Do I need to send documentation for all years?

[MagicByNature]

Hi everybody.
I recently discovered that my application for naturalisation won't be as straightforward as I expected due to the infamous comprehensive health insurance. I am a EU citizen, and been living in UK since 2004 (with a small gap). Here's my timeline:

Sep 2004-Jun 2006: Secondary school
Jun 2006-Apr 2007: Gap year, went back to my country
Apr 2007: Came back to UK, started employment (WRS registered), as well as registered as self-employed
Sep 2007-Sep 2011: University
Sep 2011-Sep 2012: Self-sufficient. During this year, I was applying for jobs and PhDs. Mostly supported myself through family, bank overdrafts and 3 months worth of housing benefit.
Sep 2012 until now: PhD.

At no point in those 11 years I have had any comprehensive health insurance, other than being covered by the NHS. However, I have been self-employed since 2007. My income through self-employment has been zero or negligible, but I have submitted a tax return for it every year. Would this be enough for me not to require the extra health insurance?

Also, how problematic would my year of self-sufficiency be? Is relying on bank overdrafts and housing benefit acceptable?

[CR001]

You need CSI for any period of self sufficiency as well.

[noajthan]

Hi everybody.
I recently discovered that my application for naturalisation won't be as straightforward as I expected due to the infamous comprehensive health insurance. I am a EU citizen, and been living in UK since 2004 (with a small gap). Here's my timeline:

...

At no point in those 11 years I have had any comprehensive health insurance, other than being covered by the NHS. However, I have been self-employed since 2007. My income through self-employment has been zero or negligible, but I have submitted a tax return for it every year. Would this be enough for me not to require the extra health insurance?

Also, how problematic would my year of self-sufficiency be? Is relying on bank overdrafts and housing benefit acceptable?

To have any chance whatsoever your self employment really needs to be shown to be genuine & effective & not marginal & supplementary (to some other activity).
Your documentary supporting evidence for all this needs to be unimpeachable.

If 'self-sufficient', as well as the need for CSI, you need to show you have not been a burden to the state.
So fewer benefits the better in that period really.

You can get into the mind of the HO caseworker assessing your case here:
https://www.gov.uk/government/uploads/s ... _clean.pdf

Your PR clock clearly only started in 2007 (due to prior gap year).

Did you have a foreign-issued EHIC in those carefree student year/s?
And/or did you have a RC issued to you as a student in or before 2011?
It's a longshot but those documents may excuse you from need for CSI (as a student not as self-sufficient) due to a transitional arrangement.

Otherwise, if no CSI when 'self-sufficient' you will have stopped your PR clock dead.
It will have restarted in 2012 and needs to run to 2017 for you to acquire PR.
(That is if the self-employment since 2007 does not stand up for a suitable 5-year period)..

Final longshot, do you have a family member (parent) who has been a qualified person exercising treaty rights continuously in UK in some 5-year period since 2007?
If so you may have acquired PR as a dependent ie a direct family member.
How old are you?

[MagicByNature]

To have any chance whatsoever your self employment really needs to be shown to be genuine & effective & not marginal & supplementary (to some other activity).
Your documentary supporting evidence for all this needs to be unimpeachable.

If 'self-sufficient', as well as the need for CSI, you need to show you have not been a burden to the state.
So fewer benefits the better in that period really.

You can get into the mind of the HO caseworker assessing your case here:
https://www.gov.uk/government/uploads/s ... _clean.pdf

Your PR clock clearly only started in 2007 (due to prior gap year).

Did you have a foreign-issued EHIC in those carefree student year/s?
And/or did you have a RC issued to you as a student in or before 2011?
It's a longshot but those documents may excuse you from need for CSI (as a student not as self-sufficient) due to a transitional arrangement.

Otherwise, if no CSI when 'self-sufficient' you will have stopped your PR clock dead.
It will have restarted in 2012 and needs to run to 2017 for you to acquire PR.
(That is if the self-employment since 2007 does not stand up for a suitable 5-year period)..

Final longshot, do you have a family member (parent) who has been a qualified person exercising treaty rights continuously in UK in some 5-year period since 2007?
If so you may have acquired PR as a dependent ie a direct family member.
How old are you?

Thanks. I just read up on the self-employment situation and mine was clearly too marginal to count. I did not have a RC issued.

