Personal Immigration
Business Immigration
2018 Image from St Pauls Carnival (@STPaulsCRNVL) on Twitter

Windrush Lessons Learned Review - Has Progress Been Made?

In March 2020, Wendy Williams conducted a review of the Home Office’s workings, and failings, in the wake of the Windrush Scandal. This review called for significant reform by making 30 recommendations to the Home Office that could be distilled into 3 main objectives. Williams wrote as follows:

…the Home Office must acknowledge the wrong which has been done; it must open itself up to greater external scrutiny; and it must change its culture to recognise that migration and wider Home Office policy is about people and, whatever its objective, should be rooted in humanity.”

She has now published a review assessing the Home Office’s progress since accepting her recommendations. Williams breaks down her progress report into 5 themes, in accordance with how the Home Office grouped her recommendations: 

  1. Righting the wrongs and learning from the past
  2. A more compassionate approach
  3. Robust and inclusive policy making
  4. Openness to scrutiny 
  5. An inclusive workforce.

Williams does note that the issue of race ought to have been included as a separate, specific theme as it was in the original review. 

This article will discuss a selection of Williams’ findings; the full report can be found here.

Righting the wrongs and learning from the past

The recommendations under this theme included the provision of a sincere apology from the Home Office, as well as the advised continuation of the Windrush Scheme and outreach, and the implementation of a learning plan on UK history. With regards to the formal apology issued by the Home Secretary, Williams writes “while the department has made an unqualified apology, some questions remain over how widely it has been disseminated, by what means, and whether it has reached its target audience. Williams also stressed that the need for systemic change is an ongoing duty that cannot be met by a statement of apology alone. On other related matters, Williams said:

It is… disappointing that at the time of writing this report, almost two years after the [original review] was published, no formal reconciliation events have taken place (Recommendation 3).

She also reports:

“I was disappointed to find that the learning programme agreed in response to Recommendation 6 has yet to be finalised and rolled out. There is clear evidence of the department’s commitment to developing this training but, by December 2021, it was still at the pilot stage, in contrast to the [Comprehensive Improvement Plan]’s aim to have it in place for all staff by June 2021.”

It is clear that the Home Office’s apologies and attempts at restorative action with regards to theme 1 have not improved faith in the Home Office amongst affected communities. Williams reports that 97% of people who applied to either the Windrush Scheme or the Windrush Compensation Scheme – who were questioned to assist with her progress review – did not trust the Home Office to deliver on its commitments.

With regards to the recommendation to run reconciliation events, Williams writes: “At the time of writing, the department is unable to point to any target dates for when the events will take place, which casts doubt on whether they will take place at all. I therefore conclude that the department has failed to implement Recommendation 3.”

Williams’ views on the department’s outreach and engagement are mixed: 

“​​Overall, my assessment of the department’s outreach and engagement efforts is positive, and I conclude that it has met the requirements of Recommendation 4 in so far as keeping the schemes open. However, I am concerned by the disparity in numbers between those applying under the Windrush Scheme and those applying under the Windrush Compensation Scheme. It is possible that many of those who have secured documents have incurred no recoverable losses, but that assumption would be inconsistent with the evidence I heard when conducting my original review.“ She also quotes several instances of negative feedback from people who have engaged with the schemes.

There is some positive feedback under this theme: “Based on the evidence I have seen, there have been some positive changes since the department apologised, including a widespread acceptance by the workforce and senior leaders that the tragedy should not have happened, and an enthusiasm to do things differently. “

A more compassionate approach

The main takeaway under the assessment of this theme is the Home Office’s failure to review its hostile environment policy (now known as compliant environment policy):

“Given its central significance to the Windrush scandal and the workings of the department, the failure to complete the review of the compliant environment policy [previously known as the Hostile Environment policy] will fundamentally hamper the department’s efforts to learn lessons and move on constructively. The department should therefore be vigilant in completing these recommendations without further delay to ensure that its strong formative work is established across the whole organisation.”

Home Office staff have themselves reported that attempts to foster a more compassionate approach are not being lead by senior officials:  

“…the overall perception was that the momentum for adopting a more compassionate approach was being driven from the grassroots, rather than in a structured way across the department.”

With regards to implementing a programme of major cultural change, Williams concludes that the recommendation is partially met. It is recognised that the Home Office launched the One Home Office transformation programme in March 2021, and this programme is described as having “a clear governance and reporting structure, which reflects a commitment to creating and sustaining a cultural change.” However, it is apparent that issues still lie with the approach of senior officials:

“Attendees at senior and mid-grade staff engagement events believed there was an issue with staff being comfortable to challenge, particularly at lower grades…External organisations considered that the necessary cultural and systemic changes will not take place until attitudes shift at senior and ministerial levels.

