The Chartered Institute of Housing’s submission to MHCLG’s call for evidence on social housing allocations

1.1 In section 1.6 of the guidance which refers to transfers at a tenant’s request, we would recommend that this flexibility is extended across local authority boundary lines and other local providers to ensure delivery of the key aims of promoting social and economic mobility and making the best use of housing stock. Below we discuss in detail mechanisms for joint working such as managed reciprocal schemes outlined in section 4.12 and shared housing registers discussed in section 6.8-6.13.

1.2 Practice to address underoccupancy in homes ('rightsizing') would be strengthened if section 1.7 of the guidance applies the same approach to assessing any housing-related debt as set out in section 2.5-2.15 of this submission. We recommend decoupling debt from behaviour and suggest the guidance should not stipulate a threshold of ‘minor rent arrears’, which could be interpreted unevenly across different local authorities. It should instead read “such as a prohibition against tenants with rent arrears transferring.” 

2.1 Since this guidance was published in 2012 and the introduction of the Localism Act in 2011, the Homelessness Reduction Act 2017 has vastly changed the homelessness duties of local authorities and has coincided with greatly increased numbers in temporary accommodationⁱⁱⁱ , growing social housing waiting lists ^ivand a continued and longstanding failure of successive governments to substantially increase the supply of genuinely affordable homes^v .

2.2 We have heard from our members that the mixture of these changes has had the unintended consequence of making temporary accommodation a key route into social housing. As the number of overall lettings available has reduced this route is simultaneously not working for families stuck in temporary accommodation while creating blockages for other routes. Many of those on the housing register would be deemed to have “unrealistic expectations” as they would not meet priority status. As such, we must be careful of the unintended consequences of reform that only considers housing need in terms of homeless households, not of the breadth of households needing to access a social or specialist or supported home.

2.3 While reasonable preference provides a safety net for those most in need of help, it emphasises the issue of vulnerability and potentially stigma for those in need of and in social housing. However, affordability is often not adequately reflected as a measure of need, meaning many on low incomes can wait for significant periods of time on waiting lists or registers.

2.4 For households subject to the benefit cap, experiencing universal credit deductions for historical debts or advance payments, or living in areas where ‘affordable rent’ homes are more available than social homes, even the social and affordable housing market can be closed to them^vi . 

“People effectively sitting their time out in temporary accommodation who have been referred to housing associations for new build properties, but they're being repeatedly turned down on the basis that the properties aren't affordable because they're on Universal Credit.”  – CIH Member, Local authority, South East

2.5 The powers in the Housing Act 1996, outlined in s.166A (5)(b) that allow local authorities to determine priority according to behaviour has led to systemic conflation between debt and ‘poor behaviour’. This has been found to trap households in unsuitable accommodation or temporary accommodation and has been described as a “modern day debtor’s prison” ^vii. It is estimated that 4 million people in England and Wales, which includes 860,000 children are living in a household where outgoings outstrip incomes^viii. One local authority member described applicants being turned away by a PRP because of rent arrears from 20 years ago.  

2.6 Indeed, recent research from the Centre for Homelessness Impact found that, “problem debt is a systemic driver of homelessness, not a marginal or individualised issue.” As mentioned above, we strongly recommend that debt be de-coupled from behaviour criteria that local authorities are allowed to apply in allocations schemes. The research notes the relationship between debt is, “cyclical and reinforcing”. It is imperative to change the underlying narrative around debt as solely a personal failure of financial literacy rather than the increasing structural reality of low-income households^ix.

2.7 In the past year at CIH we have focused on how housing-related debt rules in social housing allocations policy can act to block or de-prioritise survivors of domestic abuse from the housing register. In our report, You can’t bid because you’re in the red^x, we developed best practice guidance which recommended that all social housing provider allocations policies include an exemption for domestic abuse survivors from housing-related debt rules.

2.8 Recent interviews with refuge providers highlighted that these issues are still affecting survivors and that requirements put in place by some PRPs demonstrate the “cyclical and reinforcing” ^xirelationship noted above. One case was described where applicants are required by a local authority to maintain repayment arrangements for 13 consecutive weeks before they could receive a higher priority band status, if one week was missed the period was re-set to zero ^xii.

