A statutory body set up to monitor and review EU citizens’ rights after Brexit will review Home Office rules impacting 2.5 million European nationals living in the UK. The Independent Monitoring Authority (IMA) is challenging the Home Office decision to remove the rights of people living in the UK for less than five years before Brexit if they do not apply in time for permanent residency status. The rules mean they would be classed as undocumented migrants and lose their rights to reside, work, rent property or access services including the NHS. At worst, they could face deportation. The IMA argued the rules were a breach of the withdrawal agreement between the UK and the EU, which guaranteed the rights of EU citizens who were in the country before Brexit. There is also a real issue as to the potential application of EU law in the interpretation of the withdrawal agreement.