A tailored approach for Scotland
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Pictured in Regent Quay, Aberdeen
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What Could Work For Scotland
The Scottish Government has reflected on the input and views from stakeholders in Scotland and beyond on priorities for the immigration system, and used that to inform engagement with the UK Government on the future immigration system for the UK.
The engagement with stakeholders has also helped shape this updated policy position showing how devolution of some aspects of immigration policy within a UK framework could allow the Scottish Government, accountable to the Scottish Parliament, to set criteria for a new international migration route to start to meet Scotland’s needs. This would include requiring migrants to live in Scotland with a Scottish tax code and working with the UK Government on delivery and monitoring.
The UK Government has said it wants the UK immigration system to work for all parts of the UK. While Scotland is part of the UK, the Scottish Government has set out how it thinks tailored migration policies are increasingly necessary to enable Scotland to continue to succeed and remain attractive to migrants in a post Brexit scenario.
Employers, business organisations, universities, trade unions, local government and immigration experts support a tailored approach to immigration in Scotland. The UK Parliament’s Scottish Affairs Committee and the All Party Parliamentary Group on Social Integration have agreed that the current migration system needs to change to reflect local circumstances. The Scottish Parliament has accepted the need for the development of a differentiated, more flexible migration solution tailored to meet Scotland’s specific needs.
“We have argued that there should be a system in Scotland which responds to the particular needs of Scottish industry and demography.”
“SCDI supports greater flexibilities on immigration for Scotland to respond to its distinct demographic and employment needs… Other countries successfully operate regional migration schemes which target the specific needs of their economies and SCDI believes that there are workable options for more differentiation in the UK’s system.”
“The First Minister is right to highlight both the negative effect of pandering to anti-migrant sentiment & the need for a separate Scottish approach. The STUC supports additional powers on migration for the Scottish Parliament.”
“Bespoke visa schemes for Scotland, combined with expanding international outreach activities in relation to immigration to advertise these new arrangements, would be an effective way of ensuring that immigration policy meets Scotland’s needs.”
Law Society of Scotland
“Scotland’s future immigration needs are distinct from those of England: in particular, we need higher rates of migration. This means that we require a system which can take account of different needs in different parts of the UK, as well as different needs across Scotland.”
David Hume Institute
“Of the various approaches available, a differentiated points-based system would be the most effective in responding to Scotland’s demographic, economic and socio-cultural goals.”
Royal Society of Edinburgh
A Scottish Visa
Scotland faces distinct demographic and population challenges. Other countries face similar issues around rural depopulation, population shift and demographic change.
Places such as Canada and Australia have successfully used regional immigration schemes to allow states and provinces to attract and retain people with the skills and attributes needed to benefit the local economy and local communities and address these challenges.
Learning from these international models has helped the Scottish Government develop a tailored proposal for migration to address the distinct needs of Scotland, involving devolution of some new powers over migration policy within a UK framework. The Expert Advisory Group on Migration and Population published a report on the lessons that could be learned from Australia, Canada and continental Europe, and their findings are summarised throughout this paper.
The Scottish Government proposes that Scottish Ministers would set the criteria and rules for a visa to enter the UK that would let migrants live and work in Scotland, with a Scottish tax code. Holders of this visa would have to live in Scotland and could not live elsewhere in the UK. The Scottish tax code is an example of an existing framework based on residence and would help ensure that people with a Scottish Visa stayed in Scotland and contributed to the Scottish economy.
Who has a Scottish tax code?
The Scotland Act 2012 defined who will be a Scottish taxpayer for the purposes of the Scottish rate of income tax. There are a number of tests to determine Scottish taxpayer status. For most people who have only a single ‘place of residence’, they will be a Scottish taxpayer if they are UK resident for tax purposes and their ‘place of residence’ is in Scotland. Some people will have more than one ‘place of residence’, and if they have their ‘main place of residence’ in Scotland for at least as much of the tax year as it has been in any one other part of the UK then they will be a Scottish taxpayer. Place of residence is therefore key to establishing whether an individual is a Scottish taxpayer.
Under this proposal both migrants and employers recruiting workers would have a choice of routes through the UK immigration system.
A Scottish Visa would present an additional option for people who want to live, work and eventually settle in Scotland. The Scottish Visa would be an extra option in the UK system, and the Scottish Government would work in partnership with the UK Government to deliver this additional Scottish Visa. It would not prevent employers in Scotland or migrants to Scotland applying for any other UK visas.