2.9 We were pleased that the day after publication of You can’t bid because you’re in the red, the government committed in its National Plan to End Homelessness ^xiiito address this barrier via changes to the Allocation of accommodation: guidance for local housing authorities in England. 

2.10 Additionally, during the passage of the current Social Housing Bill, the Minister of State, Matthew Pennycook MP stated, “We continue to believe that guidance is the best route to resolving this issue. But we have been clear in the other place, and I will be happy to reiterate it again today, that if statutory guidance proves insufficient, we do have the option of making regulations to amend the relevant legislation. ^xiv”

2.11 In our briefing on the Bill, we published new data gathered by King’s College London, which shows that most local authorities are unable to report the impact of debt rules on domestic abuse survivors or how many are subject to such rules^xv. We believe that this lack of consistently collected information will mean that the government will be unable to monitor intended improvements set forth in any statutory guidance change.

2.12 The data collected by King’s showed that around 86 (5.2%) of households in temporary accommodation identified by local authorities as being subject to housing-related debt rules were owed a duty due to domestic abuse. These numbers are likely to be much higher, as only 13% of local authorities were able to provide a specific figure. (The full findings are included below in the endnotes)^xvi .

2.13 We have three recommendations to government:

• That local authorities are required to report on how many applicants on the housing register are subject to such rules and specify how many of those are living either in temporary accommodation due to domestic abuse or a refuge
• That central government set a target which sets a benchmark for sufficient improvement
• That a timeline is put forward from the implementation of updated guidance by which it must be met before secondary legislation is brought forward.

2.14 Practitioners indicate that discretion in policies may not be sufficient if that discretion is reliant on specialist advocates making requests on individual cases. Therefore, any guidance must be clear that such flexibilities are expected to be exercised.

2.15 Furthermore, proposed action by the government does not address the issue of ‘double jeopardy’^xvii , whereby, even where local authority policies have an exemption in place, housing association policies on the housing register still bar or deprioritise survivors on the same grounds. This extends beyond the highlighted issue for domestic abuse survivors. There will be more detail on how to encourage better joint working between local authorities and registered providers of social housing later in this response.

2.16 In our 2019 report Rethinking Allocations^xviii , we analysed how pre-tenancy assessments had become widespread and highlighted a cause of concern that these were a barrier or means of gatekeeping access to social housing. Most assessments look at affordability, level of support needs, history of tenancy issues (rent arrears or anti-social behaviour [ASB] for example) and the ability to afford alternative accommodation solutions. Like many of the issues highlighted in the report, these checks have proliferated and exacerbated, as shown by Watts et al, 2022^xix  and Wallace et al, 2026.^xx

2.17 However, these checks are important tools in managing organisational risk in an increasingly challenging operating environment. Used appropriately these should allow housing providers to identify what additional support a household may need to sustain their tenancy. What is necessary is a clearer national picture of how and when these processes are used to “gatekeep”^xxi  and guidance and resources to deter that behaviour and encourage support and tenancy sustainment work to be put in place.

2.18 Housing providers can also design in problematic debt when households move on from supported accommodation to settled accommodation. This is due to notice periods which are incompatible with the short notice periods given with the offer of a move-on to a social home. In some circumstances the refuge can access a two-week discretionary housing benefit overlap for affected survivors. However, in accommodation provided solely by the refuge, such notice periods do not exist, to ensure that residents do not incur extra debt or administration.

2.19 Solutions for practical funding mechanisms and clear guidance on practice by accommodation providers regarding notice periods to avoid such debt for those moving on from specialist accommodation should be considered in this review.  

3.1 The government should issue clarification on how 2025 changes to local connection criteria concerning care leavers, veterans and domestic abuse survivors apply to Rural Exception Site Section 106s, to ensure national consistency on this issue.

