Further written evidence submitted by Habinteg [HCE 079]

Context

Further to the private roundtable session on the morning of Tuesday 16 December to hear from tenants, local authority officials, housing associations, landlords and other providers. Habinteg Housing Association would like to submit some additional evidence on the following areas following the roundtable session:

• Different approaches to standards enforcement across local authorities

• Providers’ experience of commissioning temporary accommodation  

About Habinteg

Habinteg is a housing association that champions inclusion by providing and promoting accessible homes and neighbourhoods that welcome and include everyone. With over 50 years’ experience in housing and disability, we manage over 3300 accessible properties across more than 80 local authorities. We believe that people are disabled by barriers in society and negative public attitudes, rather than by their own impairments.

Introduction

Recent evidence highlights inconsistencies in the enforcement of housing standards across local authorities, widespread challenges in the quality and accessibility of temporary accommodation (TA), and substantial concerns about the sector’s capacity to implement the Renters’ Rights Act and related reforms.

Disabled and older people are disproportionately affected by these gaps, particularly where inaccessible homes, delayed adaptations, and inadequate regulatory oversight create unsafe living conditions.

Improving enforcement capability, strengthening accessibility standards, and supporting local authorities through funding and training are essential to achieving the Government’s aims for safer, healthier, and more inclusive housing.

1. Variation in Local Authority Approaches to Housing Standards Enforcement

Current challenges experienced by Habinteg

Improvement Notices, Habinteg’s experience as a landlord:

• Habinteg usually receives notification letters very shortly before or just as property inspection is taking place, which limits the opportunity for joint inspection with Habinteg representatives which would be much more constructive.
• In some cases, lack of communication from the Local Authority after inspection means that there is uncertainty about whether inspection has resulted in formal action or not. This is concerning for the team given the importance of prompt action in response to the set time frames linked to enforcement.
• High staff turnover within Local Authorities can cause lack of continuity on cases and in general we see teams doing things differently from one authority to another.

Prohibition orders:

• Apply to Category 1 hazards posing serious immediate risk; Habinteg is committed to rapid remedial action when such issues occur and decant may be necessary depending on the nature of the hazard.
• Decanting disabled tenants is challenging due to the limited amount of alternative provision that meets accessibility requirements, and may cater for care needs.
• Short-term or emergency accommodation may disrupt disabled tenants’ care packages; longer-term solutions are often constrained in terms of accessibility
• Some households involve more than one disabled person, making their temporary accommodation needs even harder to meet.

Impacts on Disabled and Older Residents

Lack of Occupational Therapists services within Local Authorities has a wide impact on safety at home for Disabled and older people.

The current position disproportionately disadvantages wheelchair users, people with mobility impairments, and older residents:

• Safety Standards do not sufficiently account for how inaccessible design can create hazards.
• There’s no enforcement mechanism for delays in provision of essential adaptations that enable safety and independence (other than ombudsman complaints)
• Without universal training, many officers are not equipped to assess disability-related risks.

Policy implications

• National consistency is unlikely without ring-fenced revenue funding for enforcement staffing.
• Mandatory training on accessibility, disability rights, and the social model of disability would support better and more equitable outcomes for disabled people
• HHSRS should be strengthened to reflect occupant-focused risk assessments, following the model of Awaab’s Law, which requires risk to be considered in relation to the household characteristics.

2. Providers’ Experience of Commissioning Temporary Accommodation: The Case for Accessibility

Why Accessibility Matters in Temporary Accommodation

People most likely to require temporary accommodation include:

• disabled people.
• older people experiencing health decline.
• families with young children, esp. disabled children (e.g. while a home is being adapted for them);
• people leaving hospital or care settings.
• Women fleeing domestic abuse – domestic abuse affects a higher proportion of Disabled women than average.

For these groups, inaccessible temporary accommodation can significantly worsen health, increase care needs, and impede recovery. The evidence demonstrates that homes built to accessible standards allow:

• faster hospital discharges
• quicker and cheaper adaptations when needed
• reduced local authority spending on domiciliary care
• maintenance of independence and avoidance of crisis escalation.

Policy Implications

To improve quality and safety in temporary accommodation:

• Accessibility criteria should be embedded in all TA commissioning frameworks, using M4(2) as a minimum benchmark or functional equivalents.
• The Government should support councils with additional enforcement powers and targeted funding to challenge poor-quality providers.

Case studies:

Case Study 1: Lorraine (Habinteg Insight Group member based in Dorsett)

Background
Lorraine is a disabled woman with significant mobility difficulties who experienced prolonged domestic abuse and coercive control. She is the primary carer for her two children. Her case highlights the compounded barriers faced by disabled survivors of abuse, particularly in relation to housing instability, access to care, and social isolation.

Abuse and Living Situation
When Lorraine left her abusive relationship, she fled with her two children and was placed in a series of temporary accommodations and refuges. These placements often consisted of a single room, offering little privacy or stability. While these environments provided immediate safety, the lack of long-term security increased her vulnerability and made recovery extremely challenging.

Like many disabled survivors, Lorraine was heavily reliant on her abuser, particularly for mobility and practical support. This dependence was exploited as a form of coercive control, significantly complicating her ability to leave safely.

