On 16th April the Government published its response to the Supported Housing Consultation, looking at the implementation of measures in the Supported Housing (Regulatory Oversight) Act 2023.  

In responding to the consultation, Imkaan worked with the Pathways of Hope partnership to understand the impact of the Government’s proposals on frontline specialist ‘by and for’ VAWG organisations. Pathways of Hope is a three-year action research partnership delivered by Imkaan members across England, looking into the systemic barriers faced by Black and minoritised women when accessing specialist ‘by and for’ housing-related support. Through research with practitioners, survivors and specialist services, Pathways of Hope aims to generate evidence that supports systemic change, strengthens inclusive housing policy and reduces homelessness for Black and minoritised women.  

In our response, Imkaan, along with many across the VAWG sector, raised several concerns about the proposals set out, and the Government has made the following changes: 

Including refuges in the list of exemptions

• The Government has now included domestic abuse accommodation (i.e. refuges) commissioned under Part 4 of the Domestic Abuse Act 2021. We raised concerns that the original list exemptions did not recognise the unique value and robust accountability already embedded within ‘by and for’ Black and minoritised specialist VAWG organisations accredited through sector-specific quality frameworks, such as Imkaan’s Accredited Quality Standards and Women’s Aid’s National Quality Standards. These standards are trauma-informed, intersectional, and tailored to meet the specific needs of women and children affected by multiple forms of structural inequality and violence. Requiring ‘by and for’ organisations to undergo further licensing would have imposed unnecessary financial and administrative burdens. Moreover, such an approach would risk devaluing frameworks developed the ‘by and for’ sector, which already ensure high standards of care, governance, and safety. 

Not forcing providers to apply for a licence for each address 

• Original proposals would have meant that supported housing providers would have had to apply for a licence for each and every address. This would have posed a significant administrative and financial burden for small ‘by and for’ VAWG organisations who may have multiple properties for domestic abuse accommodation. We therefore welcome the change that means providers could apply for a licence to the licensing district that covers all the addresses where they provide supported housing in that district. However, we note that for organisations that provide accommodation in more than one local authority, they will still have to apply for multiple licences. 

Clarity on the local connection test

• The Government plans to revise the Local Need Standard proposed in the consultation to make clear that this does not include a local connection test for residents. We welcome this clarity and hope that it is also re-asserted that the local connection test should not be applied to victim-survivors of domestic abuse. Whilst this is already Government policy, we know from Pathways of Hope that this is still routinely being incorrectly applied to victim-survivors, preventing women from accessing essential protection and support. 

Enhanced and expanded fit and proper tests for licence holders

• The Government has decided to expand the fit and proper person test to include not just the licence holder, but also the Board of Directors if the licence holder is an organisation. There will be an enhanced fit and proper person test for licensees whose residents are particularly vulnerable. This is a crucial safeguard however we oppose giving local authorities sole discretion over assessments. Instead, we call for clear national standards to assess a provider’s motivations as well as a provider’s understanding of intersectional and trauma-informed practice and demonstrated ability to deliver holistic VAWG services. 

• It is also vital that the tests do not exclude grassroots ‘by and for’ organisations through overly rigid or profit-focused criteria, and that assessors are trained to recognise their specialist expertise, ensuring licensing empowers services rooted in lived experience.  

While these changes to the original proposals are welcome, the many barriers facing Black and minoritised women that need housing support, as outlined in our joint response to the Homelessness Strategy from Pathways of Hope, remain. Without addressing the funding inequalities that caused half of the specialist ‘by and for’ Black and minoritised refuges to close down within a decade; the institutional barriers such as gatekeeping and unlawful local connection tests that prevent minoritised women from accessing housing support; and the hostile environment that means women with no recourse to public funds cannot access safe accommodation, Black and minoritised women will not have the safety and security that supported housing is meant to provide. 

We will continue to review the consultation response and monitor the implementation of these new proposals to ensure that they do not cause unintended harm to ‘by and for’ Black and minoritised VAWG organisations, the essential work they do, or the women that they support.