Dear Department of Internal Affairs,

I have a few questions regarding English language requirements for Citizenship by Grant (CBG) applications. I am seeking clarification at a general policy and practice level.

1. English language test requirements
If an applicant uses an English language test to demonstrate knowledge of the English language, what are the minimum acceptable scores for:

- IELTS (overall score and minimum component scores)?
- Other accepted tests such as TOEFL or PTE, if applicable?

2. Interview process and progression to the next decision stage

When the case officer has questions regarding the applicant's English ability, I would like to clarify whether the interview process must be completed in full before the application can progress to English Waiver assessment or Ministerial consideration.

In particular:

- Is the second interview (after a further six months) mandatory in all cases, or can an application proceed to the next decision stage without completing the second interview?
- Can an applicant choose to decline the second interview in order to avoid delay and proceed directly to English Waiver assessment?
- Is there any flexibility to accelerate the process in cases where it is evident that the English language requirement will not be met, rather than requiring the applicant to wait the full six-month period?

3. Age-related impairment under the English Language Waiver Schedule
I would like to understand how age-related impairment is assessed in practice under the English Language Waiver Schedule. Specifically:

- Can age alone be sufficient to establish age-related impairment for the purpose of an English language waiver?
- If age alone can be sufficient, is there an indicative age at which applicants may be considered unable to meet the English language requirement due to age-related impairment?
- If age alone is not sufficient, what additional factors are typically considered (for example, cognitive decline, learning capacity, or other age-related limitations)?
- Is medical or professional evidence, such as a doctor’s assessment, generally required to support a claim of age-related impairment?

4. Other personal factors relevant to an English language waiver
What other “personal factors” are commonly taken into account when assessing whether an applicant may be included on an English Language Waiver Schedule?

5. Ministerial consideration where English language requirements are not met
Where an applicant does not meet the English language requirement and does not clearly meet the criteria for inclusion on an English Language Waiver Schedule, what key factors are typically considered when the case is submitted to the Minister?
In particular, what circumstances may lead to citizenship being granted under section 8(8), as opposed to the application not being approved?

6. Process guidance / decision framework
Please provide any flowchart, standard operating procedure (SOP), or other process guidance that outlines, step by step, showing how it is determined whether an applicant meets the English language requirement?

In particular, any guidance showing how a case officer considers factors such as the applicant’s age, education background, employment, and circumstances in which concerns about English language ability may arise, as well as how decisions are made regarding English Language Waivers and Ministerial submissions.

7. Statistical information for applications with an outcome
Please provide aggregated data for the period 2020–2025 relating to Citizenship by Grant (CBG) applications where an applicant’s English language ability required further assessment.

For each outcome year, please provide data in total and broken down by the following age groups:
- 60–64 (inclusive);
- 65–69 (inclusive); and
- 70 and over.

Specifically, could you please provide:
- The number of applicants who were required to attend at least one English language interview due to concerns that they may not meet the English language requirement;

- Of these applicants, the number who were assessed as not clearly meeting the English language requirement and were referred to the English Language Waiver Schedule;

- Of those referred to the English Language Waiver Schedule, the number who met the requirements and were subsequently approved for citizenship under the Waiver Schedule;

- Of applicants who did not clearly meet the requirements to be included on the English Language Waiver Schedule and were referred to the Minister as a submission, the number who were granted citizenship following Ministerial consideration under section 8(8); and

- The number of applicants who were not approved following Ministerial consideration, due to not meeting the English language requirement.

Yours faithfully,

David Singh