Equality and Social Justice Committee

Our substantive issue this morning is the EU settlement scheme and citizens' rights after Brexit. For our first evidence session, I'd like to welcome Rhys Hughes-Evans, the service manager for Settled, and Kate Smart, the chief executive of Settled, as well as Kezia Tobin, the head of policy and advocacy on behalf of the3million organisation. So, welcome, Kezia. So just to start off, how do you support European citizens in Wales? And perhaps I could start with Kezia—it's always more difficult to bring in people online.

11:30Watch

Equality and Social Justice Committee, 1 July 2024 | Open Senedd

Kezia Tobin

Thanks. You've kind of dived straight into one of the groups of people that are struggling the most with the issues that we see with the settlement scheme as a whole, and I think, as Rhys and Kate have already touched on, the lack of digital literacy is a real concern. The current form of digital immigration status that has been rolled out, in the form that it has been rolled out, is really problematic across the board, but it's particularly problematic for people who have poor digital literacy skills, and the Roma community is, of course, one of the key groups that struggle with that. And that's because it's not just a question of being able to access digital immigration status, but because of everything else that flows from that. It has a direct impact on people's ability to access work and to accept benefits, as Rhys has already said. And what we're seeing at the moment is that—because you started by talking about the number of people who've actually been granted pre-settled status, whether their applications have been successful—is a lot of people who are coming up to the point now of the five-year mark, so they're able, at the moment, to apply for an upgrade to settled status, and what we're seeing is that a lot of people who struggled to prove that they were already entitled to settled status when they made their initial EUSS application are struggling at this stage as well. So, there are many people who may well have been in the UK for many, many years and actually ought to have been granted settled status from the off, but, at the point at which they made their initial application, they didn't have enough of a footprint to show that they had been in the UK that long. So, what the Home Office did was they granted them pre-settled status instead, but, of course, at the end of the next five years, those people are having to prove again that they've got that footprint, and they're really struggling. We've seen quite a lot of people who've contacted us to let us know about that. It's particularly relevant when looking at the Roma community, because—. There was a report that was published just in May by Mihai Bica from the Roma Support Group and Owen Parker from the University of Sheffield. I can put a link to that report in the chat—if that's acceptable, if that's possible, I'll do that—because it's a really insightful report that I would really recommend that you take into consideration. And one of things—. I've put it in the—. Oh, sorry, I've only sent it to—. No, I've not sent it to anybody.

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Rhys Hughes-Evans

Yes, of course. So, obviously we do a lot of work with partner organisations and other services that may come into contact with people who might need support with the EU settlement scheme, so we do a lot of stakeholder engagement to try and spread the word of the issues that are still impacting people to do with the EU settlement scheme. We do have a slight comms budget, so we do engage with social media, advertising; we try and get printed publications distributed as much as possible, but I guess it's a good question because I think we can definitely do more, and what we could maybe do with a bit of help with is doing a bit more of engagement and spreading awareness on these issues. As Kate mentioned, awareness is probably one of the biggest problems that we're facing in Wales, I think, for numerous reasons. Services—maybe historically Wales is not great; immigration advice provision has led to a kind of sense of, or just lack of awareness that these issues exist within statutory services and also within third sector organisations that don't particularly deal with migration issues on a daily basis. There's a lack of confidence, I think, across the two sectors with regard to migration issues in particular.

So, raising awareness is critical, and I think, if we can get maybe one thing out of today in terms of support from the committee and also Welsh Government, it's around raising awareness to people on the continued issues that exist. A few have been mentioned today, such as going from pre-settled to settled status and the challenges that people are going to encounter doing that if they don't have sufficient evidence of continuous residency in the UK. There are quite a few more with regard to late applications. You can still make a late application, but the process for doing that has been significantly tightened over recent months, and it's much harder now to make a late application that will be accepted as valid, and the knock-on effect of that is you don't receive a certificate of application. Your rights are not protected until you submit a valid late application, so you need, or we feel at Settled that people need, support to do that if there are people without status, and there will be still in Wales, and often they're people in some of the most vulnerable situations, and we encounter them—. They'll come out of the woodwork, so to speak, in a kind of crisis situation. That's when we'll encounter them, and obviously it's from our point of view better to approach this kind of issue preventatively, and that comes with raising awareness and that comes with engagement, so it's a huge focus for us. We're doing what we can, for sure, but I think there's much more we can do with that.

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Kezia Tobin

Thanks. Yes, we are seeing a lot of issues. There are some—. I don't know, necessarily, that we're seeing more of them now than we have over the last couple of years, but there are certainly very prevalent concerns that are at the forefront of people's priorities.

One of the key issues is a lack of access to welfare support for people with pre-settled status. The Government has adopted a perspective on withdrawal agreement beneficiaries that distinguishes between what they deem the 'true' cohort of withdrawal agreement beneficiaries, and then what they label as the 'extra' cohort of withdrawal agreement beneficiaries, who are people who weren't here exercising treaty rights under the old EU law framework, before the cut-off point. That has a real significance when it comes to accessing welfare support. So, although the Government says that everybody's EUSS status says it's issued under the withdrawal agreement and the official position is that people aren't treated any differently, regardless of whether they are true or extra cohort, the reality is quite different, because, at the point at which somebody comes to make an application for universal credit, for example, they, as a pre-settled status holder, are required to demonstrate they have an additional right to reside. Simply having their status isn't enough. And then, their entitlement under the old EU law framework of free movement law comes into play.

So, what we're seeing is that people who have pre-settled status have no idea, actually, whether the Government deems them to be true or extra cohort until the point at which they need support. And, at that point, the most vulnerable people, again, are the ones that really struggle to show that they were exercising treaty rights all those years ago. And there are many people who may be eligible who fall through the gap, and people who weren't exercising those rights of course also find themselves in a very, very difficult situation, and we've seen that it pushes people into destitution. It also pushes a lot of cost onto local authorities, because then they're having to deal with emergency accommodation and support for people facing homelessness. And that's something that we haven't seen any real change in the Government position on.

