Written evidence submitted by Shelter [HCE 068]

SHELTER SUBMISSION

Housing, Communities and Local Government Committee

Inquiry: Housing conditions in England

15 August 2025

Introduction

Shelter exists to defend the right to a safe home. Because home is everything. Last year, we stood with millions of people affected by the housing emergency. From advising and supporting families via our online advice, free emergency helpline, community service hubs and legal teams, to national and local campaigning for stronger housing rights and better housing options.[1]

Overarching

What is the general condition of homes in England and how prevalent are housing hazards such as damp and mould?

1. In England, it’s of great concern that some tenants live in homes which risk their health and safety, because they contain serious (Category 1) health and safety hazards under the Housing Health & Safety Rating System:

• 496,000 private rented homes (10%) have at least one category 1 hazard

• 177,000 social homes (4%) have at least one category 1 hazard.[2]

2. Well into the 21st century, some tenants’ health is being put at risk by damp: 

• 448,000 private rented homes (9%) have a damp problem
• 288,000 social homes (7%) have a damp problem.[3]

3. A greater number of rented homes fail to meet the current Decent Homes Standard (DHS):

• Over 1 million private rented homes (21%) fail the DHS.
• Currently, 431,000 social homes (10%) fail the DHS.[4]

Temporary accommodation

4. In 2023, we published Still Living in Limbo: why the use of temporary accommodation must end: the findings of the largest ever survey of households in temporary accommodation (over 1,000 respondents). This found hundreds of thousands of people, including families with children, stuck in temporary accommodation in dangerous, slum-like conditions.[5]

5. Our research found three-quarters (75%) of households were accommodated in poor conditions, including one in five (21%) with a safety hazard, such as faulty wiring or fire risks. More than two thirds (68%) of people had inadequate access to basic facilities - such as cooking or laundry facilities. Four in ten had experienced problems with damp, mould or condensation. 35% (more than one in three) had issues with insect or infestations and 18% (more than one in six) had problems accessing running water.

Social housing sector

How effective will the proposed reforms to the Decent Homes Standards be at improving the conditions of social housing?

6. We welcome the government’s commitment to reforming the Decent Homes Standard (DHS) and participated in the previous government’s review of the standard in 2022-23. Given the DHS categories were established in 2001, we agree they’re in need of review and reform to reflect modern expectations of decency. We will be responding to the current consultation on the new DHS in due course.

7. In particular, we welcome the proposal to expand the essential features assessed under Criterion C of the Standard to include window restrictors. We urged the previous government to include this following a number of tragic cases where children have fallen to their deaths because it was not possible to have windows open safely.

8. We also support the provision of suitable floor coverings. Through our advice services we see the impact of such lack of basic, and expensive, furnishings on tenants in social homes, including households who are moving on from homelessness.

9. However, the DHS is of very limited use to tenants, as they cannot use it to enforce their rights to live free of hazards and disrepair, in a home which is fit for habitation. Awaab's Law, implemented via regulations made under the Landlord and Tenant Act 1985, is so important for tenants because it better enables them to enforce their rights.

10. Furthermore, local housing standards enforcement teams already have, and will continue to have, legal duties to enforce serious health & safety hazards under the Housing Health & Safety rating System, which is also being reviewed.

11. Rather than as an enforcement tool, we see the DHS primarily as a tool for setting expectations and measuring national, regional and local housing conditions, including by tenure, in order to identify the need for investment and improvement works for the existing tenant.

12. An updated DHS and a clear timeline for implementation should mean that local authorities and housing associations plan and schedule works to improve the homes they let to ensure they are compliant for the DHS.

13. However, it’s vital implementation of a new DHS doesn’t result in detriment to the existing tenant of the home, such as being offered alternative accommodation out-of-area or steep rent increases to cover the additional costs or to reflect the better condition of the home. In some cases, very expensive major works will be needed, which may not be possible with tenants in situ, resulting in the need for alternative accommodation. It’s vital social landlords don’t fund these works by reducing the number of social rent homes in a block or on an estate – converting some homes to cross-subsidise.

