Impact, impact, impact…. It’s a bit like the “location, location, location” of the voluntary sector! We hear it time and time again, but understanding it can be a bit puzzling and frustrating. Where do I start, what do I capture, how do I do it…sometimes we allow other pressing priorities to move it to the head-scratching pile for a little while longer!

This sums up where we, and many of our members in the Lesbian, Gay, Bisexual and Trans Plus (LGBT+) sector were last year. We knew impact was important, but were unsure of where to start.

Then along came the Consortium’s Connect Fund project. We began our social investment journey knowing there were glimmers of potential within LGBT+ organisations, but needed space to think these through before we jumped in with the solutions. I remember describing the need for our project, but being quite honest that the end product was a bit unknown.

We were delighted to be given the opportunity by the Connect Fund to allow for those supportive head scratching moments. Our project now has the potential to transform the LGBT+ sector – in terms of social investment and with much wider implications.

The light-bulb moment came at the end of the opening phase of the project, capturing where the LGBT+ sector was and what might be the solution. Of course, there wasn’t just one solution! There are many. Straightaway we knew that one of the massive roadblocks preventing LGBT+ organisations from accessing social investment was the lack of coordinated approaches to impact. How can we ask investors to engage with us if we can’t properly articulate both the financial and social returns we are offering?

Working with our fabulous consultants Traverse, who have deep understanding of diversity issues and outcomes and impact measurement, we all got rather excited when we realised what we needed was an LGBT+ Outcomes Framework.

Yes, I know, there it is, my infrastructure geekery was in overdrive. We knew there was only one way to make this work, and that was collaboration. So we pulled together a cohort of 6 LGBT+ organisations to join us on this journey. Six months later, we are ready to publish an LGBT+ Common Outcomes Framework. What it means for us is incredibly exciting. For the first time we can set the challenge to the LGBT+ sector to articulate what we all do as specialist organisations in a common way, whilst still allowing for individual nuancing.

With these common areas at the forefront, we can begin to think about the data we capture and how it is presented to create long term change for individuals. As simple as it sounds, this is game-changing for a small sector like the LGBT+ sector. It opens up new doors many having been trying to push for many years, with limited success.

Of course, this is just the beginning of the story. Now that the light-bulb is on we have no intentions of switching it off.

LGBT+ Consortium will be leading the charge by adopting this new Outcomes Framework as the basis of our Strategic Plan, and challenging others to follow suit. The hope is, by articulating impact well, we will for the first time open up future social investment, and build long-lasting sustainable LGBT+ organisations.

LGBT+ people and communities are far more visible than ever before. With this enhanced profile comes a responsibility for the sector to move to maturity. I am so very excited that LGBT+ organisations want to be at the forefront of doing things differently and articulating the difference we make for individuals in need.

Paul Roberts OBE is Chief Executive of LGBT+ Consortium, a national specialist infrastructure and Membership organisation, which focus on the development and support of LGBT groups, organisations and projects so they can deliver direct services and campaign for individual rights.

This blog has been cross posted from the Connect Fund. 

A new conversation on economic growth is certainly welcome. Over a decade on from the Financial Crash of 2008 and subsequent recession here in the UK, massive inequality persists, both between and within regions. That the UK economy has the highest levels of regional disparity among OECD nations demonstrates the structural imbalances that inclusive growth seeks to address, to ensure that the benefits of economic growth are shared across every section of society – both across and within regions and places.

How inclusive growth can be developed in practice is the core question underpinning a new NLGN research project we are undertaking in partnership with Barrow Cadbury Trust. We will draw on current practice from the front line of strategy implementation and service delivery. Through a series of peer learning workshops, we will share current experience, including key challenges that organisations pioneering inclusive growth interventions have experienced, and also generate new ideas. These conversations will help to inform practitioners’ approaches. The research will also explore how communities can be placed at the heart of inclusive growth strategy and delivery, following NLGN’s vision for the future of public services as set out in our Community Paradigm report.

