Written evidence submitted by RAF Families Federation to the Select Committee on the Armed Forces Bill


EXECUTIVE SUMMARY: We welcome the focus on strengthening the Armed Forces Covenant, and the aim of removing disadvantage for those who are serving and their families.  We believe there is limited evidence in its current form that this Bill will make a marked difference to serving personnel and families.  The large majority of cases that are raised with us are not because of difficulties with the bodies that will be included in this Bill.  Because of this we would strongly welcome a wider approach including central government departments and the Devolved Administrations (DA) in the Duty to Regard. In addition, we have concerns that this Bill does not encompass more significant changes to the Service Justice System (SJS) and Service Complaints (SC) system that would deliver a fairer system for personnel.





The RAF Families Federation is funded by the RAF but sits outside the Chain of Command as an independent organisation, parented by the RAF Association. We represent all RAF personnel, be they Regular, Reserve, single, married or in a partnership, together with their families. We are tasked with representing single serving personnel as well as families. We capture evidence of issues and concerns, and report to senior RAF and MOD staffs, and government ministers, proposing changes to improve quality of life for personnel and their families.



We have answered specific questions from the enquiry list, where as an organisation we have gathered evidence, views and experiences. 

Are the specified persons and bodies proscribed in the Bill sufficient or should these be expanded?

The Bill currently only appears to apply to local government and some health and education bodies – it would be much more effective if all relevant bodies and stakeholders are included including the rUK Government and DAs.

Many of the issues raised to us would currently fall outside of the scope of the Bill (less than 20% of issues raised to us are education and health related).

An assessment of the power of the Secretary of State to issue guidance on the duties imposed by the Bill.

The RAF Families Federation work alongside Local Authorities (LA) across England and the Devolved Administrations (DA), and witness first-hand the different approaches afforded to enacting the Armed Forces Covenant. Overall, there is much goodwill, and the majority of LA and DA are very keen to support Armed Forces families and offer assistance when help is needed. 


Inevitably, due to the nature of the Covenant, responses to issues differ depending on which LA/DA jurisdiction is involved, so issuing clear guidance on the duties imposed by the Bill would seem logical and a practical way of addressing the ‘postcode lottery’ that some families report. Guidance is needed to ensure a fair and streamlined invocation of the duties across all LA/DA but it also must be careful not to be too prescriptive - this could impact on the goodwill already seen and evidenced.


The guidance should also include how the members of the armed forces community should seek redress if they feel they need to progress problems that they feel unsupported with.


We would recommend guidance highlights the background information that will equip frontline staff when dealing with service families:


Understanding the military lifestyle fully is vital in ensuring quality and effective help can be delivered quickly – if service families can reach into their LA around the country (whether they are dispersed or not) and get the support they need as soon as they need it, this will be transformational.


We strongly support having an active and effective Armed Forces Champion within each LA.  This role would be the key point of contact for Armed Forces families and it would therefore be imperative that they are fully conversant in Armed Forces life and the challenges it occasionally presents. Armed Forces Champions should complete initial training as outlined above followed by refresher training to ensure their knowledge is up to date. 


We have seen how effective these Armed Forces Champions can be and we consider it essential that funding is secured to ensure the positive impact they have had so far can continue throughout the UK, no matter their location.




An assessment of the power of the Secretary of State to make regulations to widen the duties in the Bill by specifying additional persons or bodies to be subject to those duties and to specify additional functions (areas other than healthcare, housing and education) in which the duty may apply.

Making public providers of healthcare, housing and education subject to the duties of the Bill is a good first step in supporting Service families in statute, but we would like to see a widening of the scope specifically to include employment, immigration and the standard of service housing.  Issues with immigration policy (e.g., minimum income requirement and VISA fees) have been raised by the three Families Federations since 2013 with little to no improvement and Service Family Accomodation can be of very poor quality.  Including all government departments in the scope of the Bill would be a significant step forward.   Many of the issues reported to us would currently fall outside of the scope of the proposed Bill. In fact, only around 20% of the cases reported to us at the moment would come within the scope of the current Bill. We note the intent to facilitate future upgrades to the scope and we will be looking to see progress on this as we move forward.


