Policy paper

Response to an inspection on overstayers

Published 25 June 2026

The Home Office thanks the Independent Chief Inspector of Borders and Immigration (ICIBI) for this inspection report of overstayers.

The Home Office welcomes the recommendations made in the ICIBI report and will implement those which align with our ongoing work although we also need to give consideration to their deliverability within the current operational and resourcing landscapes.

The operational inconsistencies and system limitations that the inspection highlights are being addressed within the Home Office’s broader strategic management of the Migration and Borders System. Overstaying is not treated in isolation but is managed as part of a systematic approach that intersects with other priority areas, whether that is within Immigration Enforcement or Visa, Status & Information Services or across other parts of the Migration & Borders System.

The Home Office has already started work to refresh its approach to the management and prevention of overstaying by establishing a Director General chaired governance group focusing on controlling threats and vulnerabilities in regular migration routes, which includes overstaying.

Immigration Enforcement plays a critical role in tackling abuse of the immigration system ensuring that there are consequences for those who break our rules and seek to exploit the system. Immigration Enforcement focusses on tackling harm, and maximising returns, with nearly 70,000 returns being recorded since July 2024 (1 July 2024 – 31 March 2026). Our areas of focus include targeting foreign national offenders, tackling illegal working and those who exploit the immigration system. Overstayers can fall into all of these categories, and are often encountered through this work, which is designed to protect communities and maintain the integrity of the immigration system. In particular, our illegal working activity will frequently pick up overstayers.

Since July 2024, illegal working enforcement activity has reached record levels, targeting abuse of the immigration system and returning those without lawful status.  Between 1 July 2024 and 31 December 2025, Immigration Enforcement teams made more than 12,300 arrests during illegal working visits, an 83% increase compared with the equivalent period 18 months earlier. During this period, teams also conducted over 17,400 visits to businesses suspected of employing illegal workers, a 77% increase. As a result of this intensified activity, over 1,700 people have been returned, up 35% from the equivalent period 18 months earlier.

This demonstrates the Home Office’s commitment to using resources effectively and focusing on high-harm areas while continuing to strengthen processes and systems to support enforcement activity.

The Home Office remains committed to making improvements where they can be achieved within existing resources. This includes a programme of continuous improvement in data management and caseworking platforms as part of the Home Office’s delivery of its digital immigration system. The introduction of eVisas and Electronic Travel Authorisations (ETAs) means the Home Office knows more about everyone coming to the UK, improving data quality and enabling upstream interventions. As the Home Office moves to a fully digital system, eVisas will increasingly update in real time when status changes, automatically revoking access to work, benefits, housing, and services, unlike physical documents that can be misused after expiry. Immigration status information is available automatically through system-to-system checks with public authorities and government departments.

Alongside this, the Home Office is developing a new digital capability, to be implemented in 2026, to help determine whether individuals have complied, or are complying, with conditions on the time they may stay in the UK. This will also make it easier to share travel and immigration compliance data with caseworkers and downstream services for a variety of analytical and operational needs.

Whilst the Home Office recognises the feedback provided by staff and end users of the Atlas system, the programme is in continuous development. Many of the challenges and issues identified in the report are scheduled for upgrade. The improvements in train will continue to build the platform’s reliability as the single source of information for all business areas.  

The Home Office recognises the importance of addressing backlogs to ensure the efficacy of the Migration & Borders system. The Home Office is already proactively managing the cases awaiting cancellation and is working with IT leads to routinely cleanse the caseload to ensure that cases not requiring cancellation action are removed from workflow, providing more accurate management information and more efficient allocation of resource to action cancellations where required. This has already significantly reduced processing times for workable cases to 1-2 weeks for cancellations not linked to Sponsor Revocations and 4 weeks for those whose sponsor has been revoked (to give time for any subsequent litigation to be submitted prior to cancelling). Approximately 5000 cases are resolved and closed each week.  As a result, the cancellations queue has reduced to 74,000. Approximately 60,000 carer visa holders are within this cohort, excluding them from cancellation action at this time.

The Home Office has made public, including at the Parliamentary Accounts Committee session into Skilled Workers on 8 May 2025, the decision to delay cancellations for skilled workers holding visas on carer SOC codes linked to sponsors whose licences have been revoked. The Home Office is working in partnership with the Department for Health & Social Care and the Care Sector to find alternative roles for this group.