There's some ongoing litigation that we're also involved in, actually, on that point. But, in terms of healthcare and education, there are two other points that I'd like to mention briefly. One is in terms of NHS charges that people can face. So, Rhys talked a few minutes ago about the difficulties that people now face in making successful late application to the scheme. Of course, late applications are still permitted, but an applicant now has to show that they've got a reasonable basis for having missed the deadline. Why that is significant when we're looking at NHS charging is because, if someone incurs treatment on the NHS between the point at which their deadline passed and the date on which they made their late application, even after their application has been successful—so, it's accepted that they've had a reasonable excuse for making their late application, they're granted status—they are then still faced with the bills for those NHS charges that were incurred in their treatment between those two dates, their deadline and the point at which they made their application. And often, these are fees that are not, in reality, recoverable, particularly if you're looking at vulnerable people, and yet the debt remains for those individuals, and it's hugely burdensome and hugely problematic. And, in our view, at the3million, we can't see how making people pay those charges is really compatible with the UK's obligations under the withdrawal agreement, because, of course, if they've been granted status, the implication is that it's accepted that they were here on withdrawal agreement terms.

So, that's one way in which people's health is affected. And, again, it's the most vulnerable, usually because we're finding that, as Kate said, it's the people coming out of the woodwork now, often people who are quite isolated, who are quite vulnerable, who didn't realise that they needed to make that initial application earlier on. It's often, for example, old people who have been in the UK decades who then are hospitalised and, at that point, are told that they need to make an application.

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Rhys Hughes-Evans

If I could just add on the access to housing and welfare point, I think something that was alluded to earlier, but probably fits here, is that it can impact both vulnerable people and not vulnerable people. It's what Kezia was talking about with regard to people with pre-settled status struggling to then demonstrate an additional right to reside, which would then give them entitlement to public funds, which is benefits and also local authority housing support. We have found that there's a lack of understanding within local authorities, particularly, around these rules. There are varying degrees of understanding around what to do when someone walks through the door looking for housing support who has pre-settled status.

We have seen examples of where the decisions within those cases have gone awry. We also have a particular example—I won't name the local authority, of course—where the local authority is relying upon Settled as an organisation to almost consult on these decisions. These are housing decisions, and the local authority in these cases is the decision maker. It's possibly an indicator of a lack of in-house support or just general training within local authorities on how to deal with these issues.

I think that that's something that's a significant thing, and maybe unique to Wales as well—or maybe not unique, but possibly more heightened in Wales—considering we have a dispersed migrant population and some local authorities will be much less familiar with these cases if there just aren't that many people within their constituency who are migrants, I suppose. That's definitely an issue for vulnerable people, but also people who wouldn't really fit into those vulnerability categories but by virtue of being a pre-settled status-holder are almost a little bit vulnerable in that sense, because they don't have the same entitlement to public funds as someone with settled status or a British citizen.

On the second point on late applications, I think vulnerability, at this point, so far from the deadline for the EU settlement scheme—. With regard to late applications, almost all the cases that you've got left are vulnerable cases, by nature of it being so far away. Various different circumstances have led to the application not being made until this point, and often that is different types of vulnerability. We don't see a lot of simple late applications any more, and that case will be complex for one of a variety of reasons.

To add onto that, we still do see cases of people who you wouldn't necessarily class as vulnerable or fit into these vulnerability categories but who have been in the UK or been in Wales for 20 or 30 years, and basically thought that it just didn't apply. They've got indefinite leave to remain, and the sense is, 'None of this should apply to me, because my status is secure', which I think is an understandable sentiment, but also something that again speaks to possibly a bit of a lack of awareness. We see both, basically. Their status, then, without having status, means that they're by nature in a vulnerability category, because they don't have access to any associated rights.

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Kate Smart

I'll take that one. We've been funded by the Welsh Government since the beginning, really, since the settlement scheme was announced in 2019, and we're extremely grateful for that support. The Welsh Government has been one of Settled's most loyal funders all the way through and continues to be, and we are really very grateful. This year, we have had £100,000 from the Welsh Government, and it was the same last year, and last year it went up quite significantly from what it had been previously. That work is covering advice and outreach and a bit of management. It's not covering our office—it doesn't pay for any office costs. It doesn't pay for any communications work. We have, last year, secured funding from the Home Office for the first time, so we are now the Home Office provider of advice in Wales as well. We're based in Wales, but we're UK wide, so we have some funding from the Scottish Government for providing higher level legal advice in Scotland, and then all of our other funding is from just charitable fundraising from trusts and grants and foundations, as most charities do.

Your other point was about the training courses. The Welsh Government—it was a couple of years ago now—approached us and asked if we wanted to tender for a very intensive period of running training courses for local authorities, which we did. And then, the second year, they asked us if we wanted to redo it, and we said no, because even though we'd done all the prep for year one—it's always hardest to do it in year one, isn't it—and although it was a good experience for us and we were glad to do it, and we got very good feedback from the people on the courses, it was just too intensive in terms of the impact on us for the funding and the fact that the timescale was very squeezed to run so many courses in a tight timescale. We definitely see a need for training in local authorities, but I think something that could be paced so that it's something that maybe local authorities could dip in and out of longer term, rather than saying, 'We've got some funding, please can you run it now?' would be really helpful.

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Kate Smart

Shall I make a start? We've got a bit of a tag team going on here. We have quite close connections with our grant managers at the Welsh Government and have had throughout. We have quarterly meetings, for example, and sometimes a little bit of meetings in between. There's always been a standing forum that the Welsh Government was running around EU citizen issues and the EU settlement scheme, and we attend those meetings as much as possible.

One of the challenges is that, of course, interest dips in these kinds of issues, so my sense of it is—and this is just a bit anecdotal—that those meetings used to maybe have a bit of a higher status and be a bit better attended than they are now. In some of those meetings that I attended, going back a few years, actually they were an incredibly important way of holding the Home Office to account, because the Home Office would come to those meetings. And, in fact, you could get a better dialogue with the Home Office in those meetings that were hosted by the Welsh Government than some of the other forums that are happening UK wide, because there was no escape for the Home Office in those meetings. But if the Home Office don't come anymore, then obviously those meetings are less influential.

We've participated in consultations and there was an integration framework development process of meetings that I was part of. And, really, anything that the Welsh Government is organising, if they ask us to be part of it, then we're very happy to be there. I think one of the real strengths of Settled is that it's operating right across the spectrum of society, so we have a lot of grass-roots links with communities, working in all different languages, but also we're really well respected and have a lot of contact with the EU delegation, so we're probably talking to the EU delegation about once a week and meeting with them about once a month. And we also meet with a lot of the different embassies of member states, quite often. And so, being a bit of a bridge between the Welsh Government and the EU delegation and helping with that glue is really helpful, I think.

