March 2015
Visa Applications - Documenting Decision Rationale
The Customer Perspective
Our customers and stakeholders expect (and we want to provide) a fair, fast and transparent service.
How we deliver visa decision making, including how we document the rationale for our decision, is
an important factor to the quality of the service we provide.
The Process Perspective - Rationale and the Visa Application Decision
Making process (Assess and Decide)
Documenting rationale generally occurs throughout the decision making process and explains your
consideration of the various instructions, evidence, risks and links between information.
What is “Rationale”?
“an explanation of the basis or fundamental reasons for something1 “
What is “Rationale” in the context of Visa Application Decision Making
It provides an explanation and the basis for deciding whether to approve or decline a visa
application.
1
http://en.wiktionary.org/wiki/rationale
March 2015
What does a good decision rationale look like?
Overall a good decision rationale (recorded in AMS notes) will have followed the correct process
and;
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




Show what instructions have been applied
Explain how the applicant was assessed against the relevant instructions, including how the
evidence provided and facts of the case met or didn’t meet instructions
State any risks associated with the application and any mitigation that took place (including
those raised by CrisM or the officer).
Show consideration, where applicable, of the applicant’s unique circumstances, including that an
exception to instructions was considered and whether it was granted
Explain logically how the decision (approve or decline) was reached e.g. evidence & reasoning
linked
Overall be clear and concise to the reader including external stakeholders (e.g. Immigration
Protection Tribunal, Ombudsman).
Bullet point or list style formats are good styles to adopt for setting out the facts to support your
decision. Using approved abbreviations of words/terms (provided in IAC 10/04) also helps to
simplify the text to be written. For those offices using decision templates2, rationale is documented
throughout ending with a final summarised comment.
Documenting clearly and concisely why you made a decision is dependent on how well you have
applied the instructions and followed the standard processes. Giving weight only to the information
that is relevant, and linking this clearly to instructions, is a skill that will develop through experience.
Why is it important how the rationale for my decision is documented?
Being able to expertly document the decision rationale is an important factor in the quality of our
decision making leading to a fair, fast and transparent decision for all applicants. The ability to
expertly document the rationale also aids productivity, through faster decision making and reducing
rework.
Other guidance available
In your own offices, you may have access to standard text examples to help you document rationale.
While standard phrases may be useful, they may not apply to all applicants. It is important to review
your rationale text as a “whole” to ensure it is complete and makes sense with no gaps in reasoning.
This is particularly important in applications of a complex nature.
2
Currently many offices use decision templates (for the assessment stage) to guide their decision making and to record
specific assessment information. Some of the templates have interactive forms which can simplify completion and
recording of facts. Once the form has been populated, the information can be copied and placed into AMS notes, showing
a standard and logical sequence to the decision with relevant rationale documented against the respective criteria.
March 2015
With the various different categories of visas, it is difficult to provide and maintain examples for all
scenarios. However, the next few pages provide broad guidance (for approximately 80% of cases) to
support you in explaining your rationale, helping you to develop your expertise and contributing to
Immigration NZ’s goal of attracting the best people to NZ. Attached to this document are specific
examples for;


A Temporary Visa application - Essential Skills
A Residence Visa Application - Skilled Migrant Category (SMC) with partner
These templates are examples only and should not be taken as standardised templates. They should
be used as training and coaching resources to show how rationale can be articulated in a decision
assessment.
Other key guidance documents are identified in the following table;
Document
Ops Manual - Immigration Instruction
R5.20.10- Documenting Decisions
Ops Manual - Immigration Instruction E7.16
– Documenting rationale
IAC 10/19 - Clarification of Business
Processes
IAC 10/04 - Guidelines for Standard AMS
input
Date Issued/
effective
2 Dec 2013
29 Nov 2010
1 Dec 2010
5 May 2010
Main content
General rules around documenting decisions
for residence visas
General rules around documenting decisions
for temporary visas
Use of notes to document rationale and
examples
When, why and what you should enter AMS
notes
How do I know if I am documenting rationale correctly?