14. Therefore, if government is serious about bringing all homes up to DHS standards, investment and protection for tenants will be needed to prevent homelessness and potential loss of genuinely affordable homes. Some social housing providers are likely to require additional funding ensure compliance with the new DHS. With new energy efficiency standards for social housing and a welcome drive from the government to ramp up delivery of new social homes, there are a range of competing priorities for provider spending over the next decade.

15. It’s vital investment in bringing existing social homes up to the new standard does not come at the expense of delivering the new generation of social housing needed to end the housing emergency. In some cases, these new homes will be needed so that existing tenants can temporarily move out while major works are completed.

16. Recommendation: MHCLG must ensure local authorities and housing associations have adequate financial support to plan and carry out the improvement works necessary to bring homes up to compliance with the new DHS.

Have social landlords been abiding by the Decent Homes Standard; are the consequences for non-compliance tough enough or do these need to go further?

17. Currently, 431,000 social homes (10%) fail the Decent homes standard. This is an improvement on ten years ago (2013), when 15% of social homes failed the DHS.[6]

18. We believe the consequences for non-compliance are now robust, due to the introduction of a more proactive regulatory regime by the Regulator of Social Housing in April 2024.

What should be included in the Regulator of Social Housing’s forthcoming Competence and Conduct Standard to help improve the service social tenants receive?

19. We’re currently campaigning with people with lived experience of racism in accessing a social home to call for the Secretary of State’s Direction to the Regulator of Social Housing (due to be published this autumn) to make anti-racism and cultural competence a key feature of the Competence and Conduct Standard.[7][8]
20. This campaign is based on the recommendations of our ground-breaking peer research project (My colour speaks before me). This revealed Black and Black Mixed heritage people continue to face discrimination when trying to secure a social home in England. Our analysis shows Black-led households are more likely to be stuck homeless in damaging temporary accommodation for a very long time compared with households as a whole, and much more likely to be there for a very long time compared to White-led households.[9]
21. The Regulator should be directed to require senior staff involved in letting and managing social homes to have a professional qualification which includes a module on anti-racism, cultural competency and understanding racial trauma. And to ensure senior staff and their teams practice anti-racism and promote race equity in their policies, practices and outcomes.

22. Recommendation: We recommend the Committee supports our call for the Secretary of State to Direct he Regulator of Social Housing that anti-racism should be a key feature of the Competence and Conduct Standard.

23. In our response to the previous government’s consultation on the Competence and Conduct Standard, we also strongly recommended that the standard should be is based on other key principles (in addition to anti-racism and cultural competence) if it’s to achieve genuine, meaningful improvements for tenants. These are:

• harm reduction, with qualifications prioritising senior staff to be alert to, and address, problems that put lives at risk, such as fire safety, damp and mould, domestic abuse, serious youth violence or deteriorating physical and mental health.
• cultural change in how social housing is managed, based on an ethos of serving and being accountable to tenants via professional, local, hands-on housing management.
• outcomes-focused, to deliver better outcomes for tenants, rather than focussing on ‘processing’ requests or complaints.
• robustly enforceable, via clear expectations on the steps that social landlords should take to secure the required outcomes and adhere to the standard.[10]

24. Recommendation: The standard should include content on the history of social housing, including its purpose and values. A strong knowledge of the history of social housing is crucial to truly understand its core purpose within society and the values that underpin it.

25. Recommendation: The standard should include content on awareness of, and means to address, the imbalance in power, resource and capacity between landlord and tenant which can often be compounded if, for instance, English is not the tenant’s first language.

26. Recommendation: Qualifications should specifically include content on driving positive cultural change. Senior housing managers and executives must be equipped to drive meaningful change within their organisation so that all staff throughout their entire service are expected and enabled to deliver a fully professional housing management service.

27. Recommendation: Professional practice skills for housing management should include an advanced understanding of the legal framework which governs the rights and obligations of social landlords and their tenants, to include good practice in relation to possession action and housing conditions, compliance with the relevant Protocols, Equality Act assessments, complaints processes and other approaches to resolving disputes.

How effective is the Housing Health and Rating System as a framework for identifying hazards and how could it be improved?

