HM Passport Office

5. Mr B complains about the service he received from ​HM Passport Office (HMPO) and the Office for the Independent Examiner of Complaints (OIEC)​ between 1 November 2023 and 15 August 2025. He complains that:

6. HMPO refused to accept a copy of his change of name document and would not exercise its discretion to allow him to provide this rather than the original, despite his explanations for why the original could not be provided.

7. HMPO refused to allow him to present the original document in person at its offices, which he offered to do as a compromise so he would not have to post it.

8. The OIEC took an excessive amount of time to provide a response to his complaint, and the complaint response was inadequate and not independent

9. As a result of the claimed failings, Mr B explained that he was left without a valid British passport for over a year, which prevented him from travelling freely for family, work, and urgent reasons abroad.

10. Mr B told us that he suffered financially, as HMPO retained his overseas application fee, and he had to pay again for a fast-track re-application. He incurred further costs for certified translations, postage, and courier services.

11. Mr B explained that the events caused prolonged stress, frustration, and a sense of exclusion, which was worsened by the fact he was living overseas during a time of war, which was the primary reason that posting his original document would have been unsafe.

12. The responses and comments from HMPO and the OIEC showed a complete lack of understanding of his circumstances and reinforced his concern that racial or other discrimination played a role.

13. When he arrived in the UK on 2 February 2025, he was detained at Border Control for around one and a half hours because of the lack of a valid passport. Although the officers were satisfied that he was a British citizen, he was told that because he did not hold an ETA (which British citizens are not required to have), he fell into a grey area and was effectively not free to leave. An ETA is an ‘electronic travel authorisation’; a digital entry requirement for visa-exempt travellers, allowing them to enter certain countries without a traditional visa.

14. Mr B explained that the whole experience was embarrassing, distressing and humiliating.

15. By bringing the complaint to us, Mr B is seeking a full refund of all fees and associated costs that he wrongly incurred because of HMPO’s mistakes, which amounts to £430. He wants to see HMPO provide compensation in the region of £3,500-£4,500 in addition to this.

16. Mr B has dual nationality. On 1 November 2023, he applied to renew his UK passport. However, some of the documents he submitted suggested he was also using a different name from the one shown in his existing UK passport. HMPO therefore asked him to provide further evidence to explain the name change. As part of this evidence, Mr B sent HMPO a photocopy of a change of name document (CONC) together with a translation document, a photocopy of his foreign passport, two photographs, and his existing UK passport.

17. On 20 November 2023, HMPO told Mr B it needed confirmation of the name he was using. It noted the difference between his current and previous names and asked him to confirm which name he intended to use for all purposes.

18. Mr B asked HMPO to clarify its request. HMPO replied that, although he had applied in the name shown on his existing UK passport, some of the supporting documents, including his foreign passport, were in a different name. It explained that it operated a one-name policy and again asked him to confirm which name he intended to use going forward.

19. Mr B said he intended to continue using the name shown on his existing UK passport. He accepted that his foreign passport showed a different name but said he could not officially change it for seven years. He asked HMPO to rely on the CONC and translation document he had already provided and to issue the passport in his existing UK name without further delay.

20. HMPO replied that, before it could continue with the application, Mr B had to provide official confirmation of the name he intended to use, and that this had to match either his UK or foreign passport. It said he could not hold the two documents in different names. HMPO asked him to provide proof that the chosen name was used for all official purposes and requested two supporting documents, giving examples that included a CONC signed in both the old and new names.

21. Mr B said he had already provided his foreign passport and the CONC. HMPO replied that it could not accept the CONC because it was only a photocopy and asked him to send the original document.

22. Mr B said he could not provide the original document. He explained the difficulties he faced in obtaining and sending it, and asked HMPO to accept the official translation document, which HMPO had not challenged, as evidence that the CONC was genuine.

23. On 28 November 2023, Mr B told HMPO he was in the UK. He said he had the original CONC with him and asked whether he could present it in person at the Passport Office. HMPO refused, saying that because this was an overseas application, he could not submit the document in person.

24. A few days later, HMPO contacted Mr B again. It explained that, for security reasons, it does not accept photocopies of certain documents and asked why he could not send the original. Mr B replied that he was not in the UK and that, because of the situation in his country of residence, sending the original document would be dangerous and potentially life-threatening. HMPO said this appeared to conflict with what he had said a few days earlier, when he stated that he was in the UK, and asked him to confirm which country he was in.

