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?"

The Withdrawal Agreement mandated the creation of the Independent Monitoring Authority (IMA), to protect the rights of EU and EEA EFTA citizens and their family members in the UK and Gibraltar. It launched in January 2021, after the end of the Brexit transition period.

the3million has submitted regular reports to the IMA, which you can find below:

  1. March 2022. Our fourth report to the IMA focuses on the challenges of maintaining a digital status, whether by the status holder when initiating changes to identity document or contact details, or by the Home Office when handling multiple applications by one citizen. This presents obstacles for people to access work, travel and other key requirements to live in the UK.


  2. 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. The 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. 


  3. August 2021. After the EU Settlement Scheme deadline of 30 June 2021 was behind us, we wrote a second report. It 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. 


  4. February 2021. the3million wrote its first report 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. 



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’.

To report a breach of your citizens' rights to the IMA, see their complaint portal at