MD3266 Rough sleeping services – expansion of the Private Rented Sector refugee scheme

1.1.    A total of 11,993 people were seen sleeping rough in London during 2023-24. This is a 19 per cent increase compared to 2022-23. Of these, 66 per cent were new to the streets, an increase of 25 per cent on the previous year. UK nationals accounted for 45 per cent, compared to 49 per cent in 2022-23. People from the ‘rest of the world’ outnumbered people from Europe (excluding the UK) for the first time in 2023-24: they made up 30 per cent of the whole, compared to 25 per cent from Europe.
1.2.    In his 2018 London Housing Strategy, the Mayor set out his aim for a sustainable route off the streets for every rough sleeper in London. In June 2018 he published his Rough Sleeping Plan of Action, which outlines the steps that must be taken by City Hall, government and others to achieve this aim. In 2021, the Mayor refreshed his Rough Sleeping Commissioning Framework, which sets out the overarching and cross-cutting priorities underpinning the GLA’s commissioning activities from 2021 to 2024. 
1.3.    Since taking office, the Mayor has been expanding the pan-London rough sleeping services that the GLA funds and commissions. These services – collectively forming the GLA Rough Sleeping programme – are for people with experience, or at risk, of sleeping rough. They are initiatives to tackle rough sleeping that cannot or would not be provided at a London borough level, as they either meet a very specific need or deliver at the pan-London/multi-borough level. Since 2016, the GLA Rough Sleeping programme has supported over 16,000 people to leave the streets for good.
1.4.    The GLA Rough Sleeping programme is funded from core GLA budget, supplemented by various government grants, such as the Department for Levelling Up, Housing and Communities’ (DLUHC’s) Rough Sleeping Initiative (RSI). The following Mayoral Decisions (MDs) pertain to this programme: 
•    MD2559 (March 2020) approved receipt and expenditure of £4.67m in government funding to expand various core services and to develop initiatives for non-UK national rough sleepers. 
•    MD2789 (March 2021) approved expenditure of £13.69m of GLA Rough Sleeping programme budget to extend various core services up to March 2025; and £1.36m to continue to grant-fund various projects. It also approved receipt and expenditure of £6.66m in government funding, which included the continuation of several RSI projects. 
•    MD2853 (August 2021) approved receipt and expenditure of £24.55m in government funding, and expenditure of £0.17m of GLA Rough Sleeping programme budget, to fund various projects. 
•    MD2957 (March 2022) approved receipt and expenditure of £3.65m in government funding, and expenditure of £3.85m of GLA Rough Sleeping programme budget, to fund various projects. 
•    MD2993 (June 2022) approved the receipt and expenditure of £30.38m from DLUHC’s RSI. 
•    MD3043 (December 2022) approved the receipt and expenditure of £0.54m in government funding and expenditure of £1.25m of GLA Rough Sleeping programme budget, to fund various projects. 
•    MD3089 (March 2023) approved the receipt and expenditure of £0.2m from DLUHC’s RSI, and expenditure of £0.1m of GLA Rough Sleeping programme budget, to fund various projects. 
•    MD3135 (June 2023) approved the receipt and expenditure of £3.61m from DLUHC’s RSI, £0.05m from DLUHC’s Controlling Migration Fund, and expenditure of £16.36m from the GLA’s Rough Sleeping programme budget, to fund core services and various projects. 
•    MD3161 (August 2023) approved the receipt and expenditure of £1.16m from DLUHC’s RSI, £0.14m from London Councils, and expenditure of £0.1m from the GLA Rough Sleeping programme budget, to fund various projects. 
•    MD3204 (December 2023) approved receipt and expenditure of £0.33m from the Royal Borough of Greenwich and London Borough of Redbridge, to fund various projects. 
•    MD3241 (February 2024) approved receipt and expenditure of £1.5m from DLUHC’s ‘Winter Pressures’ funding, to fund various projects.
1.5.    The service that is the subject of this decision is an expansion of a service previously approved by MD3204. 
Activity and funding profile
1.6.    The newly approved expenditure will be as follows: 