Similarly, with the Home Office, Settled is probably speaking to the Home Office every day about cases, and that relationship with the Home Office has been long-standing since 2019, but is closer now because we are their grant-funded organisation for Wales. And similarly, if we can, we're very keen to be helpful in terms of helping the Welsh Government to talk to the Home Office, if that's needed. So, yes, we're very grateful for the support that we get, and where we can help to build those bridges, because this is our day job and we do it all the time, we're very keen to do it.

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Kate Smart

As Kezia said, the big win for the IMA has been the court case where they challenged the Home Office on the pre-settled status. That's a really significant piece of work that we're all very grateful for. I think, that aside, part of the challenge is that the IMA is reliant on people complaining and collecting evidence from complaints, and Settled is extremely busy. So, UK wide, we're getting 200 inquiries a week from people with concerns about their situation, but the number of those people who, having come to us and we've resolved their case, then want to go and tell the IMA about it is minuscule, really. People can't be bothered to go and tell the IMA about their problems because they know that the IMA is not immediately going to resolve them. And therefore, inevitably, the IMA is under-representing the scale of problems. So, when the IMA then talks to the Home Office, they'll say, 'Well, we've had hardly anybody contact us this month', whereas of course what Settled is seeing is hundreds of people contacting us. So, I think that is a problem.

One of the conversations that we've been trying to have recently with the IMA—and I'm meeting with their chief exec next week—is they set the—. And I think this is Kezia's point really. They're cautious, and they set the evidence bar high. So, you know, even if they get some complaints about an issue, they say, 'Well, we haven't really had enough people come to tell us about this point for us to feel that we can do something about it.'

And the point we want to make to them is that, actually—and this is picking up on what Julie was saying—the Home Office are reasonably receptive. I don't think the Home Office want to have any problems around EU citizens' issues. I think the Home Office see the EU settlement scheme as a very good news story for the Home Office. They don't really want there to be problems. Therefore, the Home Office are quite receptive when you point out a problem to them to try and fix it generally. And the IMA could be a bit more proactive, I think, in raising issues even when they haven't been given a mass of examples, and say, 'Well, look, we've heard a few examples, and that's sufficient for us to raise it with the Home Office.' And I think they could go a bit further down that road.

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Rhys Hughes-Evans

I think, firstly, having a stronger presence in north Wales would be a really key aspect, because we know that there's a large Polish community, there's a large Bulgarian community in Wrexham and Flintshire. They particularly are counties with a large EU community in them, and I think we've got links there, but we don't have a physical presence. And for a team that's all based in south Wales, logistically it is more difficult. Face-to-face support is 100 per cent needed, and we need people on the ground, working in communities to deliver that advice, especially when you're working with vulnerable customers, the Roma community, et cetera—that face-to-face support is vital. So, for what more can be done, getting a presence in north Wales, whether that be a staff member or a centre, for example, that would be, I think, significant.

More generally, though, I think, when we're looking at what can be done for EU citizens in Wales, I think a lot of this could be potentially solved with data. And, specifically, people who've got pre-settled status at the moment who will need to go to settled status at some point, the Home Office and the UK Government have data on all of those people, and especially all of the ones in Wales. It is something that we've raised before to the Home Office directly, but I think it's something that maybe we could push for a bit more, and maybe the Welsh Government could support us in doing that, in sharing that data somehow, or at least in communications to those pre-settled status holders in Wales, who have reached the point of their pre-settled status technically expiring, but also then being extended. They are a cohort of people who will need to make an application for settled status, and they're a cohort of people that the Home Office could directly contact and tell them exactly what is available in terms of support in Wales for them, i.e. Settled. Also, I must mention Tros Gynnal Plant, who we're in a partnership with for the Home Office project. So, that is the free advice that's available in Wales, and I think things could be done more there to direct people to the support that is available.

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Kate Smart

Yes. So, the High Court ruling was clear that there shouldn't really be that distinction, that people should really just roll over into settled status, and the Home Office is very resistant to agreeing to that, possibly, and I've heard people discussing this and suggesting that it's because getting pre-settled status was relatively easy, and therefore the Home Office wants to build in some checks and balances later down the line. So, the Home Office's response has been that they will allow some cases to be automatically transferred, if they've got the data in HMRC records and so on, and then otherwise, people are now—. Well, initially, they were given an extra two years, and now they're going to be given an extra five years, extending the time of their pre-settled status in order that they can then apply for settled status later on. One of the difficulties that this is going to cause is there's a lot of uncertainty about where this leaves people in terms of the amount of time that they're allowed out of the UK. So, pre-settled status came with a condition that you could only have a certain amount of time out of the UK if you wanted to go on and get settled status at the end of it. And, by saying to people that you've got two years or five years now to make that case, they've not changed that rule about how long you can be out of the UK. And as one of our trustees, who's Italian, said, 'It's kind of like locking people in the UK, isn't it?'—that, actually, the risk is that people will continue to live here, and they might have broken the condition for how long you have out of the UK and, therefore, they still won't qualify. So, it's a muddle.

The other side of it is that people with pre-settled status as a result of all of these changes have been sent a letter. They've all been sent a letter and, because the whole thing is so convoluted, that letter is incredibly long and legal, and organisations like Settled are now being inundated with people saying, 'I've got this letter and I don't understand it.' So, we've got some people saying, 'I've got this letter and I think it means I don't need to apply for anything anymore.' We've got some people saying, 'I've got this letter and I think it tells me I've got to leave the country now', and all sorts of things in between. We've said this to the Home Office and they said, 'Well, the situation is so complicated we had to put all of the scenarios in the letter to cover ourselves legally.' You can see why they would say that, but it is causing a lot of confusion. So, they're kicking the can down the road. Who knows? There may well be further changes. With a new Government coming in, there may well be further changes to it, but that's the situation at the moment.

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Kezia Tobin

Thank you. If I can just come in on that other point—I'm conscious of time; I'll be quick—that I had forgotten, which was indeed about this issue of the two-year extension being granted to pre-settled status holders, and I think it's really important to emphasise that it's not the case that, at the end of that two-year extension, somebody rolls over into settled status. What the Government has said is, as Kate said, that they've kicked the can down the road. They've extended pre-settled status but they've not given any certainty to people about what will happen at the end of that. Recently, they've said they're going to start extending it not for two years, but for five years. But, again, there's no clarity at all for people about what happens at the end of that five-year period, particularly for people who are struggling to evidence the fact that they've got this continuous residence, which means they'll be eligible for 'settled'. So, what happens to those people?