The Scottish Government would also work with stakeholders and communities to design responsive solutions that work for Scotland, giving local accountability for decisions in the Scottish Parliament. The Scottish Government wants to provide reliable solutions, and understands that stability in immigration policy is beneficial for attracting migrants and to businesses who are making investment decisions based on access to skills and workers.
The Scottish Government doesn’t currently have the powers needed to deliver tailored immigration policies for Scotland. Devolution of aspects of migration policy within the UK system would start to allow Scotland’s most acute needs to be met. Shared responsibility for migration would allow additional routes, options and solutions for Scotland, which the Scottish Government would aim to make less restrictive in Scotland than existing UK policy.
Figure 3: Our policy in context
There are many ways a tailored approach for Scotland could be realised. Some of the different models for migration policy are summarised in Figure 4. For example, if the UK Government was to deliver regional variation in the immigration system, this could mean:
- The UK Government creates an additional route for migration to Scotland, where the Home Office defines the criteria and rules, receives and assesses applications, and issues a visa to successful applicants (Model 1); or
- The Scottish Government considers and proposes criteria for an additional route for migration to Scotland for the UK Government to establish, with the Home Office receiving and assessing applications, and issuing visas to successful applicants (Model 2).
What the Scottish Government is proposing is devolution of immigration with shared responsibility for delivery, within a UK framework. This could mean:
- The Scottish Government defines the criteria for an additional route for migration to Scotland, receives and assesses applications, and then nominates successful applicants to the UK Government, where the Home Office receives and assesses the application at this second stage, and issues a visa to successful applicants (Model 3); or
- The Scottish Government has powers to establish additional routes for migration to Scotland and define eligibility criteria, it receives applications and assesses them, and then refers applications to the UK Government, where the Home Office will verify for identity and security only and issue a visa to successful applicants (Model 4).
Although it is not what the Scottish Government is focusing on in this paper, it would of course also be possible to establish an entirely devolved/separate immigration system (Model 5). An independent Scotland would establish its own immigration system.
Figure 4: Range of tailored approaches to migration policy
Other options could also be conceived, depending on discussion and negotiation. UK Government delivery of regional variation as in Model 1 is similar to the existing Scotland Shortage Occupation List. This is underused, insufficiently responsive to need, and has no formal input from either the Scottish Government or the Scottish Parliament.
Model 2 would give the Scottish Government some role in shaping policy, with all delivery to be undertaken by the UK Government. This is similar to the experience of the Fresh Talent: Working in Scotland Scheme from 2005 to 2008. That was a successful scheme, that allowed over 8,000 students to settle in Scotland after their studies, but was ended by the UK Government against the wishes of the Scottish Government and contrary to the policy goals it was established to address. An approach along these lines would also not include a formal role for the Scottish Parliament in scrutinising policy and delivery.
Although there are many ways this could be delivered, the Scottish Government wants to see an approach where policy is set in Scotland, by Scottish Ministers who are scrutinised and held to account by the Scottish Parliament.
The Canadian and Australian examples show there is space within a regulated and controlled federal, or national-level government immigration system for a regional or devolved approach – particularly where the regional or devolved contribution is on selection of migrants along locally-determined need or criteria, with admission controlled at national level.
Here, the UK Government sets the criteria to select eligible migrants, considers applications and grants leave to enter and remain in the UK, permits entry at the border to those authorised, and monitors ongoing compliance with immigration controls. The proposal for a Scottish Visa is that the Scottish Government should have the ability to set the rules and criteria for an additional migration route to Scotland and receive and decide applications for visas, but that it would still be for the UK Government to issue visas to enter and reside in the UK, enforce border control and, working with the Scottish Government where appropriate, ensure ongoing compliance with immigration rules.
This chapter therefore explores in more detail those two similar but distinct models to create a tailored approach for Scotland:
- a devolved system designed for Scotland (Model 4); and
- a regional immigration model in the UK (Model 3).
Case Study: Canadian regional immigration programmes
Canada is an example of an immigration system with regional differentiation. Canada has established a series of Provincial Nominee Programmes (PNP) with all its provinces and territories except Nunavut, which is remote and sparsely populated and does not operate a PNP; and Quebec, which has a separate and more extensive bilateral agreement on immigration.
