On 4 September 2025, the Government introduced significant changes to the Immigration Rules through Statement of Changes HC 1298. Central to these reforms is the suspension of the refugee family reunion route. The move has been described in the accompanying explanatory memorandum as a “temporary pause” while the Home Office undertakes “a full review and reform of the current family rules to ensure we have a fair and properly balanced system”. No firm timescale has been given, though the Minister has indicated that a new family policy will be outlined before the end of the year.
Closure of Appendix Family Reunion
A new provision has been added to the top of Appendix Family Reunion, stating:
“This Appendix, also known as refugee family reunion, is now closed to new applications pending a review. For those who applied before 1500 on 4 September 2025, the Appendix FRP rules in place on that date will apply…”
In practice, this means only those who submitted an application before the deadline will have their cases assessed under the old rules. New applicants are now directed to Appendix FM and Appendix Child Relative (Sponsors with Protection).
Changes to Appendix FM
The reforms amend Appendix FM to make it the primary route for family members of those with protection status. Previously, Appendix FM could only be relied upon where Appendix Family Reunion or Appendix Statelessness was unavailable. That restriction has now been removed.
Notably:
- Children: The section allowing children to apply to join a parent has been expanded. Parents with protection status can now sponsor their children, aligning this route with the broader family migration framework.
- Sole responsibility test: Unlike the family reunion rules, Appendix FM requires a parent to show “sole responsibility” where the child is not joining both parents in the UK. This represents a more restrictive approach and may place some families in a difficult position.
The Government acknowledges this tension in the memorandum, stressing that the policy aim is to avoid drawing the UK into custody disputes. However, there remains an important safeguard:
“Where an applicant is unable to demonstrate sole responsibility under Appendix FM, the child will still be granted permission if there are serious and compelling family circumstances that make exclusion of the child undesirable.” (Explanatory Memorandum, paragraph 5.5)
Rationale Behind the Changes
The Home Secretary has defended the suspension of the route on grounds of sustainability and fairness, citing both financial pressures and the misuse of family reunion as a selling point by smuggling gangs.
The memorandum notes:
“The refugee family reunion route places further pressures on public services and local authorities, due to the lack of requirements for sponsors to be able to support their family members before they enter the UK.”
Applicants using Appendix FM must now satisfy financial and English language requirements and either pay the application fee or secure a fee waiver.
What This Means for Refugees and Their Families
The immediate consequence is that families who might previously have been able to apply under the more flexible Appendix Family Reunion rules now face stricter eligibility requirements under Appendix FM. This includes:
- Meeting the minimum income threshold or other financial support requirements.
- Providing evidence of English language ability where applicable.
- Understanding the sole responsibility test for children not travelling with both parents.
While transitional provisions protect applications made before 3pm on 4 September 2025, the reality is that many families will now encounter additional hurdles and delays.
Looking Ahead
This suspension is framed as temporary, with the promise of a new family policy by the end of the year. However, without clarity on the eventual direction of reform, refugee families are left in a period of uncertainty.
For practitioners and applicants alike, close attention to Appendix FM is now essential. Those advising refugee sponsors must be prepared to address the evidential and financial demands that accompany this route, requirements which were previously absent from family reunion applications. With over 20 years of experience and a commitment to excellence, Morgan Smith Immigration is your trusted partner for all your immigration needs. Contact us today to learn more about how we can assist you with UK Visa Applications. For any enquiries or assistance, call us at 0203 959 3335 or email [email protected].