Our goal at the end of this process is to have brought some practical clarity to the debate around inclusive growth and to have established concrete steps through which practitioners can develop their own frameworks for action. A final report will be published in January of 2020.

Charlotte Morgan and Trinley Walker

This blog was originally posted on the New Local Government Network (NLGN) website

If you would like to find out more about the project or get involved, please contact Charlotte Morgan or Trinley Walker: [email protected] – [email protected]

“Thank you very much Massimo for those very generous words and for this most astonishing award. I must say I am really stunned, although I am sure as usual I won’t be lost for words.

I am a great believer that awards and honours are symbolic of the achievements of many hands and not of one person alone. In our foundation we work on structural change for social justice ends across a variety of disciplines. Structural change can never be brought about without many hands working together over a sustained period of time augmented with hefty doses of savvy, luck and timing. So an award to me is an award to all those many hands we work with in our own foundation, in other foundations and in civil society and beyond.

As an award though, this also comes at an opportune time, showing solidarity with us in the UK who remain determinedly European in the face of our impending changing status in the European Union. Thank you to the many of you who have extended the hand of friendship to us. And, of course, this is an award for all us women who have contributed to philanthropy over time and to the EFC itself over the past 30 years.

My first EFC board meeting was the 20^th anniversary nearly 10 years ago. I was shocked to find only three other women in a roomful of 30 or so men. I want to pay tribute to those women – Ingrid Hamm, first Vice Chair, Suzanne Siskel and Betsy Campbell, who looked after me that week and have been a source of inspiration since.  And to the men who supported us over the intervening years and even at times stood aside.

EFC governance has changed dramatically since then.  Our first woman Chair Ewa Kulik-Bielińska brought a freshness to the role as a central/Eastern European. Many other women colleagues have stepped up and contributed greatly. This diversity is crucial as I passionately believe that no good things flow from poor governance, wherever or whatever we are doing.

We are living in difficult times and facing many challenges. As we have explored over the past couple of days, there are threats to liberté and egalité which we must all play our part in changing.  We started the conference by equating ‘philanthropie’ to fraternité and I will add sisterhood to that and frame them together as solidarity. Sisterhood is powerful!  As Antti Arjarva reminded me we are a broad church working in a wide variety of fields: research, climate change, culture, medicine, education and much more. Yet the key European values of liberté, egalité and solidarity can and must run through them all.

So let us all go back to work next week seeking to work in a spirit of equality and solidarity, using all the assets at our disposal to protect liberty, to increase equality and to keep improving the governance of our own organisations and that of those we support.

Thank you to all my EFC colleagues – Gerry and the staff and governing body – and of course to our own fabulous board and team at the Barrow Cadbury Trust.”

‘Liberté, Egalité, Philanthropie’ was the focus of this year’s EFC (European Foundation Centre) Annual General Assembly (AGA), and while interesting discussions of freedom and solidarity flowed among the many philanthropic institutions gathered in Paris, it was the talk of equality that resonated most with me over the three days.

The main plenary on égalité posed a call to action for foundations – to utilise their resource, their influence and their freedom of decision making to invest in systemic and structural change. The role of philanthropy should be to tackle the inequalities that current governments and markets are failing to address. While foundations cannot – and should not – try to replace the state, they have an obligation to support innovative solutions to challenges so they can prove their worth. As was pointed out during one of the Next Generation talks I attended, the money we as foundations have is in essence risk capital – we don’t expect to get it back, so we need to be bold with it. While that doesn’t mean the abandonment of good governance, there is an argument for us to take risks where the public sector cannot.

Through the work we support and partnerships we develop as a sector, we are able to see patterns of change emerging. We are able to help identify the barriers to equality that people face now and see what may be the next great struggle for civil society. This, along with our resources, gives us a power that we must own in order to fight for change. Dhananjayan Sriskandarajah, Oxfam GB’s Chief Executive, highlighted that this long-term view was a privilege of foundations. We are not curtailed by political pressures or market changes; we can invest in a vision for the future and, most importantly, see it through. This means not only repairing the problems of today but tackling the root causes of inequality to create a fairer and more just society.