28. This is not something we’ve recently analysed from a policy perspective. Legislation and guidance governing the enforcement of standards were outside the scope of the previous government’s review of the Housing Health and Safety Rating System (HHSRS).[11]

29. In our casework experience, the HHSRS is of limited use for tackling hazards in social homes. Local authority housing enforcement teams can’t take legal action against hazards in council homes, as this would mean the local authority taking itself to court.

30. Some local authority housing enforcement teams will take action to address hazards in housing association homes. But, in our experience, resource constraints mean they tend to focus on enforcing the HHSRS in private rented homes and will advise social tenants to address hazards via their landlord’s complaints procedure and the Housing Ombudsman Service.

31. This is why Awaab’s Law is so important – so that tenants can take their own enforcement action when experiencing significant health and safety hazards.

What will the impact of Awaab’s Law be on social housing providers, and will this affect social and affordable housing supply?

32. We don’t anticipate Awaab’s Law will have a significant impact on good registered providers of social homes. They should already be responsive to tenants’ reports of significant hazards, e.g. via triaging and speedy inspection, where necessary. The Landlord and Tenant Act 1985 already requires landlords to make repairs to electrical wiring, gas pipes and boilers, heating and hot water, sinks, baths, toilets, pipes and drains, and the structure and exterior of the property, including walls, stairs and bannisters, the roof, chimneys, external doors and windows.

33. Section 9A of the 1985 Act (inserted by the Fitness for Human Habitation Act 2018) requires landlords to make sure homes are fit for human habitation. In determining whether a property is ‘fit’, regard is given to its condition in respect of specified matters which include any hazards under the HHSRS. To be fit for human habitation a home must be safe, healthy and free from things that could cause serious harm to residents.

What impact will the Government’s proposed Minimum Energy Efficiency Standards have on the social housing sector?

34. We welcome the introduction of Minimum Energy Efficiency Standards (MEES) into the social housing sector. We’re currently working on our response to the current government consultation.

35. However, the implementation of MEES must work for social tenants. An unintended consequence of MEES must not be to incentivise social landlords to demolish and rebuild blocks or estates where they argue it’s not cost effective or viable to bring certain buildings within MEES. Include protections within MEES that mitigate against the potential incentive for social landlords to demolish estates.

36. It is also vital that tenants have a meaningful say over the work done to their homes. As such, the government must:
1. Centre tenant choice within how social landlords ultimately approach MEES implementation. This should involve social tenants within decision making processes all the way through the implementation of MEES.
2. Increase funding for retrofit and remediation to ensure social landlords have the resource and capital they need to undergo effective works that maximise the benefits for tenants and minimise disruption. It’s vital implementation of MEES does not come at the expense of social rent delivery.

How can technology help to monitor and improve the condition of homes, and what more can the Government do to facilitate the effective use of technology in this area?

37. We haven’t investigated this issue.

38. However, in the housing association sector, we’re concerned that repeated mergers of registered providers (which sometimes result in redundancy), may have resulted in staff knowledge and data on housing conditions being lost or held in a number of different unmerged systems.

39. For example, the Housing Ombudsman Service’s special report into Southern Housing (May 2024) highlighted risks around mergers, with the landlord experiencing a “lack of ownership within the [it’s] complaint-handling culture”, compounded by problems with knowledge and information management: Repair problems were often compounded by poor record keeping, which then also impacted the handling of the resulting complaint…Whilst some mitigations have taken place, the landlord has still not merged its systems, which will cause significant challenges in acting as one organisation. Among the recommendations, the Ombudsman has told the landlord to review its record keeping practices to ensure accurate and timely records of inspections and repairs are available to all relevant staff, including complaint handlers.[12]

What other measures can the Government take to support social landlords and residents to take effective action against hazards and improve the condition of non-decent homes?

