Visit visa requirement imposed on Nauru because of “Citizenship by Investment” scheme

Statement of changes to the Immigration Rules: HC 1491 has just been published. It is the seventh (!!) statement of changes we have had this year. It is thankfully a short one.

Visit visa requirement for Nauru: 3pm today

Effective 3pm today, nationals of Nauru will no longer be able to apply for a electronic travel authorisation to come to the UK, and will instead need to apply for and be approved for a visit visa before coming to the UK. The written statement by the Minister said that:

We are taking this action in response to the country’s decision to introduce a new Citizenship by Investment programme. The practice of granting citizenship through investment is inherently high-risk and allows individuals access to a new identity with minimal ties to the issuing jurisdiction. Careful consideration of Nauru’s programme has highlighted significant risks to UK border and national security. Its design is particularly vulnerable to misuse and, in its current form, poses an unsustainable risk of exploitation by criminal actors or individuals seeking to circumvent UK immigration controls without genuine intent to comply with UK law. Due to the programme set up, we also lack confidence in the legitimacy of any vetting and due diligence processes. This model cannot operate without rapidly escalating the level of risk to the UK border. Therefore, the Government considers it necessary to take action through this Rules change.

Transitional provisions are in place for people who already have an electronic travel authorisation and have a confirmed booking to the UK obtained on or before 3pm today, where arrival in the UK is no later than 3pm on 20 January 2026

The scheme was introduced in February this year, so it is unclear what has prompted this change now, but the Nauru government will need to update this page accordingly.

Closure of Service Providers from Switzerland route: 31 December 2025

I’ll be honest with you, Appendix Service Providers from Switzerland was a new one to me. And it is closing on 31 December 2025. The explanatory memorandum says:

The route was created in December 2020 in accordance with the UK-Switzerland Citizens’ Rights Agreement. This required that UK and Swiss companies be allowed to continue to service contracts with their respective clients in Switzerland or the UK, where the contract was signed and commenced before the end of the post-EU exit transition period on 31 December 2020. This was intended to be a transitional arrangement ceasing on 31 December 2025, unless the UK and Switzerland agreed to extend it by a further five years. With alternative routes in place for UK businesses to provide services in Switzerland (and vice versa), the UK and Switzerland have agreed that such an extension is not required and the SPS route will therefore close on 31 December 2025. Under the existing rules for the route, any visa issued under it will expire on that date where it has not already done so.

Given that explanation, it seems to make sense that no transitional provisions will be put in place, with the explanatory memorandum stating that as of 1 January 2026 “any pending application for entry clearance or administrative review in respect of that route will then be rejected as invalid”.

Changes relating to EU Settlement Scheme: 30 December 2025 and 1 January 2026

On 30 December 2025 a change is being made to Annex 3 of Appendix EU paragraph A3.3 which adds a ground for the cancellation of leave before or after arrival in the UK where:

(b) Cancellation is justified on grounds that it is more likely than not that, after the specified date, the person has assisted another person fraudulently to obtain, or to attempt to obtain, entry clearance to, or leave to enter or remain in, the UK.”

The explanatory memorandum says that this is being done to “align the grounds for cancelling pre-settled status under the EUSS on or before the holder’s arrival in the UK with those for curtailing it in-country”

On the same day, paragraph FP6(3) of Appendix EU (Family Permit) is being amended so that applicants who are EEA citizens will be eligible to apply. The explanatory memorandum says:

changes for the EUSS travel permit (in Appendix EU (Family Permit)) will enable all EUSS status holders to obtain an EUSS travel permit where they are unable to update their UK Visas and Immigration account, for example with the details of a new travel document, from outside the UK.

Unaccompanied asylum seeking children: 30 December 2025

A change is also being made to paragraph 352ZC(b) which relates to grants of limited leave to unaccompanied asylum seeking children. The old wording is: “the applicant must have applied for asylum and been granted neither refugee status nor Humanitarian Protection” whereas the new wording will be “the applicant must have applied for asylum and been refused refugee status and Humanitarian Protection” (my emphasis), to make clear that refusal of the protection claim is needed before a grant of limited leave is made.

The old version implies that a grant of limited leave could be made while a decision on the protection claim was still pending, the new version is explicit that this is not the case, meaning that unaccompanied asylum seeking children will be left in limbo for longer.

Other changes

Other technical drafting changes are being made, none of which seems to be code for a hidden policy change. Some of it is just mopping up from the introduction of Part Suitability last month.