A profession lost one adviser in seven after its regulator brought in an exam
Regulated immigration advisers: 4,153 in mid-2013, 3,587 by late 2015 — a fall of 13.6%, driven by applications to join more than halving. None of it appears in an annual report. It exists in three spreadsheets released under FOI.
By Rose Traviss · 29 September 2026
The regulator of immigration advisers stated a total adviser headcount in its annual report every year until 2008 — 4,061 at 31 March that year — and has published none since. After 2008 it reported advisers only split by advice level and fee-charging status, with no total, and since 2020/21 it has given no figure at all.
Three files released under the Freedom of Information Act fill part of that hole. They are not published anywhere; they are attachments on three request pages on a third-party website.
The headcount
Advisers authorised at the end of each quarter, by advice level:
| Quarter | Level 1 | Level 2 | Level 3 | Total |
|---|---|---|---|---|
| 2013 Q1 | 3,053 | 388 | 594 | 4,035 |
| 2013 Q2 | 3,108 | 390 | 611 | 4,109 |
| 2013 Q3 | 3,144 | 388 | 621 | 4,153 |
| 2013 Q4 | 3,125 | 377 | 622 | 4,124 |
| 2014 Q1 | 3,065 | 373 | 630 | 4,068 |
| 2014 Q2 | 3,020 | 353 | 587 | 3,960 |
| 2014 Q3 | 3,007 | 349 | 587 | 3,943 |
| 2014 Q4 | 2,840 | 344 | 580 | 3,764 |
| 2015 Q1 | 2,760 | 336 | 571 | 3,667 |
| 2015 Q2 | 2,696 | 347 | 557 | 3,600 |
| 2015 Q3 | 2,685 | 348 | 554 | 3,587 |
From the peak in the third quarter of 2013 to the last quarter on record, the regulated population fell by 566 — 13.6% — in two years. Level 1, the entry tier and 76% of the profession, lost 459 of them.
A separate release gives monthly figures for the year before: 3,937 advisers in October 2012, rising to 4,065 in October 2013. The profession was growing until the middle of 2013 and shrinking from the end of it.
It was not attrition
The obvious explanation is people leaving. It is the wrong one.
| Applications received | Approved | Left the scheme | |
|---|---|---|---|
| 2013/14 | 972 | 758 | 785 |
| 2014/15 | 471 | 456 | 664 |
Departures fell, from 785 to 664. What collapsed was arrivals: applications to join more than halved, from 972 to 471, and approvals from 758 to 456. In 2013/14 the scheme roughly replaced itself. In 2014/15 it approved 456 and lost 664 — a net loss of 208 in a single year.
Quarter by quarter the fall is abrupt. Applications ran 334, 252, 182, 204 through 2013 and into early 2014, then dropped to 96 in the second quarter of 2014 and stayed between 96 and 158 for the next six quarters.
What happened in between
A competence assessment. The regulator’s own account, in a document released in answer to a different request, is that “Level 1 assessments have been held every month since July” 2013, with Level 2 and 3 assessments quarterly from August.
Before that there was no examination to sit. From July 2013 there was, and its pass rate across 35 recorded sittings is 26% — with individual sittings as low as zero.
The sequence is: assessment introduced July 2013; headcount peaks Q3 2013; applications halve by Q2 2014; the profession falls 13.6% over the following two years while departures decline.
That is a sequence, not a proof. Nothing in these documents attributes the fall to the assessment, the same period covers substantial changes to immigration law and legal aid, and no counterfactual is available. What can be said is that the timing lines up, that the fall is on the intake side, and that nobody has been in a position to notice either, because the regulator stopped publishing the numbers five years before it happened.
Why this took a Freedom of Information Act
Of the six legal regulators this site reads, this is the only one the Act reaches. That is the reason these figures exist at all.
It is also why they stop. The three releases cover 2012 to 2015 because that is when three people happened to ask. Nobody asked about 2016, or 2020, or last year, so nothing is known about those years beyond what the annual reports chose to print — which, for the size of this profession, is nothing since 2008.
A regulator that publishes its headcount produces a series. A regulator that answers requests produces an archipelago.
The figures
Quarterly headcount and leavers from FOI.AD.15.52.xls, released in
December 2015; applications and approvals from FOI.AD.15.51.xls, released
alongside it; monthly headcount from a spreadsheet released in 2013. All
three are attachments on request pages at WhatDoTheyKnow, linked from
sources and licences, and the quarterly table is
reproduced on the immigration advisers page.
Stock and flow are kept apart throughout: how many were authorised at the end of a quarter is not the same kind of number as how many joined or left during it, and adding them is how a profession appears to double.
One request in this set was refused, and it is the one that would have extended the series. Asked for monthly application figures from January 2013, the regulator said the work would exceed eighteen staff hours because “a new program would need to be set up and run to extract this information from our database”, and that “this database cannot tell us the number of applicant advisers for 2013 and 2014”. The partial figures above are what it released instead.