.UK (www.gov.uk) ↩

7. Government Functional Standard - GovS 006: Finance (publishing.service.gov.uk) ↩

8. Office of the Immigration Services Commissioner: framework document (accessible) - GOV.UK (www.gov.uk) ↩

9. How to become a regulated immigration adviser - GOV.UK (www.gov.uk) ↩

10. OISC Criminal Enforcement Policy updated 25 August 2023. ↩

11. OISC complaints form - GOV.UK (www.gov.uk) ↩

12. Complaints procedure - Office of the Immigration Services Commissioner - GOV.UK (www.gov.uk) ↩

13. Triennial_Review_of_the_Office_of_the_Immigration_Services_Commissioner.pdf (publishing.service.gov.uk) ↩

14. Managing Public Money May 2023 (publishing.service.gov.uk) p193 ↩

15. Triennial_Review_of_the_Office_of_the_Immigration_Services_Commissioner.pdf (publishing.service.gov.uk) p6 ↩

16. Office of the Immigration Services Commissioner Annual report and accounts 2022/23. (publishing.service.gov.uk) p55 ↩

17. Consultation on changes to the Office of the Immigration Services Commissioner’s fee structure - GOV.UK ↩

18. Levelling Up the United Kingdom: Executive Summary (publishing.service.gov.uk) ↩

19. Office of the Immigration Services Commissioner - GOV.UK (www.gov.uk) ↩

20. SRA - Solicitors Regulation Authority - Solicitors Regulation Authority ↩

21. Paragraph 92 of Guidance on the undertaking of Reviews of Public Bodies - GOV.UK (www.gov.uk) ↩

22. We have categorised non-delivery staff as those in the Commissioner’s Executive, except the engagement lead; those in corporate operations, except for customer service; and those in the People, Culture and Programmes directorate. ↩

23. The ALB Sponsorship Code of Good Practice ↩

24. Government Functional Standard - GovS 006: Finance (publishing.service.gov.uk) ↩