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Apply this guidance and base your rationale on clear, concise and current examples
Review and apply learning from quality assurance checks and findings
Get a second opinion (especially in complex cases) from your trainer, colleague, Technical
Advisor and or Manager.
Take the time to put yourself in the role of a reviewer and check if the explanation for your
decision makes sense and is sound. An example of a completed decision template is attached
and you will see the relevant rationale text which has been highlighted in blue italic font.
Continuous improvement
Using standard text can help us be more efficient in documenting rationale. However you do need to
review your standard texts regularly, to prevent them becoming outdated. If you think it can be
improved, share your learning and do it! We are part of a high volume and global business so
standardisation is good for both the customer and the business.
Just as we want to improve how we document rationale, we also want to improve how we provide
guidance and advice to you on topics such as this. Your feedback is important so tell us what you
liked about this guide and or how we can improve it. Send your feedback to the Assistant Area
manager, Visa Services Operations Support.
March 2015
General guidance for all application types
Criteria
Examples
Good
General
Evidence
Poor
Logical links between Evidence & Reasoning - Ensure there is a logical link
between evidence/ risk (clearly identified) and the reasoning – which can
also be explained as the “ because..”
Ensure relevant evidence is on the file or readily available to support the
documented rationale.
IDENTITY A2
Identity
Has the identity of the applicant
been confirmed?
Passport scanned and accepted as authentic
Positive ID match
Passport submitted
[There is nothing to indicate that the officer checked
the passport and/or whether the officer checked the
passport or other identity information, including the
Verification Toolkit]
OR IF PASSPORT IS NOT MACHINE READABLE
Example 1:
Original passport sighted and accepted.
Example 2:
Passport details are a match to other information as follows:
-
Photo on application form; and/or
-
Full birth certificate supplied with application
OR IF PASSPORT IS NOT SUBMITTED AND/OR NOT REQUIRED
Submitted certified copies of full birth certificate and Colombian issued
Driver’s Licence (photo endorsed). Consistent information. Verified birth
certificate through IOM Mission in Bogota.
Health
Is ASH requirement met?
HEALTH A4
Medical certificate issued 22/12/2013.
HEALTH A4
ASH
March 2015
Criteria
Examples
Good
No significant or abnormal findings.
CXR issued 18/12/2013. CLEAR
No health issues declared on form
Approved panel clinic.
ASH
Character
Are Character
met?
requirements
Bona fides (temporary entry)
Will applicant remain lawfully
and comply with visa?
Genuine intent/lawful purpose
established?
Health requirements met
CHARACTER A5
No character issues declared on form
No AMS warnings or other information to suggest any character issues
United States police certificate issued 9/12/2013 - CLEAR
No other PCC’s required
Character requirements met
BONA FIDES E5
Self-declarations and references show PA has complied with work visas
issued. Intends to submit an EOI. Ongoing employment.
Poor
[There is no explanation of why the applicant is
ASH]
CHARACTER A5
Fiji Police certificate received
[There is no mention of whether the PC was clear or
when the PC was dated]
Satisfied PA is a bona fide applicant
BONA FIDES E5
Needs extra two weeks for sightseeing before
returns to job in home country. Low risk as short
time only – and visa granted offshore based on leave
letter from employer.
When bona fides not met, need to show reasoning and linking of evidence
i.e. a direct link should be explained between the lack of incentives to return
home and the IO not being satisfied the applicants will not stay beyond the
duration of their visa
[First visitor visa approved for three weeks in line
with leave letter. There is no further explanation or
evidence to show additional time approved by
employer].
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Criteria
Risk Assessment
Have
any/all
risks
been
identified and mitigated?
Note: This section concerns
overall risk or other risk (outside
that
addressed
against
instructions)
not
already
addressed.
