Our briefing for Second Reading of the Bill examines the impact of key provisions affecting children’s rights, including:

• Clause 18: Narrows the definition of family life for Article 8 purposes.
• Clause 19: Restricts how children’s family and private life is considered in Article 8 decisions.
• Clauses 23 and 24: Introduce powers to make recognised refugees repay the cost of their asylum support and accommodation.
• Clause 36: Introduces credibility provisions that risk child victims of trafficking being disbelieved because of delayed disclosure.
• Clause 38: Makes protection from public order disqualification dependent on a child’s immigration status.
• Clause 39: Removes the duty to grant temporary permission to stay (VTS leave) and further restricts access to secure immigration status for child victims.
• Clause 43: Removes the Secretary of State’s statutory duty to provide assistance and support to child victims of trafficking.

The RMCC is also deeply concerned about the proposed changes to the asylum appeals system in part 1 of the Bill and endorses briefings by the Law Society and ILPA on this.

The Government has committed to assessing the impact of its asylum and immigration reforms on children. We urge Ministers to ensure that this includes the measures in this Bill, takes the form of a Child Rights Impact Assessment using the Department for Education’s established template, and is published.

Read the full briefing here.

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Determining whether a young person seeking asylum is a child or an adult is of fundamental importance to their life: it determines whether they receive care from children’s services; can access suitable accommodation and education; safeguarding arrangements; and the way their asylum claim is processed. Errors at the border, where the age of unaccompanied children and young people is too often decided on the basis of ‘appearance and demeanour’, have repeatedly resulted in children being treated as adults, with serious safeguarding consequences. The Independent Chief Inspector of Borders and Immigration (ICIBI) has criticised these visual assessments as perfunctory and lacking cultural awareness and consistency, and the evidence from NGOs has consistently shown that hundreds of children each year are wrongly placed in adult settings, including immigration removal centres and adult prisons. Any reform of age assessment processes must reduce, not reproduce, those harms.

Age assessments have long been an area of contention, and there is no ‘quick fix’ for a process that can be complicated and lengthy. After many years of exploring the use of highly criticised ‘scientific methods’ of assessing age, such as X-rays, in July 2025 the government announced proposals to use artificial intelligence (AI) to assess age instead, as “the most cost-effective option”. On 29^th May 2026, the government announced that the procurement process for the Facial Age Estimation (FAE) algorithm had concluded and a contract awarded to Akhter Computers Ltd. FAE will be implemented as part of initial age decisions at the border with “further trials and testing throughout 2026” before a planned roll out in 2027.

The Home Office has made clear that the technology will be an additional source of information for immigration officers rather than a replacement for human decision-making or social work age assessments. However, the information shared to date does not provide the level of detail needed to assess whether FAE can be used safely, fairly or lawfully in this context, including the testing methodology, datasets used, performance across demographic groups, false-adult rates for 16- and 17-year-olds, or the safeguards that would apply before any operational rollout.

The development of FAE also sits within a wider government agenda to “strengthen” age assessments and “root out” allegedly false age claims, including proposals expected to be taken forward through forthcoming immigration and asylum legislation. This makes it particularly important that any technological or legislative changes are assessed against the evidence of existing safeguarding failures, and that safeguards for children are strengthened rather than weakened.

In light of extensive evidence showing how flawed human ‘visual assessments’ at the border are at present, the use of AI for age estimation in the UK asylum process could, in theory, benefit the triage process if used narrowly and with robust safeguards. However, given the lack of accuracy with existing systems, its use must be approached with caution. The use of AI also introduces new technical and rights risks that must be understood and addressed. This briefing aims to summarise the existing evidence and propose safeguards that must be put into place if FAE is ever to be used.

Key findings:

• While errors have improved over a decade, estimating age using FAE remains subject to significant margins of error. Young people aged around 18 remain some of the hardest cases, and false-adult risks vary by the threshold chosen (e.g., challenge-25/28). The technology also performs less well when images are taken in real-world conditions, such as at borders where lighting, camera angle and facial position can vary, compared with more controlled settings like office-style photos. FAE must also take into account the traumatic journeys that young people will have experienced on their journeys to the UK. These assessments often happen through the night and exhaustion and trauma are known to “age” children. Accuracy can also differ between groups, including by sex and ethnicity.
• Because of the risks that FAE can wrongly identify a child to be an adult, just as human age estimation has for a number of years, there are a number of procedural safeguards that must remain if FAE is to be used, including giving the benefit of the doubt; referral to social workers for more detailed assessment; access to an appropriate adult and legal representation; and the ability to legally challenge any decision. Any use of AI must sit within, not in place of, a lawful and child-centred process.
• If FAE is considered at all, it should be advisory only, used with conservative thresholds so that a child is only at risk of being treated as an adult in tightly defined, case-specific circumstances, where the evidence clearly and consistently indicates that they are significantly over 18 and there is no credible evidence to the contrary. FAE should never be solely used to determine age.
• Use of technology must be subject to independent validation on UK relevant cohorts and border quality imagery, and embedded within a transparent, rights compliant procedure.

