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The immigration regulator revised its own complaints history and said nothing

In 2011 the OISC reported 291 complaints about the advisers it regulated the year before. In 2013 it reported 316 for the same year. Every column of that row changed, the total rose by 98, and no note in any report mentions it.

By Rose Traviss · 29 September 2026

The Office of the Immigration Services Commissioner — now the Immigration Advice Authority — printed the same table in every annual report for more than a decade. Breakdown of total complaints received carried one row per year going back to 2001/02, so each report restated the whole history alongside the new year.

That makes it possible to check a regulator’s account of itself against its own earlier account. Twice, they do not match.

2010/11, restated

The annual report for 2010/11 gives that year as:

About OISC-regulated advisersAbout advisers under other regulatorsAbout unregulated advisersTotal
2010/11, as published in 20112913217340

The annual report for 2012/13 gives the same year as:

About OISC-regulated advisersAbout advisers under other regulatorsAbout unregulated advisersTotal
2010/11, as published in 20133166854438

Every one of the four numbers moved. Complaints about the regulator’s own registrants rose by 25. Complaints about advisers with no regulator at all — giving immigration advice unregulated is a criminal offence under section 91 of the Immigration and Asylum Act 1999 — more than tripled, from 17 to 54. The total rose by 98, or 29%.

The 2011/12 report already carries the revised figure, so the change happened within a year. Neither report explains it. There is no asterisk on the row, no footnote under the table, and no sentence anywhere in either document that says a previously published number has been corrected.

2012/13, restated

The same thing happens once more, four years later. The 2012/13 report gives:

2012/13 — 290 | 22 | 113 | 425

The 2016/17 report gives:

2012/13 — 290 | 58 | 113 | 461

One column moved. Complaints about advisers regulated by somebody else went from 22 to 58, and the total from 425 to 461. Again there is no note.

The one they did explain

This is not a regulator that never explains itself, which is what makes the silence on the other two worth remarking on.

The earliest reports give 2001/02 as 417 complaints, with an asterisk: “Includes 28 complaints that were outside the OISC’s jurisdiction.” Later reports give 389 for the same year, with no asterisk. 417 − 28 = 389. The change is exactly what the footnote describes, and a reader who has both documents can see why the number moved.

There is also a properly flagged change of scope. From 1 April 2011 the Commissioner’s oversight of designated professional bodies was limited to Northern Ireland and Scotland, and both the 2011/12 and 2012/13 reports carry an asterisk saying so. That is the right way to do it.

Why this matters more than it looks

A regulator’s annual report is usually treated as a fixed record: the thing you cite when you want to know what happened. It is not. It is the regulator’s account of the past as it stood when that report went to print, and where the account has since changed, nothing in the document tells you.

Anybody who quoted the 2010/11 report — a select committee, a researcher, a journalist — is quoting a figure the regulator no longer stands behind, and has no way of knowing it. The correction exists only as a difference between two PDFs that nobody reads side by side.

How this site handles it

Where the same figure appears in more than one report with more than one value, the later statement is used, because it is the regulator’s current view of its own past. The year is marked restated and both numbers are published, with a link to each document.

That is kept distinct from a dispute, which is two reports of the same vintage giving different numbers for the same thing. Nothing here can settle that, so both are shown as unresolved. There are no unresolved disputes in this corpus. There are three restated figures, across two years, and all of them are at this regulator.

The figures

Read from the OISC annual reports for 2009/10, 2010/11, 2011/12, 2012/13 and 2016/17, Table 8 or Table 9 in each — the table is numbered differently between editions. Every value, with the row it was read from and a link to the report, is on the reports page.

The complaints series itself, 2001/02 to 2024/25, is on the immigration advisers page. A complaint is not a finding, and the regulator’s own disposal tables show that a substantial share of complaints in every year were unsubstantiated, withdrawn or outside its jurisdiction.