2.1.    The GLA Rough Sleeping programme focuses on achieving the Mayor’s vision for everyone sleeping rough to have a sustainable route away from the streets. The programme is underpinned by the overarching priorities set out in the pan-London Rough Sleeping Commissioning Framework 2021. These are to be achieved by working with boroughs and partners, and are as follows: 
•    to prevent people from sleeping rough 
•    to provide an immediate route off the streets 
•    to deliver sustainable accommodation and solutions for those leaving rough sleeping, to ensure people have the support they need to rebuild their lives. 
2.2.    The Rough Sleeping Commissioning Framework also includes the cross-cutting priority to provide specialist advice and support for migrants who are sleeping rough. 
2.3.    Further details of the British Refugee Council PRS scheme for which approval is sought under this MD are set out below.
British Refugee Council – PRS Scheme 
2.4.    London’s housing crisis means there is a major shortage of affordable homes. In the PRS, affordability issues have been compounded by a significant increase in rents seen in recent years. Existing PRS access barriers are further exacerbated for newly recognised refugees who are transitioning out of Home Office accommodation. They may require sizeable deposits, advance rent payments, references and other supporting documents, all within a minimum 28-day period, and without previous experience of renting in the UK. This puts them at increased risk of homelessness and rough sleeping. 
2.5.    Data from CHAIN shows that 17 per cent of new rough sleepers, with a last settled base recorded in 2023-24, had come from asylum support accommodation. This is a significant increase from the previous year. It reflects policy and operational changes made by the Home Office in 2023 relating to the Streamlined Asylum Process and cessations of asylum support, as more people are being evicted from asylum accommodation in London.
2.6.    Since 2012, the British Refugee Council has been supporting refugees to enter the PRS in London. They engage landlords and vulnerable refugees to find safe and suitable long-term housing; this in turn supports people to integrate into their new community and rebuild their lives in safety. 
2.7.    In 2023, the GLA secured funding from the Royal Borough of Greenwich and the London Borough of Redbridge to grant-fund the British Refugee Council to deliver a PRS Scheme. The PRS Scheme supports newly recognised refugees who have exited Home Office asylum support accommodation, and who are sleeping rough or are at immediate risk of doing so, into PRS accommodation. MD3204 approved expenditure of £165,000 of the funds received from the Royal Borough of Greenwich and the London Borough of Redbridge, by grant to the British Refugee Council in 2023-24.
2.8.    The British Refugee Council’s PRS Scheme equips individuals with the tools to independently find a home. The scheme aims to support 60 individuals who are experiencing, or at risk of, rough sleeping in London after the cessation of asylum support accommodation, of which forty will be supported to secure private rented tenancies through the direct provision or facilitation of rental deposits, or negotiation with landlords to remove rental deposits.
2.9.    CHAIN data for Q4 2023-24 indicates that the number of people sleeping rough after leaving Home Office accommodation remains high. There is still a growing need for specialist support for newly recognised refugees experiencing, or at risk of, rough sleeping in London.
2.10.    In March 2024 the GLA secured an additional £102,000 from the London Borough of Redbridge to fund the expansion of the British Refugee Council’s PRS Scheme in 2024-25. This funding was allocated to the London Borough of Redbridge from the government’s ‘Winter Pressures’ funding, specifically for onward grant to the GLA, for the purpose of additional support for newly recognised refugees sleeping rough in north-east London. This additional funding will expand the British Refugee Council’s scheme to support an additional 36 individuals who are experiencing, or at risk of, rough sleeping in London after the cessation of asylum support accommodation. 
2.11.    This MD seeks retrospective approval of receipt of the £102,000 in 2023-24 from the London Borough of Redbridge and approval of expenditure of £102,000 in 2024-25, by way of variation of the GLA’s existing grant to the British Refugee Council, to expand the PRS Scheme. 
 

3.1.    Under section 149 of the Equality Act 2010, as public authorities, the Mayor and the GLA are subject to the Public Sector Equality Duty, and must have “due regard” of the need to: 
•    eliminate unlawful discrimination, harassment and victimisation 
•    advance equality of opportunity between people who share a relevant protected characteristic and those who do not 
•    foster good relations between people who share a relevant protected characteristic and those who do not. 
3.2.    Protected characteristics under section 149 of the Equality Act are age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation, and marriage or civil partnership status (all except the last being “relevant” protected characteristics). 
3.3.    Objective 3 of the Mayor’s equality, diversity and inclusion strategy, Inclusive London, is “to address the specific barriers that prevent some rough sleepers exiting rough sleeping and rebuilding their lives”. 
3.4.    The funding referenced in this decision will help to tackle the inequalities experienced by certain groups of Londoners most affected by homelessness and rough sleeping. Of those seen sleeping rough in 2023-24: 
•    55 per cent were non-UK nationals 
•    24 per cent were Black or Black British 
•    4 per cent were Roma
•    48 per cent had a mental health need 
•    16 per cent were female 
•    59 per cent were aged 26-45 
•    9 per cent were under 26 
•    11 per cent were over 55. 
3.5.    Homelessness in London, and specifically rough sleeping, disproportionately affects people with certain protected characteristics. Increasing the provision of preventative homelessness interventions will help to achieve positive impacts in line with the need to eliminate discrimination, harassment and victimisation. 
3.6.    Data from CHAIN has shown that 17 per cent of new rough sleepers with a last settled base recorded in 2023-24 had come from asylum support accommodation, a sharp rise from the previous year. Newly recognised refugees face specific barriers to PRS accommodation as they transition out of Home Office accommodation, requiring sizeable deposits, advance rent payments, references and other supporting documents, all within a minimum 28-day period, and without previous experience of renting in the UK. The expansion of the British Refugee Council’s PRS Scheme will contribute towards minimising the impact of Home Office policies on non-UK nationals, who make over half of London’s rough sleepers, and provide structured intervention to a sustainable route out of homelessness.
3.7.    The allocation of funding in this decision is aimed at implementing the Mayor’s policies set out in the London Housing Strategy. In May 2018 the GLA published an equality impact assessment (EIA) of that strategy. Policies related to tackling homelessness and helping rough sleepers, to which this service will contribute, were included in that assessment. The EIA concluded that measures to support rough sleepers off the streets, and to help them avoid returning, mean they will be removed from the acute risk and social isolation that sleeping rough creates. This will benefit those with protected characteristics, especially people with disabilities whom the baseline for the EIA identified as disproportionately more likely to be seen sleeping on London’s streets. 
 

