The UK Government failed to fulfil its post-Brexit commitments, leaving many Europeans struggling to work, rent homes, open bank accounts, and access benefits, according to findings from a watchdog investigation.
Approximately 1.7 million digital applications by EU citizens for Certificates of Application, which confirm their rights in the UK, were delayed over a four-year period, the Independent Monitoring Authority for the Citizens' Rights Agreements has said.
Under the Withdrawal Agreement and the EEA EFTA Separation Agreement, the Home Office is required to issue CoAs to applicants immediately.
These certificates serve as proof of rights, including the right to work, rent a property, open a bank account, or access benefits while an application for settled status is being processed.
However, the IMA discovered that an inadequate number of available caseworkers at the Home Office, due to high demand, led to significant delays in issuing these certificates.
EU citizens affected by these delays were left in a “legal limbo” for months, unable to work, leave the UK out of fear they would not be able to return, open a bank account or access Universal Credit.
The IMA's investigation found that, despite the digital EU Settlement Scheme being designed to swiftly validate applications, about 28 per cent of the 1,720,714 EUSS digital applications required caseworker intervention before a CoA was issued between August 2018 and October 2022.
The peak was reached in December 2021 when the IMA reported 87,960 applications without a CoA.
There were also delays in issuing certificates for applications made via paper forms.
This was caused not only by the lack of available caseworkers but also by the shortage of those specifically trained to issue certificates for paper applications.
The watchdog has made recommendations to the Home Office to manage the system of issuing certificates more efficiently.
These recommendations include collecting meaningful data to monitor the time taken to validate applications, adopting a service standard of five working days for certificates to be issued, and monitoring performance against this target.
The IMA has asked the Home Office to publicly release its response to these recommendations within three months.
IMA chief executive Dr Kathryn Chamberlain said: “While we recognise that millions of people have applied to the EU Settlement Scheme, many of whom without issues, we realised that this issue had the potential to severely impact people's lives and their rights.
“That's why we used our powers to conduct an inquiry as we had reasonable grounds to believe that the UK may have failed to comply with the Agreements.
“We will now work with the Home Office to ensure our recommendations are accepted and implemented in full so that citizens can be assured that they will receive a certificate following a valid application to the scheme in a timely manner.”
In response to the IMA's findings, a Home Office spokesperson said: “We take our Withdrawal Agreement obligations to EU citizens very seriously, with the great majority of applicants having their Certificate of Application issued immediately following submission of a valid application.
“We have already made substantial changes to the pace and process of issuing Certificates of Application since the Inquiry took place. We will consider the IMA's recommendations and respond in due course.”
The UK Government continues to hail the EUSS as a “great success”, stating that over 7.2 million applications have been made and 5.6 million people have been granted status as of March 31.
Ten tax points to be aware of in 2026
1. Domestic VAT refund amendments: request your refund within five years
If a business does not apply for the refund on time, they lose their credit.
2. E-invoicing in the UAE
Businesses should continue preparing for the implementation of e-invoicing in the UAE, with 2026 a preparation and transition period ahead of phased mandatory adoption.
3. More tax audits
Tax authorities are increasingly using data already available across multiple filings to identify audit risks.
4. More beneficial VAT and excise tax penalty regime
Tax disputes are expected to become more frequent and more structured, with clearer administrative objection and appeal processes. The UAE has adopted a new penalty regime for VAT and excise disputes, which now mirrors the penalty regime for corporate tax.
5. Greater emphasis on statutory audit
There is a greater need for the accuracy of financial statements. The International Financial Reporting Standards standards need to be strictly adhered to and, as a result, the quality of the audits will need to increase.
6. Further transfer pricing enforcement
Transfer pricing enforcement, which refers to the practice of establishing prices for internal transactions between related entities, is expected to broaden in scope. The UAE will shortly open the possibility to negotiate advance pricing agreements, or essentially rulings for transfer pricing purposes.
7. Limited time periods for audits
Recent amendments also introduce a default five-year limitation period for tax audits and assessments, subject to specific statutory exceptions. While the standard audit and assessment period is five years, this may be extended to up to 15 years in cases involving fraud or tax evasion.
8. Pillar 2 implementation
Many multinational groups will begin to feel the practical effect of the Domestic Minimum Top-Up Tax (DMTT), the UAE's implementation of the OECD’s global minimum tax under Pillar 2. While the rules apply for financial years starting on or after January 1, 2025, it is 2026 that marks the transition to an operational phase.
9. Reduced compliance obligations for imported goods and services
Businesses that apply the reverse-charge mechanism for VAT purposes in the UAE may benefit from reduced compliance obligations.
10. Substance and CbC reporting focus
Tax authorities are expected to continue strengthening the enforcement of economic substance and Country-by-Country (CbC) reporting frameworks. In the UAE, these regimes are increasingly being used as risk-assessment tools, providing tax authorities with a comprehensive view of multinational groups’ global footprints and enabling them to assess whether profits are aligned with real economic activity.
Contributed by Thomas Vanhee and Hend Rashwan, Aurifer
Key facilities
- Olympic-size swimming pool with a split bulkhead for multi-use configurations, including water polo and 50m/25m training lanes
- Premier League-standard football pitch
- 400m Olympic running track
- NBA-spec basketball court with auditorium
- 600-seat auditorium
- Spaces for historical and cultural exploration
- An elevated football field that doubles as a helipad
- Specialist robotics and science laboratories
- AR and VR-enabled learning centres
- Disruption Lab and Research Centre for developing entrepreneurial skills
Stormy seas
Weather warnings show that Storm Eunice is soon to make landfall. The videographer and I are scrambling to return to the other side of the Channel before it does. As we race to the port of Calais, I see miles of wire fencing topped with barbed wire all around it, a silent ‘Keep Out’ sign for those who, unlike us, aren’t lucky enough to have the right to move freely and safely across borders.
We set sail on a giant ferry whose length dwarfs the dinghies migrants use by nearly a 100 times. Despite the windy rain lashing at the portholes, we arrive safely in Dover; grateful but acutely aware of the miserable conditions the people we’ve left behind are in and of the privilege of choice.