40. Recommendation: The government must urgently implement Awaab’s Law in the social housing sector. Phase 2 (covering serous safety hazards such as fire; electrical and explosions; structural collapse; excess cold and excess heat; falls and hygiene) must be implemented in January 2026, rather than later in the year. The final phase must also be implemented in January 2027, rather than later in the year. Delay risks further fatalities. Landlords have had long enough to ensure they’re dealing swiftly with reports of significant hazards, according to existing legal requirements. The Grenfell Tower fire was in June 2017. Awaab Ishak died in December 2020 and the Prevention of Future Deaths report was published in November 2022.[13]

41. Recommendation: The Secretary of State’s Direction to the Regulator of Social Housing (due this autumn) must be for swift introduction of the new Competence and Conduct Standard for registered providers of social homes. We need urgent cultural change in the management of social homes. The government’s proposed transition periods mean larger landlords wouldn’t need to have enrolled relevant senior staff on qualifications until 2029 and smaller landlords until 2030. This is too long for tenants to wait for professional housing management, including antiracism. If social tenants are to receive a professional service when experiencing hazardous or non-decent housing conditions, which should be expected in return for their rent, swift and robust regulation is vital. Landlords have had long enough to get their house in order.[14]

Private rented sector

Does the Renters’ Rights Bill go far enough to address poor housing conditions in the private rented sector?

42. The ever-present risk of a section 21 eviction prevents many tenants from complaining about poor conditions in their homes. A 2023 Shelter survey found a quarter of private renters – over 2 million people – had chosen not to ask their landlord for repairs or improvements for fear they’d face a retaliatory eviction.[15] The abolition of section 21 will go some way to removing this barrier, but loopholes remain in the bill that will allow this practice to persist under another guise.

43. The Renters’ Rights Bill does not introduce limits on in-tenancy rent increases. With nothing to tether rents to CPI or wage growth (the market rate being out of reach for so many), landlords intent on evicting their tenants without a valid reason will be free to engineer one by forcing those who complain into arrears. So, fear of a large annual rent increase (justified by the landlord to recoup money spend on repair or improvements), could deter tenants most at risk of homelessness from enforcing their rights or reporting a failure to meet the DHS.

44. Recommendation: The government should introduce limits on in-tenancy rent increases, to the lowest of CPI or wage growth. If housing conditions in the private rented sector are to improve, tenants must not live in fear of unaffordable annual rent hikes and the risk of homelessness in response.

45. While the introduction of Awaab’s Law to the private rented sector will enable tenants to more easily identify when a breach of their rights has occurred (i.e. when timescales have not been adhered to) many tenants will find themselves without the necessary legal advice and support to challenge their landlords to meet basic standards. In February 2024, the Law Society reported that 44% of people do not have access to a local housing legal aid provider.[16] The lack of legal support will limit the success of Awaab’s Law in the PRS.

46. Recommendation: The government should reduce the administrative burden on legal aid providers for disrepair cases by bringing them fully back into scope for legal aid.

47. Local authorities are already struggling to meet existing enforcement burdens. Without adequate funding and resourcing, the new powers bestowed upon local authorities by the bill will simply result in additional burdens they cannot fulfil. The impact will be that many core tenets of the Renters’ Rights Bill that have the potential to improve conditions – Awaab's Law, the Decent Homes Standard and even the scrapping of section 21 - will not be enforced in practice.

48. Recommendation: local authority enforcement teams should be adequately resourced and funded to use existing and new powers bestowed by the Renters’ Rights Bill effectively, and registration fees from the PRS database should be adequate to support their efforts.

How effective will the introduction of the Decent Homes Standard be at improving the condition of homes in the private rented sector?

49. We welcome the introduction of the Decent Homes Standard (DHS) to the private rented sector (PRS), which has the highest level of non-decency of any tenure. Applying the standard will give renters and landlords a clear framework for expectations of conditions in PRS homes.

50. As presently proposed, tenants will see little change in terms of their ability to enforce their rights as only DHS criterion A (which overlaps with Category 1 hazards under the Housing Health and Safety Rating System) will bring a duty for councils to take enforcement action – as is already the case.

51. Therefore, implementation and enforcement of the DHS in the PRS will rely on adequate resourcing and funding for local authority enforcement teams. If local authority enforcement teams continue to be overstretched, we are unlikely to see more expansive use of powers (such as issuing improvement notices) to enforce other DHS criteria which in turn will mean private renters cannot pursue Rent Repayment Orders as a means to enforce breaches themselves.

52. Recommendation: local authority enforcement teams should be adequately resourced and funded to use their new powers to enforce the DHS.

53. Recommendation: the scope of local authorities’ duty to enforce the DHS should be expanded beyond Criteria A.

54. Additionally, it is unclear how compliance with the DHS will be measured in practice. The new private rented sector database will include whether a dwelling is DHS compliant, but at present this is planned to be self-reported by landlords.

