In 2023, the Minister opened the Immigration Service Delivery (ISD) Forms Portal. This portal provides applicants with an opportunity to submit a number of immigration applications to the Minister. This includes an application for renewal of immigration registration, an application for naturalisation for adults and minors and other specific immigration applications including de facto partner applications and applications for extension of student permissions.

In October 2024, the Minister also launched a separate portal, “The Digital Contact Centre”. It appears that the purpose of this portal is for persons to communicate with the Minister in respect of their applications, immigration concerns. However, a number of specific immigration applications are also submitted via this portal, including an application for first time registration and also applications as the parent or spouse of an Irish citizen.

The modernisation of ISD is to be warmly welcomed.

Any progress that can make the immigration system more accessible and easier to navigate for applicants is to be commended and supported.

Applicants are facing a number of issues with these portals as they currently operate.

One of the main issues with the ISD forms portal that are clients are informing us of and we are experiencing ourselves is as follows:

Once an application is submitted via the ISD forms portal, it can no longer be accessed or updated. It is possible to log in and see the data entered, however it is not possible to have sight of the documents uploaded or to amend the application in any way.

When the application is being assessed, the ISD may write to an applicant and ask for further information and documents. If this occurs, the portal application is “re-opened” and access is given to upload the further documents and or information. In many cases this system works smoothly and the documents are uploaded and submitted. However, in many cases , this creates a concerning issue with the application.

If a person needs more time to submit the required documents, perhaps documents need to be requested from other state departments and so on, there is no facility to request an extension of time.

In our experience the portal request closes after a set period of time (sometimes unknown to the applicant) , with no further notice and it is no longer possible to update the application and provide the documents requested.

Very recently, the ISD have stopped operating the email address for the Citizenship unit, which has been the main channel of communication between ISD and applicants  for many years.

Applicants therefore would have no option but to send a letter by post to citizenship or to instruct a solicitor to assist them with the predicament they find themselves in.

Our office has experienced difficulties with submitting further documents, vital to a citizenship application or indeed specifically requested, via post. We have received many responses from ISD  with a direction that documents can only be submitted via the portal- This is not workable if the portal in question has not been reopened .

The move to a portal system is a big change for all parties in this process- applicants, solicitors and the  ISD.

It should be recognised that this is changing and evolving time and applicants should be assisted and facilitated in navigating this new system and there should be a recognition by ISD that this system is in its infancy.

Applicants should not be put at risk that their application might be refused, rejected or deemed ineligible when they have made best efforts to submit a comprehensive application and have tried their upmost to comply with requests via the new portal system.

No applicant should be put at risk of a rejection in these circumstances.

We also look forward to the creation of a third party portal so that solicitors have  a real way to act for their clients on their immigration  applications and are not relying on interim solutions to use portals that have be established for use by individual applicants and not solicitors.

Berkeley Solicitors through our involvement with the Irish Immigration Lawyers Association, have brought our concerns regarding the issues we are encountering with the portal to the attention of the Department and are engaging with the Department towards seeking to improve the system