the3million reports to the Independent Monitoring Authority

"Does the hostile environment framework undermine the rights of EU citizens under the terms of the Withdrawal Agreement?"

In February 2021, the3million wrote its first report (available at for the new Independent Monitoring Authority (IMA) using its in-depth knowledge and experience to set out the key outstanding points surrounding the implementation of EU citizens’ rights. 

In August 2021, after the EU Settlement Scheme deadline of 30 June was behind us, we wrote a second report (available below or at .

In November 2021, five months on from the deadline, we submitted a further report focusing solely on the extent and impact of delays in the EU Settlement Scheme. This report was prompted by the numerous lived experiences sent to us via our reporting tool, and as such it features quotes from a selection of those accounts.

1 July 2021 was the day everything changed, and EU passports were no longer accepted as proof of access to any rights in the UK.

The report revisits our earlier recommendations to see which areas have been addressed, and it examines in great detail the issues faced by EU citizens and their family members in every aspect of the hostile environment framework.

Our key areas of concern are:

  • Those who miss the deadline and have no immigration status have no rights to work, rent or access vital services including health care. We are beginning to see examples of this, and it requires urgent attention.

  • Those with pending applications have rights but are increasingly struggling to enforce them. We are receiving increased reports of people being denied access to vital services and rights.

  • “View and Prove” is now a mandatory process for people to prove their immigration status in the UK. We continue to receive reports of technical, accessibility and other issues.

As in our first report, this update contains many recommendations and we hope the IMA will pick these up, investigate and seek solutions.


About the IMA

The IMA, launched at the end of the transition period, was born from the Withdrawal Agreement which was negotiated to protect the rights of all citizens who had used their free movement rights to cross the Channel - in either direction - to seek new opportunities and build new lives. 

Where the European Commission will continue to protect the rights of British citizens living in the EU, the new IMA has those same powers and responsibilities to protect the rights of the millions of EU citizens who have made the UK their home. 

It has a tremendous task on its hands given that, despite warm words from the Government, we are far away from calling the EU Settlement Scheme a successful ‘mission accomplished’.