We all deserve to live in a home that is safe and secure. But a proposal going through Parliament right now would mean that people could be left living in unsafe accommodation if they are seeking asylum.

If this law goes through, landlords could rent out properties that don't have basic fire protections, with unsafe gas and electrical appliances. Children could be sleeping in rooms less than 4 square metres. 

On 24 May 2023, we joined with 136 other housing and migration organisations to send a clear message: everyone deserves a safe and decent home.

Read our joint letter below - and sign up for updates.

Yes, tell me more!

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24^th May 2023

Dear Secretaries of State

People seeking sanctuary excluded from vital housing safety regulation

We are writing to express our organisations’ extreme concern about the regulations being considered by Parliament that would remove the licensing requirements for houses in multiple occupation (HMOs) used as asylum accommodation.

We are aware that the Home Office promises to repeat the requirements that normally apply in licensing via its contracts with accommodation suppliers; however, experience with enforcement of conditions in existing contracts indicates that this is very unlikely to be sufficient or comprehensive given the scale of accommodation required.

We are particularly concerned that the potential combination of overcrowding, sharing of facilities such as kitchens and potentially lax enforcement of gas and electrical safety standards poses a severe fire risk (these factors appeared to be behind the recent tragic fire in Tower Hamlets). Given that much of the accommodation is likely to be in flats or in terraced housing, the risk applies both to the property itself and to neighbouring homes. The risk is, of course, enhanced by the very real possibility of arson attacks.

As well as safety issues, the potential for increased use of substandard buildings could affect the health and wellbeing of people seeking sanctuary, for example by removing the standards that apply to the kitchen and bathroom facilities required in relation to numbers of occupants. Limited or no controls over room-sharing may well lead to conflicts between occupants, and to safeguarding dangers. Occupants could be condemned to near cell-like conditions in rooms which (for example) could have no windows.

We are also concerned that people seeking sanctuary will potentially be placed into overcrowded rooms in overcrowded housing in neighbourhoods with existing high concentrations of hostel-type accommodation, with potential ramifications for community inclusivity and the safety of people seeking sanctuary.

Existing landlords and temporary accommodation providers will be incentivised to switch their properties away from their existing uses to asylum accommodation, which may be more profitable. This could include properties which may not have met HMO standards previously. As well as leading to an increase in substandard properties, this could exacerbate local housing and homelessness pressures, with the potential for people seeking sanctuary to be blamed for causing them.

As contracts for asylum will be managed by the Home Office, councils will be much less likely to directly redress poor standards or safety issues. As a result, enforcement action may not take place or could be much slower than under current local HMO licensing arrangements. Councils will no longer receive HMO licensing fees from properties used for asylum accommodation, drastically reducing the funds available for enforcement work.

It is worth noting two important elements of HMO licensing:

1.   The reason for licensing is that, over decades, HMOs have been shown to be the properties posing greatest risk to health and safety – especially death from fire. As a bare minimum, if the plans go ahead, additional fire safety requirements (over and above those for non-multi-occupied dwellings) should be on the face of the instrument to show explicitly how fire risk will be minimised. 
2.   Licensing under Part 2 powers is pre-disclosure: councils know where these properties are before they are let, so they can be checked for safety before any incident occurs. Part 1 powers (which local authorities can still use) are only effective if they know where HMOs are; they are dependent on complaints which may not be made (especially given that the occupants are people recently arrived in the UK, who are likely less equipped to navigate local authority complaints systems).

We appreciate the need to resolve accommodation issues resulting from the backlog of asylum claims. However, we do not believe that removing HMO licensing controls is the way to proceed. In summary, our concerns are at two levels. One is the danger of failing to liaise with local authorities and the removal of local controls in situations rife with potential problems for community relations. The second, and even more important, is the potential effect on the safety and wellbeing of people seeking sanctuary. The relaxation of standards contrasts sharply with the government’s efforts to enhance building safety more generally and to tackle poor conditions in the private rented sector, which we strongly support.

We note that the strain on the asylum accommodation system is partly the result of most people seeking asylum being banned from working, as well as excessive delays in asylum decision-making. The Home Office should address these problems rather than deny people seeking sanctuary the basic accommodation rights that should be afforded to all tenants. 

We therefore urge you to abandon the planned removal of HMO licensing requirements, and instead to redouble efforts to ensure that asylum accommodation is safe, healthy and secure.