However, I discovered that I was probably still covered by the Polish health service until late 2012. I have never had an EHIC card issued in Poland (because what was the point? From what I have seen, the requirement to have CSI other than NHS cover was only established in 2011), but if I get a letter from the Polish NHS confirming my entitlement, would that be sufficient?

In that case, I would have exercised treaty rights for 5 years between April 2007 and 2012, and presumably if a PR is issued, I'd be able to apply for naturalisation straight away?

Another question is about my PhD. It is fully funded, and I get a salary every month. I get payslips, with my tax code on them, but the salary itself is untaxed. Could that potentially be treated as employment?

[noajthan]

...

Thanks. I just read up on the self-employment situation and mine was clearly too marginal to count. I did not have a RC issued.

However, I discovered that I was probably still covered by the Polish health service until late 2012. I have never had an EHIC card issued in Poland (because what was the point? From what I have seen, the requirement to have CSI other than NHS cover was only established in 2011), but if I get a letter from the Polish NHS confirming my entitlement, would that be sufficient?

In that case, I would have exercised treaty rights for 5 years between April 2007 and 2012, and presumably if a PR is issued, I'd be able to apply for naturalisation straight away?

Another question is about my PhD. It is fully funded, and I get a salary every month. I get payslips, with my tax code on them, but the salary itself is untaxed. Could that potentially be treated as employment?

Your best bet is probably 2007 - 2012. then.
Yes if you acquired PR by 2012 you could shoot for privilege of citizenship as soon as all other requirements for naturalisation have been/can be met;
(including the elusive confirmation of PR card).
No need to wait another 12 months with PR in your case.

Ofcourse this depends on assembling a bunch of unimpeachable supporting documentary evidence - including some sort of letter from the Polish health authorities.
(An official translation will be needed if you can't persuade them to entertain your request in English).

As to your PhD being classed as work, & so you as a worker, I'm not sure (I'm sure it feels like work though).

Suggest make a play for the health letter.
Collate rest of your evidence - have a few dry runs filling in the form & see how it all stands up.

What about parent as sponsor? Could that fly?

[MagicByNature]

Your best bet is probably 2007 - 2012. then.
Yes if you acquired PR by 2012 you could shoot for privilege of citizenship as soon as all other requirements for naturalisation have been/can be met;
(including the elusive confirmation of PR card).
No need to wait another 12 months with PR in your case.

Ofcourse this depends on assembling a bunch of unimpeachable supporting documentary evidence - including some sort of letter from the Polish health authorities.
(An official translation will be needed if you can't persuade them to entertain your request in English).

As to your PhD being classed as work, & so you as a worker, I'm not sure (I'm sure it feels like work though).

Suggest make a play for the health letter.
Collate rest of your evidence - have a few dry runs filling in the form & see how it all stands up.

What about parent as sponsor? Could that fly?

Sadly, parent or sponsor wouldn't work. I am currently trying to confirm if I've been covered by the Polish health service.

I just realised another potential problem though - between early July 2010 and late September 2010 I was on holiday abroad - during time between finishing my undergrad and starting my masters. This is almost 3 months abroad - although I was already accepted for my masters course when I went on holiday, so it was certain that I'm coming back. Is it likely to be a problem?

[noajthan]

...
Sadly, parent or sponsor wouldn't work. I am currently trying to confirm if I've been covered by the Polish health service.

I just realised another potential problem though - between early July 2010 and late September 2010 I was on holiday abroad - during time between finishing my undergrad and starting my masters. This is almost 3 months abroad - although I was already accepted for my masters course when I went on holiday, so it was certain that I'm coming back. Is it likely to be a problem?

You are allowed time out for good behaviour!
Continuity of residence in UK is not interrupted by absences of up to 6 months in a 12 month period.

[MagicByNature]

Hello everyone.
I posted a few months ago asking for advice. I am almost ready to apply for PR as a EEA citizen, but have a few more questions.

1. I am aware that absences shorter than 6 months during the 5 years don't really affect the application. However, do I have to account for the time I am absent? For example, I finished my undergrad in June 2010, and started another course in September 2010. Between this time, I was away from UK and did not have any accommodation during that time. Could absences like that cause any problems?

