In March, the Government launched its New Plan for Immigration – the biggest overhaul of the UK asylum system in decades. The proposals will have far-reaching, damaging consequences for anyone wishing to seek protection in this country, putting many more people at risk of destitution as they make their asylum claim and look to rebuild their lives here.

NACCOM has joined with others across the sector to denounce the plans, as well as the six-week public engagement and consultation process, which alongside partners we have labelled “vague, unworkable, cruel and potentially unlawful” (as reported in The Guardian).

Our response to the consultation:

NACCOM is deeply concerned about the consultation process around the New Plan For Immigration and the consequences of the legislation that could emerge from it.  The shared vision that our network holds, which is to see an end to destitution, is central to these concerns.

NACCOM rejects the premise of the stated vision and key objectives in the New Plan for Immigration on the basis that the changes will clearly worsen the safety, health, wellbeing and future prospects of people seeking protection in the UK, including those who are already here and those who are yet to arrive.

As a network of over 135 organisations representing and supporting people whose lives have been directly and disastrously impacted by decades of hostile immigration legislation, NACCOM’s consultation response focuses in the most part on the impact of existing and future Government policy on people who have been refused asylum (the core group of people accommodated by network members) and people who have had their refugee status recognised (the second largest group accommodated by network members). Beyond concerns that are raised regarding these two specific demographic groups, NACCOM wholeheartedly rejects all elements of the New Plan for Immigration that extend or entrench the Hostile Environment in all its forms.

Our approach to engaging with the consultation:

Along with many other organisations, NACCOM is extremely concerned by the format and timeframe of the consultation, and as such NACCOM is engaging with the consultation but in a way that is openly and strongly critical of its intentions and limitations.

Our concerns around the consultation:

➡️ It is NACCOM’s belief that the expertise of people with lived experience of the immigration system has not been heard in a sufficient or meaningful way by the Government in this consultation process and it is NACCOM’s assertion that the process is significantly poorer for it.

➡️ There is also a concern with the way that many of the questions are framed, which is in such a way that they do not allow for disagreement with the plan’s central vision. In these instances, NACCOM has made the decision not to respond; we do not want to imply agreement with the overall premise.

➡️ Finally, there are concerns about the timeframe for the consultation period, which is extremely short and during Local Authority elections, which will no doubt hamper some of the opportunities for robust responses.

NACCOM will continue to raise these concerns across forums and we have signed Refugee Action’s joint public statement which highlights many of these key issues.


Above is NACCOM’s response to the consultation on the New Plan for Immigration, laid out in the order that questions appear on the Stakeholder questionnaire.

We have decided not to answer the multiple-choice questions because it was not possible to make clear the nuance of the issues in the responses available. Any views about the questions are made in the relevant open text sections. The only exception to this is the first question, to which NACCOM has responded ‘strongly opposed’.

We encourage NACCOM members and supporters to plan for how you can best engage with the consultation and campaigning around the bill.

Members (and other organisations) are welcome to use NACCOM responses as the basis for your consultation response.