A Freedom of Information appeal challenging the Home Office's refusal to disclose a breakdown of passport issuance costs has been dismissed by the First-tier Tribunal, which ruled that the department did not hold the specific information requested.
The appeal, Dillon Crawford v The Information Commissioner [2026] UKFTT 810 (GRC), centred on a February 2025 FOI request in which Mr Crawford asked the Home Office to provide a detailed breakdown of the costs associated with issuing a 10-year adult passport and a 5-year child passport.
The Home Office declined to provide the breakdown, telling Crawford it did not hold costs data in the form requested. It directed him instead to a published table showing estimated total costs apportioned by unit for the financial year 2022/23, and reminded him that public authorities are only required under FOIA to disclose information they already hold, not to create new information in response to a request.
Following an internal review, the department maintained its position, noting that policies and working practices had changed significantly since 2011, when a similar breakdown had apparently been provided in response to an earlier request. "A response originally provided 14 years ago does not commit us to making the same response today," the Home Office stated.
Crawford complained to the Information Commissioner's Office, which conducted a detailed investigation before siding with the Home Office. In a Decision Notice issued in November 2025, the Commissioner found on the balance of probabilities that the requested information was not held, and separately found that the department had met its advice and assistance obligations under section 16 of FOIA.
Crawford advanced four grounds of challenge at the First-tier Tribunal He argued that the Commissioner had applied the balance of probabilities test inadequately; that the "not held" conclusion was implausible given the 2011 precedent; that the Home Office's request had been interpreted too narrowly; and that the Home Office's admitted failure to respond within the statutory 20-working-day deadline had not been properly recorded in the Decision Notice.
The Tribunal rejected all four grounds. On the question of plausibility, it found Crawford's argument unconvincing, noting that the existence of a breakdown in 2011 gave no reliable basis for assuming equivalent data was still collected or held. "There could be any number of reasons why the way in which statistics are collected in any large organisation will be liable to change over time," the Tribunal said.
On the question of interpretation, the Tribunal reminded itself of the need to read FOI requests "broadly and pragmatically" but declined to rewrite what it described as an unambiguous request. "Our duty does not extend to re-writing Mr Crawford's unambiguous request or deeming his request to have been wider than it was," Judge Snelson wrote.
While the appeal was dismissed in full, the Tribunal did place on record its criticism of the Home Office for failing to respond within the statutory 20-working-day deadline required under section 10 of FOIA. Although this breach did not affect the outcome - and Crawford's argument that it should have been formally recorded in the Decision Notice was itself rejected on technical grounds - the Tribunal said it was "right to place on record" that the department had "departed from the standard rightly expected of it."
The Tribunal also noted that the Home Office had advised Crawford it was in the process of developing a new cost model that would eventually produce per-item figures for passport issuance, and that the department had said it would publish the information once available. Crawford may therefore obtain the data he sought through proactive publication, even if the FOI route has now been exhausted.