Although there was a clear belief that the perpetrator should have been required to leave the family home, in practice the burden of relocation fell on Lorraine. This expectation exposed her and her children to repeated disruption, instability, and increased risk.

Accessibility and Housing Challenges
Securing safe and suitable housing was further complicated by Lorraine’s accessibility needs. While many refuges and temporary accommodations were technically wheelchair accessible, they did not provide the stability required for long-term safety and recovery. Frequent moves between properties prevented Lorraine from establishing a secure home environment.

A critical barrier arose when relocation across local authority boundaries resulted in the loss or delay of existing care packages. In some areas, equivalent care support was unavailable, creating additional risks and limiting Lorraine’s ability to live independently and safely.

Repeated displacement was exacerbated by landlords selling properties, forcing Lorraine and her children to move multiple times. Each move further undermined her sense of security and continuity of care.

The complexity of Lorraine’s needs meant that accessing consistent support was extremely difficult. Services varied significantly between local authorities, and navigating fragmented systems across different areas placed an additional burden on her at a time of crisis.

Social and Economic Impact
As a result of the abuse and ongoing instability, Lorraine was forced to give up her business, leading to financial hardship and loss of independence. Her mobility difficulties, combined with repeated relocations, left her largely confined to her home.

These circumstances significantly increased Lorraine’s isolation. She was less able to maintain social relationships, access community support, or draw on informal networks. This isolation heightened her reliance on formal services, which were often inconsistent, difficult to access, or unavailable.

Key Themes and Learning Points

• Disabled survivors often experience increased dependence on perpetrators, which heightens risk and complicates escape.
• Accessible refuges alone are insufficient without stable, long-term housing and transferable care packages.
• Frequent relocation creates financial strain, instability, and deepened isolation.
• Survivors with children require coordinated, family-centred and safeguarding-focused support.
• Systems frequently place the expectation on survivors to move, rather than holding perpetrators accountable.
• Coercive control can include restriction of movement, care provision, and access to essential utilities.

Summary
Lorraine’s case demonstrates how disability, caregiving responsibilities, housing insecurity, and coercive control intersect to create profound barriers to safety and recovery. Effective responses require stable and accessible housing, continuity of care across local authority boundaries, meaningful perpetrator accountability, and coordinated cross-agency support that recognises the specific risks faced by disabled survivors.

Lorraine has written extensively about her experience, this can be found here.

Case Study 2:  Jackie (Habinteg Tenant, based in Walsall)

Background
Jackie Willson, aged 60, had her independence restored after moving into a new wheelchair-accessible flat developed by Habinteg at Lawson Court in Walsall with her husband David (63) and son Chris (28) in November 2024. Before this, Jackie and her family faced severe housing insecurity following homelessness and temporary accommodation that did not meet her accessibility needs.

Homelessness and Temporary Accommodation
After being served a Section 21 (no-fault) eviction from their privately rented home in Walsall in December 2023, the Willson family became homeless and were placed in bed-and-breakfast accommodation in Birmingham while waiting for Lawson Court to be completed.

Jackie has chronic obstructive pulmonary disease (COPD) and significant mobility difficulties, relying on a mobility aid and scooter to get around. The narrow corridors and layout of the temporary accommodation made daily life extremely challenging, and she repeatedly injured herself trying to manoeuvre her scooter. During this period she also developed lymphoedema in one leg.

Due to cramped space, the family of three shared one room and could not access communal kitchen facilities, forcing them to rely on microwave meals or bought food. Jackie said this period was very difficult, but that they coped because they knew they would eventually move into their new home.

Accessible, Spacious Living
The Lawson Court flat is one of six wheelchair-accessible properties in a scheme of 18 homes (the other twelve are built to adaptable standards).

The design features - including a wet room and level access entrance - significantly improved Jackie’s daily living. She highlighted that the wet room made showering far easier compared with her previous home where she had to climb in and out of a bath. Jackie also explained how the level approach to the front entrance allows her to go out easily on her mobility scooter, eliminating the need to manage steps as in her old home. Her new home is also well insulated and warm, with properly functioning windows — improvements she particularly appreciates.

Boosting Independence
Jackie described regaining her freedom to get out and about and to cook her own meals as the best things about her new flat. These changes have enabled her to live more independently and with dignity.

Key Themes and Learning Points

• Wheelchair-accessible homes significantly improve quality of life and daily living for disabled tenants
• Inappropriate temporary accommodation can compound health and mobility challenges during periods of homelessness
• Accessible design features such as wet rooms and level access entrances directly support independence and reduce barriers to daily activities
• Providing accessible homes can reduce reliance on formal care services and deliver wider social and economic benefits by enabling greater self-sufficiency.

Summary
Jackie’s experience highlights the transformative impact that accessible housing can have on a disabled person’s life. After months of unsuitable temporary accommodation and housing insecurity, moving into an accessible, well-designed home has enabled her to regain independence, improve wellbeing, and re-establish routines that were previously difficult or impossible. This case illustrates the importance of accessible housing in supporting health, autonomy and long-term stability for disabled tenants.

December 2025