Homelessness Support Across the UK: Does It Matter Where You Are Based?

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Statutory Obligations Across the Four Nations

England, Scotland, Wales and Northern Ireland all approach homelessness in different ways using separate laws, which means that support can vary. Some nations have stronger protections than others, particularly when it comes to ensuring people are housed long-term. Here’s a brief overview of homelessness legislation in each home nation and how they compare:

England

The Homelessness Reduction Act 2017 focuses on preventing homelessness in England. It means that local councils have a duty to prevent homelessness by intervening at an early stage (up to 56 days before a household is threatened with homelessness). Councils must assess people who are at risk and create personal housing plans to help them find accommodation before they become homeless. However, only those in priority need (such as families with children or vulnerable individuals) are guaranteed long-term housing, leaving many people without a permanent solution.

Scotland

Scottish legislation is considered by many to be stronger than England’s, where any individual who is unintentionally homeless has the right to permanent accommodation, which differs to England’s legislation where councils must assess individuals’ priority needs before they can offer it. Local authorities in Scotland are legally required to provide long-term housing, which emphasises their sustained commitment to support. Despite this, homelessness is still on the rise in Scotland due to funding constraints and a lack of affordable housing, among other reasons. 

Wales

The Housing (Wales) Act 2014 focuses predominantly on early intervention and prevention. Under this law, local authorities across Wales must help individuals at risk of homelessness within 56 days, to prevent homelessness before it happens. The statutory obligations for Wales are broader than England’s, especially its focus on prevention and relief. Unlike in England, those seeking support in Wales do not need to be in priority need to receive homelessness prevention or relief assistance. But a priority need test is still needed when determining who is eligible for long-term housing. 

Northern Ireland 

In Northern Ireland, homelessness is dealt with by the Housing Executive under the Housing (Northern Ireland) Order 1988. Their process is similar to England’s, focusing on prevention and short-term accommodation. People in priority need can access housing support, but there is no universal right to permanent accommodation.

Which Nation Does It Best?

Despite these laws being in place, challenges remain around service provision and funding. Differences in resources, policy and local priorities means that different support is available to individuals experiencing homelessness across the four nations.

Scotland offers the strongest legal protection against homelessness by guaranteeing permanent housing for those who need it. Wales takes early action to prevent homelessness, but still applies a priority need test for long-term housing like England and Northern Ireland. All nations have legal duties to help, but Scotland stands out for its commitment to long-term solutions, rather than just prevention.

Here’s a quick comparison of how each nation in the UK approaches homelessness support.

How We’re Helping Across the UK

While the approach to homelessness may vary in different parts of the country, St Martin-in-the-Fields Charity is committed to providing support across the whole of the UK. Through our funding to individuals and organisations, we help people at risk of homelessness and those working to support them, ensuring that no matter where someone is based, they have access to vital assistance. 

Preventing Homelessness through emergency grants 

For many people facing homelessness, a small amount of financial help at the right time can make all the difference. We provide emergency grants that help people across the UK stay in their homes or move into stable accommodation. 

For example, an emergency grant of just £78 was all it took for Aaron to pay his rent in advance, and secure his new home. After turning to Shelter Lancashire for help, his support worker was able to identify a suitable flat, then applied for a VRF grant on Aaron’s behalf. 

“If it wasn’t for that £78, we wouldn’t have got this place. That’s quite weird, how one little thing like that could stop you getting one house. I’m surprised I’ve got this far this quick”. 

We provide small crisis grants of up to £350 for preventing eviction and up to £500 to help with accessing accommodation. These grants are quick, flexible and designed to offer immediate relief to those in need. 

You can find out more about the VRF here. 

Frontline Network: Strengthening Support for Homelessness Services

We know that those working on the frontline of homelessness support play a crucial role in transforming people’s lives. Our Frontline Network brings together organisations and frontline workers across the UK to share knowledge, best practices and resources, ensuring people receive the right support at the right time. 

We work across the four nations to support frontline staff who are working with people who are experiencing homelessness. One way we do this is by providing funding to staff. Our Training Fund helps to cover training costs, providing up to £500 for individual training or up to £1,500 for group training undertaken by organisations. 

We also provide opportunities for staff to come together and share their experiences and expertise at our Frontline Network Annual Conference and other events. 

Funding Services Addressing Immediate and Long-Term Needs

Beyond emergency support, we also provide financial assistance to specialist services that aim to provide long-term stability for people experiencing homelessness. While our most recent Frontline Fund is now coming to an end, we are preparing to launch a new round in March 2026, focusing on access to accommodation. This theme is shaped by insights from frontline workers, captured in our Frontline Worker Survey, who told us how difficult it has become to secure suitable housing for the people they support. 

Through our Frontline Fund and Mental Health Fund, we have supported organisations offering bespoke support such as: 

• Assisting youth in Bristol experiencing housing difficulties through Caring in Bristol’s Project Z 
• Health, education and social care support for young people across North Wales who do not have a safe place to call home with TGP Cymru 
• Specialist legal advice in Scotland with Legal Services Agency, to prevent homelessness for those who have been in the criminal justice system 
• Helping young trans people across the UK to access accommodation via the Trans Pathway project at akt 
• Improving healthcare best practises and advocacy for people experiencing homelessness across the UK with Pathway 
• Counselling for vulnerable people in Ireland who are often unable to access mainstream services due to contact with the criminal justice system, via Extern 

Why Homelessness Solutions Must Be Nationwide 

Homelessness is not isolated to any specific area, but is a UK-wide crisis that requires a unified response. While each nation has its own legal framework, the core challenges remain the same: not enough accessible and affordable housing, too few support services and a lack of long-term solutions. 

A patchwork approach means that people experiencing homelessness may receive different levels of support depending on where they are located. While Scotland provides the strongest legal protections, homelessness persists due to insufficient funding and lack of affordable housing. In Wales, prevention is a priority, but people there still face barriers to securing permanent housing. Meanwhile, in England and Northern Ireland, priority need tests continue to limit access to long-term housing. 

If the UK Government is serious about ending homelessness, there needs to be greater investment in nationwide services that provide consistent, effective support across all four nations. Charities, local authorities and frontline workers must be provided with the resources to deliver vital services such as housing support, mental health assistance and employment opportunities, regardless of location. A commitment to building more affordable housing must also be prioritised by the Government.  

We’re calling for increased investment in homelessness services to ensure that no one in the UK is left behind. 

How You Can Help

Ending homelessness requires a collective response. While policies and funding play a huge role, the need for public support has never been greater. Your support is vital in helping to combat homelessness in the UK. 

By donating to St Martin-in-the-Fields Charity, you can help provide:  

• Emergency grants, allowing more people to keep or secure a home 
• Specialist support for people experiencing homelessness 
• Training and resources for frontline workers 

Donate today and help us make sure that everyone experiencing homelessness gets the support that they need.