Provincial Nominee Programmes
- The PNPs create an additional migration route to Canada for individuals who intend to settle in a particular province or territory.
- The provincial government is able to set the criteria to select immigrants with characteristics that would benefit their economy or society.
- Immigrants apply to the provincial government, which assesses their application against the criteria they have set. If the application is successful, the provincial government ‘nominates’ the applicant to the federal government to allow their admission to Canada.
- The federal government retains exclusive responsibility for admission and border control, and also runs its own nation-wide routes to select migrants who can then settle in any province or territory – except Quebec.
- Ministers of the federal and provincial governments responsible for migration meet annually to agree quotas for the PNPs.
- Retention rates in the province of entry for those entering through PNPs vary: it is as high as 82% after five to eight years in Alberta, whereas smaller Atlantic provinces have lower retention levels.
- The Canadian government has announced a further ‘Atlantic Immigration Pilot’ to enhance options for migrants to these smaller, remoter provinces.
Bilateral agreement with Quebec
- As with the PNPs, the Quebec government sets rules and criteria to select migrants, and then nominates them for admission to Canada by the federal government.
- However, Quebec has exclusive responsibility for selection of migrants – the routes the federal government makes available do not allow migrants to settle in Quebec. If a migrant has the intention to immigrate to Quebec directly, they must be selected through the Quebec government immigration scheme.
- Quebec places particular emphasis on French language and culture when selecting migrants, as well as targeting particular demographic and economic needs (i.e. skills) the provincial government has identified.
- Internal mobility within Canada is not restricted – anyone can move from another province to Quebec freely.
Further information on Canadian regional immigration programmes is included at Annex C.
A Devolved Approach For Scotland (Model 4)
This model describes devolution allowing the Scottish Government to establish a new immigration route, working in partnership with the UK Government on delivery with a formal role the Scottish Parliament in scrutinising any policy, legislation and decisions made by Scottish Ministers.
This model, where tailored policy is set in the Scottish Parliament, draws on international examples of regional schemes. The Scottish Visa proposal outlined in the 2018 discussion paper is broadly analogous to the Canadian PNPs, although described in language and constitutional terms more relevant to the UK and Scottish context. It is not as extensive as the powers exercised by Quebec – for example, Scotland would still receive migrants through existing UK-wide visa routes, along with an additional flow of migrants selected through the criteria the Scottish Government would set in a Scottish Visa.
The Scottish Government would develop policy for the selection of migrants, and introduce regulations in the Scottish Parliament. Eligibility for the route would be satisfied by the Scottish Government checking the initial application against criteria it has set. The Scottish Government would intend to develop a selection approach that captures social as well as economic value. The Scottish Government would similarly wish to explore using devolved powers on immigration to support a less restrictive approach to family migration. Having assessed applications and selected migrants, the Scottish Government would then propose them for entry to the UK through a visa issued by the UK Government. The UK Government would make checks to verify identity, including checking immigration history; and to satisfy security requirements.
This would create a two stage process – the prospective migrant would apply first to the Scottish Government, which would consider applications, and reject or approve them based on criteria they have set. The application would move to the Home Office to consider eligibility for admission to UK. The Home Office would verify identity, including checking immigration history; and satisfy security requirements. The Home Office would not reassess the application, and would be able to refuse admission only on clear and pre-agreed grounds such as criminality. The Scottish Government first set out in February 2018 that it would commit to an agreed approach with the UK Government on matters of criminality, fraud and abuse in the immigration system.
Endorsement and sponsorship are established concepts in the UK immigration system, and nomination in this way would be similar to those processes, albeit the nominating body would be the Scottish Government rather than an employer. In Canada, the provincial government ‘nominates’ the applicant to the federal government for admission. In Australia, the state government issues an ‘invitation to apply’ to migrants they are proposing through their regional system, with the second-stage application being processed by the federal government.
The Scottish Government would be willing to consult with the UK Government on the number of applicants able to apply through this route. A quota for each regional scheme is set by agreement between the federal and state or provincial governments in the Canadian example. However, a cap or quota on a devolved approach that was driven by the UK net migration target would not be acceptable, and the UK Government should formally abandon that target in order to engage in a rational, evidence-based way on immigration policy.
