Written evidence submitted by Crisis (RTS3289)

Who we are

Crisis is the national charity for people facing homelessness. We know that homelessness is not inevitable, and we know that together, we can end it. Crisis is dedicated to ending homelessness by delivering life-changing services and campaigning for change. Every year we work directly with thousands of people experiencing homelessness, to help them rebuild their lives and leave homelessness behind for good.

Why we’re responding

Crisis provides a service to support anyone who is at risk of or experiencing homelessness. This means that we help everyone, no matter their nationality or immigration status or eligibility for statutory services. We often support people who have a right to stay here but have been forced into homelessness for many reasons, such as refugees who too often have to leave asylum accommodation before they have been able to find a place to live and a job. And we also sometimes support people who are unsure of their immigration status and whether they can stay here, who have become homeless - in those cases, if people come to us for help, we work with other organisations to support them to confirm their immigration status and whether or not they are able to stay here, live and work.

We believe in a future free from homelessness, where everyone has the right to a safe and suitable home. Our services see the impact day in day out of immigration policies that are driving people into homelessness. Our service in Brent works directly with people leaving asylum accommodation. An evaluation of this service over the year shows the positive outcomes that can be achieved even in a challenging housing climate – as of August 2024, 75% of people achieved stable housing within 3 months, with 71% sustaining tenancies after 8 months. This shows focusing on support, housing and preventing homelessness can make a huge difference but we need government policy to support this goal. If the government is serious about ending homelessness, it needs to address the impact that Home Office policies have on homelessness.

At Crisis, we see the impact of immigration policies on homelessness every day. Our recent Homelessness Monitor research found that the biggest increase in reasons for homelessness was eviction from asylum accommodation, which was up by 37% since last year.[1] This is why the government must take steps to assess the impact of any policy change on homelessness, to ensure that it lives up to its promise of getting the country back on track to end homelessness.

We are concerned that these proposed changes will push more people into housing and financial insecurity, where they are more at risk of experiencing poverty and homelessness, and less willing or able to get support. We would also like to draw the Committee's attention to evidence from organisations like Praxis who work with migrants and refugees in crisis, and whose works and research findings we have highlighted throughout in addition to our own.

Crisis is calling on government to pause any further announcements related to reform to the immigration and asylum system, until a full review is taken place of the impact these reforms would have on homelessness. This is in keeping with the spirit of the cross-government strategy on ending homelessness, which should see government departments held to account for the impact their policies may have on rates of homelessness.

What is the likely impact of longer routes and stricter requirements for settlement on migrant households already in the UK? This could include:

• the financial and economic impact, including access to benefits; and 
• the personal and social impact.

Expanding the 10-year route risks increasing financial and housing insecurity

Longer routes and stricter requirements for settlement are likely to increase homelessness for non-UK national households. A 10-year route to settlement already exists, and research from Praxis with people on the 10-year route shows that over a fifth said they had faced difficulties paying rent or had experienced sofa surfing/street homelessness.[2] Whilst on this route, people face a number of challenges which contribute to financial and housing insecurity. This includes the length of time before being eligible for settlement, the high cost of visa fees (around £13,000 over the 10-year period for an adult), the requirement for repeat applications every two-and-a-half years, complex applications with few options for legal advice, and restrictions in accessing welfare through the default ‘no recourse to public funds’ (NRPF) condition.[3] This is reflected in the high rates of rough sleeping we see amongst non-UK nationals in London, where in 2024/25 almost half of all rough sleepers (46.1%) were non-UK nationals.[4]

Non-UK nationals often face similar problems to UK nationals in accessing suitable homes to avoid homelessness, including a lack of access to affordable housing, low wages, insecure employment and mental and physical health challenges. In addition to these pressures, non-UK nationals face added barriers stemming from their immigration status, such as financial costs related to the immigration system, a lack of rights to homelessness assistance, local housing allowance and social housing, and discrimination from private landlords.[5]

Research by the Tenant Deposit Scheme (TDS) found that 24% of landlords felt unable to rent to non-UK passport holders in June 2024, and that of these, 56% cited harsh penalties as the reason.[6] This aversion to rent to people who either are or are perceived to be non-UK nationals leads to discrimination against foreign nationals and people of black and minority ethnic backgrounds. For example, we have heard examples of British citizens who have ‘foreign sounding’ names being turned away due to fears from landlords that they would have to carry out right to rent checks.

