ADD2778 Migration Programme 2025-26

1.1.    Mayoral Decision (MD) 3386 approved the delivery plan for the Accommodation and Wider Support for Those Who Need It Most programme including the resources allocated to it, and delegated authority to the Assistant Director, Housing Programme and Partnerships (in consultation with the Executive Director for Housing and Land, the Executive Director for Communities and Skills, and the Mayoral Delivery Board), as the Senior Responsible Owner (SRO), to approve the receipt of any additional funding from central government or other sources to expand or extend existing approved schemes contained in the Accommodation and Wider Support for Those Who Need It Most delivery plan.
1.2.    This decision form seeks approval for expenditure of £590,000 of GLA budget for 2025-26 as part of the Migration Team’s work to deliver on the Mayoral Mandate for Accommodation and Support for those who need it. This funding will enable the delivery of work to increase capacity of the immigration advice sector in London, and contribute towards migration system leadership, including strategic work on Modern Slavery, Humanitarian Response and lived experience engagement through the Migrant Advisory Panel. It also seeks approval for the receipt of up to £585,600, and expenditure of the same, to support the delivery of the London Strategic Migration Partnership (LSMP) and ESOL capacity. It further seeks approval of receipt of up to £1,115,836, and expenditure of the same, to support delivery of coordination work on Hong Kong and Ukraine arrivals in London and work to support mental health and wellbeing of people seeking asylum. This programme continues work approved under MD3223.
1.3.    There are three core strands to the Migration Team’s work that these budgets contribute towards. The objectives and expected outcomes are set out against these in order to demonstrate how these budgets work together to form the portfolio of work on Migration:
•    Welcome and Integration Support
•    Immigration Advice Capacity
•    LSMP and migration system leadership
 

Welcome and Integration Support
2.1.    This programme of work is funded by Ministry of Housing, Communities and Local Government funding to support the welcome and integration of Hong Kong and Ukraine arrivals. Our main mechanism for support is through investment in community-led support services that have trust and reach into communities, alongside coordination, strategic engagement and support for central government and statutory authorities’ delivery of these humanitarian routes and accompanying support programmes. This funding has recently been brought together as part of the Government’s ‘place-based’ approach, and sits alongside wider work for Afghan arrivals, people seeking asylum and refugees led by the LSMP.
2.2.    London is home to an estimated 40-50,000 Hongkongers who have arrived in the UK on the British National (Overseas) visa and our work has supported around 40,000 engagements with members of the Hong Kong community. Now in its fifth year of delivery, this phase of work is focused on building legacy through targeted work with Hong Kong led and specialist civil society, and embedding learning and best practice within service delivery to meet the cultural and linguistic needs of Hongkongers, and ensure a trauma-informed approach.
2.3.    London hosts nearly 30,000 Ukrainians through the Government schemes, alongside many more who have been unable to return home due to the invasion of Ukraine. The funding proposed has focused on support for Ukrainian led and specialist support services in London to meet Ukrainian’s priority needs, including immigration advice and support to help Ukrainians access their rights to residency in the UK.
2.4.    We propose to use funding from MHCLG to fund collaboration with London Councils to support a convening and coordination function as part of our system leadership role, and towards the Migrant Londoners Hub as hosting information online for Ukraine and Hong Kong communities is a requirement of our grant agreement.
2.5.    MHCLG are also providing funding to deliver a new English Language Integration Programme. The programme aims to improve English language learning opportunities and outcomes for specified refugee and migrant cohorts and to support integration through informal learning and community-based initiatives. Funding is split across two strands: capacity building for ESOL provision (£211,784.34) and local-level informal English learning (£423,568.68). However, there is some flexibility to rebalance funding between these two strands. This funding aligns with the Mayor’s Mandate for Supporting Londoners to Benefit from Growth.