3.2 The current definition of domestic abuse used in section 3.43 of the guidance does not accurately reflect the full definition used in the Domestic Abuse Act 2021. We would recommend that the guidance be updated to reflect that definition, specifically to include reference to the term “personally connected”^xxii, to ensure survivors who are fleeing sharing, or lodging, living arrangements are not disenfranchised and do not fail to access the support that they need.^xxiii

4.1 In section 4.2 of the guidance, local authorities are encouraged to have regard to tenancy and homelessness strategies in framing their allocations policy. We would recommend that this section is updated to reflect more accurately the span of work undertaken by local authorities. This section should also specifically refer to Supported Housing Strategies, Homelessness Action Plans, Joint Strategic Needs Assessments and Safe Accommodation Strategies.  

4.2 In Rethinking allocations, CIH explored the suitability of Choice-Based Lettings (CBL), which was introduced in a very different housing context from the current housing shortage and severe constraints on resources. More recently, the sector has raised concerns that this continued and worsened operating environment has given way to the illusion of choice.

4.3 Additionally, there are concerns that households with reduced digital literacy, support needs, employment and caring duties have an unfair disadvantage in their ability to constantly bid on available properties. We recommend that a review is undertaken into the efficacy and fairness of CBL in the current housing context. (Our Rethinking allocations report considers ways in which CBL might be improved).

4.4 The supported housing sector provides an estimated 126,000 places^xxiv  for short-term accommodation for those experiencing a life crisis, like homelessness, or domestic abuse. Following such accommodation, social housing is often the most appropriate next step. However, Homeless Link reports that of those living in their member’s services, 28% are waiting to move on into settled accommodation and more than half of those (55%) those have been waiting six months^xxv . Many will not have reasonable preference in local allocations policies.

4.5 Given the work being undertaken by the department to introduce supported housing licensing schemes as part of the implementation of the Supported Housing (Regulatory Oversight) Act 2023 and the requirement for local authorities to set out move-on pathways in their Supported Housing Strategies, better practice could be achieved by ensuring that related local authority practice reflects this. As such, we recommend that section 4.4 in the guidance be amended to include the addition of:

“(f) Those living in specialist supported accommodation.”

4.6 Supported housing often delivers better outcomes for homeless households and better value for money than temporary accommodation. To stem the rise in local authority temporary accommodation spend, local authorities and providers are shifting to offering models of temporary accommodation with support – under exempt accommodation models – including for families as well as single homeless households. These are normally costed at less per night than traditional temporary accommodation providers, others are being ‘badged’ by PRPs so that they provide such a scheme that allows the local authority to claim full housing benefit subsidy via the Department for Work and Pensions (DWP).

4.7 An unintended consequence of this change in market behaviour is that some homeless households may lose their priority status on the housing register. The adoption of the suggested wording for section 4.4 of the guidance (included in section 3.9 of this submission above) would protect such households diverted from temporary accommodation to supported exempt accommodation.

4.8 To ease the pressure felt by councils due to temporary accommodation costs, some have amended their allocations policy to allow those with a main housing duty to maintain their reasonable preference and priority banding on the housing register if they leave temporary accommodation for the private rented sector (PRS). We would recommend that this becomes standardised practice across local authorities as it both diverts households out of costly temporary accommodation, whie still being able to bid for a social home and breaks the underlying assumption that temporary accommodation is the only route into social housing .^xxvi

4.9 This, of course, depends on affordability on the PRS. Manchester City Council’s approach relies heavily on deposit schemes, incentives to landlords and rent top-ups to secure private rented accommodation.

4.10 Retaining reasonable preference groups will need to be incorporated into any new powers for local authorities to refer homeless households to PRPs. The equivalent power in Scotland (Section 5) operates within an expanded homelessness duty without reasonable preference which, in England, is intended to identify those with increased housing need due to vulnerabilities.

4.11 Any proposed duty to house homeless households should also reflect additional needs recognised by reasonable preference groups. This should include, for example, those living with a disability or support need, who are overrepresented and from a growing cohort in temporary accommodation^xxvii.

4.12 To strengthen joint working in the case of domestic abuse as outlined in section 4.23 of the guidance we would strongly recommend that the department invest in and require all social landlords to take part in a national managed reciprocal scheme, as has been proposed by Standing Together Against Domestic Abuse. Such schemes can save lives and divert households from expensive and damaging stays in temporary accommodation. The allocations guidance must support this in making explicit how these schemes override nomination rights where relevant.