The Home Office welcomes the positive reporting on the use of the Complexity Application Routing Solution (CARS) to support efficient workflow management and the consistency of its application. The guidance documents regarding the use of the Complexity Application Routing Solution (CARS) in visit and student applications are published on the public facing gov.uk webpages. It is explicit in stating that CARS is a tool for routing applications only to identify the complexity of an application. In general, more complex applications will inevitably require more rigorous scrutiny and the guidance covers this. Risk profiles, which identify individual attributes linked to visa abuse, are shared internally with decision makers. To avoid any attempts to abuse the visa system by unscrupulous individuals, and therefore the integrity of the immigration control, their details are not published. Publication of the CARS guidance, however, does demonstrate transparency of the overall routing processes and one of the methods the Home Office deploys to address potential abuse of our systems.

The ICIBI identified several areas for improvement and has made a total of 5 recommendations, 1 of which, Communication contains 6 elements, with each element therefore responded to individually. Of the five ICIBI recommendations, the Department accepts 3 and partially accepts 2.

Recommendation 1: Leadership and Strategy

Appoint a Senior Civil Servant (SCS) as the Migration and Borders (M&B) System lead for overstayers, tasked with overseeing the creation of a strategy for preventing overstaying, and identifying and removing overstayers (or regularising their immigration status). As a first step, the SCS lead should catalogue the strands of current and planned activity that contribute directly or indirectly to the Home Office’s understanding of and response to overstaying and overstayers, using this to produce a gap analysis and action plan, and to ensure that the risks surrounding overstaying and overstayers are properly reflected in risk registers at all levels across the M&B System.

Accepted

A new Director-General chaired governance group to focus on controlling threats and vulnerabilities in regular migration routes was established in March 2026. This board will draw the system together, ensuring clear focus and prioritisation of effort for all such threats, including overstaying a visa.

As part of this recommendation, the Home Office will:

• Produce a mapped list of all current and planned activity relevant to overstaying across Visa, Status and Information Services, Immigration Enforcement and other relevant business areas.
• Use this mapped activity to conduct a gap analysis and develop an action plan for improving system oversight and governance of overstaying
• Review how risks linked to overstaying are currently captured in directorate and system-level risk registers and propose updates to ensure risks are consistently recorded and monitored.

Exploratory tasking was commissioned at the board meeting held on 14 May and Home Office will take forward activity across our systems throughout the course of 2026.

Date of Implementation: December 2026

Recommendation 2: Record keeping and Information Management

Audit the IT systems used to record and manage overstaying and overstayers with the aim of reducing the number of systems in use, fixing ‘bugs’ and issues that impact efficiency and effectiveness, and standardising and assuring record keeping, ensuring that current and historic information and data about overstaying and overstayers (caveated as appropriate) can be accessed by whoever has an approved business need. This should include:

• displaying visa duration dates on the Atlas landing page, similar to the way in which they are found on the Central Reference System (CRS) landing page
• flagging previous overstaying clearly on Atlas and specifying lengths of overstaying periods on both CRS and Atlas
• providing decision makers with access to the MIDAS Travel Data Service to enable them to ascertain travel history more readily
• ensuring ISA data is requested for every individual after the expiry of their visa, to enable an ‘ISA identity status’ to be displayed clearly on Atlas
• ensuring s.3C leave is recorded consistently in Atlas and that individuals with s.3C leave are not included in data for current overstayers.

Partially Accepted

The Home Office acknowledges the five elements of this recommendation. Many of the suggested actions and improvements are already underway or embedded in current processes. Further enhancements may be added to the roadmap following impacts assessments and prioritisation decisions.

1. The Person Summary View (PSV) on the Atlas casework system is the user interface that allows data sets (including those from legacy systems) to be displayed. This “landing page” now includes “valid to” dates. An impact assessment around the usability and accessibility of data in the PSV has been commissioned, including a requirement to explore how key information, including visa duration dates, may be displayed in a more user-friendly way making it more visible. A decision to proceed with discovery has been made and this activity will be sequenced in line with other planned work from Q2 2026.

2. All potential overstayers should be identified and passed through Immigration Enforcement systems. TRAM looks to ascertain if the customer has overstayed and then refers for enforcement action where applicable. This  allows the creation of a C&E card marking the individual as an overstayer clearly on the PSV for all staff to note for any future engagement with that customer, that is to say the existence of the C&E card should prompt all staff of any previous overstaying or existing overstaying.
   - Work to enhance Notice of Liability information (which notifies customers as overstayers) was implemented in March 2026. This  ensures that when a NOL is served, the original leave is also cancelled and thus status is updated. Completing these actions will ensure that customers who should be referred to Immigration Enforcement are being referred routinely.
   The Home Office does not see any value in adding lengths of overstayer periods to CRS as that is not a decision-making system.