Read the full briefing here.

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One key area of concern for the RMCC has been the introduction of the National Age Assessment Board (NAAB). The NAAB, which was established through sections 50 and 51 of the Nationality and Borders Act 2022, is a decision-making function within the Home Office that conducts age assessments on behalf of local authorities when requested to do so by the local authority or by the Home Office (even where a local authority does not deem an assessment necessary). Members have supported young people assessed by the NAAB and noted a number of concerns about how these assessments have been conducted. The Independent Chief Inspector of Borders and Immigration (ICIBI) found that serious concerns remain about its capacity, transparency, and quality assurance – raising questions about the NAAB’s ability to fulfil its ambition of being a ‘centre of excellence’.

Read more in our detailed briefing on the National Age Assessment Board

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These changes would have profound and damaging consequences for children’s rights, wellbeing, and long-term integration. Prolonged insecurity, repeated status reviews, restricted access to family reunion and public funds, and extended routes to settlement would undermine children’s need for stability, disrupt education and development, exacerbate poverty and harms mental health.

The RMCC is extremely concerned about the introduction of “earned” settlement based on income and contribution on children, young people, families and communities; the retrospective application of reforms, and the risk that children growing up in the UK will be left in prolonged legal limbo or lose pathways to British citizenship. The proposed settlement reforms are huge in extent; will dramatically change immigration pathways across the system; and risk damaging integration in the UK, impacting thousands of children and young people who have made the UK home.

Read more in RMCC’s briefing on the government’s asylum and settlement reforms

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The report, ‘Lost Childhoods: The consequences of flawed age assessments at the UK border’, revealed that in the first half of 2024 alone, 63 local authorities in England and Scotland received 603 referrals from various stakeholders who suspected young people were being wrongly placed in adult accommodation or detention due to inaccurate Home Office age assessments. In 493 cases where a decision was made on age, over half cases (262) were found to be children. 

Children wrongly assessed as adults are not only forced to share rooms with strangers in adult accommodation, but they are also at risk of being wrongly convicted for crimes of illegal entry or facilitating illegal entry. Between June 2022 and September 2024, 510 people arriving on ‘small boats’ were charged with ‘illegal arrival’ of which 26 cases where children wrongly treated as adults were charged with offences. At least 16 children were wrongly held for various periods of time in adult prisons leaving them at huge risk. 

The process of visual assessment at ports needs urgent reform – the use of X-rays and other ‘scientific methods’ to assess age and the creation of the National Age Assessment Board (NAAB) will do nothing to address the root of the problem. 

The report calls on the Home Office to only dispute a child’s claimed age in exceptional circumstances, and to routinely notify local authorities whenever a potential child has been determined by them to be an adult. It also calls for full statistics on age disputes to be published, showing the number of children who are taken into care from the adult asylum system. The government currently refuses to disclose this data.  

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While we support the repeal of IMA measures that would have penalised young people for refusing scientific age assessments and limited legal challenges, we remain deeply concerned about the continued application of age assessment and modern slavery provisions in the Nationality and Borders Act 2022 (NABA). As organisations working with thousands of children, we consistently raise concerns with the Home Office about the serious flaws in age assessment procedures. Border guards’ misjudgements result in hundreds of children being wrongly placed in the adult system each year, posing a major safeguarding risk—one that is not treated with the urgency it demands. Additionally, child victims of trafficking continue to be denied essential modern slavery protections due to these policies.

We are also concerned that the Bill expands on NABA’s immigration offences, potentially criminalising more people—including children. Efforts to target smugglers must not lead to the unjust criminalisation of those seeking safety. Furthermore, the retention of IMA provisions that impose blanket exclusions on individuals from countries such as Albania, Georgia and India from making asylum claims is particularly concerning. For children and young people deemed inadmissible, these provisions prevent them from being properly safeguarded. They also fail to acknowledge the unique challenges children and young people may face if forcibly
returned, as well as their heightened vulnerabilities.