There is also a lot of confusion for people who might have already got the two-year extension now that the five-year one has been extended. It's not clear whether their two years will be converted to five or not. So, there's a real lack of clarity. And it's true, of course, that it was relatively straightforward to apply for pre-settled status when the scheme opened. But that was a decision that the Government chose to take, because they had adopted this constitutive scheme, and so, for administrative reasons, of course, it was much easier to simply require a proof of straight residence rather than anything beyond that. But now they're really raising the bar to try and, it would seem, exclude as many people as possible, to be frank, because it's clearly not being rolled out and designed to be a straightforward process because of this shifting, raising the bar, and evidential threshold that people are having to meet. It's very difficult for people, particularly because those people who are affected are the ones that, of course, have already got their lives here, that they are established here now. So, in terms of the future of the EUSS, I would say one of the key things that we need is more certainty and clarity from the Government about what really is going to happen to people further down the line. And it's not the case that applications are drying up, because even in the last quarter the Home Office statistics show that there were 174,000 applications to the scheme. That just goes to show how very much this is not an issue that is going to go away quickly.

And in terms of the very last question, about what the Senedd could do, I would just reiterate what I said earlier about how helpful I think it is to have letters from the Senedd and other devolved Governments to central Government, highlighting the key issues of concern, which are the ones that we've all set out in this session.

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3. The EU settlement scheme and citizens' rights after Brexit: evidence session 2

Welcome back to the Equality and Social Justice Committee and to our second evidence session on the EU settlement scheme and citizens' rights after Brexit. In this session, we are going to be taking evidence from Mihnea Cuibus, researcher in migration at the Migration Observatory at the University of Oxford, and Fiona Costello, a research associate at the EU Migrant Worker project at the University of Cambridge. Thank you very much for your presence today. I wonder if you could briefly, both of you, summarise how you think the EU settlement scheme has developed since its launch. Mihnea, you're on the left of the screen for me, do you want to go first?

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Mihnea Cuibus

Thank you so much for your invitation. I think it's important to recognise that, on the whole, it's fair to say that the EU settlement scheme has been a success and, for most of the people concerned, it has worked in a fairly straightforward manner without any significant issues. That being said, we do see issues, particularly when it comes to certain vulnerable groups, and I think there are two main aspects to that. One is that people struggle to apply or to obtain status for a variety of reasons, and here I'm talking especially about late applications, so those submitted after 30 June 2021. On top of that, there are also a number of issues related to the operation of the system—problems with digital status and the Home Office systems behind them. And also there are a number of questions that still remain unanswered, especially about pre-settled status holders and the future of pre-settled status holders. Although recent changes brought in by the Home Office to extend these statuses have somewhat addressed our concerns, there are still a number of questions remaining. So, on the whole, I think it's a fairly successful scheme, but there are a number of issues that are still worth discussing and that are still very important, even three years after the initial deadline.

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Hopefully we'll pick them up in the questions going on. Fiona Costello.

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Fiona Costello

Thank you very much, and thank you for the opportunity to be here today. I agree completely with what has just been said. I think, broadly, we can see the settlement scheme has been a success for many—those for whom it worked well, who had the digital and administrative skills, and the English language skills, of course, to be able to navigate the scheme. But it's very important to remember those who are more vulnerable, for whom the scheme has been a challenge and is still a challenge, and they include younger people, older people, children in care or who are looked after, other people with care needs, the Roma community, people who are homeless, victims of domestic abuse, et cetera.

No such scheme has ever reached a 100 per cent application rate at a global level, but looking at the numbers at a UK level, even a 1 per cent non-application rate is still a huge number of people. We may not know, as Kate from Settled said in the previous session, for maybe a generation who hasn't actually applied yet to the scheme. And equally, the funding that has been provided by the Home Office to help people make these applications has been crucial, but we can see that that funding is decreasing as time goes on, and it's not guaranteed beyond March 2025. So, I think, in terms of the evolution of the scheme, that advice, access to advice, is really important, particularly for those who are more vulnerable.

And then finally I'll just say also that linked to the funding decreasing is this idea or the assumption that the need is decreasing, but actually, while there are still groups, as I've just said, who need to apply, there are also 2 million people with EU pre-settled status who may need to apply again. So, the scheme is very much still not done. And actually I would also say that the application is the first bit of the scheme; you then need to be able to manage it and interact with it and download your share code as and when you need to. So, it's an ongoing lifetime commitment, really, that you have to your immigration status.

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Thank you. Julie Morgan.

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Thank you very much. What does the data tell us about who is applying to the EUSS? Mihnea, shall we go to you first?

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Mihnea Cuibus

In terms of the overall applications, we've seen something to the tune of 7.9 million applications across the UK. Around 2 per cent of those applications were submitted from addresses in Wales, so around 123,000 applications were submitted in Wales. The vast majority of those have already been concluded. At the end of March, which is the last point at which we have official data, there were somewhere around 1,600 applications pending in Wales. We do see a wide variety of applicants for these schemes. I think it's important to talk about children who are applying for these schemes. As Fiona mentioned, those can be in a particularly vulnerable situation. Somewhere around 18 per cent of all applications that have been submitted were submitted by children under the age of 18, so that's somewhere around 22,000 applications. In Wales, we did see many fewer applications from people aged over 65. In general, across the UK, the EU population tends to be of working age, tends to be quite young, so we've only seen around 2 per cent or 3 per cent of applications coming from people of retirement age.

Besides the age breakdowns, the nationality breakdowns are also important. While we did see applications from a very wide range of nationalities—EU 27 applicants, but also those from European Economic Area states as well as non-EEA applicants that are family members of EU citizens and the like—a lot of the applications have actually been concentrated and coming from newer member states in central and eastern Europe. We've seen the most applications on the whole from Romanians—around 1.7 million applications from Romanians—we've seen 1.2 million applications from Polish nationals, and we've also seen a large number of applications from Italians and Bulgarians.

