Homeless Persons (Unsuitable Accommodation) (Scotland) Order 2020 amendment: EQIA

Equalities impact assessment (EQIA) for the Unsuitable Accommodation Order extension.

Stage 1: Framing

Results of framing exercise

Engagement with stakeholders through the consultation on improving Temporary Accommodation standards.

The Scottish Government undertook engagement with stakeholders through a 12 week consultation from 22 May until 14 August 2019 on Improving Temporary Accommodation standards. The consultation sought views on the extension of the Unsuitable Accommodation Order, the production of a new set of standards for temporary accommodation and the introduction of a legally enforceable standards framework for temporary accommodation.

A total of 387 responses to the consultation were received, which included 65 direct responses with 24 from individual local authorities, 31 from organisations and 10 from individuals, 3 of whom had lived experience of homelessness. In addition, Crisis prepared and hosted a shortened version of the consultation on their website which generated a total of 322 responses, 26 of whom were from people with lived experience of homelessness.

Formal analysis of the consultation was undertaken and a final report produced. As a result of the consultation the majority of the responses expressed a preference that the use of unsuitable temporary accommodation should be limited to a maximum of 7 days for all homeless households. This means that the current UAO Order should be extended to all households presenting as homeless.

In regard to the date the UAO Order should be extended, respondents were split about whether the Order should be introduced as soon as possible or whether it should happen over a period of time or in line with the individual Rapid Rehousing Transition Plans. Most respondents indicated that they want the UAO to be implemented in the fastest possible way without offering any opinions on how or when this should be achieved.

As part of the Ending Homelessness Together Debate held on 29 November 2018, ministers agreed to support an amendment put forward by Graham Simpson MSP and supported by other parliamentary parties, which urged the Scottish Government to announce legislation in its next Programme for Government to limit the time that a person has to spend in unsuitable temporary accommodation to no more than seven days. The consultation analysis provides data to support the amendment to extend the UAO.

Extent/Level of EQIA required

Based on the Risk and Impact Assessment matrix the level of EQIA required is low. This is after assessment using the criteria reflected below:



Potential negative impacts identified that require mitigation.

Evidence gaps meaning potential impact on certain group(s) not known.


Some good evidence, but information gaps identified for some relevant protected characteristics that must be filled to assess impact, including consulting with people in those equality groups.


Not able to robustly demonstrate "due regard" – complaint possible.


Potential negative publicity or negative impact on relations with stakeholders and communities.

Action required to manage risk

Make adjustments to policy to mitigate identified negative impacts, or have robust reasons for proceeding.

Fill evidence gaps as far as is possible.

Mitigating action and action plan to be completed and monitored


Email: Homelessness_External_Mail@gov.scot

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