We are in the midst of a climate emergency and, as Mary Robinson explained in one of the sessions, inequality is only going to become more stark over the next ten years unless we act now. One of the closing remarks was that structural change is the work of many hands, and it is the responsibility of the philanthropy sector to use its convening power to build bridges between the private sector and civil society to work together towards a common goal. Our sector has a unique voice and now is the time for us to use this in even more decisive ways.

Liz Hayes is Assistant Manager at Connect Fund, Barrow Cadbury Trust.  This blog was originally published in Alliance magazine.

68 CEOs in the FTSE 100 earn more than 100 times the average UK worker’s salary, while almost four million (1 in 8) workers in the UK are living in poverty. How many of these business leaders have gone into the New Year with a resolution to address this disparity? Though the causes of in-work poverty are complex – with state structures, institutions, the market, an ineffective benefits system, and individual circumstances all playing their part – side by side, these figures are baffling and shine a light on some of the stark economic imbalances in the UK today.

Although UK employment rates have risen, they are still lower than they were a decade ago. At the same time, the UK’s productivity continues to decline or flat-line. There is also a concerning high number of precarious roles which are often concentrated within the lowest paying sectors in the UK.
In September 2018, the IPPR Commission on Economic Justice called for fundamental reform of Britain’s economy, finding that “the UK is being held back by a business culture dominated by decades of short-term profit taking, weak levels of investment and low wages.” This was shortly followed by a report issued by the UN’s Special Rapporteur on extreme poverty and human rights which chastised the government’s “punitive, mean-spirited and often callous approach” to poverty in the UK. In December 2018, JRF called for reduced housing costs, a strengthened social security system, and better-paid employment to reduce the number of people swept into poverty.

68 CEOs in the FTSE 100 earn more than 100 times the average UK worker’s salary, while almost four million workers in the UK are living in poverty.

From an investor perspective, the status quo calls into question to what degree businesses are embedding social, environmental and governance (ESG) responsibilities into the heart of what they do. Failure to take these factors appropriately into account has serious negative repercussions for workers and their families, and it also creates, drives and underpins a range of financial risks. This is bad news for institutional investors for whom long-term and sustainable returns from investee companies are vital.

As investor understanding related to the financial materiality of the quality of work and company labour practices gains more depth, interest in workforce policies and practice is on the rise. Also, increasingly more and more investors are motivated by the moral case to act: that this is the right thing to do and that business success can be delivered on a stakeholder model that benefits workers and society as well as shareholders.

ShareAction – with the support of JRF and Trust for London – recently published an investor briefing called Influencing UK Workforce Practices through Responsible Investment. Not only do we want to strive for 100% Living Wage accreditation across the FTSE, but we also need companies to demonstrate leadership on a range of workforce practices. If we want to see systemic change for the better, improvements are necessary across the board – from tackling endemic levels of modern slavery, breaking down barriers to freedom of association, increasing worker representation, addressing the rise in precarious jobs, to ensuring fair pay and equal opportunities for all.

Investor engagement and shareholder activism can reprogramme the economy for the creation of safe and prosperous communities supported by good, fairly-paid jobs.

Ongoing and better-aligned corporate engagement by investors has the potential to drive significant progress within publicly listed companies in the UK. Now is the time to develop opportunities for strategic collaboration and ramp up broad-based engagement on common themes that affect UK workers. In 2019 ShareAction will be exploring how to build on our long-standing Living Wage campaign to do just this. Investor engagement and shareholder activism can help to reprogramme the economy for the creation of safe and prosperous communities supported by good jobs. And the work’s already begun.

