FOI release

SIA checks on licence applicants with refugee status

Published 20 November 2025

Request

I am writing to request information regarding the vetting process for SIA licence applicants who have refugee status. Specifically, I would like to know the following:

1. Vetting criteria and steps – could you provide detailed documentation or an outline of the specific criteria and steps involved in vetting applicants who are refugees?

2. Application timelines – on average, how long does the application process take for individuals with refugee status compared to other applicants? Are there any additional steps that might extend the timeline?

3. Approval and denial rates – in the past 5 years, how many applications from individuals with refugee status have been approved, and how many have been denied?

4. Staff training and guidelines – what kind of training or guidelines are provided to SIA staff to ensure fair and unbiased vetting of applicants with refugee backgrounds?

5. Appeals process – is there an appeals process for applicants who feel their application was unfairly denied, and how often is this process utilized?

6. Audit and review – can you provide any recent audit results or reviews of the vetting process, especially concerning applicants with complex or refugee backgrounds?

Response

The SIA holds the information that you have requested. A response to each question can be found below.

Vetting criteria and steps

The SIA uses rules called ‘criteria’ to decide whether or not to grant a licence. A document called Get Licensed sets out our licensing criteria and processes.

To qualify for a licence to work in any front line licensable activity, an individual must:

• be aged 18 or over;
• pass an identity check;
• pass a criminal record check;
• have the appropriate, SIA recognised, licence-linked qualification; and
• have the right to work in the United Kingdom (UK).

To qualify for a licence to operate in a non-front line role, such as a manager or supervisor, an individual must:

• be aged 18 or over;
• pass an identity check; and
• pass a criminal record check.
• have the right to work in the UK.

Please note that the SIA may grant a non-front line licence to an applicant if they do not have the right to work in the UK, but they are a director of a UK registered company or one of its parent companies.

For applicants with refugee status or humanitarian cases, we use discretionary leave for reporting purposes. Applicants who fall under this category must provide further evidence which may extend the deadline. Such evidence includes:

• Overseas criminality checks: this will apply if the applicant has lived overseas (including the Republic of Ireland, British Overseas Territories and former colonies) for 6 continuous months or more in the last 5 years.

• Licences issued in other countries: If an applicant holds a licence to work in the private security abroad and it is a condition of that licence that they have a criminal record check, the applicant may send this to the SIA as evidence of their good character. If the SIA is not familiar with that licence, it will seek confirmation of the validity and conditions from the issuing authority in the other country.

• Sworn oaths and character references: If official sources are not available to provide criminal record checks, the SIA can let the applicant provide the following 2 documents instead:

  • an oath sworn in front of an EU registered solicitor or Commissioner for Oaths attesting to lack of criminal convictions for the period that the applicant was in another country; and
  • a character reference from a fully qualified professional who knew the applicant personally during the specified period.

Please refer to pages 41-44 of Get Licensed for further details.

Application timelines

The average time for an application to move from ‘checks in progress’ to decision made with reference to those we use discretionary leave for is 19.81 working days. For applicants with refugee status or humanitarian cases, we use discretionary leave for reporting purposes.

The average time for an application to move from ‘checks in progress’ to decision made with reference to those that do not fall within the discretionary leave is 10.26 working days.

Some applications may take longer to process, for a variety of reasons. The most common reasons for applications taking longer are where the applicant is unable to provide an overseas criminality certificate and therefore needs to provide a character reference and sworn oath, or where there is an ongoing criminal or public body investigation or trial. Other causes for longer processing times include waiting for a medical report to be provided for an applicant, or where an overseas criminality certificate is required. Applications can often involve a combination of more than one of these factors.

Longer processing times for applications typically occur where the applicant or a third party is required to provide further evidence to the SIA before we can make a decision. We balance the need to maintain efficient processing by withdrawing applications when and where appropriate to do so due to failure to provide the information we need and keeping applications open while supporting those individuals who make efforts to progress them but are dependent on third party input.