4.13 As outlined above in section 1.4, 1.5 and 1.7 the affordability of social homes is a key concern for ensuring households leave temporary accommodation. In some areas, the removal of the spare room subsidy (‘Bedroom Tax’) is a factor that may be blocking households from accessing an otherwise suitable social home which is cheaper for the public purse than temporary accommodation.

4.14 Below we have suggested an exemption to universal credit regulations from the Bedroom Tax for when such households are eligible and such a home is available. This, of course, would be rarely applicable in many parts of the country where there is a chronic lack of larger homes and high competition for them^xxviii. However, in less populous and rural areas, this exemption could enable timely move-on into suitable housing and limit costly stays in temporary accommodation and lengthy vacancy of homes.

4.15 A CIH member interviewed as part of this research raised similar concerns, whereby pregnant applicants who are currently not eligible for larger properties that they will soon need and be able to afford, are unable to move into appropriate properties. The exemption below would also be appropriate in this circumstance:

“In Schedule 4 paragraph 36 of the Universal Credit Regulations 2013 after sub-paragraph 5 insert "(5A) When calculating a renter’s housing cost element under this Part, no under-occupation deduction should be made if paragraph 3B of Schedule 1 applied to them immediately before this Part came into effect."

4.16 Section 4.34 of the guidance will be obsolete in April 2027 due to the Renters’ Rights Act and can be disregarded. 

5.1 Section 5.8 of the guidance outlines how local authorities should consider data sharing with relevant organisations such as PRPs. Our members working in housing associations have stated that clearer expectations of data sharing need to be included in the statutory guidance. Sharing the support needs of applicants accurately is one of the most important elements of this and it is recommended that it is improved and formalised to ensure that tenancy sustainment is at the heart of referrals.

5.2 We recommend that the guidance outlines PRPs as key data partners with local authorities and describes safe approaches to data sharing, setting out expectations of consistency and reviews of effectiveness. Such practice is described in the Homeseeker Plus Partnership case study in section 6.6 below.

5.3 In our 2026 review of Scotland’s Section 5 referrals (attached as an appendix), it was clear that information sharing to provide clarity on households' needs for support, and access to support services remained a critical underpinning factor of how the duty and referrals worked in practice.

5.4 To succeed, this information must be accompanied with an adequate funding settlement for support. This has been well understood by the government’s ambitious new Rough Sleeper’s Programme. However, this must be broadened to accommodate the support needs of any given nomination beyond the scope of the programme if the government is going to achieve its aims on homelessness and allocations.  

6.1 As part of this review, we strongly recommend the urgent improvement and publication of data related to the allocations of social homes. Currently the public returns from Social Housing Lettings in England do not accurately reflect who is housed in social homes. We would seek that new data accurately records lettings to statutorily homeless household, lettings from supported housing and from refuge and internal transfer, among others.

6.2 Such improved data could include where housing associations are addressing the homelessness and housing crisis beyond statutory homelessness and in some cases fulfilling a social and affordable homes function which local authorities cannot. Examples of this work may include providing homes to those subject to No Recourse to Public Funds for lettings outside of the housing register.

6.3 We would suggest that it is in the public interest to understand where the differences lie between housing associations’ practice across the country as part of the government’s wider work to introduction a Section 5 style power for local authorities announced on 28 September 2026.

6.4 For some of our members there is a gap between the responsibility that local authorities carry for meeting local housing need and the influence they have over the homes available. This is especially the case where registered providers apply additional eligibility or suitability criteria, described as a “double jeopardy” in section 2.8 above. 

“The elephant in the room is the fact that we've got some massive stock-owning housing associations who don't have the duty to house homeless people that the local authorities have…. [it’s] such a massive task to get people into homes that suit their needs.” – CIH Member, CEO veteran’s homelessness charity, North East

6.5 Nominations agreements are another element of the national allocations process where evidence is lacking and needs to be introduced as part of this review. These agreements are not public; there is no standard reporting of their efficacy and there is no requirement for them to be reviewed and updated regularly. We do not know for those who have no nominations agreement in place, what percentage of placements are from local authority nominations, or why refusals are made to certain applicants. This data is key to understanding social housing lettings in England.

