Michael Cameron – CIH Housing Festival – 6 March 2024


06 March 2024


06 March 2024

Michael Cameron – CIH Housing Festival – 6 March 2024

Late last year we updated our earlier homelessness thematic review to highlight that systemic failure is now impacting on the homeless services provided by a number of local authorities.

Last week the Scottish Government published homelessness statistics for the six months to September 2023.  These showed that the number of homeless applications is rising and that failures by local authorities to meet statutory duties have increased significantly.  Those statistics reflect what we have seen as we’ve engaged with councils through the course of the year, and those engagements suggest strongly that the next set of homelessness statistics will show a significant further deterioration.

Put simply, for many councils the demands in the homelessness system – the number of people who are homeless, and the level of need they have – exceed the capacity in the system to respond.  For some councils, the increase in capacity that is needed goes beyond that which they can deliver alone.  That is what we mean by systemic failure.

The most acute impact of this is where a council does not have suitable temporary accommodation available when a person needs it.  This results in the council breaching its statutory duties by either having to place the person in temporary accommodation that breaches the Unsuitable Accommodation Order, or in more extreme situations cannot meet its duty to provide temporary accommodation because it does not have any temporary accommodation available.  And this extreme is becoming more commonplace in some councils.

In the six months to the end of September 2023:

  • The number of households in temporary accommodation rose to more than 15,600
  • there were 1,575 instances of households not being offered temporary accommodation – a near five-fold increase on same period in 2022
  • there were 2,335 breaches of the Unsuitable Accommodation Order, up 50% on the on the same period in 2022.

So, we are now starting to see a real risk of statutory failures becoming endemic in some council areas.

Clearly, in this context and with such a significant backlog of households in temporary accommodation, it will be very difficult for councils to realise the ambitions of rapid rehousing.  I’m sure Gavin will have more to say about that.

Systemic failure requires a systemic intervention.  Over the longer term this is about reducing the demands on the system by preventing homelessness.

The Scottish Government is proposing to introduce new duties around prevention; however, the proposals will take some time to come in, and may take longer to impact on the number of people experiencing homelessness.  There is also a risk that, to begin with at least, the proposed “ask and act” duty on public bodies could result in increased referrals to homelessness services and so potentially increase the demand for temporary accommodation.

We’re also seeing risks emerging around current work to support prevention of homelessness.  Many RSLs undertake a range of activities, such as welfare and energy advice, which help tenants to stay in their homes and sustain their tenancies.  But these are not core housing services, and while a relatively small area of expenditure for most RSLs, we see from our analysis of financial projections that they plan to almost halve expenditure on these other activities in the coming five years.  This is likely to reduce RSLs’ capacity to prevent homelessness.  This is another worrying indicator of the strains in the system.

So, for now, the immediate focus has to be about increasing the capacity in the system to meet the current level of demand and need. 

And the real challenge goes back to supply: there are not adequate numbers of homes becoming available to meet the demands that are placed on many councils through people becoming homeless.

Social landlords are seeing a lower turnover of homes than they did before the pandemic hit in 2020: around 1,700 fewer homes became empty during 2022/23 than in the previous year and nearly 5,000 fewer than in 2019/20.

Of course, this may reflect the success of work that landlords do to help people sustain their tenancies, or it may be that existing tenants are less keen to move home during a cost of living crisis.  Whatever the reasons, this means that social landlords have fewer homes available to let to people in need, including those who are experiencing homelessness.

On top of that, the rate at which we are building new social homes is falling, and that is a trend which is projected to continue in the coming years.  The number of new homes RSLs are projecting to build over the next five years is down by 17% compared to the projections last year.  And we know that some have announced reductions in the size, or suspension of their new build programmes, since they gave us those figures last May, so it is likely that these numbers will have reduced further.  And of course, we have since had the Scottish Government’s announcement of the reduction in the budget for affordable housing.

We will continue to engage with councils to promote improvement where this is possible.  And there will be improvements that councils can continue to make that will help, including around maximising the use of existing homes and improving the time taken to turnaround of empty homes.  But, for some councils these improvements are likely to be at the margins.  Our view is that some councils are now at, or are approaching, the limits of their capacity to do more. 

There needs to be an immediate focus on how to resolve that challenge.  This is about increasing the availability of homes to let to people who are homeless.

We need to continue to build more new homes and buy homes where that is possible.  We need to redouble efforts to bring empty homes back in to use.  We need to maximize the use of existing homes that become available to let to people who are homeless.  And, we need to look at what support councils and RSLs need to be able to maintain those services that help people into homes and keep them there.

Much of this is happening at a local level, but we need to scale this up, and that will require resources. 

Again, that is why we have said that systemic failure requires a systemic intervention.

By definition, such an intervention is beyond the scope of what our regulation can deliver, but we stand ready to work with the Scottish Government and other stakeholders to identify and implement actions that will address the acute issues.

Thank you.