2. I did my A-levels in UK between 9/2004 and 7/2006. Then I took a gap year, during which I was mostly back in Poland. I then came back to UK in 4/2007 for a job and then uni. I assumed that the gap year will reset the timer, and I will have to start the 5 year period from 2007. However, I realised that I was actually in UK for a few days in 12/2006 and 1/2007 for university interviews and exam resits. That sounds like a longshot, but could I have my 5 year period start in 2004 in that case? This would make my life a bit easier.

3. After I finished my masters course, I looked for a job/PhD for some time and got into a bit of a debt. For some time, I relied on overdrafts, my limited savings and help from my family. I also got some housing benefit, although that was already granted when I had my PhD secured. Again, could that in any way harm my claim as self-sufficient/job-seeker?

4. While I discovered that I was not covered by my home country's health service while in UK, I also remembered that I had a comprehensive, international travel insurance linked to my Polish debit card (I assume that a policy that covers 60,000 euros of potential medical costs is comprehensive enough for the purpuse of the application). However, there might have been some short periods (eg. when my card expired, and a new one was still being issued) when I was not technically covered - although I still need to confirm that. Is this likely to be a problem, or might that be overlooked?

[noajthan]

Hello everyone.
I posted a few months ago asking for advice. I am almost ready to apply for PR as a EEA citizen, but have a few more questions.

1. I am aware that absences shorter than 6 months during the 5 years don't really affect the application. However, do I have to account for the time I am absent? For example, I finished my undergrad in June 2010, and started another course in September 2010. Between this time, I was away from UK and did not have any accommodation during that time. Could absences like that cause any problems?

2. I did my A-levels in UK between 9/2004 and 7/2006. Then I took a gap year, during which I was mostly back in Poland. I then came back to UK in 4/2007 for a job and then uni. I assumed that the gap year will reset the timer, and I will have to start the 5 year period from 2007. However, I realised that I was actually in UK for a few days in 12/2006 and 1/2007 for university interviews and exam resits. That sounds like a longshot, but could I have my 5 year period start in 2004 in that case? This would make my life a bit easier.

3. After I finished my masters course, I looked for a job/PhD for some time and got into a bit of a debt. For some time, I relied on overdrafts, my limited savings and help from my family. I also got some housing benefit, although that was already granted when I had my PhD secured. Again, could that in any way harm my claim as self-sufficient/job-seeker?

4. While I discovered that I was not covered by my home country's health service while in UK, I also remembered that I had a comprehensive, international travel insurance linked to my Polish debit card (I assume that a policy that covers 60,000 euros of potential medical costs is comprehensive enough for the purpuse of the application). However, there might have been some short periods (eg. when my card expired, and a new one was still being issued) when I was not technically covered - although I still need to confirm that. Is this likely to be a problem, or might that be overlooked?

1) No accounting if you were abroad.
See related question:
http://www.immigrationboards.com/eea-ro ... 13738.html

You have to prove residence in UK ofcourse.

2) A one-off absence of up to one year for an exceptional reason can be justified eg study leave, pregnancy etc.
Or unlimited military service. (Or, possibly, a combination of these factors).

Just travelling and being on holiday will not cut it and will have reset your PR clock.

It all depends on the reason and the evidence, which needs to be rock-solid. Eg Erasmus documentation, letter from university & etc.

3) That is not really jobseeking, sounds more like selfsufficient qualified person status.
If you were a jobseeker you need evidence of registration as a jobseeker and jobseeking.
For selfsufficiency to fly you need to have had CSI in place.

4) Travel insurance or those 'repayment type' or cash-back schemes may not be enough.
Dig into that vital question here:
https://www.whatdotheyknow.com/request/ ... issued.pdf
& here:
https://www.gov.uk/government/uploads/s ... _clean.pdf
- ref page 41
If you had a foreign EHIC or a RC issued to you as a student in/before 2011 that would fit the bill too.

[MagicByNature]

2) A one-off absence of up to one year for an exceptional reason can be justified eg study leave, pregnancy etc.
Or unlimited military service. (Or, possibly, a combination of these factors).

Just travelling and being on holiday will not cut it and will have reset your PR clock.

It all depends on the reason and the evidence, which needs to be rock-solid. Eg Erasmus documentation, letter from university & etc.

Is that really just travelling and being on holiday though? I have evidence that I applied to universities in UK in 10/2006, and was attending a university interview and exam re-sits later. It is clear that I was planning on staying in UK, and my continuous absence in UK never reached 6 months.
As I said though, this point is not critical, as I'm absolutely okay with the residence to start in 2007.