The top in Wales is relatively similar to the one across the UK, with the exception that Polish nationals rather than Romanians have been the largest group of applicants. We've seen around 34,000 applications from Polish nationals, compared to somewhere around 22,000 applications from Romania. That was followed by Bulgaria with 9,000 applications. So, we can see around half of all applications that were submitted in Wales came from these three nationalities, which is important to keep in mind, because our research has shown that a lot of these eastern European nationals tend to be concentrated in lower-income work, and they're often more likely to be in situations that make them more vulnerable to missing out on the EUSS.

13:34Watch #Official Record

Thank you very much. On the 18 per cent that you said were children, was that in the UK or in Wales?

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Mihnea Cuibus

The percentage is very similar in Wales and the UK. I think it's around 18 per cent in Wales and around 17.5 per cent across the UK, so very similar figures.

13:37Watch #Official Record

And how many of those would have been care-experienced children?

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Mihnea Cuibus

I'm afraid I don't have those numbers to hand, but I do believe that local authorities have been keeping track, and I'd be very happy to track these down for you after the hearing.

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Thank you very much. I don't know if Fiona has got anything to add.

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Fiona Costello

I don't have the looked-after children figures to hand, but I know the independent monitoring authority has done quite a lot of work around this, and also at a Wales level as well. All of the local authorities have now been graded green in terms of that outreach to looked-after children and children in care, because it was a significant issue while the scheme was still open. I'd just add to that that, first of all, it was quite a missed opportunity to collect the data on ethnicity and gender as well as nationality data on the EUSS. I would say that, because I'm a researcher, but it would have been great to also have that fuller picture of who are the communities and the people that are making applications.

On the 3 per cent of applications from older people, I think this is a real issue that maybe hasn't been looked at as much as it should be, both in Wales and at the UK level. The EU settlement scheme application deadline was also running alongside the global pandemic, so we had a lot of services that went online, so you may not have been able to get face-to-face advice—for older people who may be in care or have dementia et cetera, who may not have been able to access the support that was needed. So, I do think this is a group that it would be beneficial to have more focus on, moving forward.

I think the earlier session also mentioned people who'd moved to the UK maybe after world war two, et cetera, or those who may already have permanent residency. We saw, post the referendum in the UK and before the EUSS was introduced, a significant hike in applications for the EU permanent residency scheme. People didn't know what was going to happen, so they looked to guarantee their rights in a different way via a route that was still open. Of course, that permanent residency card then became void and you needed to make an application through the settlement scheme. But we have seen cases of people who've lived here for quite a long time thinking, 'I have permanent residency, the settlement scheme doesn't apply to me.' I wonder if there are many people in that older group who may also be in that position: 'I've lived here for such a long time, this isn't relevant for me, I already hold permanent residency.'

I think the late applications as well are worth mentioning in terms of who's been applying, because they have continued at pace since the deadline closed. There hasn't really been much of a drop-off in applications, and I think the average is about 50,000 a month at a UK level. Actually, in Wales, I noted that, since the annual report was finished at the end of December 2023, in the first quarter of 2024 you had a 10 per cent increase in late applications, and also an increase in rejected applications, invalid applications. So, you can see that late applications have continued to the scheme, and, actually, now that it's become more difficult to make a valid late application, we're seeing these rejections happen in larger numbers, as well.

Thank you.

13:41Watch #Official Record

Just finally, are the rejected applications being taken note of? Do we know who these individuals are so that they could be spoken to, in theory, or is that not published data?

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Fiona Costello

I don't actually know. Most of my work is in England, and specifically in the east of England. I work with a charity there that does front-line advice. Normally, people will present to that charity after they get that rejection and now look for support to submit another application. So, that's, at a local level, how we become aware of people, and probably the same is happening with the advice centres in Wales. But, of course, then they've already had—. What used to happen was that people would submit another application, previously, once they were rejected, when it was, in a sense, easier to do so. But now that's not the case, and people find that they can't submit another application as easily, they can't receive their certificate of application and then the domino effect on the rest of their lives happens when they can't work and they can't rent, et cetera.

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Thank you. Carolyn Thomas.

13:42Watch #Official Record

Thank you. Hundreds of applications are still being made from Wales. Do you know why this might be? Why do you think it could be?

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Mihnea Cuibus

I'll come in on this one. You're perfectly correct, there are still around 600 to 800 applications being made every month from Wales, and the numbers haven't really been going down over the last year and a half. We've seen consistently this pattern. I think it's important to make a distinction between late applications on the one hand, and applications submitted after the deadline in general. The 600 to 800 applications a month figure, that's for all applications that have been submitted after the deadline. But the vast majority of those will actually be repeat applications, so mostly people who already have pre-settled status applying to move on to settled status.

A subset of all these applications, one that's smaller than that of repeat applications, is what we would actually call late applications, which are applications submitted by people not already holding a status under the EUSS. At the UK level, those are around 10,000 to 15,000 a month, and have been in the last year or so. Out of 40,000 to 60,000 applications a month, about 10,000 to 15,000 are actually late applications. Unfortunately, the Office for National Statistics doesn't release any breakdown for Wales, so we're not aware of how many of those 600 to 800 applications are actually late applications. It would be very important to have more information on this issue.

As to why they are coming in, there are a number of reasons why people apply late to the scheme. There's a number of people who are simply not aware of the need to apply, as Fiona was mentioning—some people who have been here a long time. There are also situations where people found themselves in very difficult personal circumstances, so long-term illness for example, or very specific vulnerable positions. We know that a number of people applying late to the scheme are actually victims of domestic abuse or even modern slavery. So, there are a lot of specific motivations for applying late.

One final thing would be to say it's true we haven't really seen late applications level off significantly, but over the last four to five months, we've actually seen the average across the UK go down from that 12,000, 13,000, 15,000 a month to below 10,000 month, so, I believe, in March, we saw somewhere around 7,000 late applications. It is possible that some of that has to do with the reluctance of people to apply under the much stricter rules that were introduced around the validity of late applications in August 2023, when the Home Office decided to increase the stringency of those requirements.

13:42Watch #

Very good. Thank you. Joel James.

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Thank you, Chair. And thanks ever so much for coming in this afternoon. I just want to ask you a quick question. You touched upon it briefly about the digital status and, obviously, those are issues that have been brought up with this committee in the past, and I just wanted to get your ideas of the issues that might be arising now that we need to also focus on. Is that something that your research is picking up, some issues like it's said that the digital status isn't an immigration document in digital form, it's something completely different, and that's causing a lot of issues? I just wanted to know if there are other issues we should be looking at. Thank you. I don't know who might want to go with that first.