3. Decision makers already have adequate access to MIDAS Travel Data Services, and when new capabilities such as Counting in and Counting out (CICO) are introduced, further improvements will be evaluated.

4. The ISA system combines data based upon set criteria that link an individual’s travel in or out of the country with their immigration history, to create, as far as possible, a person-centric dataset. The output daily analysis is uploaded in bulk on a weekly basis into PSV which is viewable to all users. National Returns Progression Command also receive an extract of the overstayers report on weekly basis to check the accuracy of “departed” data. An extract of ISA data is also provided for Out of Country operations and used within the CARS application. The previous travel data is provided to decision makers as part of their consideration if there is a match based upon passport number. ISA is due to be replaced by CICO by the end of 2026. As CICO is developed and ISA is decommissioned any reasonable adjustments that improve the clarity of this data will be considered.

5. Section 3C leave is inferred through other data available in the data platform such as an in-time application for permission to stay, an application for asylum, appeal information or administrative review information. The recording of section 3C leave does not constitute a formal application outcome or an official record of status. The customer’s full history is recorded in the data platform and would exclude the case from being referred to Immigration Enforcement through tools such as TRAM. Increasingly, section 3C leave is also reflected in an individual’s digital status, enabling their continuing rights to be viewed via the UKVI account and shared with authorised third parties, such as employers. The accuracy and consistency of the recording of 3C, how this is displayed and utilised are key elements for review included in the 2026 status accuracy roadmap.

Date of Implementation:  December 2026

Recommendation 3: Communication

Develop internal and external communication plans covering overstaying and overstayers, identifying (and updating as appropriate) key messages, target audiences, delivery methods, and metrics for measuring effectiveness. This should include: - creating (or re-focusing) boards and fora to share knowledge and experience of overstayers and overstaying between M&B directorates and business areas, and between the Home Office and stakeholders - reviewing Home Office engagement with visa sponsors, creating the means for sponsors for each of the different routes to share their knowledge and experience of overstaying and overstayers with each other - (with input from stakeholders) reviewing guidance and messaging where these bear on overstaying and overstayers and ensuring that they are clear and unambiguous (taking account of the fact that visa applicants may have limited English) - (in order to develop a better understanding of the factors that lead to overstaying) ensuring that the Home Office’s information and intelligence requirements in relation to overstaying are clearly defined and are understood by teams within the Home Office who encounter overstayers, and by others, such as the police - examining ‘Right to Work’ or ‘Right to Rent’ referrals to establish whether the system is working and why, in particular, employer referral numbers are so low - producing a response to questions about the size and nature of the overstaying population that does not fall back on exit check data published in 2020

Partially accepted

The Home Office recognises the importance of clear and effective communication with both internal and external stakeholders regarding overstaying and will as part of a wider review of its strategic oversight of the management of overstayers (recommendation 1) review its communications strategy and where enhancements may reasonably be made.

1. The Home Office is committed to responding to feedback and building on recent initiatives which have enhanced intelligence flows and improved outcomes across the system. However, the Home Office notes creating new boards or fora, may not deliver measurable benefits beyond current arrangements. In line with recommendation 1, the Home Office will review existing fora to assess whether adjustments to agendas, membership or frequency are required. The Home Office’s focus remains on practical outcome-driven engagement and will continue to do this through existing fora with partners.

2. The Home Office already routinely engages with visa sponsors focusing on those who are non-compliant and who have failed to meet their sponsorship duties. The Home Office’s priority is to address sponsorship duties where there are concerns. The Home Office believes that extending engagement with compliant sponsors would offer limited additional value but will continue to review and develop its engagement strategy to ensure it keeps pace with sector developments. Additionally, the education sector already hosts a range of umbrella bodies to bring organisations together to discuss best practice and experiences. UKVI regularly contributes to sector led events and fora.

3. The Home Office has recently piloted notification messages to students and their adult dependants to promote compliance with the terms and conditions of their permission to enter. The Home Office will, following evaluation of this pilot (due in the latter half of 2026), explore opportunities to extend and develop messaging for visa holders and review existing messaging and guidance available to customers. Internally, training is in place for Immigration Compliance and Enforcement (ICE) Officers and ICE Teams who regularly engage with local police, partner agencies and intelligence colleagues, to raise awareness and share information about immigration offenders, including overstayers. The National Community Engagement Team also works with diaspora communities to highlight the consequences of overstayer and signpost options for regularising status or departure from the United Kingdom.

