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Home Office age assessment inspection: Insights for local councils

03 October 2025
Miya Watson

Age assessments are crucial in determining the support and legal rights of young migrants, yet they raise significant ethical and accuracy concerns.

This article summarises the Home Office's inspection and outlines the responsibilities of local government during the age assessment process to ensure compliance.

The investigation, An inspection of the Home Office’s use of age assessments (July 2024 – February 2025) - GOV.UK looked into the Home Office’s use of age assessments, their effectiveness, the challenges encountered, and the recommended reforms to ensure fairness and accuracy in handling vulnerable individuals within the asylum system. 

Local authorities and their social care workers can use insights from this investigation to enhance their internal procedures and training. Those improvements could significantly fortify the age assessment process, leading to more robust and reliable outcomes and reduced costs

The key findings of the investigation:

1. The inherent difficulty of age assessments

Chronological age is difficult to assess on solely on physical appearance or demeanour. Physical appearance can vary due to an array of factors such as ethnicity, environment, and the trauma suffered by the presenting individual. Countries such as France and Spain use scientific and medical methodologies to determine age, by examining bones and teeth. However, these additional tests have significant margins of error, carry ethical issues and cannot be used as standalone evidence to settle an age-dispute claim.

2. Initial age decisions made upon entry into the UK 

When migrants arrive into the UK initial age assessments are made by border control in order to determine what next steps are required for everyone. However, these assessments are often compromised due to the large arrival numbers, the pressure for staff to process new arrivals quickly, and the mental and physical state of the migrants upon arrival.

Those conducting the initial age decisions often lack training, usually learning off “more experienced” colleagues or simply “learning on the job”. New training was piloted but during the investigation and by late 2024, a majority of staff were still yet to receive it, leaving inconsistencies on how staff are to approach initial age decisions.

The lack of effective and reliable communication between officers and migrants also causes difficulty within the initial decision process. For example, “statement of age” forms are put to migrants to sign when it is believed they are over the age of 18. By signing this document, they ‘admit’ that they are an adult.

The investigation reported that due to the lack of communication and understanding, migrants often felt pressured to sign out of fear, or simply did not understand what they were signing. Further, the approach taken by officers when interviewing new arrivals was deemed inadequate. There was a failure of assessing officers to take into account cultural background and differences, alongside insensitivity towards the trauma the migrants will have faced throughout their journey.

3. The age-dispute process and local authority age assessments 

Following these initial age decisions, local authorities have the responsibility of conducting Merton-Complaint Age Assessments for those that qualify. The report recorded a sample of 100 cases: 38 people were initially assessed to be adults by the Home Officer upon entry into the UK and disputed this.

Of the 38 disputes, 22 were found to be children by the local authorities and the Home Office accepted the revised age in many of those cases. In effect the lack of training and knowledge of staff at the initial decision stage meant local authorities had to take on the increased pressure of re-assessment on already-stretched resources.

The investigation found that local authorities must also assess the “spontaneous arrivals” of migrants who are dispersed to their area after being assessed as an adult, which they subsequently dispute. These “spontaneous arrivals” create many difficulties, including increased costs and stretched resources. These impact accommodation, legal and support services, and staff availability/capacity to conduct the assessments in a timely manner.

4. National Age Assessment Board (NAAB)

The National Age Assessment Board is intended to be a body to conduct Merton-Complaint Age Assessments on behalf of the local authorities. Its aim is to reduce burden, improve the consistency of assessment and share expertise.

Whilst the NAAB has been a great support for local authorities and the age assessment process, there are still issues regarding staff vacancies, capacity and assessment turnaround. Limited staff availability and the lack of capacity to conduct assessments, means on average, it takes the NAAB 54.6 days to complete an assessment. Only a small fraction of claims meet the 28-day turnaround target.

5. Data, transparency, safeguarding and quality assurance

The investigation concluded that particularly during the initial stages, quality assurance focussed on whether all the relevant paperwork has been completed so individuals can be processed as quickly as possible, rather than the substance the decisions made. This means migrants are often left without adequate reasoning as to why they have been assessed as an adult. Local authorities often have to rectify these mistakes by re-assessing multiple individuals.

Record keeping and data collection is very patchy. There was limited data available to see how many initial age decisions have been overturned, or how many individuals dispersed as adults are later found to be children. 

The lack of concise record keeping and data collection, prevents the Home Office from highlighting trends and re-evaluating their initial processes to uphold their duty to safeguard children, young people and young adults with vulnerabilities – something which is often missed during the initial stages.

Key recommendations

The report puts forward the below recommendations for the Home Office to review and rectify:

  • Improve and evaluate the training for initial age decision makers, involving local authorities and the NAAB, who will be able to offer expertise.
  • Publish clearer guidance on the “Statement of Age” document and its process, to ensure that individuals are aware of what they are signing and the consequences.
  • Enforce a set standard for triage, interviews, decision making and record keeping, ensuring procedures are followed, consistency is maintained, and substantive decisions are made rather than simply focussing on whether relevant paperwork has been completed.
  • Collate detailed data to provide local authorities on dispersed age-disputed individuals so they can plan services, accommodation and safeguarding based upon the demand in their area.
  • Ensure NAAB’s role and capacity is clarified, they are properly resources, such as staff recruitment, and provide clear guidance on the prioritisation of referrals and its support to the local authority.

What does this mean for local authorities?

Local authorities are expected to re-assess all age-disputed individuals under Merton, alongside “spontaneous arrivals”. They have to provide accommodation, support and services during the assessment period, which can take months to complete. Local authorities are unable to plan or budget the necessary resources required when there is limited data available relating to the number of age-disputed individuals dispersed in their area.

The stretch and stress on resources subsequently results in age assessment delays which leave individuals in limbo, and adds complications to placements, childcare, and other entitled services.

The inconsistent process, lack of training, poor record keeping and limited data increases the risk of mis-classifying young people as adults and subsequently placing them in adult accommodation, risking potential abuse. Additionally, there is the potential risk of adults being placed with children if assessed incorrectly.

Whilst this is a multi-organisation issue, local authorities can contribute to the improvement of the age assessment process:

  • Provide staff with full, comprehensive training on Merton Complaint Age Assessments and procedures to ensure staff all consistently follow protocol, and keep detailed records to enforce robust assessments. Ensure staff take into account vulnerabilities, trauma, cultural background, physical and mental health factors during the assessment, with care.
  • Keep detailed records of age assessments conducted, professionals involved and substantial reasoning behind the decisions made. This can be shared with the Home Office and NAAB. This will hopefully promote collaboration between organisations to identify areas of weakness within the age assessment process.
  • Collaborate with other organisations if an individual dispersed within the area is age-disputed, begin the process to assess age and such as strategic migration partnerships, NGOs and legal advisers to support the individual during this process and to understand their rights.
  • Record data on all cases whether or not the age assessment outcome differs from the initial decision. Capture data on the reasons for assessment delays and resource effects, and feedback to the Home Office and relevant organisations such as NAAB, to support shared learning and promote collaboration.

Get in touch

Our legal experts within the social care team can discuss any further questions you have regarding age assessment guidance and related issues.

Contact

Contact

Miya Watson

Paralegal

miya.watson@brownejacobson.com

+44 (0)330 045 1179

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