Immigration Advice Capacity

2.6.    This programme of work aims to increase the quality and capacity of immigration advice in London. The current lack of immigration advice can leave people trapped in destitution, homelessness, exploitation, and abuse. Many organisations struggle to meet the high bar for qualification, and to work across complex intersects of immigration law and other types of advice, specifically in relation to exploitation in the workplace. There are three programmes of work that deliver this in London, set out below. 
2.7.    The Frontline Immigration Advice Programme grant funds Refugee Action to deliver training and support to organisations on a pan-London basis, enabling organisations to establish or expand their immigration advice capacity at Level 1 and Level 2 IAA – this refers to the Immigration Advice Authority and refers to the necessary qualification of organisations to provide immigration advice and at what level of complexity they can provide advice at. This work has a particular impact for communities who are underserved in both basic and complex immigration advice, both due to limited number of advisors and barriers to mainstream advice provision. This programme targets a specific underfunded part of the immigration advice sector that would ultimately provide an essential future pipeline for other funding including Legal Aid. This year this programme will include an element of focus on serving the Windrush generation and their descendants.
2.8.    The Migrant Employment Rights Programme commissions an organisation to deliver bespoke training on the specific intersection of employments rights and immigration, to address a gap in specialist provision across London. Many migrants experiencing exploitation in the workplace require advice that addresses both the immigration and employment rights issues, but there is a gap in organisations and advisers that are able to work across this complex intersect. This programme deploys extensive training as well as specialist supervision that sustainably upskills organisations. This work is supported by our collaboration with the Citizenship and Integration Initiative, which seconds frontline experts into the Migration Team to provide additional specialism.
2.9.    The Migrant Londoners Hub is a commissioned service that provides access to a centralised source of good quality information and signposting to support Londoners with immigration needs to understand their status, rights and entitlements. The aim is that all Londoners have access to the information they need as early as possible, reducing pressure on advice services and ensuring that people are more likely to seek advice at the earliest opportunity, preventing cases from increasing in complexity and urgency, and the harms caused by immigration precarity.

London Strategic Migration Partnership (LSMP), and migration system leadership
2.10.    Through the work of the LSMP and wider GLA support, this programme steers London through humanitarian crisis, evacuations, and helps to deliver government priorities in relation to asylum, resettlement, and ESOL. It also seeks to effect systems change through targeted interventions that require the GLA’s convening power, with a priority focus on delivering the GLA’s commitment to protect migrant workers from exploitation.
2.11.    The London Strategic Migration Partnership budget primarily covers GLA staffing, with additional funding for hosting the LSMP Board and expenses incurred. The work of the LSMP centres around convening the LSMP Board, its sub-groups and task and finish groups as well delivering core functions to boroughs including matching resettled refugees to accommodation in London. Goals of the Board include enabling London to play its part in meeting national humanitarian commitments, developing new approaches to accommodating and supporting people seeking asylum, and enabling access to high-quality and appropriate English for speakers of other languages to support economic participation, social integration and wellbeing. The team also deliver a core service to boroughs as single points of contact, and providing an accommodation matching service to support boroughs refugee resettlement work – this has so far included enabling over 1,000 individuals to be matched and resettled in London.
2.12.    The LSMP has also received an additional grant of £197,600 this financial year with the aim of protecting vulnerable asylum-seeking people by delivering a trauma-informed therapeutic support service. People seeking asylum in the UK often face profound and complex mental health challenges stemming from experiences of trauma, displacement, and prolonged uncertainty. Many have fled war, persecution, or violence, and may have endured exploitation, bereavement, or torture. The GLA will grant fund local authorities and Integrated Care Boards (ICBs), or their equivalents, in London to deliver this work, with the aim of addressing the needs of groups where there is evidence they have higher needs that are not being currently met by existing services, with a focus on protected characteristics to improve equality and inclusion. 
2.13.    The Migrant Advisory Panel supports our convening and system leadership work through the inclusion of lived experience, in recognition that structured consultation and co-design with migrant Londoners themselves enables stronger and more relevant GLA programmes. The Panel reflects all types of immigration status and supports the GLA Group to understand the intersecting needs of migrants who face additional barriers and vulnerabilities. Their work to date has included input into the Good Work Standard, the Policing and Crime Plan and the GLA’s ESOL Strategy. A partner organisation is commissioned to deliver this support.
2.14.    The Humanitarian Response capacity fulfils a necessary part of London’s resilience to humanitarian and migration crises, interacting with London Resilience Structures and often directly taking the lead where crises fall outside of Gold Command Structures. To date this has included the initial response work on Afghan and Ukraine arrivals, dealing with evacuation of British nationals and their families from conflict zones and addressing urgent challenges including the transition to e-visas and various acute asylum pressures as they arise. This is reactive funding to support the Migration Team to be agile towards responding to humanitarian need, with new crises emerging during most years this funding has enabled the team to convene emergency summits, and rapidly deploy funding to meet urgent advice and information needs in London. This funding further supports capacity within London Councils through a direct grant fund to facilitate work with boroughs and to enable ongoing shared leadership.
2.15.    The Modern Slavery programme is investing in commissioned research in collaboration with MOPAC to create a blueprint for safe reporting of migrant victims of crime, with a particular focus on migrant victims of slavery and survivors of violence against women and girls. Migrant victims of crime often fear reporting to the authorities, out of fear of being referred to immigration enforcement – something often manipulated and weaponised by abuses to further their control. This research furthers our understanding of practical ways to progress statutory services’ desire to support victims and safeguard them from harm through enabling a victim first approach, and work towards a firewall for migrant victims to safely report crime. This work is supported by our collaboration with the Citizenship and Integration Initiative alongside the Employment Rights programme outlined above.

