changes to child student visa immigration rules
Nominated guardians are now a must for parents and Bright World is here to help
UKVI immigration rule changes ahead
There is a new Statement of Changes to the Immigration Rules (HC 733), that will be coming into effect on 29th May 2025 and particularly in relation to Child Student visa holders and their guardianship arrangements. There are a number of changes being made to improve safeguarding on this visa route:
nominated guardians
What is a Nominated Guardian?
The guidance published by the Home Office entitled: 2025 Spring Rules: Student Policy Changes states "A person aged 18 years old or over who is appointed by the Child Student’s parent, legal guardian, or school as the Child Student’s carer in the UK outside of term-time for less than 28 days and/or is the school’s emergency contact in the UK for the Child Student."
A Nominated Guardian can be an Education Guardianship Organisation like Bright World Guardianships. A 'Child Student’s carer' or ‘intended carer’, also referenced in the guidance, may include host families appointed by us.
Screening of the Nominated Guardian
Nominated Guardians will have to meet the same requirements as those for close relatives and Private Foster Carers, including a requirement to provide a Letter of Undertaking that satisfies both the school and the UKVI. Bright World can offer the name and details of all host family members before the student applies for their visa.
DBS Checks on family friends
Where a family friend or individual is appointed as Nominated Guardian, they will need to have a DBS check on every member of the household. This is because UKVI Caseworkers will also be given broader powers to refuse Child Student applications where the Child Student’s carer in the UK has committed a relevant criminal offence, or they pose a safeguarding risk to the applicant once they are in the UK. They will also need to be visited regularly to monitor facilities and the student's welfare.
Bright World Guardianships, as a Gold Standard AEGIS Accredited Guardianship Organisation, and associated staff and host families, will satisfy both school and UKVI standards.
permitted living arrangements
A new list of permitted living arrangement categories has been created and applicants must specify which arrangement they will be entering into when apply for a visa. This means providing the details and address of where they will stay during the holidays.
All of Bright World's guardianship students fall under the category of Full Boarders in independent schools who reside with a nominated guardian during the holidays. At time of writing, we are assuming that this includes, a host family, a family friend or in a recognised half term programme.
Some students are also cared for by their Parents or Legal Guardians who fly over during the holidays. Some students fly home. These categories must fall outside of the permitted living arrangement categories.
Bright World Host Family Stays
Where a student is staying with a Bright World host family, as they have been screened to a high level of safeguarding standard, this will qualify as a permitted living arrangement whilst the student is under the umbrella guardianship of Bright World.
Family Friend
Where the student's parents are nominating a family friend to host during the holidays, these will also need to be DBS checked and have house inspections conducted. We are equipped and ready to do further checks such as DBS checks on members of the household, offering our bespoke online safeguarding training and conducting house inspections should this be deemed necessary by a school's Compliance Officers and the UKVI. No costs will be levied to schools for this service.
Holiday courses
Some of our students prefer to select half term residential revision or activity programmes rather than staying with host families. The new living arrangement criteria does not mention such holiday courses. It does exclude students being permitted to stay in hotels or youth hostels and asks for confirmation that the residence is not operated as a commerical enterprise. At the time of writing, we are assuming that British Council accredited schools or boarding schools themselves running such programmes will be a permitted living arrangement.
letter of undertaking
To meet these new requirements, we have updated our Letter of Undertaking, which outlines the specific care arrangements for each student under our guardianship. This includes details of their term-time boarding, host family arrangements during holidays, and travel logistics. The letter can be adapted to 6 different scenarios we have identified as possible living arrangements for the holidays. This letter can be issued immediately a child has enrolled on and paid for our service and can be provided to the school and parents as needed.
travel arrangements
We understand that schools will be given additional duties, as the visa sponsors, to collect travel arrangement information for students with a nominated guardian.
Schools must endeavour to find out all travel arrangements for students on Child Visas.