The recommendations to develop ethical standards and an ethical decision-making model, and to improve UKVI customer experience, were also deemed partially met.

Robust and inclusive policy making 

There is some positive feedback in relation to this theme: 

The department has undertaken positive work to implement the recommendations that relate to achieving more robust and inclusive policy making… One of the reasons for the Windrush events was that groups were largely forgotten as successive policies were introduced, which directly led to their detriment. I have seen that this has been specifically highlighted in both the general and the expert training slides on the PSED.”

And with regards to delivering Equality Act and Human Rights Act training:

“There is clear evidence of a commitment to roll out the training and support staff in understanding their equality duties.” 

As with much of Williams’ evaluation, praise in this area was not unqualified. An important finding was that the department appears to be expending resources on controversial political endeavours:

“The department continues to work at pace on highly contentious and politicised policies, so it is the responsibility of senior leaders to work at a faster pace.”

A common theme throughout Williams’ report is that the Home Office has outlined and proposed various promising measures without bringing them into fruition. This theme is no different:

“Overall, the recommendations under this theme reflect a notable level of ambition by the department for policy making which would, if achieved, provide compelling evidence of both a cultural and professional shift in the organisation. However, there is limited evidence that the positive developments are being consistently translated into tangible effects across the department. The recommendations are all currently in their formative stages, with limited progress in many of the examples. In others, the plans and timescales for coordinating the policy-making framework are not yet clear. A few of the recommendations show little or no progress.”

Openness to scrutiny 

One of Williams’ focal recommendations under this theme was for the introduction of a Migrants’ Commissioner. This target remains unmet, as does the recommended review of the Independent Chief Inspector of Borders and Immigrations, and the Independent Case Examiner. Recommendation 20, to review the borders, immigration and citizenship system complaints procedure is also deemed unmet. With regards to the lack of a Migrants’ Commissioner, Williams writes: 

This situation means that so far, the department has been unable to reap the benefits that opening itself up to wider scrutiny would bring. Since my original report was published, there have been a number of occasions where, for example, the expertise and independence of a Migrants’ Commissioner could have provided an evidence-based perspective on migration policy proposals…It was to the department’s immense credit that it accepted Recommendation 9. By failing to implement what would be the cornerstone of its plan for engaging effectively with the public, the department risks undermining its stated commitment to transparency and effective policy making, as well as the efforts to rebuild its reputation.”

There are, however, positives to be taken from the revision and clarification of the Home Offices risk management framework: “Overall, I consider that the approach taken to Recommendation 23 shows examples of good practice for the department to follow, in terms of design and roll-out.” Though, again, this commended framework is “yet to be embedded”.

An inclusive workforce

Williams’ view on the implementation of a review of diversity and inclusion training in the department is largely negative. She explains in her report that the delivery of proposed training programmes have been significantly and unjustifiably delayed. 

However, the department does seem to have revised its Inclusive by Instinct strategy in order to include aspirations for senior-level black, Asian and minority ethnic representation and a plan to bring them to fruition. In response to this recommendation, the department published its Roadmap to Inclusion Delivery Plan, and this has been labelled “an improvement on its predecessor”. Though Williams offers some improvements, including the introduction of specific, measurable targets and elevating understanding of diversity and inclusion in order to embed the strategy. This recommendation – number 28 – was deemed met.


It is apparent from Williams’ review that there is still significant work to be done in order to bring about systemic improvement in the Home Office’s workings. Williams does reiterate in her conclusion that she is neither surprised nor disappointed that many of her recommendations remain unmet because of the sheer size and scale of the targets in place. It is acknowledged that there has been an increase in momentum and drive towards a cultural shift in the department, though evidence of tangible, evidenced change remains quite scarce. 

There are references throughout the progress report to the staff members’ enthusiasm for the recommendations, and the devising of comprehensive frameworks designed to rectify pervasive issues. These plans carry little weight for those impacted by the Windrush Scandal until they are put into practice. It seems that, for the most part, this implementation remains to be seen. 

Contact our Immigration Barristers

For expert advice and assistance with a UK visa application, contact our immigration barristers in London on 0203 617 9173 or complete our enquiry form below.


To arrange an initial consultation meeting, call our immigration barristers on 0203 617 9173 or fill out the form below.

    Attach a file if it supports your enquiry. Only .doc or .pdf files.


    Expert advice & representation from immigration barristers that you can rely on.

    Google+ - Five Stars

    Read the 600+ five out of five star Google reviews of our immigration barristers.