6.6 Our Rethinking allocations report recommended the establishment of strong and robust partnerships that enable discussion of difficult issues, accurate and up to date information sharing to support appropriate nominations, clear follow up and monitoring of outcomes, and routes for dispute resolution. We still believe this is the key to achieving good outcomes for all of those in housing need across England.  

6.7 Many of these nominations agreements are historical arrangements that may no longer be fit for purpose or represent local housing need. For some housing associations with 100% nomination rights, little space is left to ensure that emerging housing need can be accommodated for via internal transfers.  

6.8 One of the most important elements of housing management is creating cohesive communities. Allocations can be a tool for balancing communities and ensuring that existing residents have access to more appropriate homes where necessary. An approach to cooperation which builds in this balance is shared housing registers.

6.9 This model of collective allocation responsibility is an approach which can ease reservations held by both registered providers and local authorities about the unintended consequences of mechanisms which focus solely on facilitating the allocations of home to statutorily homeless households.

6.10 These types of arrangements could do well in encouraging the best use of stock across localities, such as adapted homes without a suitable internal nomination. However, such models could have downsides for larger registered providers working across many local authority boundaries having to navigate individual alignments to shared housing registers.  

6.11 Below are two case studies given to us which describe effective partnership working between local authorities and PRPs. Our recommendation to government is to review these models and consider the case for compelling nationwide adoption.  

6.12 An interview with a CIH member in an English local authority, who had previously been working in a Registered Social Landlord (RSL) in Wales, provided a unique insight into partnership working and differences between England and Wales. They described that in comparison to Wales, local authorities in England have a lot less influence over registered providers and “floating support and supported housing options are less prevalent”. This influence predates new powers which are not yet in force in Wales, through the Homelessness and Social Allocations Act. They made it explicit through their experience that dedicated revenue funding for support would make allocations easier for both local authorities and registered providers in England. As recommended in Section 5.1 and 5.4, the government must seriously consider this to support any new allocations duties.

6.13 In Wales local authorities also have greater influence over capital funding for new homes and its alignment with assessed local housing need, especially for homes with specialist adaptations, that could serve to free up larger, general needs homes. We would suggest that the SAHP allocations and bids are more closely aligned with local housing needs assessments and the needs of those stuck in temporary accommodation. This may require more flexibility in value for money assessments to allow for an increase of larger or adapted homes in certain areas.  

6.14 The government's recent announcement of new powers for local authorities to refer homeless households to PRPs indicates that councils will be able to require their PRP partners to assist in providing secure accommodation in social homes, as currently happens in Scotland under Section 5 of the Housing (Scotland) Act 2001, which has been in operation since 2002.

6.15 Overall, the duty in Scotland has been seen as positive, but several reviews have led to some key findings to consider in the development of such powers in England, including:

• There is a lack of consistency about when Section 5 powers should be used compared to nominations, for example
• Information sharing, for example of support needs, is better with Section 5 referrals than nominations, but more could be done, both in sharing information and to access support services required for sustainable, successful tenancies
• There are discrepancies in operation according to councils and social landlord partners, in the use of Section 5 or other routes to house homeless households
• There is little clear recording of the different routes by which social landlords house homeless households other than through Section 5 and therefore some concern that the level of support PRPs make to councils’ homelessness duties is not fully recognised - an SFHA study estimated that 67% of housing association partners used other mechanisms to house homeless households^xxix
• Some councils and partners have a pre-referral process which may impact how accurate records are, for example, when and why referrals are refused. 

6.16 To date no refusals have been referred to arbitration, reflecting perhaps an awareness by all partners that the Section 5 powers are just one tool within the context of wider partnership approaches to deliver more social housing as well as to house homeless households.  

6.17 While Section 5 has enabled greater access to more homes, Scotland has still seen increasing numbers of households becoming homeless, reflecting the underlying problem of a lack of social housing. While new powers will potentially increase access to social homes for homeless households, it will not address this underlying factor.