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Mihnea Cuibus

Fiona wants to jump in.

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Fiona Costello

Okay. Yes. Thank you very much for that, and thank you for the clarification on the late applications, I should've set that out more clearly.

So, digital status, I mean, certainly, the work that we've been doing—. We've been working particularly with people in low-paid work, what's called low-skilled work, and, for this community, English language skills, about 70 per cent report very low English language skills and about a similar number report low digital skills. So, the digital nature of the status and the online nature of the status is indeed a significant problem. We recently ran a survey with about 400 EU nationals, of which about 14 per cent self-identified as Roma, and the majority who had applied via the settlement scheme were unable to generate their own share code and were very reliant on children or other friends and family, or if they were lucky enough to have an advice organisation in their local area who could help them with their application, they would go back to that. They're very reliant on that advice organisation to continue to help them to navigate the scheme. And that's kind of okay if you have time and, obviously, you want to decrease that dependency on others, but if you're in a time-critical situation, for example, if you're at the airport or you need to provide a share code to your employer or your landlord, it then can get you into significant difficulties if you have a status that's only online, but you're not able to access it. So, some campaigning organisations have called for a kind of offline hard copy, similar to a COVID pass, that somebody would be able to have to hand, should they not be able to, in that instant, navigate their online-only digital status.

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Thank you. Mihnea.

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Mihnea Cuibus

We also ran a survey at the end of last year at the Migration Observatory. We surveyed around 5,000 individuals online, looking at their experience with the UK immigration system, and asked them a number of questions specifically related to digital status and we would be happy to share the final report with the committee. But I think one key thing that comes out is, again, this pattern where, for the vast majority of people, this has been a pretty smooth experience and they haven't experienced issues, but we do see a certain consistent minority, around 10 to 15 per cent of respondents, saying they have encountered issues when trying to prove their status using the digital systems. And I suppose one interesting thing that comes out of it is that almost half of those who said they've had issues proving their status said that the person who was checking, so the employer or landlord, was actually not satisfied by what they were seeing there, and we saw that happen more often for those who had digital-only statuses, like those under the EUSS. So, this might be an issue more of ensuring that everyone knows what the rights of individuals are, because while some people do argue that bringing back a paper-based document would be good, it's unlikely that the Home Office will be doing that. The EUSS was the first national visa scheme that was digital only and it was also supposed to be a pilot for gradually moving the entire visa system to a digital-only format. So, I think it's more an issue of making the best out of this transition, rather than expecting for it to be delayed.

13:48Watch #Official Record

Just one last question.

Yes.

Thanks, Chair. With regard to this—I don't know if this is a little bit off topic—but you mentioned there about looking for an offline hard copy, and issues with employers then not necessarily understanding, but not satisfied with the digital thing. Have you had experience now with—? Because they're rolling out the biometric residence permit cards, and they're all going to be digital going forward, have there been concerns expressed about those? Because I know from my own experience, where people have had the BRP cards and they have an expiry date, that doesn't mean that their immigration expires at that date, that's just when the card ceases. Have there been issues highlighted to you there, then?

Mihnea Cuibus

There was a very similar issue, actually, related to pre-settled status holders. So, a lot of organisations, including the IMA, were arguing that that's actually a problem, that landlords and employers were reluctant to hire or take someone on as a tenant, because their expiration date was too close for pre-settled status. So, that's something that the Home Office seems to have addressed. So, this May, they announced that there won't be an expiry date shown on pre-settled status holders when they show that to the employer. So, again, I think it's about making sure that the design of the scheme is the best that it can be.

More generally, there are, of course, concerns about the move to a digital status. And some people will, of course, struggle to do that, so older people, people with low digital skills, marginalised communities, like the Roma. But that being said, I think, it's a matter of making sure that that Government support is there and that those kinds of organisations are there to provide support for individuals who find themselves struggling with these things.

Thank you. I think we'll have to move on. Jane Dodds.

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I'll be asking my questions in Welsh. And this is about support that this Government in Wales and also the UK Government provide. Do you have an opinion, please, on the support that's provided? And also, do you have any experience or an opinion on what else those Governments can do in terms of supporting European citizens here in Wales? Thank you very much. Who wants to go first? Mihnea, do you want to go first?

Translated from Welsh13:52Watch #Official Record

Would you like to go first?

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Mihnea Cuibus

Of course, very happy to. So, I think, on the whole, the approach taken by the various Governments in the UK—and I'm talking about the one in Westminster, but also the devolved Governments in Scotland and Wales—the approach has been fairly similar, so providing grant funding to different civil sector organisations. Oftentimes those organisations were receiving support from multiple Governments. We've seen the UK spend around £32 million since 2019. So, last year, I believe, in April they extended that funding by another two years, going into spring 2025, and earmarked another £2.5 million for that. Scotland and Wales both spent a little over £2 million in total. The Scottish Government last extended its funding in May of last year, by around £200,000. And that, of course, is very similar to what we've seen in Wales. I think, as the discussion has made obvious, it is essential to have those organisations to make sure that those vulnerable groups have some kind of support available to them when they fall through the cracks of the system. I think it's absolutely essential.

If anything, one thing that does come up in conversations with organisations is the lack of predictability. And I suppose there's been, to a certain extent, a sense in Government that the EUSS will be an issue that will gradually go away. It's been a long time since the scheme was introduced. But, as mentioned earlier, these problems will continue to be here for a very long time, and I think it's very important that that certainty is available, both for these groups and for the organisations that are supporting them. So, if there's any work to be done, it's probably with regard to that certainty.

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Thank you. And Fiona.

Translated from Welsh13:55Watch #Official Record

Fiona Costello

Thank you very much. Yes, I agree with that. I think the provision of advice and the funding that's been made available has been a lifeline. What we can see though, and something to potentially keep an eye on, is that, as applications become more complex, the level of expertise needed to provide that advice also increases. So, previously, most EUSS applications could be done at level 1 OISC accreditation, and I think now these more complex late applications will need a level 2 advisor, maybe above level 3. So, it's worth looking again at mapping out what free immigration advice is available and what's being funded, but also what level of accreditation is being offered in order to match the needs. While the need decreases, the complexity increases, and that increases the accreditation that's needed to offer that advice, which is really important.