Examples
Good
Poor
EXAMPLE 1
RISK ASSESSMENT
CRiSM: No risk identified
Client Alert/Warning: None
Employer/Adviser Alert/Warning:
[Alerts/warnings exist but there is no indication
anywhere in AMS notes that they have been
considered and mitigated or generic phrases such as
“no further action required in this instance” recorded.
This doesn’t explain WHY no further action is
required.]
None
There are no concerns with the documents supplied. Evidence accepted as
credible. Risk acceptable.
EXAMPLE 2 re face value documents
PA is a UK national and comes from a low risk background. MRZ clear.
No CRiSM triggers activated.
Documentation of good quality (originals or certified copies). Nothing
identified to elevate risk level, therefore accepted as low risk
applicant. In view of above no further verification carried out and
documents accepted at face value.
In this section the 3 main 
identifiers are:
 CRiSM (including VT Toolkit) 
 INZ History (AMS)
 Third party (including INZ
local
knowledge,
IO’s
[A medical risk was identified in a client warning.
However, no follow-up action was taken. The officer
recorded “no further action required in this instance”
for the medical risk. This does not show any
mitigation.]
[A character risk was identified – for example AMS
shows that the applicant was stopped for driving with
excess blood alcohol, yet no NZPC was requested]
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Criteria
Examples
Good
intuition or to test for EXAMPLE 3
Risk management
possible trends)
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CRiSM profile initiated – no risk activated.
INZ history indicates warning on employer reveals previous job offers
found to be genuine but roles inflated
Partner is declared and holds a work visa issued under WF3 but is not
included in the PA’s SMC application.
These risks have been mitigated by:
1) Site visit completed to verify job offer and duties
2) Summary of Earnings obtained for last 12 months to check income in
line with EA
3) Rang PA – he advised his partner is not included as has decided to
apply separately under SMC. Is otherwise aware that she could have
been included in his SMC application (they have lived together for 12
months).
Poor
March 2015
Temporary Visa- Example of Rationale within a Decision Template
(rationale text in Blue italic font)
Assessment - Temporary Visa - Work - Essential Skills
IDENTITY A2
Acceptable original passport
Passport scanned authentic
Positive ID match
HEALTH A4
Medical certificate issued dd/mm/yyyy – No significant or abnormal findings.
CXR issued dd/mm/yyyy – CLEAR
No health issues declared on form
ASH
A4.15/A4.25 Health requirements met
CHARACTER A5
Declared declined NZ visa application [month] 20XX. PA answered ‘no’ to other character
questions. Declined visa has no adverse effect on character.
No other information to suggest any character issues.
AMS history shows employment in third country – Country B – but less than 5 years.
Country A PC issued with previous application – dd/mm/yyyy - CLEAR
A5.1/A5.5/A5.10 Character requirements met
OFFER OF EMPLOYMENT
Job Title: Registered Nurse
ANZSCO Title: Registered Nurse (Aged Care)
ANZSCO Code: 254412
Skill Level: 1
Employer: ABC Limited
Location: Wellington
Pay rate: $25.60 per hour
Employment period: Ongoing/Full time
Registration requirements: YES – Certified copy of practising certificate included
ESF lists position requirements as:
- Experience: Minimum of 2 years registered Nurse experience
- Qualifications: NZ Registration and current practising certificate
Correct ANZSCO code for job identified? WK1.5
Confirmed job description including core tasks best matches registered nurse as set out in
the ANZCO.
Full time requirements W2.2.10 and WK2.5 (b) (iii):
Employment agreement confirms that job is fulltime at 40 hrs per week.
Market rate requirements W2.10.5:
Careers NZ website checked. Avg pay $18-$23 per hour. Market rate met.
March 2015
Compliant NZ law and genuine/sustainable requirements W2.10.5 and WK2.5 (b) (iii):
EA appears compliant and includes mandatory clauses; ESF form shows employer in
operation for 15 years (no risks indicated), and employer contacts report checked and is
acceptable; noted approved residence applications.
SKILLS AND EXPERIENCE
 Nursing Diploma (from Country A)
 Over 3 yrs of work experience as a nurse which is documented and/or verified in
applications (application references quoted).