6.18 To understand and establish an effective allocation system, and any new powers for local authorities, there should be a baseline to understand what routes provide access for homeless and other households into social housing, and to evaluate the real outcomes from partnership approaches. More detailed information on Section 5 can be found in appendix 1.

6.19 In section 6.5-6.11 of the guidance, it is outlined how local authorities can contract out allocations functions to external partners. There is currently no evidence as to how these set-ups are working in practice and whether they are producing better, similar or worse outcomes than local authority run or shared allocations schemes. We would therefore recommend that a review is undertaken of these arrangements to understand their function within the wider allocations landscape. 

7.1 To simplify and update the guidance we would suggest removing “lack of inside WC” from the indicators of criteria in reasonable preference. As figures from over 10 years ago suggest less than 0.1% of England and Wales’ population still have one^xxx.

7.2 Our recommendation would be to remove ‘lack of access to a garden for young children’ as an indicator of reasonable preference. In densely populated areas of England this not reasonable to expect or deliver. What is more important is the consideration of a household’s proximity to quality green spaces and their ability to access these spaces. There are important accessibility and equity considerations here, such as the ability of wheelchair users to safely access good quality green spaces.

7.3 Similarly, with ‘young children in flats above the ground floor,’ this is not reasonable to expect or deliver. However, more must be done to ensure that recommendations from the 2025 National Child Mortality Database report on children’s deaths from windows and balconies are implemented across the housing sector^xxxi.

7.4 Lifts must also be in working order to ensure that those with young children can navigate above the ground floor safely and with ease. 

7.5 To avoid inconsistency of practice, give a clearer steer to local authorities and to narrow the gap where Awaab’s Law is yet to apply we would recommend, that ‘property in disrepair’ explicitly include the new hazards included in phase 2, and category 1 Housing Health and Safety Rating System (HHSRS) hazards such as ‘damp and mould’ as an indicator to consider.

7.6 This could be worded as follows: ‘households living with serious category 1 HHSRS hazards, or other phase 2 hazards that pose a significant risk to the health of a household member, particularly where the hazard cannot be remedied within a reasonable timeframe or the household cannot safely remain in the home’. Local authorities would benefit from guidance on how such considerations sit alongside Awaab’s Law (and the wider HHSRS) and its difference to a decant under it. 

i Sanders, B, Fitzpatrick S, Albanese, F, Grainger G and Allard M. 2025. Moving the deckchairs?: Social Housing allocations in England. https://www.crisis.org.uk/media/v1houc4m/863_cr11215_movingthdeckchairs_a4_digital_final.pdf

ii MHCLG, Allocation of accommodation: guidance for local housing authorities in England, 2025 ( https://assets.publishing.service.gov.uk/media/691c4d2421ef5aaa6543eec3/allocation_of_accommodation_guidance_1_April_2026.pdf)

iii Office for National Statistics (2025), Homelessness in the UK 2004-2024, https://www.ons.gov.uk/peoplepopulationandcommunity/housing/articles/ukhomelessness/2004to2024

iv Gov.uk (2025) Social housing letting in England, tenants: April 2024 to March 2025, https://www.gov.uk/government/statistics/social-housing-lettings-in-england-april-2024-to-march-2025/social-housing-lettings-in-england-tenants-april-2024-to-march-2025 . It reports, as of March 2025 that there were 1.34 million households on local authority housing registers, the highest report since 2024. 

v Perry, J (2024) The new government has set challenging housing strategies – will it achieve them?,UK Housing Review Autumn Briefing. Between 2002 and 2023 the net delivery of additional housing in England has failed to reached the Government’s target of 300,000 homes per year.  

vi Wallace, A et al, (2026) Algorithmic risk and social housing access in England, Housing and Society, 1-19, https://doi.org/10.1080/08882746.2026.2736191

vii Brickell, K & Nowicki, M (2023) The Debt-Trap: Women’s Stories of Navigating Family Homelessness and Temporary Accommodation in Greater Manchester

viii Citizens advice, The National Red Index 2025: negative budget households face a debt crisis like quicksand, 2025 (https://www.citizensadvice.org.uk/policy/publications/the-national-red-index-2025-negative-budget-households-face-a-debt-crisis/). It reports that 1-in-7 single parents were in a negative budget, a cohort overrepresented in those living in TA (almost 60% of all families in TA, according to Shelter.)

