Introduction

There is little research looking at the specific manifestations of gatekeeping for people from migrant communities seeking homelessness assistance, including new refugees. This group might have particular challenges securing homelessness assistance from LAs, such as lack of understanding of the homelessness assistance process, lack of medical evidence to demonstrate priority need, mental health challenges, or language barriers. As a result, they might face particular challenges around gatekeeping. This report provides initial evidence to address this gap.

Research findings are based on analysis of comments, questions and case examples from 127 participants in three Advicenow training courses on housing rights for refugees delivered in 2025 and 2026. This training was attended by staff and volunteers from frontline charities, grassroots and community groups, advice organisations, health professionals and faith groups across England. Their experiences suggest a pattern of gatekeeping practices and systemic obstacles at every stage of the homelessness process, leaving refugees at risk of prolonged homelessness.

Key findings

Local authority gatekeeping of homelessness assistance for refugees was a key issue raised by course participants. They identified the following gatekeeping practices:

a. Barriers to accessing the homelessness process

Participants described barriers for people with refugee status accessing homelessness services in the first place. These included services not being accessible, for example people being required to make their homelessness applications online or by telephone. This increases the complexity of the process for often vulnerable people, and creates additional barriers for people with digital access challenges, such as not having a phone or access to data or having language/ communication barrier. Other barriers to access included councils turning people away at reception without providing support,  refusing to act until the point of eviction, or incorrectly advising that they need to apply to a different local authority. LAs have a legal duty to accept a homelessness application from anyone who may be homeless or threatened with homelessness, and to conduct an assessment as soon as they are satisfied that that is the case and that the person meets immigration conditions - also known as being ‘eligible’.

b. Unlawful evidence requirements: barriers to assessment and support

Councils are legally obliged to accept a homelessness application regardless of whether the person is ultimately entitled to assistance. Furthermore, when someone presents as homeless, if the council has 'reason to believe' they may be homeless, meet immigration conditions and are in priority need, they should be provided with interim accommodation while the council finds out more about their situation. However, participants provided examples of councils unlawfully requiring lots of evidence before agreeing to do an assessment or give someone interim accommodation.

c. High thresholds for support

Participants told us that some local authorities have very high thresholds for providing accommodation – both at the initial decision around whether to provide interim accommodation, and at the final decision around whether the council has a duty to provide someone with long-term housing. They highlighted that councils would not recognise clients as vulnerable or potentially vulnerable, even with well-documented serious medical conditions.

Some participants told us that councils are not engaging with the potential priority need of single male refugees, taking a default position that single men are not eligible for interim accommodation or the full housing duty rather than considering potential vulnerability on a case-by-case basis.

d. Failure to provide written decisions or Personal Housing Plans

Participants provided examples of clients not being given written decisions on their homelessness applications, or not being provided with written assessments or Personal Housing Plans - even though councils have a legal obligation to provide these. Without a written decision, applicants are unable to request a review as they have nothing to challenge.

e. Unsuitable offers

Whilst not technically gatekeeping, a related area of poor local authority practice identified by several participants was unsuitable offers of both temporary and long-term accommodation. One example involved hostel‑style accommodation with a cockroach infestation and high levels of ASB. Accommodation supplied under the homelessness provisions is legally required to be suitable.

f. No action without legal challenge.

Some participants found that LAs continue to act unlawfully unless they were subject to a legal challenge. Given the cuts to legal aid and pressure on capacity for housing legal aid teams, in practice getting legal advice or representation is extremely difficult or impossible in many parts of the country.

Conclusion

This research contributes to evidence of gatekeeping of homelessness assistance by local authorities, grounded in the experiences of frontline practitioners. The questions, comments and case examples raised by training participants suggest a pattern of gatekeeping practices and systemic obstacles to support for refugees seeking homelessness assistance. Many of these practices, such as refusing to provide an assessment for people who are homeless or threatened with homelessness and eligible, are unlawful. This suggests local authorities are frequently failing to meet their legal obligations under the Housing Act 1996 and Homelessness Reduction Act 2017.

The consequences of these practices are serious. It seems inevitable that gatekeeping of homelessness assistance for refugees, who may have a legal entitlement to support, contributes to increased refugee homelessness, including rough sleeping. This is of particular concern in a context of rising far right violence, given street homeless refugees present highly visible targets. Both homelessness itself, and navigating the homelessness process only to be refused support, can be traumatising for refugees who may already have a history of trauma. As some LAs only appear to act lawfully when faced with a formal legal challenge, the current shortage of housing legal aid providers creates a justice gap where gatekeeping can go unchallenged.

Gatekeeping must be understood in the broader context of the housing crisis, austerity and LA budget cuts. This leaves LAs in a challenging position where demand for homelessness assistance often exceeds available resources. However, gatekeeping serves to hide the true extent of demand and entitlement to homelessness assistance, disguising the gap between the supply and demand of social housing resources. This in turn has consequences for transparent and accountable political choices about investment in public housing. 

Andy Burnham’s first pledge as incoming Prime Minister was to end rough sleeping in England. Achieving this will require serious engagement with refugee homelessness, given people leaving the asylum system are the second biggest group of people sleeping rough after leaving a public institution. It will also require action to prevent gatekeeping of homelessness assistance, which plays a crucial role in keeping people off the streets.