If you have been told your refusal is "a 320(7A)", the person telling you is working from a rule that has been superseded twice. The substance survives; the reference does not.
What replaced what
| Period | Operative provision |
|---|---|
| Until 2020 | Paragraph 320(7A) / (7B) |
| 2020 – 10 Nov 2025 | Part 9, Grounds for Refusal |
| From 11 November 2025 | Part Suitability (SUI) |
Under the current framework:
- SUI 9.1 — the deception ground
- SUI 12.1 — where the bans are codified, replacing the former Part 9.7 / 9.8
The legacy numbering persists because reported case law still cites it. A judgment from 2016 discusses 320(7A) and always will. That does not make it the rule your caseworker is applying in 2026.
Practical test for any guide you read: if it describes Part 9 as current, it has not been updated since November 2025. If it describes 320(7A) as current, it is five years out of date.
What the deception ground actually requires
Under SUI 9.1, an application must be refused where the decision-maker is satisfied, on the balance of probabilities, that the applicant used deception by:
- making false representations
- providing false documents or false information, or
- failing to disclose relevant facts
Two things are worth extracting from that.
The standard is balance of probabilities, not beyond reasonable doubt. The Home Office has to think it more likely than not. That is a lower bar than people expect.
"Failing to disclose relevant facts" is included. Deception is not only about what you said — it covers what you left out. An omission you considered immaterial can be characterised as non-disclosure.
Innocent mistakes are the hard cases
The provision requires deception, which implies intent. In practice the difficult cases are the ones where an applicant made a genuine error — a wrong date, an incorrectly described role, a document from an agent they did not scrutinise — and the Home Office treats it as dishonesty.
That distinction is where challenges are won or lost. If a mistake was genuinely innocent, the argument is that the deception threshold is not met at all, rather than that the deception was minor.
A deception finding carries a ban of up to ten years. That is why these refusals are worth taking seriously in a way an ordinary refusal is not — the consequence is not one lost application but a decade of them.
If you are facing one
- Get the full refusal wording, including which SUI provision is cited. The specific ground determines what you are arguing against.
- Establish whether deception is actually alleged, or whether the refusal is on other suitability grounds. They are treated very differently.
- Take legal advice early. A ten-year ban is not an area to self-represent in, and the balance-of-probabilities standard means the Home Office does not need much.
- Preserve evidence about how the error occurred — agent correspondence, drafts, anything showing the mistake was not deliberate.
How this compares
Deception provisions across countries share the same shape but not the same consequences:
| Country | Provision | Typical ban |
|---|---|---|
| UK | SUI 9.1 deception | Up to 10 years |
| Schengen | Article 32 refusal grounds | Case by case; SIS alert possible |
| US | Misrepresentation (INA 212(a)(6)(C)) | Potentially permanent |
The US position is the harshest — which is why we say elsewhere that deleting social media accounts to avoid disclosure is a far worse risk than the refusal it is meant to avoid.
What applicants told us
[Contributed accounts — refusal wording under the new SUI numbering would be genuinely original; almost nothing published shows a post-November 2025 notice.]
Frequently asked questions
Is paragraph 320(7A) still used? No. It was replaced by Part 9 in 2020, and Part 9 was replaced by Part Suitability on 11 November 2025. Deception now falls under SUI 9.1.
Why do people still refer to 320(7A)? Because reported case law cites the old numbering and will continue to. Historic judgments do not update.
What standard of proof applies to a deception finding? Balance of probabilities — the Home Office must be satisfied it is more likely than not.
Does an innocent mistake count as deception? It should not, since the provision requires deception. In practice genuine errors are sometimes treated as dishonesty, and that is where most challenges focus.
How long is the ban? Deception findings can carry a ban of up to ten years.
Does failing to mention something count? Yes. The provision expressly covers failing to disclose relevant facts, not only positive false statements.
Official sources
- UK Immigration Rules — Part Suitability
- Home Office — Suitability guidance
- GOV.UK — Visas and immigration
Verified 29 July 2026. Part Suitability took effect on 11 November 2025 and guidance is still settling. This is a reference, not legal advice — a deception allegation warrants a qualified UK immigration solicitor.