4. There are examples of good practice amongst the ICE Teams. A notable example of good practice can be seen in the collaboration between the Northern Ireland ICE Team and the Northern Ireland Operational Intelligence Unit (OIU) over the past year. Together, they have forged a highly effective partnership focused on sharing intelligence. As part of this collaboration the ICE Team’s Community Engagement Lead invited the OIU to attend community events, introducing them to new partners who work directly with vulnerable individuals. This approach has enhanced community awareness of the work of Immigration Enforcement, generated new intelligence referrals, and strengthened trust within local communities. As a result, further operational activities and ongoing taskings have been initiated. Additionally, the OIU has gained a deeper understanding of the issues facing the communities they support. The Home Office will review the information and intelligence requirements associated with overstaying as part of the system‑wide governance work under Recommendation 1, ensuring that these requirements are clearly defined and communicated across relevant operational teams.

5. The Right to Rent and Right to Work reporting mechanisms operate differently, with distinct drivers and perceived benefits for landlords and employers. This may contribute to the disparity in referral volumes. By December 2026, the Home Office will further explore current usage of these referral routes to better understand any barriers to reporting and the reasons for low employer referral levels. Insights from this work will inform broader analysis of referral data alongside policy and operational engagement. Planned communications to support the expansion of the right to work scheme, alongside targeted messaging to landlords following legislative changes, will be used to raise awareness of the schemes and how to refer concerns.

6. In relation to the size and nature of the overstaying population, the Home Office has been clear that it is not currently possible to produce reliable estimates, as there is no complete dataset for individuals who have overstayed their visa. The Home Office will continue to improve available data as resources and priorities allow.

Date of Implementation: December 2026

Recommendation 4: Visa Decision Quality Management

Review quality management in relation to visa decision making, ensuring that quality is not being compromised by the daily benchmarks set for decision makers. This should include:

• regularly updating training for decision makers and for entry clearance managers to reflect identified risks and issues, for example overturned decisions and poor-quality refusal letters
• ensuring Immigration Enforcement reports all confirmed instances of overstaying to the relevant team(s) within Visa, Status and Information (VSI), using this feedback to review visa decisions, facilitate learning, and improve future decision-making

Accepted

The Home Office is committed to maintaining high standards in visa decision-making and regularly reviews demand forecasts, productivity expectations and resource allocations to ensure that Service Lines are equipped to deliver quality outputs in line with service level agreements. Training is routinely refreshed, and robust quality assurance processes are already in place across visit, study, and work service lines, ensuring decision makers receive feedback on overturned decisions and the quality of refusal notices. VSI’s Cross-Cutting Service Operations will explore opportunities to bring greater co-ordination across Service Lines to drive further improvements and consistency, including discussion at relevant operational boards to monitor performance and delivery. 

Information about overstayers identified by Immigration Enforcement is routinely shared with the teams responsible for visa decision-making. When someone is found to have overstayed, this is recorded in our systems so that relevant teams can access the information and take appropriate action. The Home Office is committed to making these processes as efficient and joined up as possible, and we continue to review how information is shared to ensure it supports learning and improvements in future decisions.

Work to strengthen how information about overstayers is captured, shared and used in visa decision‑making will be reviewed as part of the strategic oversight work under Recommendation 1, to ensure that cross‑system dependencies are properly understood and governed.

Date of Implementation: December 2026

Recommendation 5: Visa Cancellations

In order to reinforce the importance of visa holder compliance, as a matter of urgency, review the backlogs of visa cancellation cases and identify how these can be reduced to manageable levels and how cancellation processing times can be cut to a maximum of two months, if necessary, surging staff resources to bring the backlogs and timescales down initially

Accepted

With the exception of those cases which remain on hold, pending redeployment back into the sector, who have worked as Carers or Senior Carers and their Sponsor’s licence has been revoked, we are currently cancelling individual’s leave within 1-2 weeks of them entering the work queue if the cancellation is not linked to a Sponsor Revocation. If the case is linked to a Sponsor revocation, we are holding these for 4 weeks and cancelling at that stage to ensure that any possible litigation challenge is not submitted.

This has been achieved through the deployment of additional staff to the cancellations team and also by utilising data and technology to routinely ‘cleanse’ the queue for cases that do not require pursuing. On average, we are concluding c5000 cases per week.

The Home Office will ensure that insights from the cancellations caseload feed into the wider system‑level oversight work being taken forward under Recommendation 1. This will help maintain a consistent strategic approach to tackling overstaying across the Migration and Borders System.

Date of Implementation: Implemented