ix Centre for Homelessness Impact, 2025, Exploring the relationship between problem debt and risk of homelessness, https://cdn.prod.website-files.com/646dd81ef095aa13072c44e0/6a2941f2b4f84b62cf8f1607_CHI-PROBLEM-DEBT-V8.pdf.  “Once homelessness has occurred, existing debts and the accumulation of new ones can entrench housing insecurity and delay or prevent recovery.”

x Brickell K, Morphew S, & Nowicki M. Chartered Institute of Housing, King’s College London and Oxford Brookes. https://www.cih.org/media/jyklh3yn/you-cant-bid-because-you-are-in-the-red_digital-version_10_12.pdf . We recommended the following wording, drafting by Nick Bano at Garden Court Chambers by included in all housing provider allocation policies: “[Name of housing provider] is committed to ensuring that survivors of domestic abuse are not unfairly prejudiced under this allocations scheme. When applying [Refer to rules concerning qualification and priority that related to debt], [name of housing provider] will not have regard to any debts that have arisen in consequence of domestic abuse”.

xi CHI, 2025

xii Refuges report that in facing these rules, same survivors considering returning to abusers.

xiii Gov.uk, 2025, A National Plan to End Homelessness. https://www.gov.uk/government/publications/a-national-plan-to-end-homelessness/a-national-plan-to-end-homelessness . “We will address the barriers faced by survivors of domestic abuse with debt when applying for social housing, highlighted by recent research.”

xiv Hansard, 2026, Social Housing Bill [Lords] Volume 790: debated on Thursday 10 September 2026. https://hansard.parliament.uk/Commons/2026-09-10/debates/5AF2599A-D2BC-465C-AB4D-AF62826EC2E8/SocialHousingBill[Lords] 

xv Chartered Institute of Housing, 2026, The Social Housing Bill: Second reading briefing (House of Commons stage) - domestic abuse, https://www.cih.org/news/the-social-housing-bill-second-reading-briefing-house-of-commons-stage-domestic-abuse/

xvi CIH 2026  
- “In one month alone (December 2025), local authorities identified at least 86 households in temporary accommodation owed a homelessness duty because of domestic abuse who were ineligible/disqualified to bid for permanent social housing because of rent arrears. This should be seen as a minimum estimate, rather than a national count.
- This means that 5.2% of households identified as being ineligible/ disqualified to bid for permanent housing because of rent arrears were owed a duty because of domestic abuse
- The number is likely to be significantly higher as only 13% of local authorities were able to provide a specific figure. If that number were extrapolated to all 317 councils that would suggest around 737 households
Many authorities who reported significant numbers of disqualified households were unable to provide any domestic abuse breakdown, reporting the FOI cost limit being exceeded (e.g. Westminster who disqualified 835 households). Local authorities with the largest debt-related exclusion numbers were often those that could not identify whether domestic abuse survivors were among those affected
- Apart from local authorities who do not disqualify households, common reasons given for being unable to provide the information asked for were that the information was not held; that domestic abuse data is not recorded in allocations systems; that data on housing-related debt disqualifications is not recorded; or that homelessness and housing allocations systems are separate and require manual cross-referencing which would exceed FOI cost limits. The repeated references to unlinked databases, manual checking, non-reportable systems and missing data suggest that many authorities are unable to systematically monitor the impact of their own policies on domestic abuse survivors.”

xvii Brickell K, Morphew S, & Nowicki M, 2025

xviii Greaves, F, 2019, Chartered Institute of Housing, Rethinking Allocations. https://www.cih.org/media/ezugl10q/rethinking-allocations.pdf. This detailed report outlined the national policy factors which impact access to social housing, the competing priorities that social housing providers have in delivery and managing homes. How applicants interact with the processes in place and how Choice-Based Lettings and Nominations Agreements are working in practice. Since it’s publication, many of the findings are still applicable to the modern housing landscape. However, the challenges faced by both local authorities and housing associations have exacerbated since 2019. Underlining the key insight from this piece of work, that changes to allocations guidance alone, will not sufficiently impact the increasing housing and homelessness pressures faced by households.