2.16.

3.1.    Under section 149 of the Equality Act 2010, as a public authority, the GLA must have ‘due regard’ of the Public Sector Equality Duty, that is, the need to:
•    eliminate unlawful discrimination, harassment and victimisation
•    advance equality of opportunity
•    foster good relations between people who have a protected characteristic and those who do not.
3.2.    Equality, integration and inclusion are the drivers behind these programmes. All these programmes seek to tackle the inequalities that pose barriers to migrants, refugees and people seeking asylum. These barriers can prevent Londoners from fully participating in their communities. The related work of these programmes includes improving access to services that, in turn, promote Londoners’ access to their rights and entitlements.
3.3.    Any commissioning and grant-making processes will ask potential partners to demonstrate how their projects: are inclusive of a diverse group; and actively work to eliminate discrimination based on the nine characteristics protected in the Equality Act 2010. To ensure the highest standards of equality, diversity and inclusion are upheld, the GLA will use outreach and engagement approaches to target activities at particular groups that are less able to engage, or face greater barriers to engagement. This will enable them to participate, while ensuring that activities are open and accessible to all Londoners.
 

4.1.    The risks and mitigations are outlined in the table below:

Conflicts of interest
4.2.    There are no conflicts of interest for any of the officers involved in the drafting or clearance of this decision form. Appropriate mitigations will be put in place throughout all tendering and grant programmes to remove relevant officials from a decision-making role regarding funding where any conflict does arise. This applies to GLA officers and those funded to deliver work on our behalf. All commissioned services will be procured competitively in accordance with the Contracts and Funding Code.
Links to Mayoral strategies and priorities
4.3.    This work sits under the Mayoral mandate and associated delivery plan for Accommodation and Support for those who need it which has a focus on vulnerable migrants.
Consultation and impact assessment
4.4.    The design of this programme has been informed by research and engagement with specialist partners working in the migration sector and delivery will be shaped through our governance structures including the Migrant Londoners Panel.
Subsidy control 
4.5.    GLA officers have carried out an analysis of the proposal against the Statutory Guidance for the UK Subsidy Control Regime (“Statutory Guidance”). Officers have assessed that the Subsidy Control Regime does not apply to the proposed award of grant funding to either Refugee Action or London Councils because the proposed financial assistance to both does not meet all four limbs of the four-limbed test.
4.6.    In particular, the proposed financial assistance fails to satisfy Limb B of the four-limbed test set out in the Subsidy Control Act 2022 (the SC Act), as the beneficiaries of the funding are not acting in the capacity of an enterprise.
4.7.    The rationale is that:
•     whilst Refugee Action undertake some limited ancillary economic activities, it’s primary purpose and that in respect of which the funding is to be awarded to provide support to refugees on a non-economic basis. The Statutory Guidance provides that such financial assistance is unlikely to satisfy Limb B of the four-limbed test.; and 
•    London Councils is a public body, specifically a joint committee established pursuant to the Local Government Act 1972 and the activity in respect of which the funding is proposed to be awarded is non-economic in nature and concerns London Councils’ discharge of its public functions. Again, the Statutory Guidance provides that such financial assistance is unlikely to satisfy Limb B of the four-limbed test.    
 

5.1.    The Mayor’s approval is sought for:
•    expenditure of £590,000 of GLA budget for 2025-26 as part of programmes to increase capacity of immigration advice and migration system leadership within the Accommodation and Support for Those Who Need It mandate.
•    receipt of up to £388,000 of grant funding from the Home Office in 2025-26 financial year, and expenditure of the same, to meet costs related to the delivery of the London Strategic Migration Partnership
•    receipt and expenditure of up to £480,483 of grant funding from the Ministry of Housing, Communities and Local Government (MHCLG) for the delivery of coordination work on Hong Kong and Ukraine arrivals.
•    receipt and expenditure of £635,353 from MHCLG on ESOL capacity building, split across two strands: capacity building for ESOL provision (£211,784.34) and local-level informal English learning (£423,568.68) with some flexibility to rebalance funding between these two strands.
•    receipt and expenditure of £197,600 from the Home Office on work to support the mental health and wellbeing of people seeking asylum.
5.2.    This expenditure is detailed below.

5.3.    The Expenditure of £590,000 will be funded from the GLA Migration Support budget in 2025-26 financial year and it is included in the GLA budget approved in February 2025.