Part Suitability Replaces “General Grounds for Refusal”: What Applicants Need To Know (Effective 11 November 2025)

From 11 November 2025, the Home Office has replaced the long-standing “General Grounds for Refusal” with a new framework called Part Suitability. The core principle is unchanged: applications can be refused, or existing permission cancelled if the applicant fails the suitability rules. The important practical change is that Part Suitability now applies across almost all routes, including human-rights based categories such as Appendix FM, Appendix Private Life, Appendix Adult Dependent Relative and Appendix Settlement Family Life. Where a refusal under Part Suitability would breach the UK’s obligations under the European Convention on Human Rights (ECHR), the route-specific rules set out the approach to be taken, but the starting point is that the Part applies to decisions taken on or after 11 November 2025. 

Which Applications Are In Scope (and Which Are Not)?

Part Suitability SUI 1.1 and SUI 1.3 states expressly that it applies to all routes under the Immigration Rules except a small list of exclusions:

• Appendix EU
• Appendix EU (Family Permit)
• Part 11 Asylum, except Part Suitability does apply to paragraphs 352ZH to 352ZS, and 352I to 352X
• Appendix Service Providers from Switzerland
• Appendix Settlement Protection
• Appendix Electronic Travel Authorisation

• For applications for permission to stay under Appendix Domestic Worker who is a Victim of Modern Slavery, paragraphs DWMS 2.1: SUI.2.1(c), SUI.2.2, SUI .3.1, SUI.3.2, SUI 5.1(b), SUI 5.1(c), SUI 5.2, SUI 5.5, SUI 9.1., SUI 9.2., SUI 10.1., SUI 14.1, SUI 14.2., SUI 24.1, SUI 28.1, SUI 29.1; and
• For applications permission granted under the Agreement, paragraphs SUI 2.2, SUI 3.2, SUI 5.2, SUI 5.5., SUI 8.2, SUI 10.2., and SUI 27.2 apply where the criminal offence or adverse conduct occurred after 11pm on 31 December 2020; and
• for applications for permission to stay under Appendix ECAA Extension of Stay, paragraphs SUI 2.1, SUI 3.1, SUI 5.1, SUI 5.3., SUI 8.1, SUI 9.1, SUI 10.1, SUI 16.1, SUI 17.1 and SUI 27.1, and in relation to such permission paragraphs SUI 2.2, SUI 3.2, SUI 5.2, SUI 5.5, SUI 8.2, SUI 10.2. and SUI 27.2 apply where the criminal offence or adverse conduct occurred after 11pm on 31 December 2020.

Key Grounds that Now Matter Across Family and Human-Rights Routes

Criminality Grounds

The criminality grounds are set out in SUI 5.1. It makes refusal mandatory where an applicant has been convicted of an offence for which they received a custodial sentence of 12 months or more. It also allows refusal where an applicant is a persistent offender showing particular disregard for the law, or where an offence (or offences) caused serious harm. These provisions, which previously sat in different places for different categories, now apply via Part Suitability to routes such as Appendix FM and Appendix Private Life. 

Safeguarding Ground

A new safeguarding ground for Appendix FM entry clearance appears at SUI 6.1, which replaces the previous S-EC1.9 risk posing provisions. Entry clearance must be refused if the decision maker considers the applicant’s parent, or the parent’s partner, poses a risk to the child applicant. This is an express child-protection bar at the gateway to family migration. 

Deception Grounds

The deception provisions have been consolidated. Under SUI 9.1, an application must be refused where the decision maker is satisfied the applicant used deception, for example by making false representations, providing false documents or information, or failing to disclose relevant facts. Cancellation of leave extended under section 3C can also follow where deception is established (SUI 9.2). While the evidential burden still has to be applied lawfully and in line with case law, the drafting centres the decision maker’s satisfaction rather than the older “prove it is more likely than not” formulation. 

Breach of Immigration Laws

Part Suitability also codifies what counts as a breach of immigration laws. SUI 11.4 confirms that breaches include overstaying (subject to limited exceptions), breaching a condition of leave, illegal entry, and deception in a previous application. In addition to the existing mandatory re-entry bans and other sanctions, SUI 11.3 allows a discretionary refusal of applications on the basis of past or present breaches, even where leave was subsequently granted, although decision makers must still exercise discretion lawfully and proportionately. 

Exceptions for Overstayers

The long-familiar exceptions for overstayers in paragraph 39E have been brought into Part Suitability SUI13. SUI 13.1 preserves the 14-day “good reason” window following expiry or following certain appeal/administrative review outcomes, and records the pandemic/exceptional assurance periods during which individuals will not be treated as overstayers. In practice, if you missed a deadline, you will need to evidence the reason carefully and ensure it falls within these narrow carve-outs. 

How this interacts with Appendix FM, Private Life and other human-rights routes

Because Part Suitability now applies to decisions made on or after 11 November 2025, it becomes the default suitability framework for family and private life routes. The routes still contain important human-rights safety valves: the Rules recognise that, where refusal under Part Suitability would be incompatible with the UK’s ECHR obligations, the route-specific approach must be followed. However, mandatory refusal provisions such as SUI 5.1 (serious criminality) or the new Appendix FM safeguarding refusal can preclude a grant unless the route expressly allows an outcome compatible with Article 8 on its own terms. Applicants should expect closer scrutiny of historic conduct, and should not assume that “family life” alone will outweigh suitability without cogent evidence and clear legal representations. Applicants filing after a short period of overstaying must justify the delay within the narrow SUI 13.1 framework. Those with older convictions or complicated immigration histories should not rely on past grants as a shield; the new drafting allows refusal on the basis of earlier breaches even where leave was later given, subject to lawful discretion. 

How Angelov Solicitors can help?

We analyse suitability risks at the outset, mapping your facts against the exact SUI paragraphs that could be engaged and the route-specific human-rights provisions. We draft detailed legal representations that address both the mandatory and discretionary limbs of Part Suitability. Where the Rules preserve a path to a grant notwithstanding suitability concerns, we frame the case accordingly; where refusal would be incompatible with the UK’s ECHR obligations, we make that argument precisely and with reference to the evidence and the Rules.

If you are preparing to apply, or you have concerns about how the new framework may affect an extension or settlement, get in touch with one of our solicitors.