This blog has been cross-posted from Share Action and written by Mara Lilley, Senior Campaigns Officer, Share Action

Two years on, what has the Connect Fund achieved?  Since its launch in June 2017, £2.2 million has been disbursed to 51 projects across nine regions in England. A further £500,000 was committed alongside the Connect Fund by external funders to match or part fund these projects. The Connect Fund has built online and face-to-face learning communities which have highly encouraging buy-in and participation. While only 20% of these projects have finished, some initial outputs and interim findings can be shared.

Connect Fund projects to date have delivered:

• 234 new connections, collaborations and partnerships between social investment intermediaries and social sector organisations
• 265 social sector infrastructure staff received social investment training
• 126 peer support visits by VCSEs to learn about social investment
• 2,000+ hours of enterprise development support delivered to VCSEs
• 84 social investment events were held

See this data in a visual format in this short animation.  The Connect Fund uses both quantitative and qualitative evaluation methods, independently supported by NPC, to gather critical feedback on its effectiveness. An external survey has found that 59% agree there are better connections between social investment intermediaries and VCSE infrastructure organisations, and 91% strongly agreed or agreed with the statement that the Connect Fund supports collaborative working. Over one-third of respondents specifically mentioned increasing connections, networks or partnerships as a result of Connect Fund projects.

Champion voluntary sector infrastructure

Voluntary sector infrastructure organisations are building the knowledge and skills to support enterprise development and social investment. These initiatives have created an ecosystem of social sector support organisations that champion social investment and develop pathways to enterprise. Infrastructure organisations have created clusters of activity for skill development, awareness-raising, communities of practice and peer learning to advance knowledge of and engagement with social investment. The focus has been to avoid duplication by strengthening anchor institutions and linking voluntary sector infrastructure to existing resources such as Good Finance. The early foundations are being laid for a voluntary sector that is informed and engaged with social investment with the potential to underpin place-based initiatives across the regions.

Catalyse market initiatives

The Connect Fund has bridged gaps in the market by funding joint initiatives. The social investment sector is increasingly evolving to focus on blended, flexible or patient finance. In a fragmented market, the need for innovative, more inclusive and collaborative problem-solving is evident. The Connect Fund has supported projects to improve market information, open data sharing, and strengthen sector networks. As our funding evolves, we will move from a general approach, to more strategic alignment to ensure effectiveness, drive further collaboration and ensure the legacy of interventions.

As a result of Connect Fund projects, Social Enterprise UK, Women in Social Finance, UK Community Foundations, Responsible Finance, VONNE and many other regional networks like Social Enterprise East of England have been more engaged with social investment. Across multiple issues, the Connect Fund has provided the first risk finance to intermediaries and infrastructure organisations working jointly to solve challenges.

Convene new voices for social investment

A priority for the Connect Fund is to increase the diversity of voices in social investment. This means regional diversity to broaden a London-centric market, and diversity in terms of the protected characteristics of race, gender, sexual orientation, and disability, among others. In addition to funding across the 9 regions, the Connect Fund actively supported 9 diversity projects.

The Connect Fund was the sole funder of the Diversity Forum, a much-needed, timely and insightful coalition of social investment intermediaries committed to expand the diversity of investment decision-makers. In addition to its learning community events, the Connect Fund helped to convene The Gathering for 150+ social investors in Leicester. This was a co-created event for the sector, by the sector that took over one year for the Steering Group to organise, as a key means of sharing learning and driving collaboration.

What does this all add up to?

The work of the Connect Fund is not done. Local infrastructure is vitally important to place-based initiatives and social investment at a time when the market is highly fragmented. We will continue to advocate for the value of supporting social investment infrastructure. Resource to drive forward collaboration to fill gaps in the market remains essential. Challenges remain to be solved.

In partnership with Access, the Connect Fund has a role to play in championing infrastructure, promoting collaboration, convening new voices and catalysing enterprising initiatives. Let us know if you would like to be part of building these solutions.

http://www.connectfund.org.uk/

https://twitter.com/connectfund

What is the difference between a single parent starving themselves to feed their children, an elderly person unable to get out of bed because they can’t afford to heat their home and a person developing a mental health condition due to debt crisis? The answer is “absolutely nothing”, if you think about it in financial terms.

