The EU Exit: ID Document Check app was launched for a public testing phase on 21 January 2019. The app was created with the intention of making it easier for EU nationals and their family members to apply for pre-settled or settled status, thereby maintaining their rights to remain in the UK.
In contrast to the current process for applying for residence cards or documents confirming permanent residence status under the Immigration (EEA) Regulations 2016, which requires the completion of an arduous application form alongside supporting documents, this app was designed to provide a simple, hassle-free means of obtaining the required status.
But how successful is the app in achieving this objective? Since its launch, we've been testing the app with clients, and have some initial observations.
First up, the app is straightforward to use, and the government website provides clear guidance on how to use it. The app can be downloaded on Android devices 6.0 or above, which have Near-field Communication (NFC). It's free to download, but does require 135 megabytes of storage.
The app itself consists of five main stages: registration, taking a picture of your passport, scanning your face, taking a photograph of yourself and scanning the biometric information (reading the chip) from your passport. The app guides you through each step with simple instructions, which include useful visual prompts. Following this, you are then directed to the online portal to complete further steps in the application process.
While at first glance, it looks as though you are able to complete the entire application process on the app, this is not in fact accurate: the user is still required to complete further steps online. Overall, however, the whole process is notably simpler than other application pathways.
What are the pitfalls?
As mentioned above, the app is only available to Android users, and even then the device must have an NFC feature, which naturally limits its use. To increase accessibility, the government has set up ‘ID document checking locations’, but as these require the user to go in person to the locations, it's not as convenient a process .
We've also heard of a few technical glitches being reported with the app. On registration, you are required to enter a contact number and to select an area code to receive a verification pin. Despite selecting your country code, applicants still need to insert their full telephone number to receive their code (ie in the UK, when selecting +44, you would still need to include the 0 – this is arguably counter-intuitive and adds unnecessary confusion for users.
We've also seen that the app takes users back to the registration page if they take too long to scan the biometric information on their passport, which is particularly frustrating as it's the last step in the app process.
Setting aside these teething issues, the biggest controversy has been around the £65 fee to process the application. On the day of the app launch, Theresa May announced that this fee had been lifted, however applicants are still required to make this payment and await a refund. This has understandably resulted in reluctance in applying until after the fee has been removed, which somewhat defeats the value of having an early launch of the app aimed at encouraging EU nationals to apply.
What’s the verdict?
It's not perfect, but it's significantly better than the existing alternatives. This app is a technological advance on previous systems, and it provides Android users with a simpler application process. The instructions provided are very clear and user-friendly, and the glitches are only minor.
The real outstanding question is whether this app alone can support the deluge of applications anticipated in the coming months, as the UK prepares to withdraw from the EU. We've not seen it in peak use, and so can't see whether it will withstand a surge in applications.
Kimia Sepahzad is an immigration consultant in the employment law team at Stephenson Harwood LLP