The other point, which we've touched on a little bit already, is, obviously, the EUSS is an individual status, but landlords, employers, statutory services all interact with the status on a daily, weekly basis. And, actually, I think more training and more information for this group of people, as well as how to look at a share code, what it means, what titles and what rights are attached to each status, would probably be really, really helpful. I remember helping a landlord in Great Yarmouth in Norfolk who was an EU national, but he was also a landlord to other EU nationals, and he only had a Nokia 3210 phone, and he was struggling to make his own application, because he simply didn't have a smartphone and he didn't use the internet, so checking his residence status was also going to be really, really difficult. So, I think looking at how we support this group of individuals as well, because it makes life easier for both sides and for both groups.

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Thank you very much, Chair.

Translated from Welsh13:56Watch #Official Record

Thank you. Sioned Williams.

13:56Watch #Official Record

Thank you very much. Could you give us your opinion on the changes that have been made to the EUSS?

Translated from Welsh13:57Watch #Official Record

Mihnea Cuibus

Of course. There's been a number of changes introduced. I think the most significant ones were in response to the High Court decision in February 2023, which stated that pre-settled status holders cannot lose residence rights just for failing to apply for an upgrade to settled status after five years. So, that has prompted—. The Home Office didn't appeal that decision, so it's prompted them to respond by deciding to introduce automatic extensions of pre-settled status by two years. They introduced that in July of last year. And they've also promised to look at automatic admin-based upgrades from pre-settled status to settled status, and they are supposed to start doing that later this year, although it's been some time since we've had an update on that.

On top of that, the IMA and a number of organisations argued that those changes don't really go far enough, and so there's been a number of other changes introduced in May of this year. The extensions go from two years to five years for pre-settled status holders, and also, as mentioned earlier, the expiry date has been removed from the page that shows those share codes to employers. And for landlords, there's also no more need to do work or tenancy checks for those who keep staying in the same job, or in the same accommodation, so that takes a bit of pressure off pre-settled status holders.

There's no question that these changes have been positive for those with pre-settled status, however, there's a number of questions that still remain open. It's good to have these extensions going on, and that they've gone from two years to five years, but the question is still open on what happens to pre-settled status holders after those five years. There's no plan currently in place for that. There are also questions about what happens to those individuals who've had their pre-settled status extended by two years, between May of this year and July of last year. So, will those extensions automatically go from two to five years, or will they not? We're still not sure of that. And then the automated upgrades, which are due to come online this year. Now, this is, obviously, an improvement, because is ensures that everyone who has that paper trail of continuous residency for five years automatically switches, but a large number of individuals won't be able to have that kind of paper trail, so a lot of individuals will still be missed by the system of automatic upgrades. Once again, we see that certain groups that are most vulnerable are again most likely to be missed by these automatic upgrades. Again, children are unlikely to leave that kind of work paper trail. People in informal work are much more likely to be missed by this kind of system. So, again, even though for a number of people this this solves the problem of moving from pre-settled to settled, there's still a large population that will have to eventually apply themselves to have their status upgraded, and that's a big question for the future, I think.

Thank you very much. And Fiona, would you like to give your opinion on the effect of the changes?

Translated from Welsh14:00Watch #Official Record

Fiona Costello

Thank you. Yes. So, I think, again, obviously the extension is welcome in terms of people not facing that kind of expiration of their status, but it does kick the can further down the road from what was two years to five years, and we may still be faced with a group of people—. What happens to them at the end of five years if they didn't know they needed to upgrade at any point during that time? And of course, the High Court ruling also said that permanent residency is automatically accrued, so how do we mesh those two positions, where somebody would still need to have made an application, or does their pre-settled status still expire at the end of that? So, I think some clarity around what happens to this group would be most helpful.

As was rightly outlined, many of those that we've been working with in our research aren't generating that digital footprint that is needed. People are on zero-hour contracts. Many people don't have tenancy agreements. They pay cash in hand. They're living in a house of multiple occupation. Their name isn't on any of the utility bills. And so those automated checks just will not generate the digital footprint that they need. And equally, for the extension of pre-settled status, the Home Office have said they will start to do checks on continuous residency, and I also fear that that same group of people who aren't generating that digital footprint may fall foul of being able to prove their continuous residency in that way, in which case I believe they would maybe get a notification. For the automatic upgrade, they would get notification of that, but you also need to be able to manage your status and make sure that your details are up to date, your phone number, your e-mail address et cetera, in order to receive that communication, notwithstanding that you may not speak English and you may not be able to read the communication that comes forth.

14:00Watch #Official Record

Thank you. You've mentioned the research that has been done and that big survey you've done, Mihnea, in terms of the impact of the changes and the situation of people. Is there anything that you haven't mentioned so far, anything that you've found out from the research that you can share with us about the impact of the changes?

Translated from Welsh14:02Watch #Official Record

Mihnea Cuibus

I think one thing that hasn't really come up that much is the issue of absences from the UK. So, of course, for everyone who has pre-settled status, perhaps the most important issue is that of upgrading, of being forced to upgrade and the High Court decision and all that's been focused on it. However, there's also the fact that those who have pre-settled status but leave the UK for over six months in a one-year period would, in theory, no longer be eligible to keep their status, and there's a question as to what is going to happen with these individuals. We know that the population holding status under the EUSS is significantly larger than the EU population that is actually living in the UK. Now, the exact difference there is a bit uncertain, but the numbers are significantly larger. It does imply that a significant number of people who hold status, who hold pre-settled status, were, at least at the time of the census, which is the best data we've got, actually living outside of the UK. A significant number of them may no longer meet the residency requirement stated under pre-settled status.

We don't know currently how many individuals have had their pre-settled status removed. My general understanding is that there are no significant numbers and most people still hold their status, but the question is what is going to happen in the future. There were some indications that the Home Office, once it begins doing those automated residence checks in order to upgrade individuals to settled status—. There were some indications that they might also use those residency checks to see if people still maintain their eligibility criteria, and potentially inform people that their pre-settled status has been revoked, of course, subject to appeal. But, again, we're still very much waiting for confirmation from the Home Office, but this is potentially an important uncertainty there.

14:03Watch #Official Record

Diolch. Diolch, Cadeirydd.

Thank you. Carolyn Thomas.

