Response to Scottish Government's consultation on temporary accommodation standards | CPAG

Response to Scottish Government's consultation on temporary accommodation standards

Post date: 
21 August 2019
Written by: 

Kirsty McKechnie

Welfare rights adviser, Early Warning System


CPAG in Scotland responded to a question in the Scottish Government's consultation on improving temporary accommodation standards. The Scottish Government are proposing to adopt and update guidance on standards for temporary accommodation that was published by CIH Scotland and Shelter Scotland in 2011.

Section 3 - Question 2: Do you think these standards are still relevant and fit for purpose?

CPAG in Scotland are not housing or homeless experts. We are responding this consultation to highlight the need to consider incorporating the impact of some social security changes in the guidance.

Consideration should be given to expanding the detail around the affordability of temporary accommodation standard. The CIH Scotland/Shelter guidance from 2011 refers to difficulties experienced by those in work or seeking work in terms of housing benefit payments. There have been a number of changes in social security policy that have impacted on the affordability of temporary accommodation since then.

The benefit cap

Evidence submitted to CPAG in Scotland’s Early Warning System highlights that people who are subject to the benefit cap are often unable to afford their temporary accommodation.

A lone parent with five children staying in temporary accommodation having left her husband due to domestic abuse, had her housing benefit reduced to 50p a week once the benefit cap was applied. Even when she finds permanent accommodation, it is unlikely that she will receive full support with her rent because the size of her family means she is likely to continue to be affected by the cap #69


Guidance on the affordability standard could include:

  • ensuring clients are placed in temporary accommodation which avoids or minimises any shortfall between housing benefit and the rent charged.
  • advising and assisting people to request discretionary housing payments


Sarah is a lone parent with seven children. They were evicted from their private tenancy after Sarah found herself unable to pay her rent when her housing benefit was reduced from £750 to £100 a month. They are now staying in overcrowded local authority temporary accommodation in which Sarah has to share a room with her two children. The temporary accommodation is not close to the children’s school, so paying for bus fares in further impacting on Sarah’s financial situation. She is currently only receiving 50p a week housing benefit towards her temporary accommodation with discretionary housing payments covering the rest for now. OPFS client


EU nationals

Considerable evidence has been submitted to the Early Warning System regarding EU nationals being unable to pay for temporary accommodation because they do not have right to reside that entitles them to benefits. EU nationals are not excluded from receiving homeless or housing assistance in Scotland if they do not have a right to reside, so local authorities can find themselves with a duty to provide accommodation to homeless applicants who have no means to pay for it.


An EU national with two children left her husband due to domestic abuse and requested accommodation from the local authority. She has just been told that she will not be entitled to any housing benefit because she does not have a right to reside that the will entitle her to any benefits. #1720


The Scottish Government may wish to develop guidance about how local authorities should best respond to this situation. Analysis of EWS evidence concludes that often EU nationals who are not entitled to any benefits are not able to establish a right to reside by moving into work because they have caring responsibilities for very young children or disabled family members, are disabled themselves, and/or have recently experienced domestic abuse, relationship breakdown or bereavement.