25. Mr B said he had since left the UK and that, in any event, his brief time there was irrelevant because HMPO had already told him he could not deliver the document in person. He said that if HMPO changed its position, he would be willing to take the document to its office, but he was not prepared to send such a sensitive legal document by post. HMPO again said it would not progress the application until it received the original CONC, as it could not accept photocopies.

26. HMPO added that customers could not attend in person to show documents, because in-person appointments were only available for fast-track applications and by appointment only. It said that if it did not receive the original document, it would treat the application as withdrawn and keep the application fee.

27. Mr B said he was unhappy with the situation and felt he was being blackmailed. He asked how to make a formal complaint. HMPO explained the complaints process but said that making a complaint would not affect the application and that he still had to provide the requested document.

28. Mr B then made a formal complaint to HMPO. He said he had provided the necessary documents and that HMPO had failed to take proper account of the situation in his country, namely an ongoing war affecting every part of daily life. He accepted that the CONC was a photocopy but said it had been supported by official documents that effectively confirmed its authenticity.

29. In December 2023, HMPO replied that its records showed it had explained several times why it needed the original document, but that Mr B had still not provided it. It said that if he did not send the original by 5 January 2024, it would treat the application as withdrawn.

30. On 2 January 2024, HMPO contacted Mr B again and said it was giving further consideration to the situation in his home country and how this might affect his ability to provide the requested document. It asked him to allow time for that review.

31. Mr B asked HMPO for a clear timescale, saying he had already waited three months. HMPO replied that it could not say exactly how long the review would take.

32. On 12 January 2024, HMPO formally treated the application as withdrawn because Mr B had still not provided the original CONC. It wrote to him the same day to confirm this.

33. Mr B then contacted HMPO again. He said that the last update he had received, on 2 January, indicated that the matter was still under review. He again explained why he could not provide the document because of the situation in his country, and asked HMPO to stop delaying matters and issue his passport without further delay.

34. In February 2024, Mr B sent HMPO a copy of his approach to his MP. In it, he set out what had happened so far and suggested that HMPO’s actions might be racially motivated. He again asked for his passport to be issued without further delay.

35. Later that month, HMPO replied again to Mr B’s complaint. It repeated its reasons for withdrawing the application and said that if he wished to reapply, he would have to pay the fee again. HMPO added that its procedures applied to all applicants for a British passport and rejected Mr B’s suggestion that it had discriminated against him.

36. Over the following weeks, Mr B continued to pursue his complaint, both directly and through his MP. He said he could not understand why HMPO appeared to be making matters more difficult and repeated his view that this might be due to racial bias. He also repeatedly referred to the situation in his country and what he saw as HMPO’s failure to take proper account of it when considering his application.

37. HMPO initially maintained that it had done nothing wrong. It again explained why it had asked for the original CONC and said the application had been withdrawn because Mr B had not complied with that request.

38. However, in late March 2024, HMPO changed its position. It said the office handling Mr B’s application should have sought advice from a specialist team within HMPO. Had it done so, the specialist team would have advised that the documents Mr B had provided were acceptable because they included formal confirmation from the authorities in his country that the CONC was genuine. HMPO therefore accepted that the passport should have been issued. It apologised for the error and the inconvenience caused and said a new application could be processed free of charge.

39. Mr B said he did not consider the matter resolved. Although his main concern was to receive his passport, he also wanted HMPO to properly acknowledge and remedy the stress and inconvenience it had caused. HMPO offered him £100, but he did not accept this and instead escalated his complaint to the Office of the Independent Examiner of Complaints (OIEC), the final stage of HMPO’s complaints process.

40. The OIEC did not uphold Mr B’s complaint. It said HMPO had followed the correct procedures when considering the application and that the delay arose because Mr B had not sent the original CONC. The OIEC noted HMPO’s later view that the application should have been processed on the basis of the documents already provided but said this was mistaken. Although there was formal confirmation that the CONC was genuine, the OIEC said HMPO should only have accepted it if that confirmation had been attached to the original document, not a photocopy.

41. It added that HMPO might have been able to accept the document if Mr B had shown that it was impossible for him to send the original. However, it concluded that, while he had explained why he did not want to send it, he had not shown that it was impossible for him to do so.

44. To help put this complaint, and our decision, into context, we think it would be helpful to say more about the HMPO’s approach to issuing passports to overseas applicants.

45. HMPO is the Home Office department that issues UK passports. It follows the Home Office policy that a person’s name should be the same across official documents, including passports. This is partly for security reasons.

46. At the time, HMPO’s guidance for passport applications made outside the UK explained which documents applicants had to provide.

47. If someone had changed their name since their last UK passport was issued, they had to send documents proving the name change. HMPO said these had to be the original documents or official replacements, not photocopies unless it specifically said otherwise. It also warned that sending the wrong documents could delay the application.

