Temporary accommodation: the housing need that the planning system forgot

The homelessness landscape has worsened dramatically over the past decade, yet the planning system has barely shifted to accommodate the realities facing local authorities. There are systemic tensions between the urgent need for temporary accommodation and a planning framework that does not recognise or enable it.

Within housing need, and even the government’s own homelessness strategy, there is a simple truth that good quality temporary accommodation is a critical part of the housing system. Yet it sits awkwardly within planning policy that was designed for permanent housing, not emergency housing solutions. This gap can lead to confusion, misinterpretation, and difficulties in meeting need.

Temporary accommodation is essential but often missing in planning policy

Under the Housing Act 1996 and the Homelessness Reduction Act 2017, local authorities must provide temporary accommodation to households who are homeless, at risk of homelessness, or awaiting longer-term placements. Temporary accommodation spans hostels, bed and breakfasts, leased accommodation, and purpose-built units. It is an essential safety net to addressing homelessness when it occurs.

Local authorities are legally required to provide temporary accommodation, but the planning system provides no clear route for delivering it. Neither the National Planning Policy Framework nor many Local Plans contains policies written specifically for temporary accommodation. The NPPF focuses predominantly on permanent housing delivery against local housing need assessments, calculated using the standard method. The standard method to calculate unmet (gross) need for affordable housing includes numbers in temporary accommodation. It also includes the number of homeless households, which means it underestimates affordable housing need given official counts exclude certain forms of homelessness, such as sofa surfing.

It is right to focus on the delivery of permanent housing. This is the best way to meet people’s housing need. Yet even in a well-functioning housing system, temporary accommodation will always be needed in an emergency, to house those who are experiencing homelessness while their application is assessed or suitable accommodation is found.

Temporary by name, permanent by nature

Without providing a planning framework to help with the strategic assessment of need, then temporary accommodation ends up using housing that could be used for secure rentals or to buy. It allows less control over supply and quality.

With no specific policies on provision, applications typically come forward as windfall sites (unidentified and unallocated within plans) without the benefit of plan-led support. Temporary accommodation is generally considered sui generis use class in planning, ‘in a class of its own’, sitting outside the standard planning use class for residential, C3. By contrast, Houses in Multiple Occupation (HMO) have their own use class (C4) and planning policies. Temporary accommodation is not the same as permanent housing or HMOs and the absence of policies can force planning officers to stretch unrelated policies to assess applications. Some local authorities are planning for this with specific policies in their local plans, such as Hastings Borough Council, whose draft Local Plan includes support for certain proposals for Temporary Residential Uses.

National homelessness data shows a rapidly escalating need. The latest statistics show that 1.8 households per 1,000 were assessed as homeless in England from July to September 2025. There were 5.4 households per 1,000 in temporary accommodation. Councils recognise this as a critical issue, with several declaring a housing emergency. The District Councils’ Network estimates that the temporary accommodation funding gap is costing the average district £1.6m every year.

Despite this acute demand, planning ignores temporary accommodation rather than seeing it as a core component of local housing and homelessness strategies. The planning system operates as if temporary accommodation is temporary in both name and necessity. But with chronic shortages of social housing, pressures on affordability, and frozen Local Housing Allowance, temporary accommodation now exists as a subset of the housing market and is an essential part of addressing homelessness when it occurs.

Without planning for provision, there are also risks around quality. Research from University College London and University of Liverpool highlighted that Permitted Development Rights (PDR) conversions from commercial to residential use have been particularly prevalent for temporary accommodation, often resulting in poor-quality accommodation with inadequate amenities.

Until planning policy explicitly recognises temporary accommodation as a necessary form of emergency housing, distinct from HMOs or permanent housing, the planning system will continue to underassess and underdeliver on housing need and lack the teeth to ensure quality accommodation for those facing homelessness.

 

Written by Dr Bekah Ryder, Research and Insights Manager at Altair Ltd with input from Daniel Frisby, Associate Planner at DMH Stallard and Chris Hancock, while in his position as Head of Housing at Hastings Borough Council.