55. Recommendation: The government should consider how local authorities can use their new investigatory powers in conjunction with the database to enforce and monitor landlord self-declarations under the Decent Homes Standard - and provide the funding and guidance to enable local authorities to carry out proactive inspections of properties.

56. One concern about extending the DHS to the PRS is it may not improve the homes for existing tenants, who could be at risk of homelessness and/or displacement. As set out in paragraphs 38-39 above, without in-tenancy rent stabilisation in the Renters' Rights Bill, an unintended consequence of applying the DHS to the PRS is could put private tenants at risk of steep and unaffordable annual rent increases, justified by the landlord to recoup the cost of improvement work and on the basis the newly-modernised home can now command a higher market rate.

57. If this were to happen, the DHS could have the unintended consequence of causing gentrification, displacing low-income tenants into homelessness or substandard homes elsewhere. Low-income households could be be pushed from poor housing to poor housing, while only more affluent tenants and, ultimately, landlords, benefit from the modernised homes. This is why rent stabilisation is vital for the DHS.

58. Recommendation: The government should limit rent increases on recently improved properties, especially where they have benefitted from government grants to bring them up to standard. This should help prevent low-income households, who are most at risk of homelessness, from becoming trapped in cycles of poor housing conditions and displacement.

What impact will the introduction of the Decent Homes Standard have on landlords in the private rented sector?  

59. The introduction of the DHS to the PRS is likely to require a shift in behaviour on the part of landlords. One-fifth of private landlords report that, at present, they only inspect dwellings they own when there is a specific reason to, or do not inspect at all.[17] This is similar to the proportion of homes in the PRS currently estimated to be non-decent. The introduction of the DHS ought to mean that all landlords take a proactive approach to monitoring and improving conditions in rented homes to ensure continued compliance.

60. There is also a risk that many private landlords respond reactively to the introduction of the DHS on its implementation date: given that this is currently proposed to be 2035, a full decade after the passage of the Renters’ Rights Act, many renters are likely to be waiting years to see improvement to the condition of their home.

61. Recommendation: The Decent Homes Standard for the private rented sector should at the very least be introduced via a phased approach in advance of the current proposed date of 2035 to encourage landlords to bring properties up to compliance incrementally and in advance.

What impact would applying Awaab’s Law to the private rented sector have on landlords and will this affect housing supply in the private rented sector?

62. It is important that the effect of Awaab’s Law on private landlords and supply is not assumed or overstated. While Awaab’s Law will introduce timescales for repairs and improvements, it does not demand anything more of private landlords than to fulfil their existing legal obligations to let homes that meet all legal standards. This is a minimum requirement of letting out a home, in return for rent, and the vast majority of landlords are already aware of their responsibilities.

63. Awaab’s Law does not introduce a new standard or additional burdens on landlords – rather it is a clarification of the process landlords must adhere to when investigating and dealing with significant hazards. Introducing timescales will provide much-needed clarity in disrepair cases.

64. Despite apparent concerns around changes to legislation and the impact this may have on PRS supply, the English Housing Survey tells us that the number of homes rented out by private landlords is at its highest since the EHS records began in 2008, having recovered after a dip during the Covid-19 pandemic.[18]

65. Recommendation: Awaab’s Law should be introduced to the PRS without delay.

66. As set out above in paragraphs 38-39 and 51-52 above, there’s a risk that, without rent stabilisation measures, the cost of rectifying significant hazards (e.g. damp-proof courses) could be passed on to tenants, via steep annual rent hikes, putting them at risk of homelessness.

New-build homes

How can the Government ensure that new-build homes are as high-quality as possible?

67. It is critical that the new Affordable Homes Programme, surrounding net zero funding and Housing Strategy are designed to ensure that homes are delivered with climate justice at the front of mind. We recently published a report (Building Climate Justice) on social housing new build and retrofit, which highlights the following. [19]

Funding

68. The 2025 Spending Review investment of £39 billion of funding for the Affordable Homes Programme and surrounding funding announcements will go some way, but it is likely that more funding will be needed to reach the levels of social homes needed. Many housing associations and councils are apprehensive about required improvements to existing homes and the impact on new supply.