The proposed Scottish Visa would not have a sponsorship role for employers, removing a significant burden from the small and medium enterprises which make up a higher share of the economy in Scotland than in the rest of the UK. Because it would not be a sponsored visa, employers taking on someone through this route would not need to be licenced by the Home Office. That also means the immigration skills charge would not apply, as currently defined by the UK. There would be no salary threshold although earnings could be part of the selection process. This could encourage highly skilled people to take up quality jobs in Scotland but not exclude anyone solely on the basis of salary.
Applications would be online by default. The UK is investing in upgrades to the IT systems supporting the Borders, Immigration and Citizenship System. In both the regional model and the tailored approach for Scotland described above, the initial application would be to the Scottish Government. This could be through a shared online portal, or a dedicated interface. Guidance would be provided to ensure that users understand their options in the UK immigration system and are able to apply for the route that best fits their needs and circumstances.
A Regional Approach For The UK (Model 3)
This model describes an immigration route established by the UK Government, in which the Scottish Government and potentially other governments and bodies participate. This shows how an additional route in the UK immigration system that meets Scotland’s needs could be designed to be adapted according to the needs of other parts of the UK as well. Although there are different levels of devolution within the UK, there are other areas with the local accountability and administrative capacity needed to participate in a regional migration policy, such as the city regions with metro mayors in England as well as the devolved administrations. This could be described as a ‘regional nomination scheme’, where a designated public authority – the Scottish Government, for example – would endorse applicants they have selected according to criteria they set, and nominate them for entry to the UK through a visa issued by the UK Government.
The UK Government could establish a regional nomination scheme as a pilot in Scotland, with the Home Office working in partnership with the Scottish Government to design, deliver and evaluate it. Scotland is uniquely well placed to take forward such a pilot arrangement.
For a pilot scheme, a lower initial cap or quota might be an appropriate control as systems, processes and demand are tested. A pilot might start with a low volume with the aim of expanding over time, following evaluation of benefit.
This would still be a two stage process – the applicant first applies online to the endorsing body (such as the Scottish Government) for a ‘certificate of endorsement’ or ‘work permit endorsement’. The nominating body would consider applications and reject or approve them based on criteria they have set. When a decision has been made by the nominating body, the nomination would be sent to the UK Government to make necessary identity, immigration history and security checks, then grant entry to the UK. As before, admission would be refused only on clear and pre-agreed grounds at this stage.
Family members of the primary applicant would be eligible for visas through existing UK family migration routes under this proposal.
This approach would require political agreement and changes to the devolution settlement to allow the Scottish Government to select and endorse applicants for immigration purposes. This would still involve a role for the Scottish Parliament in scrutinising eligibility criteria, retaining an important aspect of local accountability for decision-making. However, without devolution to allow the Scottish Government to establish the new route there is a risk that this model might not guarantee the permanence of the arrangement.
Residence In Scotland As A Requirement
A condition for admittance on a Scottish Visa route should be residence in Scotland. This is easy to understand and follow and residence is the basis of existing obligations and entitlements. For example, the Scottish tax code is based on residence, as is eligibility for many public services and benefits delivered by the Scottish Government and local government in Scotland.
The Scottish Government would consider carefully what compliance framework would need to be put in place to ensure proportionate, risk-based control for the requirement that holders of this visa stay in Scotland. That would include what information and data sharing arrangements are then put in place with UK authorities; particularly Immigration Enforcement, but also other bodies such as HMRC who are responsible for the Scottish tax code.
In the majority of cases, a requirement to ordinarily reside in Scotland would likely also mean an individual would be working in Scotland. Therefore, the Scottish Government is not proposing additional restrictions on working within the UK – although would be prepared to discuss that with the UK Government if needed.
The previous and current examples of regional differentiation for Scotland did not include any additional control mechanisms to ensure retention. For example, the Fresh Talent: Working in Scotland Scheme was open to graduates of Scottish institutions who intended to live in Scotland for up to two years after their studies; but residence anywhere in the UK was valid for compliance with the visa. The current Scotland Shortage Occupation List creates an easier pathway through the immigration system for roles that are in shortage in Scotland; but there is no ongoing control to ensure that (for example) a chemist in the nuclear industry recruited on the basis of that occupation being on the Scottish SOL remains employed in Scotland after they first enter the UK.