I didn’t know until I started campaigning for change that it costs more to be poor! Many services and products that are essential to daily living have extra charges attached, and premiums are paid by people struggling to make ends meet that mean they find it even harder to survive. The list below is just a few of the ‘poverty premiums’ encountered:

• Energy tariffs
• Prepayment meters
• Paying for insurance in instalments
• Higher insurance policy prices
• Convenience shopping
• High-cost short-term credit (e.g. payday loans)
• Travel costs
• Life emergencies (e.g parking at hospital, prescription charges)

These premiums are something I had been unaware of throughout the eternal money struggles of my daily life.

The everyday costs of the Poverty Premium

It was a foregone conclusion that council housing had prepayment meters for electricity and gas. Of course, I wasn’t allowed an overdraft or credit card – they were for people far better off than me, the “normal” people. Contents insurance was a luxury, but I hadn’t got anything worth stealing anyway! That being said, the policy payments would have been high as we always were always housed in “high-risk” areas. The only way I could afford anything half decent was using doorstep lenders and high cost credit like shopping through rent to own lenders.  The problem? 47% interest.

What could make life easier?

Obviously more money. Despite working at every opportunity I could, and not wanting to rely on handouts, insufficient benefits payments and poverty wages are the reason so many people find themselves living in poverty in the first place. However, an eradication of those Poverty Premiums would have made my money go further, maybe help to make ends meet. An average amount of £490 per year could be saved for low income households if such premiums didn’t exist.

Payday lenders, rent-to-own retailers and credit repair credit cards could reduce or eradicate high interest charges. Energy companies that rely on loyalty, need and not always best practice, coin in huge profits off standing charges and high-priced tariffs. Reducing their charges in line with direct debit customers and realising that one size does not fit all would go a long way to helping.

Social housing making use of furnishings left by previous tenants could stem the need to use payday loans, rent-to-own and doorstep lenders, leaving more available funds to prevent tenants getting into rent arrears. The regulation of high cost lenders by capping interest rates will definitely help the extraordinarily high use by struggling households.

How would you feel?

Just take a minute to calculate what you class as the necessities and daily spending that cannot be avoided in your life. How would you pay for them if your existing finances were not available? Would you be outraged at the hidden costs you would be forced to pay?

Let’s get the message out there to the people, businesses, housing companies, government, industry and regulators.

Alicia Vernalls

The Poverty Premium can sometimes come over as an ethereal concept, so it’s the concrete examples that really bring it alive. These are the ones where it’s clear that the people impacted are being driven into yet more poverty because of it.  The way the Poverty Premium impacts on them is clearly an injustice. These concerns hit me squarely when reading the February 2019 column by Michelle Edwards in independent local newspaper, the Waltham Forest Echo. Edwards is a campaigning journalist and a Marlowe Road Estate resident in the London Borough of Waltham Forest. Her piece on the newly completed affordable housing block on the estate as part of its regeneration programme raises a particular concern for those residents in relation to their energy provision.

Energy costs for people in poverty are the biggest driver of the Premium, so when we saw her piece we thought it was really important to highlight it as a part of our involvement in the APPG on Poverty Inquiry into the Poverty Premium.

Edwards told me “All the new and existing tenants moved into the block as part of the regeneration development were given an eleven-page Residential Heat Supply Agreement for their heating and hot water.” The dictated terms in the Agreement for their method of payment is a pay-as-you-go prepayment meter. In her words, “Having a prepayment meter almost always means paying more than you need to for energy bills. Not only is the unit price for energy more expensive with a prepayment meter, but the cheapest tariffs offered by energy suppliers are usually not made available for prepayment customers. The council may at its own discretion vary the energy tariff rates for the supply of energy at any time. As it stands, the meter is the only option available to residents”.