More people subject to NRPF will push more non-UK nationals into poverty

Expanding the use of longer routes to settlement will see more people subject to No Recourse to Public Funds (NRPF) conditions. One of the main causes of destitution and homelessness amongst non-UK nationals is NRPF, often applied to work, study or spousal visas.[7] Being subject to NRPF means that, if something unexpected happens in someone’s life such as losing a job, illness or relationship breakdown, they are left without access to benefits and may struggle to afford the basic necessities, including housing costs.

There is no data on how many people subject to NRPF are homeless, and therefore the true scale of the impact of NRPF on homelessness is unknown. However, we do know from research into the impact of the policy, especially in big city areas like London, that being NRPF is driving higher poverty rates amongst those subject to it. It is estimated that there are 120,000 households subject to NRPF and at risk of destitution in London alone.[8]

Non-UK national families with children are particularly at risk, with research showing that children from non-UK national households are disproportionately impacted by child poverty. Almost 40%, or 1.75 million, of all children living in poverty were in families where both parents were born abroad (including families where parents have obtained indefinite leave to remain or citizenship).[9] Many of these children will be in families where the parents are subject to NRPF, which is estimated to impact 722,064 children in the UK. Of these, around 382,000 are estimated to be in poverty.[10] Whilst the government’s announcement to end the two-child benefit cap is extremely welcome, it will fail to end child poverty for all children unless it addresses the experiences of children in families with NRPF.

Currently non-UK national families with children subject to NRPF who are destitute, should be able to access support from their local authorities under Section 17 of the Children Act. Whilst this support should extend to the whole family, in reality, underfunded and overstretched local authorities are in some cases either turning families away or only providing support to children.[11] Trapping more people in settlement routes that are subject to NRPF for longer, will therefore likely create more demand on local authorities to fulfil their duties towards families with children, at a time when affordable housing is scarce and demand for homelessness support is at a record high.

These reforms will hit finances of people born outside the UK and our economy hard

The financial impact of these proposed changes to individuals will be huge, with a notable increase in the amount they have to pay before achieving settlement – because of the 2.5 yearly renewal costs and the extension to 10 years. We know from the existing 10-year route that the cost is about £13,000 over 10 years.[12] This will hit low-paid non-UK nationals the hardest, both because of the high costs, but also because they are less likely to meet the criteria that shortens the qualifying period for ILR, such as having higher earnings. Non-UK nationals are more likely to be in insecure work than UK nationals, which means they’re also more likely to be at risk of losing their job. Non-UK nationals in lower-paid work are also most likely to be in precarious housing situations and are therefore at greater risk of homelessness.

The risk of poverty and homelessness increases the longer people are denied secure immigration status. It encourages financial and housing hardship and makes it more likely that someone will ultimately lose their immigration status altogether because of the prohibitive costs and administrative burden this places on non-UK nationals.[13] The cost for settlement on the 10-year route as it exists currently is about £13,000 overall, and people on this route are expected to renew every 2.5 years through complex applications.[14] All of these changes have made it more expensive, longer and more complicated for someone to obtain a secure immigration status.

Making people wait longer until they can have secure immigration status means trapping people in insecurity for longer. Many will be at risk of economic exploitation, as they remain reliant on employers to obtain visas needed to stay in the UK. This has already happened in the care sector, where UK care agencies have been accused of exploiting foreign workers caught in debt traps.[15]

Introducing penalties for people who have to claim benefits, risks driving people away from support for fear of having to wait longer to gain indefinite leave to remain (ILR). This will drive some individuals and families into poverty, destitution and homelessness – which will then place an added burden and strain on local authorities and voluntary organisations who are picking up the pieces.

There will also likely be an economic impact for the UK as well, as critical skilled workers leave the UK and less arrive due to restrictions on settlement. We have already seen the impact of immigration reforms with a 69% reduction in net migration year on year.[16]