A consultation has been launched by the Home Office on a major increase to OISC registration fees. The deadline for responses is 5 June 2024. Fees currently bring in around £1.3 million and the OISC costs around £2.2 million to run. The increase is intended to close that gap so that the scheme is self-funding.

The proposals are essentially

• increase annual registration and renewal fees
• start charging a new per adviser fee on top of the organisation fee
• charge that new per adviser fee to not-for-profit organisations, i.e. charities and NGOs, who have previously benefited from free registration.

A small profit-making company registered at level 1 would pay £1,037 to renew annually compared to £733 currently, an increase of around 40%. On top of that, the company would need to pay an additional fee of £329 per caseworker (or £103 on renewal). For a company with 10 advisers, that all works out as considerably more than double the current cost for renewals.

The impact on not-for-profits is likely to be considerable given that many register as many advisers as possible in order to increase capacity in the immigration advice sector. The logical response to this proposal would be to limit the number of registered advisers but increase their individual caseloads. That seems likely to significantly decrease capacity over time.

As I understand it, a proposal is also made to allow for split fees to be charged, for example enabling a separate charge to be levied for assessment and for registration. Apparently primary legislation would be required for that, though, so that bit seems unlikely to happen any time soon.