A residence requirement is an innovation to help ensure that migrants entering through this route are contributing to the Scottish Government’s strategic goal to ensure communities in Scotland can grow and thrive.
Currently applicants, once in the UK, can arrange for delivery of a residence permit to a home address or to a local Post Office. The Home Office is increasingly moving to a digital-only residence status, and not issuing physical permits. The Scottish Government would consider whether a physical proof of status (e.g. a residency card) would aid understanding and compliance, learning from the experience and concerns raised about the use of a digital-only status in the EU Settlement Scheme.
Length Of Stay And Permanent Settlement
The goal of this approach is to provide an additional route for migration to Scotland with an explicit focus on attracting people with the intention to permanently live and work here. There are therefore questions about the duration of a visa (the time the individual is under ‘immigration control’) and what pathway is available to permanent settlement, known as Indefinite Leave to Remain (ILR).
The main skilled worker visa currently allows applications for ILR after five years’ lawful residence. Some categories of visa have expedited eligibility for ILR, and some may take longer. Some visas do not allow a pathway to settlement, for example student visas or temporary work visas, but may allow switching onto other routes that can lead to settlement. Looking at international examples, the Australian regional route
The Scottish Government would want to ensure there was a pathway from the Scottish Visa to ILR. It is currently intended that someone holding a Scottish Visa would make an application for ILR to the UK Government. This would be for leave to remain in the UK. If granted, it would remove the requirement to reside ordinarily in Scotland. If this was not possible, alternative arrangements for permanent settlement in Scotland could be considered.
If five years’ residence on the Scottish Visa was required to apply for ILR, the visa could be offered for five years at the outset (or five years and three months, to allow a window for ILR application). Alternatively, a shorter initial visa term could be offered, with a renewal point required to reach five years, for example, three years plus three years. This would potentially include a caseworker review of compliance with the residence requirement, complementing ongoing monitoring. A six-year period of immigration control overall would allow a full year toward the end of the visa term to apply for ILR.
Working With UK Immigration Authorities
Devolution within a UK framework implies a strong focus on partnership working with both the Scottish and UK Governments taking responsibility for different elements of the system. The key in both instances is that the process for employers and for individuals should be easy to navigate and understand, the decision making process should be transparent and prompt while charges should reflect the cost of the process. This commitment to transparency should also mean that the immigration exemption in the Data Protection Act should be removed.
Although the Scottish Government favours a system where applications are determined in Scotland, a different approach would be for the relevant UK body – in this case, UK Visas and Immigration, part of the Home Office – determine applications based on the rules and criteria set by Scottish Ministers.
An example of a UK body following devolved policy in delivering a service is HMRC, which collects income tax from Scottish taxpayers according to the rates and bands for non-savings non-dividends income set in the Scottish Parliament.
However, the judgment made in devolution of powers on social security was that a new executive agency in Scotland should be established to deliver that service, rather than delivering through a UK body.
Therefore, if powers over immigration are devolved, the Scottish Government will consult on the most appropriate mechanism to receive, process and make decisions on behalf of Scottish Ministers.
Whatever option is most advantageous, it will be important to learn lessons from all relevant sources on issues such as organisational culture, and training and support to empower caseworking staff, helping them to make better decisions that are correct first time. While an appropriate appeals process is necessary, good decision-making and clearer rules will also help reduce the burden of reviews.
This is important in Scotland where the Court of Session undertakes judicial review of decisions made at immigration tribunals. Three-quarters of all judicial reviews initiated at the Court of Session in 2017-18 related to immigration decisions. The number of judicial reviews of immigration decisions disposed of by the Court of Session in 2017-18 had more than doubled since 2008-09.
The 2018 discussion paper proposed no changes to arrangements for border control. When the applicant presents at the UK border (on arrival at a port), Border Force officials would review their documentation and make a decision on whether to allow entry to the UK.
The Scottish Government remains concerned about the use of long-term and indefinite immigration detention and wants to see the system of immigration detention centres, such as Dungavel, replaced with a more humane approach including a maximum 28-day limit on immigration detention. The UK is the only European country that allows indefinite immigration detention with no statutory time limit. The Scottish Government is keen to explore with the Home Office how to increase the use of community-based solutions for people currently held in immigration detention, where no crime has been committed or where a sentence has already been served. Closure of Dungavel should be part of a wholesale reform, otherwise it risks further isolating vulnerable people who could be transferred to another facility in the UK, limiting access to family and legal representation.