 Copy of NZ Nursing Registration (General/Obstetric) provided and verified ONLINE with
the Nursing Council website.
Satisfied the applicant’s qualifications/experience meets requirements of W2.10.1 (b), WK1.5
(c) and WK2.5. (b) (i).
LABOUR MARKET TEST (WK2.10)
Occupation appears on LTSSL/ISSL and applicant has the required skills/experience therefore
accepted no New Zealanders available as per instruction WK2.10 (b).
BONA FIDES E5
 Successfully completed CAP for Nurses programme during period of VV issued for this
purpose.
 First WV
E5 bona fide requirements met
RISK ASSESSMENT
CRiSM:
No risks identified
Immigration History: First offshore visa declined because did not have a place in the CAP for
nurse’s programme. Reapplied and approved after securing course placement. Potential for
ongoing work visas as a registered nurse and/or residence under SMC. No dependents
indicated (checked family tab).
Client Alert/Warning: None
Employer/Adviser Alert:
None
Evidence accepted as credible and verification done offshore. Risk acceptable
DECISION
Approve as instructions/requirements met under WK – essential skills.
First work visa in NZ following registration.
Visa approved to:
dd/mm/yyyy, with multiple travel conditions. Funds and outward ticket
requirements waived as covered by salary.
March 2015
Residence Visa Application- Example of Rationale within a Decision Template
(rationale text in Blue italic font)
FINAL SUMMARY FOR A SKILLED MIGRANT DECISION – extract
assessment of skilled employment; SA partnership and risk management
Lodgement Date: 07/06/2013
DOA: 09/07/2008
POINTS CLAIMED/AWARDED
AREA CLAIMED
AWARDED
Age
30
30
Skilled employment 50
0
Employment bonus points 10
Qualification 40
40
Qualification bonus points 0
Work experience
0
0
–
Selection Point: 130
0
0
Skilled Employment (E1-E9, SM7)
PA is employed as Store Manager with ABC Ltd t/a: XX Pizza, (a franchise of XOX) based in
[location]. PA claims the ANZSCO code for his occupation is 141111 - Café or Restaurant
Manager. This occupation is included on Part A of Appendix 6 and is assessed as skill base 2.
Applicant meets the ANZSCO requirements via his qualification, a Level 6 National Diploma in
Business awarded June 2011.
The PA and SA appear to be the only applicants to be supported by this business through any
visas. PA is currently receiving salary of NZ$40,560PA or $780 per week. The average labour
market rate for a Café or Restaurant manager in [location] is $17.96. The current
employment agreement shows the PA is working 40 hours per week meaning his hourly rate
is: $19.50.
Employer financial documents show the establishment in deficit from 2011-2012 but has
made a profit for the 2013 end of the financial year. The PA appears on each month of
employer monthly schedules showing full time employment.
Phone verification performed on 01/11/2013 with Person A (employer and owner of this
store); from this conversation I had concerns that the PA’s role does not substantially match
a café or restaurant manager as described by ANZSCO. The description of the PA's role did
not appear to show he had responsibility over management tasks in this business.
PPI sent on dd/mm/yyyy in regards to the PA's employment not being a substantial match to
ANZSCO for a restaurant manager. In addition I requested further information including
employer questionnaire form.
Phone verification performed on dd/mm/yyyy with Person B from XOX head office on
dd/mm/yyyy.
ANZSCO 141111 states that this code does not extend to Fast Food Managers and Fast Food
Managers should be assessed under 142111 (Retail Manager (General)).
PPI sent on dd/mm/yyyy in regards to the PA’s employment not being a substantial match to
ANZSCO for either a restaurant manager or retail manager. Response received from Person
A (employer/owner).
The PA is considered the Store Manager at the XX. There are 11 people who work in this
store, included in this list is the owner, the owner's partner and the PA. The XOX franchise
has control over the menus, recipes, operations, appearance of shop, advertising, marketing
March 2015
and pricing and provides each shop with manuals in regards to the operations of the shop
and the training of staff. This shop is predominately takeaways with no seating areas.
