Ms Mary Heavey:

That is definitely one part of it, but what more frequently comes up in our work is that the individuals who come to us have a long-term right to reside in the State, but their particular basis for residency is not covered by the circular. Again, the circular itself is not law. It is purely administrative guidance. The circular is contrary to EU law in that it does not reflect all categories of people who have an entitlement to be in Ireland and access those supports. Very often, it comes down to reminding the local authorities that the circular is not lawful and there is a whole other host of categories of lawful residents who are here. Sometimes it is a matter of gathering the information but, more often than not, it is about reminding the local authority that, despite what the circular says, a certain person does have a lawful right to reside here.