User Journey Through Scottish Visa Application
UK Immigration Policy After Leaving The EU:
Impacts on Scotland’s Economy, Population and Society
The impact of ending free movement from the EU and restricting future immigration will have a more pronounced detrimental impact in Scotland than in other parts of the UK. The first report of the Expert Advisory Group on Migration and Population showed how future UK Government migration policy changes are likely to affect Scotland. This analysis helped inform the Scottish Government’s proposals for a tailored approach to migration policy for Scotland.
The UK’s departure from the EU will usher in important changes to immigration policy. The UK Government’s proposals on immigration… suggest that from January 2021, EU nationals will be subject to UK immigration rules. The proposals also suggest changes to the current points based system… [and] are intended to reduce overall net migration to the UK, while expanding opportunities for skilled migrants.
The UK’s withdrawal from free movement would restrict EU immigration to the points based system, with most labour migration channelled through Tier 2 [the Skilled Worker route].
Drawing on a range of data, we develop two scenarios for future migration flows.
Scenario 1: 80% reduction in EU net migration
Scenario 2: 50% reduction in EU net migration
The first scenario builds on the analysis of the White Paper, while the second takes into account inflows of dependents, family migration, and also factors in an expected increase in non-EU nationals because of changes to Tier 2.
Based on these scenarios, we project that the proposed changes could lead to a reduction in annual overseas net migration to Scotland of between one third and one half after 2020.
Key to understanding the effects of this change is how reduced migration flows are distributed – both across sectors, and across different areas of Scotland.
Overall, 63% of workers in Scotland earn less than the proposed £30,000 salary threshold. In occupations such as textiles, social care, leisure and travel, sales, and elementary occupations, almost no jobs would qualify for a £30,000 threshold.
One example of a severely affected sector is social care, where less than 10% of those in caring personal service occupations in Scotland earn above £25,000, and none earn £30,000. Therefore, the proposed changes will exacerbate existing labour shortages in many areas.
Looking at the effects by age and gender, only 25% of those aged 22-29 meet the £30,000 threshold, rising to between 43% and 45% for those in their 30s and 40s. A far lower proportion of female employees meet the £30,000 threshold… implying that the proposed arrangements could create a gender disparity in the supply of future migrants.
If we look at the regional distribution of salaries across Scotland, we see a wide variation in the proportion of jobs that meet the £30,000 threshold, ranging from 49.5% in East Renfrewshire to just 16% in Na h-Eileanan Siar. This implies that very few migrants would be able to move to those areas to work under Tier 2. This would limit labour migration in areas of Scotland that already… face challenges of depopulation.
The fiscal effects of EU migrants on the Scottish economy are similar to the effects on the UK economy as a whole. The UK evidence suggests that EU migrants typically contribute more through tax revenues than they consume by way of public services. As in the rest of the UK, EU migrants to Scotland are typically young and economically active, and people of their age group tend to consume a relatively small amount of public services because they are not usually receiving welfare benefits, nor are they heavy users of health and social care services… [T]he lifetime balance of their contribution to tax revenues and use of public spending will tend to be favourable.
While immigration will not significantly reduce the speed of population ageing in Scotland, it will have a considerable effect on the absolute size and age composition of the working age population. At current immigration rates, the working age population is expected to remain stable over the next 25 years, whereas with reduced migration from the EU, it is projected to decline by between 3% and 5%. Reduced EU migration would lead to a gradually declining and rapidly ageing working age population. This is in contrast to the UK as a whole, where the working age population would still grow with reduced international migration. Overseas migration is especially conducive to future demographic stability because of its relatively young age structure.
For remoter rural areas and islands, attracting working-age migrants is the only realistic option to avert a downward demographic spiral driven by the age structure legacy of selective out-migration. Free movement has enabled EU migrants to live and work across Scotland including in rural and remote areas, including through routes that begin elsewhere in the UK. The flexibility of free movement has facilitated the emergence of migrant networks, as family and friends move to join previous migrants, and such networks facilitate integration and settlement. In some areas facing population decline, EU nationals have made an important contribution to sustaining [public] services, in turn helping to retain existing populations in these areas.
Source: Expert Advisory Group on Migration and Population (February 2019)
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