With the support of three other organisations who work on Change of Conditions applications (Praxis, Ramfel and the Refugee and Migrant Centre), we have put together a report into the Home Office’s increasing use of Requests for Further Information (RFIs).
Key findings from the report are:
- All organisations have observed a steady increase in the use of RFI’s, which are now a routine part of the CoC application process.
- RFI’s add around a month to the application timeframe. The expansion in their use has has coincided with a dramatic slowdown in decision-making and an increase in the proportion of applications which are refused.
- RFI’s often contain a large number of requests which are not necessary to assess an applicant’s need for public funds. Applications can be – and are – granted without these requests being responded to in full.
- RFI’s increase the work required to navigate the CoC process and risk applications being refused due to unnecessary considerations or evidence requests.
The report includes five policy recommendations:
1. Transparency – The Home Office should publish data on the number of RFI’s issued nationally, and the outcomes of their corresponding applications.
2. Prompt decision-making – RFI’s should not seek updates on applicant’s circumstances which are necessitated only due to an unreasonable delay in decision-making.
3. Compliance with policy guidance – RFI’s should only be issued when an applicant has failed to provide information or evidence required within the application form, or an adequate explanation of why they have not provided it, as per the policy guidance.
4. Evidential flexibility – If an applicant has given an explanation for not providing information or evidence but the Home Office finds this to be inadequate, the RFI should clearly explain why this decision has been made, referring to the specific circumstances of the case and taking account of the principle of evidential flexibility in published Home Office guidance.
5. Specificity – RFI’s should make reference to the specifics of the applicant’s case and previous submissions, not general pro-forma requests.
The report can be read in full here.