3) That is not really jobseeking, sounds more like selfsufficient qualified person status.
If you were a jobseeker you need evidence of registration as a jobseeker and jobseeking.
For selfsufficiency to fly you need to have had CSI in place.

I can indeed provide evidence of jobseeking. I have not registered as a jobseeker - firstly, I was mostly applying for PhDs, which is not exactly what Jobcentres are designed for, and secondly I was not eligible for any Jobseeker's Allowance at that point. Anyway, I should have CSI for that time and could do it as self-sufficient. My question still remains - am I self-sufficient if I rely on my family and overdrafts to support myself?

4) Travel insurance or those 'repayment type' or cash-back schemes may not be enough.
Dig into that vital question here:
https://www.whatdotheyknow.com/request/ ... issued.pdf
& here:
https://www.gov.uk/government/uploads/s ... _clean.pdf
- ref page 41
If you had a foreign EHIC or a RC issued to you as a student in/before 2011 that would fit the bill too.

Yes, I have read the second article before, and I interpreted it that a UK-issued travel insurance is not acceptable (which makes sense). My insurance was provided by an insurance company in Poland, covered me in UK (and other countries), and in my view, satisfies this condition: "...cover the costs of the majority of medical treatment they may receive in the UK... if the policy covers the applicant for medical treatment in the majority of circumstances you can accept it." Sadly, never had EHIC, because really - what was the point when NHS covered me anyway?

[noajthan]

2) A one-off absence of up to one year for an exceptional reason can be justified eg study leave, pregnancy etc.
Or unlimited military service. (Or, possibly, a combination of these factors).

Just travelling and being on holiday will not cut it and will have reset your PR clock.

It all depends on the reason and the evidence, which needs to be rock-solid. Eg Erasmus documentation, letter from university & etc.

Is that really just travelling and being on holiday though? I have evidence that I applied to universities in UK in 10/2006, and was attending a university interview and exam re-sits later. It is clear that I was planning on staying in UK, and my continuous absence in UK never reached 6 months.
As I said though, this point is not critical, as I'm absolutely okay with the residence to start in 2007.

3) That is not really jobseeking, sounds more like selfsufficient qualified person status.
If you were a jobseeker you need evidence of registration as a jobseeker and jobseeking.
For selfsufficiency to fly you need to have had CSI in place.

I can indeed provide evidence of jobseeking. I have not registered as a jobseeker - firstly, I was mostly applying for PhDs, which is not exactly what Jobcentres are designed for, and secondly I was not eligible for any Jobseeker's Allowance at that point. Anyway, I should have CSI for that time and could do it as self-sufficient. My question still remains - am I self-sufficient if I rely on my family and overdrafts to support myself?

4) Travel insurance or those 'repayment type' or cash-back schemes may not be enough.
Dig into that vital question here:
https://www.whatdotheyknow.com/request/ ... issued.pdf
& here:
https://www.gov.uk/government/uploads/s ... _clean.pdf
- ref page 41
If you had a foreign EHIC or a RC issued to you as a student in/before 2011 that would fit the bill too.

Yes, I have read the second article before, and I interpreted it that a UK-issued travel insurance is not acceptable (which makes sense). My insurance was provided by an insurance company in Poland, covered me in UK (and other countries), and in my view, satisfies this condition: "...cover the costs of the majority of medical treatment they may receive in the UK... if the policy covers the applicant for medical treatment in the majority of circumstances you can accept it." Sadly, never had EHIC, because really - what was the point when NHS covered me anyway?

If under 6 months (in a 12-month period) the absence from UK is not an issue and continuity of residence is maintained.
Exceptional reason is only required for a one-off absence of up to one year.
I leave you to do the maths as you know your own timeline best.

The basis of your selfsufficiency is immaterial (as long as legal). CSI is the key.

The point of foreign EHIC (or other alternative for CSI) is ofcourse because NHS is inadequate and is not accepted as CSI.
That's the point; as an economically-inactive person, relying on the NHS places a burden on the country's social assistance system. (It doesn't matter if you worked out, ate vegetables and never troubled a doctor for x years).

I cautioned about travel insurance as you appeared to classify it as 'travel insurance'. Travel insurance is not medical or sickness insurance.

You will be unlikely to be given any benefit of doubt if, as you say, there were gaps in between issue of valid bank cards and the associated policy. That alone makes me nervous about this policy.