Priority- congestion

69. Social housing providers are often met with ‘priority congestion’ as they navigate competing demands for good-quality new-build and retrofit of existing homes. Social housing providers continue to call for more support in meeting climate change goals and net zero targets, as well as incoming regulations. UCL research showed that 53% of local authorities are facing challenges with delivering new homes due to the increased costs of retrofitting.[20]

Skills

70. New supply, retrofit and maintenance of current homes, are also riddled with labour skill shortages and capacity issues. The implementation of low carbon technologies requires specialist skills at a level that can’t currently be provided by the UK workforce. There are significant skills gaps in the energy efficiency and retrofit sectors and in the measurement of embodied and whole-life carbon assessments.[21]

71. While the government has committed to 300 planners, there are specific challenges with expertise, within the social housing sector, including recruitment and retention, that need to be specifically addressed and properly supported. Unfortunately, this gap in labour skills and lack of capacity in-house within councils, housing associations and the general workforce will not impede delivery of social rent homes but also the government’s ambitious target of 1.5million new homes.

Coordination

72. Currently, no single government department is solely responsible for the policies and legislation related to building new homes and retrofitting existing ones. For example, the Ministry of Housing, Communities and Local Government—along with Homes England— oversees new housing delivery, while retrofitting is managed by the Department for Energy Security and Net Zero (DESNZ). Past initiatives like the Social Housing Decarbonisation Fund were also administered by DESNZ.

73. This fragmented approach can be mirrored at the local level, making it difficult to coordinate efforts and realise the opportunity existing buildings play in the delivery of new homes. As a result, national and local strategies to address both the housing and climate crises remain disjointed. The previous government’s 2021 Net Zero Strategy acknowledged the need for better coordination between national and local stakeholders. Yet, little progress was made, and the system remains fragmented.

74. Recommendation: The government must ensure there is a committed coordination framework for both new-build and retrofit.

Alternative Delivery Methods and Private-Public Partnerships

75. The Modern Methods of Construction (MMC) industry is seeking innovative ways to deliver homes at pace. We don’t explicitly endorse specific MMC schemes as ideal examples, nor believe there is a one size fits all approach. However, it is vital to learn from existing MMC developments to understand the potential for the industry in this sector.

76. A 2024 exhibition (New Homes in New Ways- Collaboration and Innovation through Modern Methods of Construction) focused on how the MMC industry could deliver high quality, energy efficient and sustainable homes, including ‘delivering the social rent housing needed at pace amidst the current housing emergency’. The exhibition included case studies demonstrating how MMC unlocked sites for affordable and social rent homes, that were energy efficient and good quality, while also building faster than traditional construction, all while delivering social, economic and environmental benefits. Some of these can now be viewed virtually on the Building Centre’s website.[22]

77. The exhibition was accompanied by a conference (February 2025) which hosted conversations by industry leaders, engineers, academics and developers to share lessons and gauge what was needed from each other and the government. The consensus was a public led initiative to drive success.

Octopus Energy Zero Bills Homes

78. In 2022, Octopus Energy launched Octopus Zero Bills. This was an energy saving tariff which included zero energy bills for five years, for new homes, with certain energy specification and use of an Octopus energy platform to help with cost of low carbon technology and energy use.

79. The scheme works with developers to agree on heating and water consumption specifications, which the housebuilder must build. The homes are marginally more expensive to build. While not a social rent scheme, this is a good example of a development that focused on the use of low carbon technology by housebuilders.

80. Recommendation: The government should consider partnering with energy companies and other industries to create demand and a pipeline for low carbon or energy efficient homes to deal with the lack of expertise that resides within local governments, while also investing in a public asset like social housing.

Section 106

81. Recommendation: The government should address issues within the process surrounding section 106 agreements that lead to poor quality social homes being built by private developers.

Temporary Accommodation

How prevalent are the “appalling conditions” the Committee found in some instances of temporary accommodation in its recent inquiry, and how can the Government best address this?