48. The guidance also said that an enrolled CONC from an overseas court could be accepted as proof of a name change. But if any document was not in English or Welsh, the applicant also had to provide an official translation. HMPO would only accept the translation if it was attached to the original document.

49. Based on the evidence we have seen so far, there is little we can add to what the OIEC has said already.

50. The main issue is HMPO’s decision not to accept Mr B’s photocopied CONC. We do not think it would be right to look at that document on its own. The photocopy came with a translation, and in some cases a translation can help confirm a document is genuine. But the OIEC explained that HMPO could only rely on the translation if it was attached to the original document. Without the original, HMPO could not be sure the translation and the CONC matched. For that reason, we think HMPO acted reasonably and in line with its guidance when it asked to see the original CONC.

51. We understand Mr B’s concern about posting an important legal document while he was living in a country affected by war. We do not dismiss that concern. However, the evidence we have seen does not show it was impossible for him to provide the original document.

52. The evidence also shows that Mr B visited the UK during these events and, by his own account, had the original document with him. We understand why he wanted to show it in person rather than post it. However, HMPO and the OIEC found no good reason why he could not have posted the document to HMPO while he was in the UK. We agree with that view.

53. We recognise that Mr B offered to show the document in person. But HMPO explained that this was not available for his overseas application. Organisations should consider acting flexibly where appropriate, but we have not seen evidence that HMPO had to change its normal process here. Mr B had another practical option, which was to post the document while he was in the UK.

54. We have noted the confusion caused by the HMPO’s later contention that it should have accepted Mr B’s documents when he first applied. This no doubt would have been compounded by the HMPO’s decision at that point to issue Mr B’s passport without further delay (and free of charge). However, the OIEC later explained that HMPO’s later position was itself wrong. Based on the evidence we have seen, we agree with the OIEC’s view.

55. We found the OIEC’s view to be correct because there is nothing in the policy guidance that says HMPO must accept photocopies. While it had discretion to do so, and could have done should they so choose, it was not obligated to. Therefore, it is not a failing that it did not.

56. Our role is to consider what should have happened, not only what HMPO later said it would have done. In our view, HMPO should have asked for the original CONC and, when it was not provided, it was entitled to treat the application as withdrawn. Because that is what happened, we cannot say there was maladministration in HMPO’s handling of the application.

57. Mr B had made it clear that he felt HMPO’s decision to not allow the use of the photocopy, and its handling of his case was discriminatory. Specifically, he told us that he believed antisemitism had played a part in the outcome because Israel was the country in question.

58. We have not seen any evidence of discrimination. When we reviewed the evidence, we saw nothing to suggest HMPO handled the complaint this way because Israel was the country involved or because Mr B is Jewish.

59. As has been laid out already, we have found that HMPO’s handling of the matter of the request for original documents was in line with guidance. The policy is relevant to all countries, and the decision HMPO made was the one we would expect to be made regardless of the nationality or religion of the applicant.

60. We are glad HMPO recognised that the process caused Mr B stress and inconvenience and offered him a goodwill payment. We have not found maladministration, so we would not expect HMPO to offer more than that.

61. In summary we have decided not to uphold this complaint. This is because we have seen no indication of maladministration in HMPO’s handling of Mr B’s passport application.

62. We found that the OIEC’s own investigation did take a significant amount of time. We understand that, due to resource issues, there was a backlog of cases at the time, but it would not fall to us to tell organisations how to expend its resources.

63. We realise this is unlikely to be the outcome Mr B was looking for when he approached our office. We hope this report reassures him that we have considered his concerns thoroughly and we thank him for bringing these issues to our attention.

1. This statement sets out our final decision on this case.

2. Having looked carefully at the evidence available to us so far, we have decided to not uphold Mr B’s complaint. This is because we have not seen evidence that HM Passport Office (HMPO) acted wrongly when it handled his passport renewal application. Nor have we seen evidence that the Independent Examiner of Complaints (OIEC – the final stage of HMPO’s complaint process) unreasonably delayed its response to Mr B’s complaint.

3. We accept that HMPO later caused confusion by saying it should have accepted Mr B’s documents and by issuing a passport free of charge. However, having reviewed the evidence it is our decision that this retraction was itself an error. We therefore cannot say Mr B was disadvantaged by HMPO’s original decision to ask for an original document rather than a photocopy.

4. We realise this has been a lengthy and very difficult process for Mr B and we thank him, both for bringing these matters to our attention and for his patience while we carried out our work.