If that's all you've got then translate the policy, submit it as evidence - see what happens.

[MagicByNature]

Quick question:
I will be applying for a PR based on my residence between 2007 and 2012. I have actualy lived in the UK since 2004, and still live here, although the 2007-2012 period is the easiest for me in terms of producing evidence. On the form, do I need to cover the entire time (together with evidence), or only those 5 years?
Thanks

[noajthan]

Quick question:
I will be applying for a PR based on my residence between 2007 and 2012. I have actualy lived in the UK since 2004, and still live here, although the 2007-2012 period is the easiest for me in terms of producing evidence. On the form, do I need to cover the entire time (together with evidence), or only those 5 years?
Thanks

At least 2007 up to current date.
Caseworker will want to check you haven't lost PR in subsequent years even if you did acquire it in 2012.

[MagicByNature]

Quick question:
I will be applying for a PR based on my residence between 2007 and 2012. I have actualy lived in the UK since 2004, and still live here, although the 2007-2012 period is the easiest for me in terms of producing evidence. On the form, do I need to cover the entire time (together with evidence), or only those 5 years?
Thanks

At least 2007 up to current date.
Caseworker will want to check you haven't lost PR in subsequent years even if you did acquire it in 2012.

Thanks.
I assume having no CSI after 2012 while being a student wouldn't be a problem in this case?

[noajthan]

Thanks.
I assume having no CSI after 2012 while being a student wouldn't be a problem in this case?

Why would you assume that?
CSI has been mandatory (for students) since 2006. HO started enforcing this since 2011.
And now they play hard ball even on historic applications.

If you were a student and hope your carefree student years counted towards acquiring PR you need to have had CSI (or alternative) in place.

Have you/did you

[MagicByNature]

Thanks.
I assume having no CSI after 2012 while being a student wouldn't be a problem in this case?

Why would you assume that?
CSI has been mandatory (for students) since 2006. HO started enforcing this since 2011.
And now they play hard ball even on historic applications.

If you were a student and hope your carefree student years counted towards acquiring PR you need to have had CSI (or alternative) in place.

Have you/did you

Yes, and I did have CSI while I was a student between 2007 and 2012. I started another course in late 2012 and I don't have CSI since then. That would mean that I am a PR since 2012, and hence there is no need for me to have a CSI now. Am I correct?

[noajthan]

Yes, and I did have CSI while I was a student between 2007 and 2012. I started another course in late 2012 and I don't have CSI since then. That would mean that I am a PR since 2012, and hence there is no need for me to have a CSI now. Am I correct?

If you mean do you have to exercise treaty rights after acquiring PR then no, you do not.

It remains to be confirmed that you did acquire PR in 2012. And have not lost it since.
If you did acquire CSI when you think, your activity is now immaterial and so no CSI required would be required for immigration reasons.

[MagicByNature]

Hi,
I am planning on finally sending my EEA (PR) application next week. The whole timeline can be found in my previous posts, if anyone's interested. I have some final questions regarding some of the things.

1. I first arrived to UK in 2004, where I completed my A-levels in July 2006. After that, I took a gap year and was outside of UK for a while, hence the period between Sept 2004 and July 2006 is probably not going to count towards my residence. However, during my time away I was applying for universities in UK and retaking some exams - and for those purposes I was in UK for a few days in December 2006 and for over a week in January 2007. Could those two periods count as excercising treaty rights? If they do, that would be somewhat helpful, as my residence would then start in December 2006 instead of April 2007.

2. Between April 2007 and now, I was a jobseeker, worker and a student. Additionally, for the entire duration of my stay here, I've been registered as self-employed. However, this self employment was marginal, and no case worker in their right mind would decide it's 'effective' - for the first three years, the turnover was between £200 and £700, and then the business was effectively inactive and there was no turnover whatsoever. However, I remained self-employed and filed a tax-return every year. Now, looking at the guidance to EEA (PR), the evidence required for self-employment is quite extensive. I can of course submit my tax returns and small earning certificates which would show the negligible income derived from this self-employment. In this case, would I really need to submit other stuff, such as invoices, testimonials, proof of advertising my business, etc., or should I keep it light for the case workers?

