DocsCheck & OISC / IAA Compliance

The regulator: OISC to IAA

Responsibility for regulating immigration advice in England, Wales and Scotland passed from the Office of the Immigration Services Commissioner (OISC) to the Immigration Advice Authority (IAA) in June 2025. This was a change of regulator, not a change to the underlying law: the statutory framework in Part V of the Immigration and Asylum Act 1999 remains in force, existing registrations carry over, and the Code of Standards continues to apply under the IAA. Throughout this page we refer to "OISC/IAA" where a point applies under both the previous and current regulator. For the definitive current position, see the Immigration Advice Authority on GOV.UK.

The statutory basis for regulation

Immigration advice and services are regulated under Part V of the Immigration and Asylum Act 1999. Under that framework it is, broadly, an offence to provide immigration advice or services for reward unless you are a "qualified person" — a person regulated by the IAA (formerly the OISC) or a member of a designated professional body, such as a solicitor regulated by the SRA. What counts as "immigration advice" and "immigration services" is defined by the Act itself, not by any software vendor. DocsCheck does not and cannot change those definitions; it is built so that its use sits outside them.

Regulated advice vs a document-checking tool

The distinction that matters is between giving regulated immigration advice and services and using a tool to check documents. Giving regulated advice means things like assessing a client's eligibility, recommending a visa route, interpreting the Immigration Rules for their circumstances, advising on appeal rights, or making representations to UKVI — all activities reserved to qualified persons under Part V of the 1999 Act.

DocsCheck does none of those things. It checks whether the documents in a case file are present, of the right type, internally consistent, and complete against route-specific expectations. That is administrative and quality-assurance work that a regulated adviser would otherwise do manually. The advice, the professional judgements, the representations, and the client relationship remain entirely with the instructed regulated adviser. In short: DocsCheck is a document-checking tool used by advisers — it is not an adviser, not regulated advice, and not legal advice.

How DocsCheck fits within your regulated workflow

DocsCheck is designed to slot into an adviser's existing regulated process rather than replace any part of it. A typical flow looks like this:

• The regulated adviser opens the case and selects the relevant visa route — a professional decision the adviser makes, not the software.
• The client uploads documents; DocsCheck flags missing items, wrong document types, expired certificates, and inconsistencies for the adviser's attention.
• The adviser reviews every flag and AI output, applies their own professional judgement, and decides what to do — the software's output is an aid, never a determination.
• Any AI-drafted representation letter is reviewed, edited, and approved by the responsible fee-earner before it is used.

At every step the adviser remains responsible. Because DocsCheck never advises the client directly or makes representations to UKVI, its use does not cross into regulated activity.

What DocsCheck does and does not do

Using DocsCheck within the OISC / IAA Code of Standards

Regulated advisers must ensure that their use of any technology tool is consistent with the Code of Standards (carried forward from the OISC and continuing under the IAA) and, for solicitors, the SRA Standards and Regulations. Key points relevant to DocsCheck:

Competence and supervision

All DocsCheck outputs — including AI document scores, risk indicators, and AI-drafted letters — must be reviewed and verified by the responsible registered adviser before reliance. AI can flag a likely gap, but it does not exercise professional judgement and can be wrong; the adviser remains responsible for the accuracy and quality of all work submitted in their name.

Confidentiality and data protection — UK GDPR Article 28

When you use DocsCheck, your firm is the data controller and DocsCheck acts as your data processor. Article 28 of the UK GDPR requires processing by a processor to be governed by a written contract setting out the subject-matter, duration, nature and purpose of the processing, the types of personal data, and the obligations of each party. Our Data Processing Agreement provides exactly that. Client data is isolated per organisation, stored securely on Google Cloud Storage, is never shared between firms, and is not used to train third-party AI models. We can provide the DPA on request for your own compliance records.

Client care and communication

DocsCheck's client-facing questionnaires and messaging features are tools to assist you in communicating with clients — they do not provide advice to clients. All client-facing content sent through DocsCheck remains under your control and responsibility.