82. Appalling conditions are very prevalent in temporary accommodation, where people are often at a very vulnerable point in their lives (e.g. having escaped domestic abuse or when dealing with serious illness). Our 2023 Still Living in Limbo research, reference in paragraph xx above, found hundreds of thousands of people, including families with children, stuck in temporary accommodation in dangerous, slum-like conditions. Three-quarters (75%) of households were accommodated in poor conditions, including one in five (21%) with a safety hazard, such as faulty wiring or fire risks.

83. However, our research also found temporary accommodation is damaging to mental health, children’s education and employment and entrenches poverty, including child poverty. This is because it’s profoundly insecure and uncertain, with frequent, short-notice moves; has high costs; can lack basic essential amenities (e.g. laundry facilities and Wi-Fi); and because around one third of households (41,560 households) are accommodated out-of-area, necessitating long and expensive commutes to school and work or having to give up employment or settled school places.

84. Therefore, even if conditions of temporary accommodation were to be addressed, it would remain damaging, particularly to children. There are now a record number of 169,050 children stuck in temporary accommodation. The government’s priority should therefore be to get people, particularly families, out of temporary accommodation as a matter of urgency.

85. Recommendation: The government must prioritise delivering social rent homes in the locations and of the correct type (e.g. family-sized homes) to move the record number of households, families and children out of temporary accommodation as quickly as possible. Households in temporary accommodation must be prioritised in social housing allocations.

86. Recommendation: The government must use the Autumn Statement to unfreeze and restore local housing allowance to cover at least the cheapest 30% of rentals in each area. This will enable families to move out of damaging temporary accommodation into a settled private rented sector home. Around a third of private renters rely on local housing allowance to afford private rents. The freeze leaves families stuck homeless in damaging and costly temporary accommodation and is driving a billion-pound temporary accommodation sector of unregistered and unregulated private providers (often brokers), luring landlords away from direct lettings to claimants with higher rates and driving homelessness still further.[23] [24]

87. Recommendation: The government must use the Autumn Statement to abolish the Household Benefit Cap, which leaves thousands of lone mother households (including those who’ve survived domestic abuse), stuck in damaging temporary accommodation, which undermines employment. The cap renders them too poor to afford either a suitable private rental or even social housing. Our analysis shows that in 78 local authority areas in England, average council and/or housing association rents are unaffordable for capped families.[25]

88. Recommendation: The government must regulate temporary accommodation providers, which offer contracts to statutory services such as local housing and social services authorities, via the Regulator of Social Housing. Their websites often describe them as providing ‘social housing solutions’ or ‘affordable housing solutions’, yet they’re entirely unregistered and unregulated. A national regulatory body is vital because local housing authorities, which are desperate to procure temporary accommodation at the cheapest rates, can have a conflict of interest.

Has there been any progress in tackling the “shocking conditions” in exempt accommodation, identified by the predecessor to this Committee in 2022?

89. We’ve not recently analysed this. In our view, much better funding of housing-related support services is needed.

How can local authorities best be supported to take action against rogue landlords operating in the temporary and exempt accommodation sectors?

90. See paragraph 63 above. The government must prioritise delivering social homes in the areas and of the types needed to get families out of damaging temporary accommodation. They must require local housing authorities to prioritise households in temporary accommodation in allocation of social homes. This will reduce demand and competition for temporary accommodation, driving ‘rogue’ providers out of business.

91. See paragraph 66 above. Local housing authorities have a conflict of interest in regulating statutory temporary accommodation because they have statutory duties to provide it and are desperate to procure it at the cheapest rates. Most housing authorities have contracts with private temporary accommodation providers, which presumably require them to provide accommodation meeting all legal standards. However, they appear to be failing to enforce these contracts, presumably because the need to meet high demand at low costs puts them in a weak negotiating position with providers. A national regulatory body is needed.

92. Recommendation: The government must end the 14-year freeze (since 2011) to housing benefit subsidy to councils for temporary accommodation. Councils are legally required to provide suitable temporary accommodation within their district. However, the freeze means councils dealing with record numbers in temporary accommodation face spiralling costs. To avoid overspends on their homelessness budgets, they are clearly procuring substandard, low quality and unsuitable temporary accommodation, including accommodation out-of-area, in areas with poor connectivity and few childcare and employment options. Adequate subsidy would allow councils to move away from using ‘rogue’ providers.

August 2025