Read more:

RMCC briefing for Second Reading of the Bill in the House of Commons, February 2025

RMCC evidence for Committee Stage of the Bill in the House of Commons, February 2025

Debate on age disputes during Committee Stage of the Bill, March 2025

RMCC briefing for House of Commons Report Stage on New Clause 42 – Transparency in age dispute decision-making, May 2025

RMCC briefing for Second Reading of the Bill in the House of Lords, June 2025

RMCC briefing for Committee Stage of the Bill in the House of Lords – Age Assessment amendments, August 2025

RMCC briefing for Committee Stage of the Bill in the House of Lords – Safe Routes amendments, October 2025

RMCC briefing for Report Stage of the Bill in the House of Lords, November 2025

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The Bill legislates that Rwanda is safe, something that has been authoritatively found to be false by the Supreme Court, and in doing so is likely in breach of international law. It is an affront to the rule of law. International law, including the UN Convention on the Rights of the Child, is integral to children’s rights and their protection. The Bill disapplies domestically treaties that the UK remains bound by internationally – this clear violation of international law obligations sets a dangerous precedent, damages the UK’s reputation on the international stage, and jeopardises the rights of children.

Read our briefings for the House of Lords Committee Stage on unaccompanied and accompanied children.

Read our briefing for House of Lords report stage.

Read our briefing for House of Commons consideration of Lords amendments at ping pong.

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The submission was in response to the OHCHR study pursuant to Human Rights Council resolution 54/6 on the centrality of care and support from a human rights perspective

You can view the full submission here.

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The government has not only failed to properly consider children’s rights with this Bill (indeed, it has failed to uphold anyone’s rights with this legislation), it is aiming to undo over a decade’s worth of progress made under the Conservative government for the protection of child victims of trafficking and will reverse the ending of child detention.

This is not just about ‘small boats’ – under this Bill nearly all children who have not arrived via the very limited ‘safe routes’ (i.e. resettlement schemes) will be blocked from protection as refugees and victims of trafficking. All children from countries such as Afghanistan, Eritrea, Sudan, Iran and Syria, fleeing war and persecution and having endured traumatic journeys to the UK, will now be potentially subject to indefinite detention and removal. Most will be left in limbo for years, unable to access any form of status or rebuild their lives.

Read our briefings for Report Stage in the House of Lords on Exemption from inadmissibility of claims for unaccompanied children and Age Assessments, June 2023.

Read our general briefing for Committee Stage in the House of Lords and our briefing on age assessment clauses in the Bill.

Read our briefing for Second Reading in the House of Lords on 10th May here

Read our briefing for Report Stage in the House of Commons on 25th April here and supplementary briefing on the Age Assessment amendments to the Bill tabled by the government.

Read our briefing for Committee Stage in the House of Commons on 27th and 28th March here

Read our briefing for Second Reading of the Bill in the House of Commons on the 13th March here

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The Review did not comment extensively on the experiences of migrant children receiving support from children’s social care but these young people will undoubtedly be affected by a wide range of the Review’s recommendations. There are some of the Review’s recommendations, such as changes to advocacy, the creation of a National Children’s Social Care Outcome Framework, and localisation of National Referral Mechanism decision-making, which present significant opportunities to improve the care provided to migrant children – whether living with their families, in wider kinship care, in the care system, or as care leavers.
There are other recommendations which, without further detail or if implemented without mitigation, could put migrant children at risk. These include changes to Section 17 of the Children Act 1989, the regional commissioning of placements for children in care and, potentially, a lack of ambition to improve the lives of former unaccompanied children through improved support for care
leavers.

The RMCC has put together a range of briefings looks at how to maximise the potential, and mitigate the risks, of the Review’s recommendations for this group. The briefings highlight key issues, ask important questions about implementation, and provide some ways in which the policy recommendations of the Review could be mitigated or modified to eliminate risk and have the most positive impact possible on the lives of children subject to immigration control.

The briefings make many proposals however some of the most crucial include:

• Support for children to resolve their immigration status is embedded into the new National Children’s Social Care so that secure immigration status is a properly recognised outcome of children’s social work. As a result of this practice guides, training, and continuing professional development around immigration issues in social work is properly embedded to improve the knowledge, skills and confidence of the workforce.
• Any reform of Section 17 of the Children Act 1989 to enable the Review’s proposed Family Help model maintains the rights of families receiving support under section 17 to relieve destitution as a result of having no recourse to public funds.
• Reforms to the care system and leaving care support are truly ambitious for unaccompanied asylum seeking children and other children subject to immigration control. Reform should see the provision of their care fully integrated into the wider care system and arrest moves towards a two-tier care system which sees unaccompanied and other migrant children treated differently from other children in care.

Read more:

• Executive summary
• Briefing #1: National Children’s Social Care Framework
• Briefing #2: Family Help
• Briefing #3: Families and Children’s Social Care
• Briefing #4: Safeguarding and Extra Familial Harms
• Briefing #5: Placements
• Briefing #6: Advocacy
• Briefing #7: Relationships
• Briefing #8: Education, Employment and Housing
• Briefing #9: Health
• Briefing #10: Workforce
• Appendix: Children Subject to Immigration Control

The RMCC has also responded to the following government consultations:

Consultation on the strategy for social care: Stable Homes, Built on Love

Consultation on the Children’s Social Care National Framework

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