Record keeping and audit log

DocsCheck maintains a complete, timestamped audit log of all actions on each case — document uploads, approvals, rejections, status changes, and messages — recorded against the user who took them. This supports your record-keeping obligations, makes internal supervision and file reviews straightforward, and gives you an exportable trail to evidence your process if your regulator inspects your files. The audit log assists your record-keeping; it does not replace your responsibility to keep proper records.

Our disclaimer in plain English

Questions for OISC / IAA advisers

If you are considering using DocsCheck and have compliance questions specific to your registration level (Level 1, 2, or 3) under the IAA (formerly the OISC), we are happy to discuss how the platform can be used appropriately within your authorised activities.

Frequently asked questions

Did the OISC become the IAA, and which regulator applies now?

Yes. Responsibility for regulating immigration advice in England, Wales and Scotland passed from the Office of the Immigration Services Commissioner (OISC) to the Immigration Advice Authority (IAA) in June 2025. The underlying statutory framework — Part V of the Immigration and Asylum Act 1999 — is unchanged; the regulator carrying out that function has been renamed and reconstituted. Existing registrations and the Code of Standards continue to apply under the IAA. For the current regulator position, refer to GOV.UK.

What is the statutory basis for regulating immigration advice?

Immigration advice and services in the UK are regulated under Part V of the Immigration and Asylum Act 1999. Section 84 makes it an offence to provide immigration advice or services unless you are a qualified person — broadly, someone regulated by the IAA (formerly the OISC) or a member of a designated professional body such as a solicitor regulated by the SRA. The Act, not any software vendor, defines what counts as regulated activity.

Does using DocsCheck count as giving regulated immigration advice?

No. DocsCheck is a document-checking and case-management tool. It does not advise on a client's immigration position, recommend a visa route, assess eligibility, interpret immigration law, predict outcomes, or make representations to UKVI — those are the regulated activities under Part V of the Immigration and Asylum Act 1999. DocsCheck supports a regulated adviser's own workflow; it does not provide advice and is not a substitute for a regulated professional.

Who remains responsible for the advice and the application?

You do. DocsCheck is software used by a regulated adviser, not a regulated adviser itself. Every professional judgement, every piece of advice given to a client, and every representation made to UKVI remains the responsibility of the instructed IAA-registered adviser or SRA-regulated solicitor. AI outputs — document scores, risk flags, and drafted letters — must be reviewed and verified by the responsible adviser before reliance.

Is DocsCheck legal advice?

No. DocsCheck is not legal advice and not regulated immigration advice. It is a document-checking tool that helps you identify missing or inconsistent documents and organise casework. It does not interpret the Immigration Rules for a particular client or tell you whether an application should succeed. Those determinations remain matters of professional judgement for the instructed adviser.

How does DocsCheck handle personal data under UK GDPR?

When you use DocsCheck, your firm is the data controller and DocsCheck acts as your data processor. Our Data Processing Agreement provides the written contract required by Article 28 of the UK GDPR between controller and processor, setting out the scope, purpose, and security measures for processing. Client data is isolated per organisation and is never shared between firms or used to train third-party AI models.

Can I use DocsCheck to meet my record-keeping and audit obligations?

DocsCheck maintains a timestamped audit log of actions taken on each case — document uploads, approvals, status changes, and messages — which supports the record-keeping expectations in the Code of Standards. The audit trail is exportable, which helps with internal supervision, file reviews, and any regulatory inspection. You remain responsible for ensuring your overall record-keeping meets your regulator's requirements.

Does DocsCheck change my obligations under the Code of Standards?

No. Using DocsCheck does not reduce or alter your professional obligations. You remain bound by the Code of Standards (including competence, supervision, confidentiality, client care, and record-keeping) and, for solicitors, the SRA Standards and Regulations. DocsCheck is a tool that helps you meet those obligations more consistently — it does not assume any of them on your behalf.

Further information

• Understanding AI in DocsCheck — what our AI features do and don't do
• GDPR & data protection — how we handle personal data
• Data Processing Agreement — Article 28 UK GDPR compliance
• Terms of Service — full platform terms including the not-legal-advice disclaimer
• Immigration Advice Authority (IAA) — the regulator for immigration advice (formerly the OISC)
• Immigration and Asylum Act 1999, Part V — the statutory basis for regulating immigration advice