According to the piece, payments for the prepayment meter are managed by a third party called EEMonitor. Of the residents she spoke with each had reported problems with their meter. “Apparently the top-ups disappear at an astonishing rate.” One tenant told her he moved in on 12th December 2018 to find his meter was already showing a reading of minus £5. Apparently, the construction workers had left the heating on. Up to 20 January, the tenant had put £60 on the meter.  As a disabled occupant he can only afford to turn his heating on for one hour a day. In another of her examples for a similar period, a household had spent £70. The children of that household were told to cut down their showers and only turn the heating on when absolutely necessary. A third resident she met required consoling in the foyer. His mother has a medical condition that affects her bones. In order to keep warm, she has to stand up against the radiator.

This is the stark reality of how people are being locked into extra charges for their energy. There are many more across the UK. There must be a better way to support poor and vulnerable communities to enable them to make ends meet rather than locking them into yet more hardship. We hope the APPG on Poverty Inquiry into the Poverty Premium report makes a real difference to those on the ground who, like the Marlowe Road residents, are struggling to keep their heads above water. It’s time for action.

Lucie Russell

Fair by Design is a movement dedicated to reshaping essential services, like energy, finance and insurance, so they don’t cost more if you’re poor.  People in poverty pay more for energy, finance and insurance than those on higher incomes.  This is the Poverty Premium.

Following the dramatic defeat of Theresa May’s Brexit deal in the UK Parliament this week, all bets are off when it comes to whether the UK will crash out of the European Union on 29 March without a Brexit deal. A no deal scenario would have seismic ramifications for the legal residence, work rights, benefits and pensions, and health care for nearly 1 million UK nationals living on the continent. But 30 months after the Brexit referendum, and with the hourglass running out on the UK’s fated departure, EU-27 Member States are finally starting to offer some reassurances on citizens’ rights.

Contingency planning regarding citizens’ rights – the status of more than 3 million EU nationals in the UK, and UK nationals in the European Union – had been shelved, despite considerable consensus on this topic throughout the UK-EU negotiations. This was in part because citizens’ rights were seen as an important bargaining tool by both sides. And the European Commission, keen to avoid breaking the bloc, imposed a moratorium on bilateral discussions with the United Kingdom outside of official negotiations, a prohibition that filtered through to officials in Brussels literally taking pains to avoid each other on the street. Yet with the 29 March Brexit Day looming and No. 10 Downing Street and Westminster trapped in mazes of their own making, the European Commission recently has shifted to Plan B, urging Member States to take a ‘generous’ approach to protecting UK nationals in the case of a no-deal Brexit.

Until recently, Member States released few details on what their plans would include. France was first to the table with a draft legislative proposal in October that, among other things, would enable Brits working in the French government to avoid a general prohibition on employment of third-country nationals for certain civil service jobs.

In December, Italy announced it would allow all current registered or permanent residents to stay. In early January, the Dutch government published its plans for a 15-month transition period in the case of no deal, during which all municipally registered British citizens will be able to apply for a national residence permit on the same basis as other EU nationals. And the Spanish government has promised a contingency plan is forthcoming, and in the meantime agreed a partial deal with the UK government on voting rights. It is likely other Member States will follow suit over the coming months.

Gaps in the contingency planning

But are these announcements all too little, too late? Time is extremely short to address the multiple complex issues thrown up by a no deal, from qualification recognition to health care and pensions. And given many of these issues will require bilateral agreement, there are significant questions about timing and stopgaps to avoid temporary chaos.

Among the major outstanding questions as governments step up contingency planning:

How will negotiations move ahead on issues that require bilateral agreement?