This is easily resolved and attainable if students are under Bright World Guardianships. Our current process of providing detailed email confirmation of travel arrangements and profile of the adult collecting the child, will satisfy the requirements. We provide these to schools and parents within 48 hours of a travel request being made to us.
does this mark the end of the family friend as Nominated Guardian and/or as a permitted living arrangement?
Avoiding the risk of Child Trafficking
There are sensitivites around the nomination of what is called a 'family friend' by parents to act as guardian to students and/or provide accommodation for them during the holidays. In the eyes of the UKVI, we believe it is because in the past, child traffickers often call themselves or the intended carer, a family friend on visa applications and guardianship forms, which leaves students, overseas parents and schools vulnerable to crime and exploitation.
With this in mind, and due to first hand experience of the risk of trafficking, as guardians, we are accustomed to carefully verifying the details of a family friend that is nominated by the parent to accommodate the student during holidays. This is often quite an undertaking. Attempts to connect on the phone or via email often fail and require numerous attempts. Often once we have got through to the intended carer they seem brusque in nature and quite offended to be being checked. Some attempt to refuse sending us their photo ID as they are suspicious of why we are asking.
The new rules imply that family friends will need to undertake the same level of screening as a Private Foster Carer. This, as is our host family screening, is rigorous and very thorough. We are not sure that overseas parents will feel comfortable asking their friends to undertake the same level of screening and we doubt that the family friend will, in every case, happily agree to it.
No back-up plan and impossible to DBS in time
Notwithstanding the risk of trafficking, schools are also often worried about the family friend not being able to offer the same level of assistance as a professional guardian. Using a family friend as the only permitted living arrangement does not allow for emergency changes and there would be no back up plan available.
DBS Checks
DBS checks can take weeks and some months to come back and therefore the replacement of the family friend that complies with the new rules would, in our opinion, be impossible.
Our view is that the only way to guarantee that the permitted living arrangement is compliant is to use an AEGIS accredited guardianship organisation host family.
fee charging individuals or non AEGIS accredited guardianship companies
inspection and scrutiny of non accredited guardians
Where a fee charging individual or non-inspected guardian is selected by the parent, the onus will, be on the school to ensure they meet the same level of safeguarding checks as a Private Foster Carer. This will include a DBS check on every member of the household who is over the age of 16, monitoring the living arrangements, conducting house inspections and student welfare visits. They must also ensure than no more than 3 students are accommodated in the house. This is because more than 3 students is considered to be a boarding house/commerical enterprise in Private Fostering guidance which must be followed here.
no lodgers and no paying guests allowed
Host Family screening visits help to ensure “CS 9.4. is fully met and details are presented in the Letter of Undertaking. These vital inspections and spot checks help to mitigate the following risk to Visa sponsors highlighted in the Home Office 2025 Spring Rules: Student Policy Changes.
“Caseworkers will also have the power to refuse applications where they are not satisfied there are appropriate care, living and, where applicable, guardianship arrangements in place for the applicant’s safety whilst in the UK.”
This is much more than DBS checking nominated guardians and can only be met by inspecting the property where a child will be living outside of term time. AEGIS Gold standard members like Bright World must ensure Gas certificate is renewed each year, there is a working smoke alarm and there are no lodgers residing in the property and no paying guests.
AEGIS Standards
Bright World, as an AEGIS-accredited Guardianship Organisation, is duty bound to only allocate 3 students as a maximum in a host family. We also, as a matter of course, conduct all necessary checks on the hosts, houses and student welfare for every child in our care.
AEGIS accredited Guardianship companies are subject to inspection and re-inspection by ISI trained inspectors every four years, follow a strict standards framework and complete an annual declaration. This is not the case for fee charging individuals and non-AEGIS accredited guardians.
readiness to support the new rules
I am very pleased that the UKVI is focussing on stronger safeguarding for international students. Bright World can easily adapt to the changes to the rules and is ready to help and support schools and overseas parents with Letters of Undertaking issued promptly and containing full information required.