What's your view on the future of the EU settled status, and how do you think it will develop? I'll go to Fiona first.

Fiona Costello

Thank you. So, as I've outlined, I think the EU settled status will be an ongoing application for people; they will need to maintain their status. So, it's really important that we keep that in mind. And the people that have really struggled to make their application will potentially, for some time, still struggle to be able to interact with that status, and they will continue to need help, and looking at where that funding might come from. I think also monitoring the complexity of applications and this idea of having appropriately accredited immigration advice services available for those who are struggling the most.

So, our recent survey that we undertook that had about 14 per cent of people who self-identified as Roma, actually, 25 per cent of that group of Roma had refused applications and 15 per cent pending applications. So, I think that would be my third point, that we're certainly done with the EUSS, and the future is there's still many people navigating the application process in the first instance, or applying again after a rejected or refused application.

Okay, and Mihnea.

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Mihnea Cuibus

I very much agree with that, and I think most of the uncertainty, actually, is more around pre-settled status than settled status, and I think a lot of the issues will be there. But that continuing support and, finally, the issue of making sure that everyone who has to be upgraded, everyone who has acquired residency rights, actually ends up applying. That's going to be an issue long into the future, and I think so is going to be maintaining the scheme. Of course, people with settled status who spend another 12 months in the UK are eligible to apply for citizenship, but still, even though we've seen an increase after Brexit, the proportion of EU nationals applying for naturalisation is relatively low, especially when compared to other kinds of migrants in the UK. So, there is definitely a long-term future for the scheme, and there's the question of if the majority of them will eventually acquire citizenship or not.

14:06Watch #Official Record

Okay. I'll just ask you a question regarding UK and EU relations, and also Welsh Government involvement, because I understand that they've not been able to attend withdrawal agreement meetings. So, do you have a view on this going forward, about the importance of that happening? I think, Mihnea, you're on the screen here for us, so if you'd like to go first.

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Mihnea Cuibus

Yes. Of course, these issues are more political than technocratic, so not really in our specialty, but I believe that the really important thing with this scheme is making sure that the citizen engagement is there. For example, we've done a fair amount of work with the EU delegation in London, and they work with a lot of different organisations. And I think that, beyond any kind of high-level conversations about the withdrawal agreement or anything else, making sure that those grass-roots conversations between UK institutions, civil sector organisations and the EU and EU institutions, both the EU-wide ones and the specific national embassies here—I think making sure that that contact operates is perhaps even more important for citizens who are affected by the scheme.

14:08Watch #Official Record

Okay. Fiona, have you got any comments?

Fiona Costello

Thank you. No, I would agree with that, and I think also ensuring that we're reaching those who are more under-represented, equally in research and in surveys and the IMA, who they may not be hearing from, because of their online portal that accepts English-language complaints et cetera, and how we make sure that we're communicating those who don't speak English, or who live in more rural areas and who are quite isolated, and that their views are also being represented and fed back at both levels as well.

Okay. And do you have any other views on the future of EU settled status? How do you think it will develop? I know we've discussed it quite a lot, but is there anything we've missed here going forward?

Fiona Costello

I think on that point about, obviously, upgrading from EU pre-settled status to settled status, there's a huge amount of people who will need to do that in the fullness of time, and whether or not they're able to do that via an automatic upgrade, or else they need to make that application without an automatic upgrade, i.e. apply again, it's really important to continue to monitor that as time goes on, and that's quite difficult. The thing with the first deadline of June was that everyone had the same deadline by which they had to apply, but here, with the pre-settled status and upgrading, people have their own individual deadlines, so it makes it more difficult to communicate that information, because there are so many different individual deadlines involved.

So, it's really important to think about how that communication is happening and if people know that they need to apply. And many don't know that they need to apply again, or think that, because they have pre-settled status and they're hearing about automatic upgrades, that is what will then happen to them and they're okay, for example. So, that will go on for a long time to come, and then, of course, we have future generations and children who may reach issues even further down the line. So, it's really important, I think, to take that long-term view, although that can be difficult with funding, as has been discussed, and funding might be annual, et cetera. But, on the whole, it's important to take that long-term view of the EU settlement scheme in order to avoid a Windrush situation in the future for future generations.

Thank you.

Joel James.

Thank you, Chair. And it's just probably one final question from me, really: as you mentioned, Fiona, you saw the last evidence session, where I asked about what the committee could do and what role the Welsh Parliament could play, and I was just wondering what your views are on that, if that's possible.

Fiona Costello

Thank you. Just from reading the annual reports, getting prepared for this session, I think that they are incredibly useful, and the view that the committee's taken, and the investigations that are happening, really bring to the forefront the experiences of EU citizens in Wales.

I think, again, it's thinking about the information in terms of it being multilingual: are you reaching all of the groups that you need to reach? Who are your more under-represented groups, and how do you reach those? And I know Settled have some multilingual workers, so obviously they are reaching into the communities, but I think it's really important to keep a view of that. Because of our research that we've done, the majority are non-English-language speakers. And, actually, going back to that Roma cohort I mentioned, 92 per cent were non-English-language speakers in that cohort, and over 75 per cent were unaware of their citizens' rights under the withdrawal agreement, and none had ever made a complaint to the IMA. So, I think a really important focus is keeping in mind those more under-represented groups, and particularly non-English speakers or non-Welsh speakers, and how do we reach those groups.

Perfect. Mihnea, anything you might want to add?

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Mihnea Cuibus

I very much agree with Fiona. I think it's a matter of continuing most of the work that's been done in three areas, and one is monitoring, so keeping ahead of the issues that are arising. These issues will keep popping up in different ways, and I think the work of this committee, and organisations similar to it, is essential in keeping ahead of those. I think it's important to make sure that that support is there for these vulnerable groups and these support programmes potentially go into the future with a long-term perspective. And finally, working with, as Fiona's mentioned, local authorities, because, in the end, they have a better awareness of what's happening in communities on the ground, and making sure that they're organised and really making an effort to both understand the vulnerable spots in communities and engage with certain groups.

14:13Watch #Official Record

Thank you. If there are no further questions from Members, we'd like to thank you both for your evidence. It's been a really useful session, and we'll send you a transcript of your evidence, so if there's anything that we've captured inaccurately, please do amend it. Thank you very much for your time this afternoon.

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Fiona Costello

Thank you very much.

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Mihnea Cuibus

Thank you very much.

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