3. I finished my masters course in October 2011, and between then and June 2012 I was looking for a job/PhD, and can submit plenty of evidence for applying (do I need to submit all? or a few letters/interview invitations/rejections would be sufficient?). I am assuming that for that time I should be classified as a worker, as I was a jobseeker. However, during that time I did not register as a jobseeker with the Jobcentre - I don't think I was eligible for any jobseeker's allowance at the time, and my main priority was finding a PhD (although I applied for a fair number of jobs). I eventually got a PhD offer in June 2012, which started in October 2012 (this raises another question: what am I during that time after accepting the offer and the PhD starting - a jobseeker? Self-sufficient?). Anyway, my main question is whether me not registering at the Jobcentre is likely to pose a problem for PR application?
Also, if I am indeed classified as a worker for that time, I was effectively self-sufficient. Should I submit evidence for self-sufficiency for that time?

[noajthan]

Posts merged.
No need for multiple posts.

[noajthan]

1) Continuity of residence is maintained if absence less than 6 months in a 12 month period (from anniversary of entry into UK). That is, assuming you were a qp for all periods back in UK.

2) On top of cleaner, purer EU law (for genuine/effective work), UK applies its somewhat controversial MET test.
A minimal income will fail such a test.

3) A jobseeker is not a worker, its a jobseeker.

If you are a worker you are not selfsufficient, you are a worker.

See https://www.gov.uk/government/uploads/s ... _clean.pdf

What happened to checking some Polish insurance policy to see if it covers you in lieu of CSI?
Then, as discussed at length previously, you may be able to make a case for being selfsufficient from 2007-2012 - when you may have acquired PR.

If not, based on previous lengthy analysis, it appears your PR clock may have started in 2012 and will have to run through to 2017.

[MagicByNature]

1) Continuity of residence is maintained if absence less than 6 months in a 12 month period (from anniversary of entry into UK). Assuming you were a qp for all periods back in UK.

Yes, I get that. The question is: am I a qualified person while attending a university interview? or attending exams?

2) On top of cleaner, purer EU law (for genuine/effective work), UK applies its somewhat controversial MET test.
A minimal income will fail such a test.

I realise that, and I don't even plan to claim that my self-employment was meaningful. When the caseworker sees that my turnover never exceeded £700, it will be clear that my business is not effective whatsoever. My question regards more to the evidence they need. The guidance document suggest I send invoices, proof of advertising of my business, testimonials from clients, business bank account statements etc. Digging out some of these documents would be a bit hard for me and in some cases impossible. Since the self-employment is 'meaningless' for the immigration purposes anyway, do I really need to send this stuff, or would my tax returns be sufficient?

3) A jobseeker is not a worker, its a jobseeker.

If you are a worker you are not selfsufficient, you are a worker.

And what is my status between finding employment (or in my case, a funded PhD position) and actually starting it? It was 3 months in my case, so not insignificant. In theory, this shouldn't matter, as I am hoping for the 5 year qualifying period to end before that time, but I need to submit evidence for that nevertheless.

What happened to checking some Polish insurance policy to see if it covers you in lieu of CSI?
Then, as discussed at length previously, you may be able to make a case for being selfsufficient from 2007-2012 - when you may have acquired PR.

If not, based on previous lengthy analysis, it appears your PR clock may have started in 2012 and will have to run through to 2017.

Yes, I have indeed confirmed that I had indeed an insurance policy covering me between 2006 and 2012 (and earlier in fact, but the insurance provider does not store policies that far back). Whether this is accepted as a CSI proof remains an open question, although I'd say that it definitely "covers the applicant for medical treatment in the majority of circumstances", so in my view should be accepted.

Sadly, if that fails, my PR clock would not start in 2012, as I haven't had any CSI whatsoever since then. So, unless it is decided that my PhD counts as employment (which in my view should be the case, but I doubt it would happen), I have to hope for the 2007 (or possibly late 2006) to 2012 route to be my only option.

[noajthan]

The answer for those odd few weeks back in UK and waiting to go to uni is: which category of qp do you fall into - with rock-solid proof. There's only 5 to choose from.

But instead of agonising over odd details and odd periods of time, suggest shoot for selfsufficient 2007-2012 backed up by that policy. (Official translation required).
EU law does not prescribe what CSI policy is required so give it a go with what you've got; after all, worst case you lose £65.

For nonsense activities send minimal evidence and caseworker will simply disregard it.

If not wait until 2017.
You could apply for an EEA QP RC in meantime.