CIH NI response to Department for Communities Budget 2025/26 equality impact assessment

The EQIA acknowledges the need for additional support in housing supply for specific groups. However, NIHE’s response further highlights that a shortfall in funding for social housing will adversely impact many Section 75 categories. This includes older people, disabled people (especially those requiring wheelchair accommodation or ground floor access), and homeless people, many of whom have additional complex needs. The data as of 31 March 2025, shows 49,083 households on the social housing waiting list, with 37,635 in housing stress. Of the 6,054 allocations made in 2024/25, 171 required wheelchair accommodation, 1,970 needed ground floor accommodation, and 1,080 were over the age of 60. A sustained supply of social housing is required over the long term to meet new household formation and migration needs, and a shortfall could contribute to lengthening waiting lists and widening differentials between groups.

Additionally, the Housing for All (shared housing) programme, despite its proven positive impact on enabling communities to live together, has no specific funding earmarked within the Social Housing Development Programme for 2025/26, leaving this programme at risk. Also, there is no capital funding allocation for scheduled improvements to Irish Travellers' sites, which impacts NIHE’s ability to provide culturally sensitive accommodation and promote equality for this ethnic minority group.

The EQIA acknowledges the negative impact of reduced capital funding on social housing waiting lists. We re-emphasise the potential for this impact to be disproportionate, particularly for:

• Older people and persons with disabilities: The proposed reduction in the Affordable Warmth Scheme funding (from a projected £14 million requirement to an allocated £7.5 million) will adversely impact these groups who are more likely to be affected by cold temperatures, have higher heating needs, and may be in fuel poverty.
• Homeless households: The funding shortfall for new social housing will impact the supply, leading to longer stays in temporary accommodation, which is more expensive for the public purse. The number of households requiring temporary accommodation has increased by over 160 per cent in six years (from 4,527 to 11,887 placements annually). This disproportionately affects younger people, young people leaving care, children living in temporary accommodation, women impacted by domestic abuse, refugee families and households with mental health or addiction challenges.
• Racial groups (including refugees and Irish Travellers): There has been an increase in refugee households granted ‘leave to remain’ entering the homelessness system. A reduction in housing supply could adversely impact equality of opportunity on the grounds of race. The lack of capital funding for Irish Traveller sites will limit access to quality transit and settled sites for this community.
• Service providers in the Supporting People Programme: While funding has increased to £81.697 million, it does not fully meet the NIHE's budget submission of £90.1 million, and importantly, it does not account for inflationary cost uplifts or increases in Employer National Insurance Contributions. This financial pressure may question the viability of some schemes and impact staff retention, particularly affecting groups with significant support needs where approximately 50 per cent are associated with disability.

To effectively reduce adverse impacts, we urge the department to:

• Prioritise securing additional funding during the monitoring rounds: This is critical to address the dire shortfall in capital funding for new build social housing, with a requirement of £230 million for 2,000 starts but only £168.5 million allocated, leaving a shortfall of £61.5 million. The recent £9 million allocation of additional capital through the June monitoring round is acknowledged and welcomed. Additional funding is also crucial to ensure adequate support for homelessness services and the Affordable Warmth Scheme.
• Ring-fence funding for key programmes: Specifically, allocate dedicated capital funding for ‘Housing for All’ (shared housing) and for scheduled improvements to Irish Travellers’ sites to ensure these vital programmes can continue and address specific equality needs.
• Address inflationary pressures for Supporting People providers: Provide adequate funding uplifts to cover increasing costs and ensure the financial viability of schemes, preventing potential service reductions and ensuring continued support for vulnerable individuals.
• Accelerate efforts to increase temporary accommodation supply: NIHE's focus on securing more single-let properties and repurposing existing stock is positive, as this helps reduce the reliance on more expensive hotel and B&B accommodation. Continued investment in this area is vital to manage the growing demand.
• Promote energy efficiency measures in existing social housing stock: This could help reduce fuel poverty and lower energy bills for tenants, particularly benefitting older people and those with disabilities.
• Support multi-year budgets and strategic planning: The move towards multi-year budgets, as indicated by the Spending Review, is vital for enabling a long-term strategic approach to housing and other key sectors. This would facilitate improved strategic planning and investment in social housing.

The development of a five-year departmental plan is a positive step towards strategic planning. To shape future service delivery effectively with limited resources, we believe the department should:

• Prioritise statutory and high-need services: Focus resources on core services and programmes that address demonstrable housing need and tackle housing inequality, as these are often contractually or statutorily mandated.
• Leverage borrowing powers for NIHE: Actively pursue and enable NIHE’s borrowing powers, a long-standing issue for housing investment, to unlock additional capital for social housing development.
• Explore innovative funding models: Investigate and implement alternative funding mechanisms, potentially including further revenue-raising measures beyond traditional allocations, to supplement the budget for critical housing initiatives.
• Strengthen cross-departmental collaboration: Programmes like ‘New Foundations’, which aims to prevent young people leaving care from becoming homeless, are innovative and cross-departmental, demonstrating effective use of resources. Continue to foster such initiatives.
• Emphasise preventative measures: Investing in homelessness prevention and community-based support initiatives, as highlighted by the NIHE's budget allocation for these areas, can lead to long-term savings by reducing the reliance on more expensive reactive measures like temporary accommodation.
• Ensure data-driven decision-making: Continue to base budget submissions and service delivery models on projected demand for housing and housing services, using data and evidence to target those most in need and experiencing the greatest levels of housing inequality.

The departmental EQIA is a positive process, but a strategic assessment of the entire budget is crucial. Section 75 of the NI Act 1998 demands this broader analysis, especially considering potential cumulative impacts across different sectors. Departmental cuts, on their own, may not reveal how disadvantaged groups are disproportionately affected. A comprehensive strategic EQIA, as advocated by the Equality Commission for Northern Ireland, would provide a holistic view and allow informed mitigation of potential inequalities.

For more information on the impact assessment and the budget visit the DfC's website.

For more details on our response please contact Justin Cartwright, national director for CIH Northern Ireland, justin.cartwright@cih.org