Your sincerely,

Gavin Smart

Chief Executive, Chartered Institute of Housing, on behalf of the following 141 organisations

Dr C Wooff, Joint leader, ACAP (Ashton Churches Asylum Project)

Duncan McAuley, CEO, Action Foundation

Rosie Boyd, Refugee Integration Officer, African Rainbow Family

Steve Valdez-Symonds, Refugee and Migrant Rights Programme Director, Amnesty International UK

Giles Peaker, Partner, Anthony Gold Solicitors LLP

Anna Rudd, Interim Director, ASSIST Sheffield

Ewan Roberts, CEO, Asylum Link Merseyside

Mabli Jones, Deputy Director, Asylum Matters

Kat Lorenz, Director, Asylum Support Appeals Project

Mark Goldring, Director, Asylum Welcome

Nadia Hussain, Liaison Worker, Aylesbury Women's Aid

Pierre Makhlouf, Legal Director, Bail for Immigration Detainees

Emma Hawthorne, Chair, BIRCH (Birmingham Community Hosting)

David Brown, Chair, Birmingham City of Sanctuary

Mandy Ross, Refugee Support Group member, Birmingham Progressive Synagogue

Barbara Forbes, Local lead Birmingham, Birmingham Schools of Sanctuary

Dr. Wanda Wyporska, CEO, Black Equity Organisation

Ros Holland, Chief Exec, Boaz Trust

David Thomas, Legal Officer, Brighton & Hove Housing Coalition

Laura Chester, Host Network Manager, Bristol Hospitality Network

Hana Cogingsford, Solicitor, Bristol Law Centre

Qerim Nuredini, Chief Executive Officer, Bristol Refugee Rights

Caroline Gregory, Director, Calais Action

Amber Ray, Communications and Engagement Lead, Calderdale Valley of Sanctuary

Catharine Walston, Trustee, Cambridge Refugee Resettlement Campaign

Eleanor Brown, CEO, CARAS

Central England Law Centre, Central England Law Centre, Central England Law Centre

Tom Martin, Director, City of Sanctuary Sheffield

Sian Summers-Rees, Chief Officer, City of Sanctuary UK

Toni Soni, Centre Director, Coventry Refugee and Migrant Centre

Sally Hyman, Trustee and founder, Cribs International

Matt Downie, CEO, Crisis

Fran Wood, Chair of DAR, Darlington Assistance for Refugees

Steve Cooke, Chair, Derbyshire Refugee Solidarity

Alex Vessis, CEO, Devon and Cornwall Refugee Support

Disrupt Foundation,  ,

Karuna, National health advisor, Doctors of the world

Penny Hardcastle, Teacher, Farnham help for refugees

Joanne Watters, Head of Community Projects, Father Hudson's Care

Alan Strang, Volunteer, For Refugees Birminghan

Amber Bauer, CEO, forRefugees

Anna Pincus, Director, Gatwick Detainees Welfare Group

Dan Wilson Craw, Acting Director, Generation Rent

Jason Tetley, Director, Greater Manchester Law Centre

Stephan Morrison, Researcher, Groundswell

Rose Nickolds, Housing and Destitution Caseworker, Hackney Migrant Centre

Hansen Palomares, Solicitors, Hansen Palomares

Madeleine Evans, General Manager, Haringey Migrant Support Centre

Lucy Nabijou, Coordinator, Haringey Welcome

Polly Gifford, Co-Chair, Hastings Community of Sanctuary

Jane Grimshaw, Convener, Hastings Supports Refugees

Kerry Smith, Chief Executive, Helen Bamber Foundation

Angus Clark, Chief Executive, Herts for Refugees

Rosie Carter, Director of policy, HOPE not hate

Phil Davis, Director, Hope Projects

Simon Mullings, Co-chair, Housing Law Practitioners' Association

Sarah Teather, Director, Jesuit Refugee Service UK

Lisa Norcross, Project Manager, Kairos Housing

Sue Willman, Supervising Solicitor, King's College Legal Clinic

Nimrod Ben-Cnaan, Head of Policy and Profile, Law Centres Network

Dragica Felja, Head of education, Law for Life

Jenny Willison, Trustee/Secretary, Leeds Destitute Asylum-Seekers Support

Pete Hobson, Chair, Leicester City of Sanctuary

Rosario Guimba-Stewart, CEO, Lewisham Refugee and Migrant Network (LRMN)