Approval and denial rates

In the past 5 years a total of 26,555 applications from individuals with refugee status have been approved and a total of 163 applications from individuals with refugee status have been refused.

Staff training and guidelines

As set out in the response to question 1, the SIA uses rules called ‘criteria’ to decide whether or not to grant a licence. The criteria are found in the document Get Licensed. The criteria are applied to all applications to ensure fair and unbiased vetting of applicants with refugee backgrounds.

Appeals process

Where the SIA intends to refuse an application, the SIA will write to the applicant to explain the reasons why. The letter will provide an applicant with details of how an applicant can send us an appeal before the decision comes into effect.

An applicant will need to submit an appeal within 21 days, and the SIA will explain what information an applicant needs to send with your appeal. If an applicant cannot send all the information within 21 days, they should let us know within this time limit. In certain situations, the SIA can give more time to submit their appeal.

If the SIA receives an appeal within 21 days, the information provided will be given consideration. The SIA will then let the applicant know whether it stands by its decision to refuse an applicant’s licence.

If the SIA stands by its decision, it will come into effect immediately. However, an applicant can still appeal against the decision to the Court.

Audit and review

We confirm that 2 separate audits were carried out in relation to our vetting process. The first audit was carried out in July 2023 and the second in November 2024. Please note that these audits do not cover reviews on how we assess applicants with complex or refugee backgrounds but focuses on how we assess whether an applicant with a criminality record is fit and proper to hold a licence.

This information is exempt from disclosure under section 36 FOIA because it would prejudice the effective conduct of public affairs. Section 36(2) states that information is exempt if, in the reasonable opinion of a qualified person, disclosure of the information under this Act would, or would be likely to:

• inhibit the free and frank provision of advice,
• inhibit the free and frank exchange of views for the purposes of deliberation, or
• otherwise prejudice, or would be likely otherwise to prejudice, the effective conduct of public affairs.

In this case, a qualified person has given their reasonable opinion that disclosure of the requested audit documents would be likely to prejudice the effective conduct of public affairs. This opinion has been recorded in accordance with the requirements of FOIA.

The information you have requested includes audit findings and internal assessments which identify vulnerabilities and weaknesses in the SIA’s vetting process. Disclosure of this material could:

• inhibit officials from providing full and candid advice or opinions in future audits
• deter internal and external stakeholders from engaging openly in vetting process reviews
• undermine the safe operation and integrity of our security and personnel processes, which depend on open critique and internal candour to remain effective and improve over time
• damage public trust and compromise public security concerns and therefore disclosure of audits would impair the quality of decision-making

The SIA must also consider whether the public interest in maintaining the exemption outweighs the public interest in disclosing the information.

The public interest factors tending in favour of disclosure are:

• promoting transparency and accountability in how the SIA assesses and improves critical internal processes
• increasing public confidence that any weaknesses identified are being addressed appropriately
• encouraging public debate around standards and integrity in the vetting procedure
• supporting external scrutiny around how public resources are used to ensure robust practices

The public interest factors in maintaining the exemption are:

• ensuring SIA staff and auditors can provide full, honest, and candid assessments without fear of public exposure or misinterpretation
• protecting the space for internal debate and deliberation about operational risks and weaknesses without creating undue reputational risk or undermining staff morale

On balance, we have concluded that the public interest in maintaining the exemption outweighs the public interest in disclosure.

Editor’s note

The SIA cannot produce a report specifically and solely focused on refugees. This is because we do not categorise them in that way and cannot report on them as a discrete group.

We have therefore based our reporting on people who have a right to work status of ‘discretionary leave’. This is a classification often (but not always) granted by the Home Office to refugees and other humanitarian cases. This may include people who are not refugees.

This response is therefore as accurate as we can make it under the circumstances, but it may not include all SIA licence applicants with refugee status and may include others who are not refugees.

[Ref: FOI 0571]