While much is possible through unilateral action, including granting residents the right to stay and access to labour markets, other areas, such as social security co-ordination, require bilateral agreement. For instance, retirees are concerned they will miss out on annual inflation-related increases to their pensions (known as uprating). Gaps in health care coverage could arise both for UK nationals resident in the EU-27 and for British visitors accustomed to the existing scheme of free or low cost reciprocal medical treatment. While the UK government introduced a bill that would establish a legal framework for reciprocal health care, it takes two to tango. Member States have been instructed by the European Commission to ‘refrain from entering into bilateral agreements, arrangements, and discussions with the United Kingdom’. The European Commission is trying to balance two competing priorities: Its desire to underscore the significant costs that come with no deal, and chaos minimisation for companies and citizens. But there is only so much that is possible to achieve unilaterally, and waiting for the deal to be unequivocally dead may mean waiting till Brexit Day – when many UK nationals will be left unprotected. Moreover, bilateral deals take time to negotiate, not to mention ratify and implement.

Another option is for the European Commission to provide a stopgap of its own, essentially ringfencing the citizens’ rights aspect of the deal. While it is unlikely that the Commission would move ahead with this while the withdrawal agreement is still nominally in the UK government’s in-tray, it could start preparing on this front.

What happens to people who fall through the cracks?

The stopgap systems already announced by Italy and the Netherlands will be based on municipal registration systems, but many countries lack full registration for all resident UK nationals. In some countries, barriers to registration have pushed many mobile EU nationals into a state of limbo. In Sweden, for instance, the requirement to have a permanent employment contract makes it hard for EU nationals to register for a personnummer. In other places, registration has not been required, enforced, or encouraged. And countries with large numbers of seasonal residents, such as Spain and Cyprus, are thought to have chronic levels of under-registration – a problem that especially affects pensioners, as an MPI Europe report recently noted.

Countries without compulsory registration may have to consider introducing new systems for UK nationals to register. But then the question arises as to what documentary evidence will be required. Any requirement to show backdated documents, such as evidence of years of work or residence, necessarily creates a trade off between inclusiveness and deterring fraud: you either choose to accept almost any documentation (making it possible that UK nationals could move to any EU country in the future and claim they entered before the cut off date) or impose certain requirements (running the risk that some will fall through the gaps).

Deal or no deal, questions remain whether people will be required to show evidence of legal residence in order to be able to stay – this could include evidence of comprehensive health insurance for students and the inactive, although Italy has promised to drop this requirement following the UK promise to do so in relation to EU nationals. (Last summer, the UK government promised to secure the status of UK-resident EU nationals regardless of the outcome of negotiations through its new ‘settled status’ system, which is already being trialled – albeit with some teething problems, including a lack of support for applicants and reported issues with data privacy).

Those forced to return to the UK could also be confronted with challenges. Returning UK citizens with medical and financial vulnerabilities could face delays accessing the National Health Service and benefits reserved for those ‘ordinarily resident’. And without so called ‘Surinder Singh rights’, UK nationals with non-British family members would again have to meet UK income requirements for family migration – upwards of £22,400 for a partner and one child. Mixed status families could be especially affected, according to a recent MPI Europe analysis.

How can Member States ensure orderly processes?

Especially in localities with large numbers of British residents, processing residence applications after Brexit could overload already burdened immigration offices. Dordogne, France was already struggling with the carte de séjour system, which in July was booked until October, causing Brits to incorrectly book up the appointments for non-Europeans. Germany has promised that British citizens will have a three month grace period after Brexit Day to possess a German residency title. The Berlin immigration office points out that it coped with the refugee crisis and can handle the increased workload. But it also asks for patience: An estimated 15,000 registered UK nationals in Berlin will need to book an appointment within that three-month window.

When the stopgap is the best option

While contingency planning for UK nationals after Brexit is a positive step given the sheer unpredictability of how the British Parliament will resolve the current chaos, there is too little time to address all issues. At most one can hope for a stopgap. Existing deficiencies in municipal registration systems and barriers to accessing health care are likely to be amplified hundredfold by a no deal Brexit – in ways that cannot even be anticipated yet. Those who are currently vulnerable are likely to remain vulnerable – or worse.

Michelle Mittelstadt is Director of Communications and Aliyyah Ahad is Associate Policy Analyst  at Migration Policy Institute and MPI Europe