XOX's also has a dedicated Health and Safety representative who ensures all stores are
complying with the Health and Safety standards.
SUMMARY OF FINDINGS – Comparison of PA’s tasks/duties with ANZSCO
141111 - Café and Restaurant Manager
Planning menus in consultation with Chefs:
-All recipes and menus are created and set by the XOX franchise.
-No chefs in XX and no scope for influencing menus
Planning and organising special functions:
-No seating area at XX’s in which to hold functions
-The PA does help respond to large orders e.g. from local schools, but I am not satisfied this
is equivalent to ‘planning or organising’.
Arranging the purchasing and pricing of goods according to budget:
-Prices set by XOX centrally, so no scope for PA to set prices
-Employer is in charge of financial oversight and budget, but PA is involved in ordering
-PA uses ‘Pulse’ system for ordering. PA determines how much stock to order based on
standardised stock requirements, i.e. PA orders more when stock drops below a certain level.
-PA does not choose suppliers or products to order
-PA can pay for small purchases using company credit card
Maintaining records of stock levels and financial transactions:
-All stock records managed through Pulse system, linked to stock and the till
-Records produced by Pulse go to employer, not PA, to analyse and maintain
-Employer manages large purchases, mainly through automatic payments
-PA does manage end of day cash up and small purchases through company credit card
Ensuring dining facilities comply with health regulations and are clean, functional and of
suitable appearance:
-XOX head office has a member of staff who is dedicated to visiting stores to ensure they are
complying with Health and Safety Regulations
-PA's ensures that XOX's standards are upheld
-The appearance of the shop is determined by XOX. The primary control over this task is with
XOX's head office.
Selecting, training and supervising waiting and kitchen staff:
-The employer/owner is in charge of all hiring and firing
-PA would be training and supervising trials of new/perspective staff from the XOX's manuals
and signing off the manual checklists once completed.
-PA will make a recommendation to the owner of who he thinks in best for the job. This
shows the PA has involvement but not control over this task.
May take reservations, greet guests and assist in taking orders:
-No seating in this establishment therefore there is no scope to complete this task.
142111 - Retail Manager (General)
Determining product mix, stock levels and service standards:
-Product mix set by XOX centrally
-PA has administrative function in ordering stock, see above, but no ability to determine
levels
Formulating and implementing purchasing and marketing policies, and setting prices –
-Determined by XOX franchise. (See next section)
March 2015
Promoting and advertising the establishment's goods and services –
-Overall marketing and control of advertising is the responsibility of XOX’s head office
-The PA then decides what promotion and e-club deals will be going to the customers. XX is
able to control pricing in relation to sales and food cost percentage but the level of control is
limited as pricing still has to be consistent in all XOX stores
- The PA has shown he has involvement in this but not control
Maintaining records of stock levels and financial transactions –
-XX’s records are all completed through the pulse system linked to the stock and the till
-All big purchases are paid by the employer and bills are set up as automatic payments. The
records are produced from the pulse system and analysed by the employer/owner
-PA does not have any financial duties although has started to do the end of day cash up and
the paying of small bills through the company credit card
Undertaking budgeting for the establishment -PA is not involved in budgeting for XX’s.
employer/owner.
This is the entire responsibility of the
Controlling selection, training and supervision of staff –
-Employer/owner is in charge of all hiring and firing (although they reduce underperforming
staff members’ hours until they quit)
-PA is involved in training and supervising trials of new/prospective staff. The PA is training
from the XOX manuals and signing off the manual checklists once a member of staff has
completed training. The PA will make a recommendation to the employer/owner of who he
thinks is best for the job.
- PA has involvement but no control over this task.
Ensuring compliance with occupational health and safety regulations –
-XOX has a member of staff at the head office who is dedicated to going around stores to
ensure all stores are complying with Health and Safety Regulations.