The concern is that other areas not included in the duties of the Bill may be downgraded in importance – all areas of policy where disadvantage may be experienced should be included so that there is the same legal requirement.


There are already some excellent examples of LA/DAs working hard to prevent disadvantage, but legislation will make this more robust and broadening the duty will ensure the fine balance of all aspects of service family life is positively supported.


Without seeing the statutory guidance, we cannot comment on how this legislation will benefit particular members of Service families e.g., children with Special Educational Needs (SEN).  Simple steps like requesting Education and Healthcare Plans (EHCP) to be portable could have a hugely positive impact on families of children with SEN and guidance can direct these processes.


We would like to see regional schools commissioners being brought into the scope of the bill to ensure Service children attending academies and free schools are also protected under the auspices of the Covenant.


What are the resource implications of these measures and how will success be measured?

Mechanisms of measurement already exist via the Covenant Reference Group (CRG) and there is an aspiration to strengthen the metrics being reported on – with a more forceful political and cross government senior executive leadership, targets and a baseline, this process could work much more effectively.  The CRG would definitely benefit from an injection of dynamism rather than adding another layer of reporting.


The Covenant Annual Report is currently how success is reported and this could be expanded to include more specific metrics on the success of the Bill.

The Welsh Government also reports progress in its Armed Forces Covenant Annual Report whereas activity in Scotland and Northern Ireland is included as part of the main report.


The Devolved Administrations must also have measures in place to demonstrate success and ongoing desire to continue to support the Armed Forces families residing in their jurisdictions.


The Charity sector cannot be expected to extend their services in order to deliver these additional measures, it would be more logical to utilise current reporting methods but stipulate the metrics to be included.


How far does the Bill address concerns about the handling of serious crimes committed by service personnel in the UK? 

Given this is an excellent legislative opportunity to make changes to the Service Justice System (SJS) following reviews of the SJS and Service Policing, it appears that the Bill misses an opportunity. It has been four years since the Lyons Service Justice Review, and since then there has been little information on how the important recommendations contained within the report will be taken forward.  It could be argued that not all the recommendations require legislative changes and are not therefore contained within the Bill, however there is no clarity on when these changes will happen if not through legislation.  As a bare minimum, if the MoD has opted to retain the right to try serious crimes - including rape - through the SJS, then evidence of a systems wide approach to better supporting victims and educating everyone involved is needed.

It has been very clear in some compelling evidence given to this Bill Committee - and the Enquiry on Serving Female Personnel - that significant concerns have been raised about the efficacy and fairness of both the SJS and the Service Complaints (SC) system. Large amounts of written and oral evidence have been given on both, which only reinforces the points repeatedly raised by the previous SC Ombudsman.  We would ask the Committee to press the MoD for the detail on their plans for reforming the way these systems work – or changing them profoundly - as there is no sign that the proposed legislation will do this, and in actuality the proposed change around time scales for submission of claims may put off complainants whilst not actually targeting the root cause of delays.

We echo the concerns highlighted by the previous SC Ombudsman that the recommendations from her previous reports have not yet been acted upon – and that the recommendations from the Wigston Report have also not been enacted.  Given the MoD accepted the recommendations of the Wigston Report in full, it is hugely disappointing that there has been little evidence of progress on these.

There seems little point in making a minor (and potentially adverse) change on time limits within the SC system in this Bill, when there has been extensive evidence presented that there are significant challenges throughout the system, including fundamental points around whether SP have any trust in it. Evidence from both AFCAS and the SC Ombudsman points to a belief that nothing will happen as a result of a complaint, and careers will be adversely impacted. In addition, less than half of those who did complain were satisfied with any element of how the complaint was handled.[1]


18 March 2021

Written evidence submitted to the Select Committee on the Armed Forces Bill




[1] Annex B to AFCAS main report 2020 reference table (