Catherine Pellegrino, Senior Policy Officer, Maternity Action

Dr Joanna Dobbin, GP registrar, Medact

Sebastian Rocca, Founder and CEO, Micro Rainbow CIC

Cllr. Dr. Hosnieh Djafari-Marbini, Co-founder, Migrant Champions Network

Lara Parizotto, Co-Director, Migrant Democracy Project

Son Olszewski, Caseworker, Migrants Organise

Fizza Qureshi, CEO, Migrants' Rights Network

Ceri Hutton, Chair, MigrationWork CIC

Jane Long, MTVH Migration Foundation Committee Member, MTVH Migration Foundation

Bridget Young, Director, NACCOM

John Mayford, CEO, Olmec

Shelley Meister, Founder, trustee, One and All Aid

Salma Ravat, CEO, One Roof Leicester

Alex McMahon, Senior Associate, Osbornes Law

William Ford, Partner, Osbornes Law

Amos Schonfield, CEO, Our Second Home

Paul Quinn, Owner, Paul Quinn writing and editing

Elaine Fraser, Co Founder, PEOPLE IN MOTION

Wren Trevisan, Manager, Phone Credit for Refugees

Sally Daghlian OBE, CEO, Praxis

Kristine Harris, Policy Coordinator, Project 17

Jean Demars, Director, Public Interest Law Centre

Shameem Ahmad, CEO, Public Law Project

Nick Beales, Head of Campaigning, RAMFEL

Anna Jones, CEO & Co-founder, RefuAid

Tim Naor Hilton, Chief Executive, Refugee Action

Sarah Fenby Dixon, Trustee, Refugee Aid Network

Shari Brown, Partnership and Development Manager, Refugee and Migrant Centre (West Midlands)

Shelley Braddock- Overbury, Senior Caseworker, Refugee Asylum Seeker Migrant Action (RAMA)

Ruhi Akhtar, CEO / Founder, Refugee Biriyani & Bananas

Enver Solomon, CEO, Refugee Council

Nick Harborne, CEO, Refugee Support Group Berkshire

Nese Davidson-Birch, Supported Lodging Lead, Refugee Welcome Homes

Alison Moore, CEO, Refugee Women Connect

Mandy Littlewood, Project manager, Refugees & Mentors CIC

Sarah Crowther, Director, Refugees in Effective and Active Partnership (REAP

Jeremy Thompson, Manager, Restore - a project of Birmingham Churches Together

M El Sayed, Research and Advocacy Officer, Rethink Rebuild

Caroline Coombs, CEO, Reunite Families UK

Derek White, Trustee, Rochdale Action with Destitute Asylum seekers and Refugees

Polly Neate, CEO, Shelter

Elizabeth Morgan, Trustee/Treasurer, Side by Side Refugees

patrick marples, CEO, South West London Law Centres

Lucy Parker, Homeless Advice Worker, Southwark Day Centre for Asylum Seekers

Robert Rush, Garden coordinator, Southwark Day Centre for Refugees and Asylum Seekers

Rebecca Bahar, Solicitor, Southwark Law Centre

Liz Needham, Chair of Trustees, St Albans for Refugees

Abigail Martin, Manager, St Chad's Sanctuary

Becky Hellewell, Head of Support & Immigration, St. Augustine's Centre

Stephanie Neville, Project Manager, Stories of Hope and Home

Emily Crowley, Chief Executive, Student Action for Refugees (STAR)

Rachel Balabanoff, Coordinator, The Care Rights Project

Alexandra Lopoukhine, Interim Executive Director, The Joint Council for the Welfare of Immigrants

Jane Williams, Founder, The Magpie Project

Alex Kempton, Director of Operations and Campaigns, The Refugee Buddy Project

William Gomes, Director, The William Gomes Podcast

Susanne Schuster, Publicity and Events volunteer, Thousand 4 £1000

Sue Hirschler, Volunteer, Thousand for £1000

Susie Dye, Grants Manager, Trust for London

Laura Coyle, Partner and Housing Solicitor, Turpin Miller LLP

Dania Thomas, Co-Director, Ubuntu Women Shelter

Andrew Jackson, Chief Executive, Upbeat Communities

Mel Steel, Director, Voices in Exile

Marcie Winstanley, Volunteer Coordinator, West End Refugee Service

Jason Hussein, Head of Advocacy and Support, West End Refugee Service

Joanne MacInnes, Director, West London Welcome

Ted Britton, Chair of Trustees, West Yorkshire Destitute Asylum Network (WYDAN)

George Reiss, Vice chair, Wolverhampton City of Sanctuary

Alphonsine Kabagabo, Director, Women for Refugee Women

Debby Wilson, Domestic Abuse Caseworker, Women's Aid

Jo Cobley, CEO, Young Roots

Valerie Clark, Director, Youth Legal