-It is PA's job to ensure the standards of XOX are upheld.
Tasks from ANZSCO which the PA is completing in full:
 conferring with customers to assess their satisfaction with meals and service
 selling goods and services to customers and advising them on product use
Conclusion: I am not satisfied that there is a substantial match between the Café and
Restaurant Manager role or the Retail Manager role as described in ANZSCO and the PA’s job.
Although the PA does have some involvement in some of the tasks, it is at an administrative
level where he is carrying out functions according to rules set by the owner (XX) or of the
XOX franchise, rather than having the managerial authority to organise or control those
functions himself.
Therefore it has been assessed that the PA's role is a substantial match to a Retail Supervisor
ANZSCO 621511 which is considered unskilled for the purpose of Immigration:
Tasks Include:
 ensuring that customers receive prompt service and quality goods and services
 responding to customers' inquiries and complaints about goods and services
 planning and preparing work schedules and assigning staff to specific duties
 interviewing, hiring, training, evaluating, dismissing and promoting staff, and resolving
staff grievances
 instructing staff on how to handle difficult and complicated sales procedures
 examining returned goods and deciding on appropriate action
 taking inventory of goods for sale and ordering new stock
March 2015


ensuring that goods and services are correctly priced and displayed
ensuring safety and security procedures are enforced
Also to be noted is the fact the Person A owner is in the process of buying another business
(Thai Restaurant). This will change the structure of the business at XX's and give the PA
further scope in his employment. This assessment is of what the PA is doing in his current
employment, not what he may be able to do in time.
Therefore the employment has been assessed as not a substantial match to any occupation
on Appendix 6.
Employment Bonus Points (SM8 and 9) Claimed but not awarded as PA does not meet Skilled
employment.
Applicant is not eligible to claim bonus points for: Having acceptable offer of skilled
employment outside of the Auckland Region - [location] as the PA does not have skilled
employment.
Partnership Status (F2) Married
Partnership was established at least 12 months prior to the lodgement of this application.
Evidence to show the couple have been living together in a genuine, stable and on-going
relationship for greater than 12 months:
Marriage Certificate dated dd/mm/yyyy
Travel Bills for PA and SA dd/mm/yyyy
Medical Receipt for SA addressed to 502 Hurry Way dated dd/mm/yyyy
Letter from SA describing timeline of the relationship
Letter of support from a friend
Letter from the landlord stating the couple have been living at his property ([address]from
Aug 20XX to Apl 20XX)
Photos
Tenancy Agreement for PA and SA dated dd/mm/yyyy
Energy Bills for PA dated mm/yyyy addressed to [address]
Letters from the landlord of 502 Hurry Way dated mm/yyyy, mm/yyyy and mm/yyyy
ANZ Bank Statements (Joint Account) from mm/yyyy to mm/yyyy
Risk management
The following risk factors CRiSM have been activated: No risk activated
The following risk factors have been identified from sources other than CRiSM:
This may include local knowledge, your intuition or to test for possible trends
1.
Employment - Phone verification completed, 2 x PPI's sent, employer questionnaire
and financial documents provided. This proves the employment is genuine. The PA is
working full time and that the tasks completed are not a substantial match to ANZSCO
for 141111, 142111 or any other employment on Appendix 6.
2.
NZPC - Returned and clear
3.
English - Not pursued as the PA does not have skilled employment.
4.
Partnership - Verified
5.
AMS Warnings in regards to providing false and misleading information and evidence.
Therefore all evidence provided has been fully verified.
These risks have been mitigated by: Phone verification with employer, financial
documents requested, employer questionnaire requested, 2 x PPI's sent.
Summary of final decision
Following processing, I am recommending that the application be declined because points
cannot be awarded for skilled employment and therefore the PA does not meet the key
employability and capacity building factors. Points awarded for age and qualification total 70
March 2015
points.
Additionally and based on the information provided PA does not meet the
requirements of any other residence category.
Health, character and partnership requirements for PA and SA met.