OISC/IAA vs SRA route for immigration PI — a comparison
UK immigration advice operates under two regulatory routes: the Immigration Advice Authority (IAA, formerly OISC) for non-solicitor advisers, and the SRA for solicitors doing immigration. Two distinct regulators, two distinct PI regimes. This deep-dive sets out how they differ and which route fits which practice.
The two regulators
IAA (Immigration Advice Authority)
Rebranded from the Office of the Immigration Services Commissioner (OISC) in 2024. Regulates non-solicitor immigration advisers under three levels: Level 1 (initial advice and casework), Level 2 (more complex casework including appeals), and Level 3 (advocacy work at tribunals and courts, plus judicial review).
SRA
Regulates solicitors doing immigration work under the SRA Standards and Regulations. No separate immigration authorisation for solicitors — if the solicitor holds SRA authorisation for legal practice, immigration falls within their permitted scope.
PI framework compared
IAA PI requirements
IAA-regulated advisers must hold PI as a condition of authorisation. Cover level scales with authorisation level. Level 1 minimum ~£500k; Level 2 ~£1m; Level 3 £2m+ typical. Specific rules published in the IAA's regulatory guidance.
SRA PI — the MTC route
Solicitors doing immigration are covered under the SRA MTC (Minimum Terms and Conditions) — the mandatory PI regime for all SRA firms. Minimum £2m per claim, aggregated by same-or-related-series of acts, six-year run-off, from a SRA Qualifying Insurer.
Practical differences
IAA cover is scaled to activity; SRA cover is mandated at the firm level regardless of immigration activity level. IAA advisers renew immigration-specific PI; SRA solicitors have immigration exposure inside their broader MTC placement.
When each route fits
When IAA fits well
Non-solicitor advisers with focused immigration practice; sole practitioners; small firms without wider legal practice; specialist areas (sponsor licence, EUSS, family reunion) served on standalone basis.
When SRA fits well
Solicitors with mixed practice including immigration; firms wanting a single PI placement covering all legal work; firms needing the SRA-Qualifying-Insurer's established claim-handling infrastructure.
Level-3 IAA advocacy — specific wording concerns
Level-3 advisers doing tribunal advocacy or judicial review face additional wording concerns. Standard PI wordings may exclude or restrict court-advocacy work. Level-3 practitioners need specific wording extension covering advocacy activities.
SRA solicitors face the same issue under MTC — the MTC covers civil litigation broadly, so tribunal work is included, but the specific insurer's wording extensions should be reviewed.
Common failure modes
- IAA advisers with tribunal or JR work not confirming wording covers advocacy.
- SRA firms with material immigration workload not communicating the caseload composition to insurers — loading applies but requires disclosure.
- Post-authorisation-lapse coverage — run-off treatment critical for both routes.
- Sponsor-licence work requiring both employment law and immigration cover treatment.
- Cross-border advice to clients whose immigration decision requires foreign-jurisdiction input — not always covered.