xix Watts, B., Bramley, G., Pawson, H., Young, G., Fitzpatrick, S., & McMordie, L., 2022. The homelessness monitor: England 2022. Crisis. https://www.crisis.org.uk/media/246994/the-homelessness-monitor-england-2022_report.pdf. “a large majority of local authorities report that affordability and financial capability checks by housing providers make accessing social housing difficult for homeless households in their area”.

xx Wallace et al, 2026

xxi Wallace et al, 2026. “Reading them [affordability checks] only as instruments of exclusion misses the extent to which landlords experience them as responses to a business environment not of their own making.”… “At the level of policy rhetoric this is framed as responsible letting practice; in everyday practice, it has become a significant gatekeeping mechanism.”

xxii Legislation.gov, 2021, Domestic Abuse Act 2021. https://www.legislation.gov.uk/ukpga/2021/17/contents

xxiii Drawing from conversations with Galop, the charity to for LGBT+ survivors of abuse. The current omission of ‘personally connected’ can lead to gatekeeping of services to this cohort, who may be more likely to be living with friends or “chosen family”. https://www.galop.org.uk/helpline?gad_source=1&gad_campaignid=23123767344&gbraid=0AAAAAD16MGexcG9S8-4cgveadZp82dqOO&gclid=EAIaIQobChMIx6WTsdeTlwMVYY9QBh1-gT0jEAAYASAAEgLxq_D_BwE

xxiv Beatty, C, Bimpson E, Gilbertson, J, McCarthy, L, Sanderson, E and Wilson, I, 2024, Centre for regional Economic and Social Research, Sheffield Hallam University, Supported Housing Review 2023: Executive summary. https://www.gov.uk/government/publications/supported-housing-review-2023/supported-housing-review-2023-executive-summary

xxv Homeless Link, 2025, Support to end homelessness 2025. https://homeless.org.uk/knowledge-hub/support-to-end-homelessnesss-2025/introduction-support-to-end-homelessness-2025/support-to-end-homelessness-2025-move-on-from-accommodation/.  Homeless Link, 2025, Support to end homelessness 2025. https://homeless.org.uk/knowledge-hub/support-to-end-homelessnesss-2025/introduction-support-to-end-homelessness-2025/support-to-end-homelessness-2025-move-on-from-accommodation/. 39% of residents in homelessness services ran by Homeless Link members move on into the social housing sector.

xxvi Brighton and Hove City Council. 2025. Housing allocation policy and guidance.https://www.brighton-hove.gov.uk/housing/council-housing/housing-allocations-policy-and-guidance#tab--local-lettings-plans

xxvii Dore, A, 2025, physical disability, housing insecurity and homelessness. UKHR Autumn Briefing 2025. https://www.cih.org/media/gj0hs1qi/ukhr-autumn-briefing-2025.pdf

xxviii Crisis, National Housing Federation, Shelter. 2025. Ending homelessness can deliver lasting change. https://www.housing.org.uk/globalassets/files/supply/ending-homelessness-joint-paper-1-1.pdf . This report found, that at current letting rates, there are three local authorities where it would take over 100 to clear the waiting list of current applicants for home with three bedrooms or more.

xxix SFHA, (2025), Homeless Allocations by housing associations: evidencing the contribution of the sector https://thinkhouse.org.uk/site/assets/files/3331/sfha0326.pdf

xxx BBC, 2013, General lifestyle survey: 10 changes from 40 years of questions. https://www.bbc.co.uk/news/magazine-21698533

xxxi National Child Mortality Database, 2025, Deaths of children aged under 11 years as a result of a fall from a window or balcony. https://www.ncmd.info/wp-content/uploads/2025/08/NCMD-falls-from-windows-and-balconies-briefing.pdf 

If you'd like to get in touch about our response, please email Stephanie Morphew, Policy Lead at stephanie.morphew@cih.org or Sarah Davis, Policy Manager at sarah.davis@cih.org.