Key risks and issues
4.1.    The key risks associated with the decisions in this MD are outlined in the table below: 

Links to Mayoral strategies and priorities 
4.2.    The projects and services for which this MD seeks approval will help meet Policy 7.2 of the Mayor’s London Housing Strategy: “Supporting Rough Sleepers off the Streets.” This will occur through a range of actions to help meet the stated central aim of the Mayor “to ensure there is a route off the streets for every single rough sleeper in London”. The GLA Rough Sleeping team works closely with partners in local authorities, London Councils, DLUHC and the charity sector to support rough sleepers off the streets; and provides pan-London leadership and coordination. The services and projects funded form part of proposal B of the same policy, which states: 
“The Mayor will fund and commission a range of pan-London services and other initiatives to complement those provided by local councils. These will focus on identifying rough sleepers and intervening rapidly to support them off the streets, providing specialist support for particular groups, and helping rough sleepers stay off the street.” 
4.3.    The project funded through this MD will also help meet the objectives of the London Health Inequalities Strategy. Addressing homelessness and rough sleeping is one of the seven objectives set by the Mayor to achieve the aim that all Londoners benefit from an environment and an economy that together promote good mental and physical health. 
Conflicts of interest 
4.4.    There are no known conflicts of interest for those involved in the drafting or clearance of this report. 
Subsidy control 
4.5.    GLA officers have carried out an analysis of the proposal against the four-limbed test set out in the Statutory Guidance for the UK Subsidy Control Regime. Follow the said assessment, officers have concluded that the proposed grant of £102,000 to the British Refugee Council does not amount to a subsidy. 
4.6.    In particular, the proposed financial assistance fails to satisfy Limb B of the four-limbed test set out in the Subsidy Control Act 2022 (the “SC Act”), as the beneficiaries of the funding are not classed as enterprises. 
4.7.    This proposal is consistent with the example set out in section 2.17 of the Statutory Guidance. This example states that “a ringfenced grant to a charity for its non-economic activities (even if the charity also provides some goods or services on the market)” is unlikely to meet the four-limbed test. 
 

Mayoral approval is sought for expenditure of £102,000, funded by a grant from the London Borough of Redbridge. The grant will be awarded to the British Refugee Council to support the expansion, in 2024-25, of the PRS Scheme for newly recognised refugees. Retrospective Mayoral approval is also being requested for the GLA’s receipt of the £102,000 funding from London Borough of Redbridge, which was received in 2023-24. The funding received in advance was accounted for accordingly.

Power to undertake the requested decisions
6.1.    The foregoing sections of this report indicate that the decisions requested of the Mayor concern the exercise of the GLA’s general powers; and fall within the GLA’s statutory power to do such things considered to further, or that are facilitative of, or conducive or incidental to, the promotion of social development within Greater London. In formulating the proposals in respect of which a decision is sought, officers have complied with the GLA’s related statutory duties to:
•    pay due regard to the principle that there should be equality of opportunity for all people
•    consider how the proposals will promote the improvement of health of persons, health inequalities between persons and to contribute towards the achievement of sustainable development in the United Kingdom
•    consult with appropriate bodies.
6.2.    In taking the decisions requested, the Mayor must have due regard to the Public Sector Equality Duty, namely: the need to eliminate discrimination, harassment, victimisation and any other conduct prohibited by the Equality Act 2010; and to advance equality of opportunity between persons who share a relevant protected characteristic (age; disability; gender reassignment; marriage and civil partnership; pregnancy and maternity; race; religion or belief; sex; sexual orientation) and persons who do not share it and foster good relations between persons who share a relevant protected characteristic and persons who do not share it (section 149 of the Equality Act 2010). To this end, the Mayor should have particular regard to section 3 (above) of this report.
Receipt of grant funding
6.3.    Decision 1, above, seeks approval for the receipt of £102,000 from the London Borough of Redbridge. Officers are reminded to comply with any legal conditions that the London Borough of Redbridge places on the use of the grant funding.
Provision of grant funding
6.4.    Decision 2, above, seeks approval for the provision in 2024-25 of up to £102,000 grant funding by way of a variation to the British Refugee Council’s existing grant from the GLA, to allow for the expansion of the British Refugee Council’s PRS Scheme for newly recognised refugees. The proposed grant funding of the British Refugee Council may be viewed as a conditional gift rather than a contract for services. Officers are reminded to vary the British Refugee Council’s existing funding agreement in accordance with the requirements of that agreement.
Subsidy Control
6.5.    The SC Act requires that proposed grants of funding be assessed in accordance with its four-limbed test. Officers have explained at paragraphs 4.5 to 4.7, above, that the proposed grants do not meet Limb B of the four-limbed test. Accordingly, the proposed grant does not amount to a subsidy for the purposes of the SC Act.
 

7.1.    The project will be delivered according to the following timetable: