The UK’s housing challenges are vast and multifaceted, ranging from affordability crises to inadequate supply. The devolved nations offer valuable insights into addressing them through innovative approaches and long-term strategies.
1. Leveraging devolution for a tailored approach
Since devolution, Scotland, Wales, and Northern Ireland have shaped housing policies to meet their specific needs. A good example of this is the Right to Buy (RTB), which Scotland abolished in 2016 to protect social housing supply. Similarly, Wales phased out discounts before fully abolishing the scheme in 2019, prioritising affordable housing supply.
The UK government has begun welcome reforms to limit social housing loss, but RTB remains centrally controlled. Since 2012, local authorities (LAs) have managed their Housing Revenue Accounts (HRAs) independently, yet RTB rules remain dictated by central government. Given councils’ financial independence—reflected in their ONS classification as “public corporations” and the £8 billion debt incurred to gain autonomy—local authorities should arguably have the power to set their own RTB policies. In contrast, Scottish LAs have had financial independence for many years and there is no centrally determined rent policy, so they still have more financial freedom than in England.
Empowering councils to manage RTB aligns with the government’s “devolution revolution” and would allow them to tailor policies to local housing needs, ensuring the scheme supports sustainable social housing supply.
2. Scaling up affordable housing supply
Scotland’s Affordable Housing Supply Programme aims to deliver over 110,000 homes by 2032, with at least two thirds allocated to social rent. Wales aims to deliver 20,000 affordable homes by 2026, prioritising social housing. Whilst neither is doing well against current targets, for various reasons, they both met those which were previously set. To date, Northern Ireland has committed to delivering at least 2,000 new social homes annually to address its pressing housing need, against an average annual build of 1,400 over the past ten years. Furthermore, the Northern Ireland Executive recently endorsed a cross-departmental housing supply strategy aiming to deliver 100,000 homes by 2039, a third of which will be social homes. These nations demonstrate that ambitious targets, backed by substantial funding, can yield significant results.
In England, affordable housing delivery has consistently fallen behind. According to CIH’s 2025 UK Housing Review, England allocates just 53% of housing investment to affordable housing compared to Scotland’s 99%, Wales’ 78%, and Northern Ireland’s 100%. The Joseph Rowntree Foundation’s latest poverty report highlights that a lack of affordable housing is a key driver of poverty, with increasing numbers of families facing financial hardship due to rising rents and insufficient housing supply.
To bridge this gap, the UK government should increase grant funding for social housing to levels comparable with Scotland, Wales, and Northern Ireland. Grant is already much higher in Scotland, covering around 60% of new build costs for housing associations (40% for LAs). In comparison, the average funding per affordable home in England sits at £56,800, while the cost of building an average three-bedroom home typically reaches to over £202,000. Moving beyond reliance on developer contributions would provide a more stable and predictable funding stream, ensuring that affordable housing targets are met regardless of market fluctuations.
3. Addressing decarbonisation and building safety
Scotland’s Energy Efficiency Standard for Social Housing (EESSH) sets ambitious emissions reduction targets with clear milestones (though there is some way to go to realise them). The Welsh government has made retrofitting of social housing a priority in the new iteration of the Welsh Housing Quality Standard, though levels of government investment fall short of that suggested by the Future Generations Commissioner’s “Homes Fit for the Future” report. The UK government should move ahead with establishing mandatory energy efficiency standards for social housing, enshrining in legislation the target of reaching EPC Band C (or equivalent) by 2030 that most providers are already working towards. It should also invest further in retrofitting to reduce emissions and alleviate fuel poverty.
Building safety is another critical area where lessons can be drawn. Scotland’s comprehensive regulations and funding frameworks have ensured high standards. Meanwhile, in England, financial pressures hinder housing providers’ efforts to remediate safety issues. While the Social Housing Regulation Act marked progress, a unified, well-funded approach to safety and decarbonisation is essential to protect residents and improve living conditions.
4. Innovative approaches to homelessness prevention
Wales has led the way in tackling homelessness through progressive legislation. The Housing (Wales) Act 2014 introduced a duty on local authorities to prevent homelessness, focusing on early intervention. Despite initial progress, Wales, like other jurisdictions, faces the same pressures around finding suitable accommodation and responding to the additional demand created by the Covid-19 pandemic and cost of living crisis. However, there has been some success with the roll out nationally of the Housing First model since 2018 which has delivered significant results.
Scotland has gone further with its commitment to end homelessness, underpinned by a shift to a Housing First approach, strengthened legal duties and the abolition of priority need. The Scottish Government’s Ending Homelessness Together plan prioritises rapid rehousing and long-term support, ensuring that people experiencing homelessness have access to stable, permanent housing as quickly as possible. Although it was undermined by cuts in 24/25 to the affordable housing supply budget, the budget has been restored for 25/26. Northern Ireland has strengthened its homelessness prevention framework, incorporating long-term housing-led strategies.
The Public Accounts Committee’s recent report on homelessness in England underscores the need for urgent and focussed action, highlighting rising levels of temporary accommodation and the growing number of children affected (though all administrations are struggling with TA and B&B use.) The report highlights systemic issues, including a lack of affordable housing, inconsistent funding, and insufficient local authority capacity, which have left councils struggling to manage the crisis. Joseph Rowntree Foundation’s analysis also links homelessness with deepening poverty, reinforcing the need for stronger preventative measures.
England’s homelessness strategy should adopt similar preventative measures by:
- Expanding discretionary housing payments to provide immediate financial relief to households at risk of homelessness.
- Enhancing local authority capacity with resources and training to deliver effective homelessness prevention services.
- Ensuring consistent, long-term funding for prevention initiatives to reduce reliance on temporary accommodation and tackle root causes of homelessness.
- Implementing a Housing First approach nationwide.
These steps, combined with a national commitment to increasing affordable housing supply, would shift the focus from crisis management to early intervention. This approach not only reduces long-term costs but also delivers better outcomes for vulnerable households, ensuring fewer families face homelessness.
5. Lessons in governance and funding
Stable funding and coherent governance are critical to successful housing outcomes. Scotland’s commitment to high grant levels per home has enabled consistent delivery of affordable housing. In contrast, fragmented funding streams and short-term policymaking hinder progress in England.
The government should provide multi-year funding settlements for housing programmes and empower local authorities with greater fiscal autonomy, such as through land value capture mechanisms.
Conclusion
The devolved nations have shown that bold, well-funded policies can deliver tangible housing outcomes. By embracing the learning, England can create a sustainable, inclusive housing strategy that addresses the pressing challenges of the next decade.