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


The Naval Families Federation


The Naval Families Federation (NFF) speaks up for serving members of the Royal Navy (RN) and Royal Marines and their families.  We represent their views and experiences to policymakers. We meet regularly with the Royal Navy’s Chain of Command, Government Ministers, Other Government Departments, and other key stakeholders.  We also support appropriate and relevant research and undertake advocacy for serving people and their families when they experience disadvantage compared to the general population, or face issues that cannot be resolved through existing channels.


The evidence offered below is the NFF’s perspective on the issues raised, based on feedback from serving personnel and their families, and discussions with local authorities and other service providers.


Armed Forces Covenant


Is the ‘duty to have due regard’ the appropriate mechanism to further incorporate the Armed Forces Covenant into law?  What alternative mechanisms could be used?


The ‘duty to have due regard’ is believed to be a suitable mechanism to further incorporate the Armed Forces Covenant into law as it offers flexibility to encompass a wide range of areas including and beyond healthcare, education, and housing.  A more prescriptive approach would be restrictive, and to make the Armed Forces community a protected characteristic would seem to go too far.


Is the focus on healthcare, education, and housing matters appropriate? Could this have a detrimental impact on other areas of the Armed Forces Covenant?


The NFF engages with, and advocates on behalf of, RN families in relation to the whole gamut of Armed Forces Covenant issues as described in the Families Federations’ Formal Observations in the Armed Forces Covenant Annual Report 2020[1].  These issues include immigration, spouse employment, childcare, living overseas, access to state benefits and tax, and transition. Whilst we are delighted to see a focus on healthcare, education and housing matters, we would welcome a widening of the scope to include all aspects of the Armed Forces Covenant.  It would seem likely that only those areas that are in focus will be addressed if resources are limited.  If this is not achievable in the timeframe for the Bill, we would hope to see the additional areas added as soon as is practicable.


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


It would seem reasonable to include all the relevant stakeholders that are responsible for delivery of the Armed Forces Covenant, so not only Local Authorities but also Government departments and the Devolved Administrations.  For example, the Department for Education is responsible for national policy regarding the School Admissions Code in England, which will affect Service children, whilst local authorities have the lead for delivery of that policy.




An assessment of the Bill’s application to Scotland, Wales, and Northern Ireland in respect of the Armed Forces Covenant and the Secretary of State’s duty to consult the devolved administrations.


It is vital that the Devolved Administrations are consulted throughout the process of developing statutory guidance as the content will need to be tailored to the way in which the Armed Forces Covenant is delivered in their respective nations. Alternatively, the statutory guidance will need to be sufficiently broad to include all methods of delivery. The risk is that the Armed Forces community could face greater differences in the provision of services as they move around the UK if we do not have coherent statutory guidance which will ensure that due regard is applied equitably and effectively across all four home nations.


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


We are encouraged that the MOD is inviting relevant stakeholders amongst the military charities, including the Families Federations, and in local government,  to inform the statutory guidance on the duties imposed by the Bill. It is vital that the context of Service family life in the single Services, and the issues that face the veteran community, are well understood, and articulated in the guidance.


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.


We suggest that the evidence of issues presented via the Covenant Commitments Tracker to the Covenant Reference Group, and ultimately to the Ministerial Covenant and Veterans Board, beyond the current scope of health, education and housing, would strongly encourage the Secretary of State to widen the duties in the Bill as soon as is practicable in order to address these issues.


An assessment of the enforcement of the ‘duty to have due regard’ and the impact on enforcement bodies such as relevant Ombudsmen.


It is our experience that local authorities, health service providers and other agencies are incredibly supportive of the Armed Forces community and, when they learn about the Armed Forces Covenant and the challenges faced by Service families, are invariably helpful.  Up to now the difficulty has been to communicate with, and inform, the right people on the ground who are delivering services to the Armed Forces communityAll 407 local authorities in mainland Great Britain and a number of councils in Northern Ireland have signed the Armed Forces Covenant.  Their support is not in doubt.  The challenge is to raise the profile of the Covenant and understanding of the challenges faced by Armed Forces families, such that all are aware. It will be imperative that appropriate training is delivered to educate staff sufficiently, so that service providers can give ‘due regard’ to this community when developing new policy, implementing processes, or delivering services.


Given that currently there is little resistance to implementing the Covenant, once service deliverers are informed and aware of the lifestyle of the Armed Forces community, we would expect the existing infrastructure of relevant ombudsmen within the local authorities, the health sector and other providers, to be sufficient to enforce the Covenant when required. More information needs to be made available about the current provision however, so that members of the Armed Forces community know who to approach if they do encounter problems with the delivery of services.


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


We would suggest that it is unrealistic to expect that the duties of this Bill will be entirely cost neutral.  We have observed that those local authorities that have received grants from the Armed Forces Covenant Fund Trust (£6.6M over 5 years) to establish dedicated posts have been extremely effective in delivering the Covenant to the Royal Navy serving community. For example, Portsmouth City Council recruited an Armed Forces Covenant Programme Manager who undertook a Needs Assessment of the Armed Forces Community within the Solent area, on behalf of the Solent Armed Forces Covenant Partnership Board [2]. The Covenant Lead Officer for Wiltshire County Council led on the development of the Forces Connect South West programme and website[3], which includes a wide range of information about, and for, the Armed Forces community. These programmes were delivered because there was a dedicated post within the local authority with delivery of the Armed Forces Covenant as their primary objective. This is not the case in other areas, where this role is a secondary duty for some paid officers. We have found that whilst some great initiatives are being delivered, it can be personality driven, usually by those with a personal connection to the Armed Forces.


We would seek reassurance that appropriate support and resources will be offered to all local authorities to enable them to deliver their commitments, including those with a limited military footprint or visible Armed Forces community presence.


We would be keen that any mechanisms that are introduced to measure success are not burdensome to service deliverers, so that resource is focussed on delivery rather than measurement.


We will continue to gather evidence of how the Covenant is being delivered to inform the Covenant Annual Report, the Covenant Reference Group, the External Partners Board and the Ministerial Covenant and Veterans Board. This Bill would also seem to offer an opportunity to strengthen and increase some of the current metrics employed in the Covenant Annual Report.


Whether the provisions impact differently on Serving personnel (both Regulars and Reservists), veterans, and their families?


The provisions will impact differently on Serving personnel (both Regulars and Reservists), veterans, and their families as each of these cohorts has their own set of unique challenges:











22 March 2021

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





[1] Armed Forces Covenant Annual Report 2020

[2] The Armed Forces Community within the Solent:

[3] Forces Connect South West Website: