Affordability Fee Waivers: Citizenship Registration for Under-18's

The fee for a British citizenship application for a child is £1,012. However, the Home Office has recently introduced fee waivers for registration citizenship applications for children under the age of 18 if they or their parents can prove they cannot afford it. 

Detailed guidance on affordability fee waivers for citizenship registration applications for children under the age of 18 was released on 26 May 2022. A ‘child’ and ‘applicant’ is considered as the individual under the age of 18.  This article will summarise the guidance published on how to apply for a fee waiver for a child, what qualifies an individual to apply, and the evidence required.

How to Make an Affordability British Citizenship Fee Waiver Application

There are two ways of making an application for a fee waiver. If you decide to use the online form, then you must submit the citizenship application online. If you decide to apply using the paper waiver request form, then you must print and submit the form alongside your main citizenship application. 

Those who have been granted their online fee waiver request will receive a token to use when completing their application. You must then submit your citizenship application within  28 calendar days of the fee waiver decision date and submit your biometrics within 45 calendar days of the decision.

If you have applied with a paper fee waiver request, you will be notified of the decision alongside a request to enrol your biometrics. This must also be submitted within 45 calendar days.

The guidance applies to the following types of application: 

• Form MN1: Registration of children under the age of 18; 
• Form S2 and S3: Registration as a British citizen if you are a stateless person 
• Form T: Registration as a British citizen if you were born in the UK on or after 1 January 1983 and lived here until you were 10 years old. 
• Form B(OS): Registration as a British citizen if you are a British Overseas citizen, British subject, British protected person, or British National (Overseas) and have no other citizenship or nationality 
• Form B(OTA): Registration as a British citizen if you are a British Overseas Territories citizen, a British Overseas citizen, a British protected person, a British subject or a British National (Overseas) 
•  Form EM: Registration as a British Citizen through residence in Hong Kong before 1997 (paper only)

Qualifying for a Citizenship Registration For Under-18’s Application Fee Waiver

The two requirements for a minor citizenship registration fee waiver request application to be granted are that the applicant (the child) and parent(s) must:

• Credibly demonstrate they cannot afford the fee; and
• Show their income is not sufficient to meet the child’s needs

The affordability test

To show that you cannot afford the fee, the Home Office guidance notes that this is when the applicant and the parent(s) do not have sufficient funds at their disposal…after meeting their essential living needs, and continuing to meet any other child’s essential needs, such as housing and food. This means that the applicant, or the individual(s) supporting them financially, are unable to pay the fee if they must also pay for essential needs.

After considering the costs of accommodation and essential living needs, the Home Office will consider the surplus income left. Essential living needs include utilities, food, clothing, toiletries, non-prescription medication, and household cleaning items. This also considers travel costs and communication required to allow the child to maintain interpersonal relationships and access a reasonable level of social, cultural and religious life. 

It is of course understood that essential living needs for different applicants will vary, and this will be assessed on a case-by-case basis. The main consideration taken by the Home Office will be whether you can demonstrate that you cannot afford to pay the fee whilst meeting essential needs.

All financial circumstances will be taken into consideration such as:

• If others are supporting the applicant, their parent(s) and any other dependents with their accommodation and essential needs, but the applicant and their parent(s) can still credibly demonstrate that they cannot afford the fee. This support may be provided by family and friends, a local authority, a NGO/charity, or their home country’s government.
• Any savings held or reasonable efforts to save for the fee across a reasonable amount of time in the past 6 months. This is so that those who truly cannot afford the fee or were unable to save for the foreseeable fee qualify for a waiver. 
• If an excess amount has been spent on essential living needs by the applicant or parent(s).

The Home Office will consider various questions when assessing your application. Some of these include the following:

• How essential living needs are met and by whom;
• All sources of income, including investments and bonds held;
• If there is surplus income, excluding the costs of accommodation and essential living needs, that may be used to pay the fee;
• Whether any non-essential or excessive purchases have been made. This includes holidays or luxury items; 
• Is the applicant or parent(s) financially dependent on someone who can afford to pay the fee.

Income is not sufficient to meet the child’s needs

It is understood that this part of the test may already be demonstrated above. When your application is assessed, it will be considered in light of the need to safeguard and promote the welfare of a child in the UK in line with the duty in section 55 of the Borders, Citizenship and Immigration Act 2009. This considers the child’s best interests and their well-being. 

The overall assessment from the evidence provided is whether paying the fee would have a disproportionate impact on the child’s best interests, such as the inability to meet the needs of the child due to low income. All matters will be reviewed on an individual basis.

This might be by the child being deprived of something that they currently enjoy partaking in or not being able to do or have something that benefits them.  Such factors can include after school activities, participating in a faith, or adjustments for a disability. An example provided is whether paying the fee may stop a child from participating in sports lessons which would harm their wellbeing. 

Other factors that may be considered are:

• Whether the child lives with both parents or a legal guardian who is not their parent and who provides support;
• Whether the absent parent, if so, has previously provided support and if they can do so on this occasion;

A child under the care of a local authority will not need to demonstrate the above. Please see further on in this article for more information.

Evidence Required for a Child Citizenship Registration Affordability Fee Waiver Application

It is up to the applicant and parent(s) to provide the evidence and demonstrate that they cannot afford the citizenship registration application fee, and thereby qualify for a fee waiver. The evidence provided must be clear and compelling.

Evidence of financial circumstances showing the income of the parent(s), type of accommodation, amount of  their rent/mortgage, and any outgoing payments should be provided. This may be in the form of: 

• Bank statements
• Payslips
• Tenancy agreement
• Utility bills

If the child or parent(s) are being supported by a registered charity, central/local government, or friends or family, then they should provide evidence of this, explaining the nature and amount of support provided. The form of evidence is not specified in the guidance, though this can be, for example, a letter.

Additionally, if the child or parent(s) has a physical and/or mental disability that is material to their application, then this must be demonstrated by evidence such as a letter from a hospital consultant.

Children in Local Authority Care

If an application is made on behalf of a child looked after by a Local Authority, or a child outside the UK in similar circumstances, then the fee does not need to be paid. Therefore, it follows that evidence of financial circumstances nor a fee waiver request form are not required. Rather, this exemption should be indicated on the main citizenship application.

Those receiving local authority support, but not cared for by the local authority, are not eligible for the above exemption. However, they may still qualify for the fee waiver and will still need to meet the affordability test when applying.

Contact our Immigration Lawyers

For expert advice and assistance with a British Citizenship by Registration application or any immigration matter, contact our immigration barristers on 0203 617 9173 or complete the enquiry form below.