Students and their homelessness are invisible in MHCLG

You know, the one where the Westminster government publishes a policy and ignores students.

The National Plan to End Homelessness is pretty ambitious. It sets targets to eliminate unlawful B&B use for families, halve long-term rough sleeping, and increase the proportion of people helped to find settled accommodation before they enter the temporary accommodation system.

It commits £3.5 billion over three years, introduces a “duty to collaborate” across public services, and runs to tens of thousands of words covering prison leavers, care leavers, veterans, domestic abuse survivors, and the interaction between substance dependency and housing crisis. It’s a serious document produced by people who have read the evidence.

But as ever, students don’t appear in it.

That is not to say that students deserve special treatment or extra sympathy. Students are not a special category in homelessness law – the ordinary framework applies to them like anyone else.

A full-time student threatened with homelessness within 56 days is threatened with homelessness. A full-time student who has no accommodation available to them, or for whom it would not be reasonable to continue to occupy their current accommodation, is homeless. Local authorities must provide free advice and information to anyone in their district regardless of immigration status or student status.

The problem isn’t that students are excluded from the legal definition. It’s that almost the entire prevention and financial support architecture the strategy builds around that legal framework is unavailable to most of them.

Hidden by design

The strategy’s approach to preventing homelessness before crisis point relies heavily on a set of financial instruments – Universal Credit, Housing Benefit, Local Housing Allowance rates, Discretionary Housing Payments, and the new Crisis and Resilience Fund.

Full-time students can’t usually access any of them, with narrow exceptions for lone parents, certain disabled students, and some younger students without parental support. Even where a student does qualify, maintenance support is normally counted as income in the UC calculation, which partially claws back whatever support they might receive.

As such, the strategy invests £3.5 billion in homelessness prevention services that, as a matter of structural design, won’t reach the majority of students at risk. It’s an architecture that was built for a population that includes almost everyone except students.

Frustratingly, sStudent homelessness is mostly invisible in official data. There’s no routine UK-wide student homelessness dataset, and when it does show up, it tends to be in snapshot surveys conducted by NUS or student campaign groups rather than in the statutory returns that feed into the kind of evidence base a strategy like this would be built on.

LSE’s CASE unit has argued that the most common form of student homelessness is hidden homelessness – sofa surfing, informal staying arrangements, short-term crisis accommodation, and other forms of housing loss that sit below the threshold of official counting.

NUS Scotland surveys suggest around 12 per cent of students have experienced homelessness during their studies, rising to around one in three for estranged or care-experienced students. NUS UK’s housing survey in 2024 found 36 per cent of students reporting difficulty paying housing costs and 84 per cent reporting some form of housing problem.

None of that translates into the statutory homelessness figures that MHCLG uses to set policy, because most of those students never present to a local authority.

The HEPI report published in 2022 described it as striking how incurious UK universities and funding bodies had been about homelessness among students and former students. The Centre for Homelessness Impact’s comparative analysis for that paper found that homelessness applications per head are significantly higher in university towns and cities than in comparable large towns without a university, with rough sleeping more than three times greater.

Universities are in the same places as the homelessness. They’re just not in the same conversation.

To be fair to the policy process north of the border, Scotland has at least noticed. The Cross-Party Group on Housing published a report in 2024 documenting bedspace shortfalls of over 13,000 in Edinburgh alone, explicitly framing student homelessness as a hidden problem driven by supply shortages, affordability pressures, and students not recognising their own situations as homelessness.

The subsequent Housing (Scotland) Bill introduced an “ask and act” duty on public bodies – and during Stage 2, non-government amendments were tabled that would have brought higher education institutions into the list of relevant bodies subject to that duty. They weren’t agreed to, with the government’s position being that the list could be expanded via secondary legislation later.

That’s not exactly a triumph but it’s more than England has managed. The National Plan to End Homelessness contains a new “duty to collaborate” for key public services. Universities are not among them.

The groups that fall hardest

The strategy does cover care leavers extensively – exemptions from local connection tests, new duties on councils, corporate parenting responsibilities extending across government departments. The English Homelessness Code separately recognises that care leavers in full-time FE or HE whose term-time accommodation is unavailable during vacations retain certain duties.

But it catches students only when they already belong to another defined vulnerable category. The wider population of students – particularly those who are estranged from their families, those on courses that don’t map neatly onto the academic calendar, those in joint tenancies where one person’s notice can destabilise the whole household, international students with no recourse to public funds who can get advice but can’t have accommodation duties triggered – remain in a gap between the higher education system and the homelessness system that neither owns.

The summer vacation is the sharpest edge of this. When undergraduate accommodation contracts end, maintenance loans stop, and the benefits system remains closed, students who are estranged or have nowhere to go enter a period with no institutional relationship and no financial safety net.

The HEPI report noted that when campuses closed in spring 2020, universities discovered unexpected numbers of students who couldn’t go home. That hidden population existed before the pandemic and exists now. The National Plan to End Homelessness won’t reach it.

Who’s responsible?

The strategy’s answer to cross-departmental coordination is an Inter-Ministerial Group on Homelessness and Rough Sleeping, which brings together MHCLG, the Home Office, DfE, DWP, DHSC, MoJ, and others.

DfE is at the table – but whether anyone at DfE has asked what happens to students who become homeless, or whether universities have any responsibility in that chain, is, as ever with students and housing, presumably someone else’s problem.

Widening participation, as a policy, means admitting more students whose backgrounds correlate with higher homelessness risk. The policy infrastructure around what happens to those students once they’re in hasn’t kept pace. It probably won’t, until the data exists to make the scale of the problem undeniable – and the data won’t exist until someone requires institutions to collect it.

I’m assuming that stuff like this still goes into a “write round” process around Whitehall. Do DfE ministers and officials just ignore everything not about universities per se?