Warm Scots Welcome programme: equality impact assessment

Executive summary

The policy changes assessed in this EQIA are:

1. the introduction of the Offers of Accommodation policy and

2. revisions to the provision of concessionary meals for displaced people living in welcome accommodation.

These policy changes were introduced following the publication of the Review of the Super Sponsor Scheme in November 2022, which highlighted the need to reduce reliance on temporary accommodation and refine the welcome accommodation offer to improve the sustainability of the Warm Scots Welcome programme.

Through the Offers of Accommodation policy, the Scottish Government and its partners aim to support displaced people in moving from temporary welcome accommodation into longer-term housing, while also improving the financial sustainability of the programme. The policy standardises the number of offers of longer-term accommodation provided to displaced people while in welcome accommodation; clarifies how offers should be made; defines what constitutes a ‘reasonable offer’; and introduces a defined exit period where offers are not accepted.

Revisions to the provision of concessionary meals were introduced to enhance the overall sustainability of the programme, ensuring that welcome accommodation and a Warm Scots Welcome could continue to be offered to new arrivals. This change recognised that many displaced people living in welcome accommodation were either employed or receiving social security benefits and therefore able to contribute towards the cost of food.

Throughout the development of these policies, the Scottish Government and its partners worked to identify potential impacts, including those affecting people with protected characteristics. Stakeholders engaged in this process included the Convention of Scottish Local Authorities (COSLA), local authorities, the Scottish Refugee Council, the Ukrainian Consul in Edinburgh, third sector organisations such as the Association of Ukrainians in Great Britain, and, where possible, displaced people living in welcome accommodation.

Where potential negative impacts were identified, the Scottish Government collaborated with stakeholders to develop and incorporate appropriate mitigations into the policies.

Key findings: Offers of Accommodation Policy

It was identified that introducing a policy under which displaced people in welcome accommodation receive offers of longer-term housing could have a different impact on women compared to men.

Because women make up a higher proportion of those in welcome accommodation, more women would be affected by the policy. Overall, this is likely to have a positive impact, as evidence shows that prolonged stays in temporary accommodation can negatively affect health and wellbeing, while settled housing better supports integration and long-term outcomes.^[1].

It was also identified that women may be less likely to accept offers of accommodation due to concerns about their ability to financially sustain a tenancy. This is influenced by the gender pay gap, as women often earn less than men^[2]. The issue is particularly pronounced for women in lone-parent households, who typically work fewer hours than those in dual-income households^[3].

Due to military conscription in Ukraine, lone-mother households have made up a significant proportion of those living in welcome accommodation. As a result, affordability concerns may lead to more women than men declining offers of accommodation. This could have negative consequences for women and any dependent children in their household, who may spend longer periods in temporary accommodation.

To address affordability concerns that might prevent displaced people from accepting offers of accommodation, several mitigations were built into the policy. These include agreeing a definition of a ‘reasonable offer,’ which requires that the offer be affordable for the household, taking into account access to benefits and employment. Local authorities assess options based on individual circumstances, including affordability, and displaced people have the right to request a review if they believe an offer is not reasonable for their household. In addition, local authorities provide support to ensure displaced people are aware of their benefit entitlements and assist with applications where needed. Social Security Scotland also supplies information on benefits in Ukrainian to improve accessibility.

It was also identified that disabled people may face additional barriers under the Offers of Accommodation policy compared to non-disabled people. For example, if specific accessibility requirements limit the types of properties available, disabled guests may receive fewer offers of longer-term accommodation, potentially resulting in extended stays in welcome accommodation.

Affordability concerns were also highlighted as a potential barrier, as research indicates that disabled people typically have higher living costs^[4] and earn less on average than non-disabled people^[5]. These factors may make sustaining a tenancy more challenging for disabled households.

To reduce the likelihood of disabled guests receiving fewer offers of accommodation, the Scottish Government facilitated Regional Partnership meetings to encourage local authorities to collaborate on a regional basis. This approach helped identify suitable properties for complex cases, including those involving disabled people, ensured shared knowledge of available properties, optimised their use, and enabled offers to be made across local authority areas where necessary. The definition of a ‘reasonable offer’ also required that any accommodation offered must meet disability requirements, including any necessary adaptations or adjustments.

To address affordability concerns, local authorities worked with displaced people in welcome accommodation to raise awareness of benefit entitlements and support applications for relevant benefits, including disability-related benefits. Additionally, local authorities assessed entitlement to disability-related support and housing adaptations before making offers, ensuring that offers were appropriate to individual needs.

Key findings: Revisions to the provision of Concessionary meals

Two changes were made to the provision of concessionary meals for displaced people in welcome accommodation. From December 2022, displaced people without access to kitchen facilities were no longer provided with concessionary lunch and snacks, with only breakfast and dinner continuing to be offered. From August 2024, a dinner contribution charge of £3 per meal was introduced for all displaced people in welcome accommodation, with exemptions for children below school age and for new arrivals during their first six weeks in welcome accommodation.

Prior to implementing the change to cease provision of concessionary lunches and snacks, physical access to alternative meal options at lunchtime was identified as a potential challenge for displaced people, particularly for those living in welcome accommodation located far from food outlets. While many displaced people were not present in welcome accommodation during the day due to employment or education, ensuring access to affordable and nutritious lunches for all remained essential.

This challenge was considered especially significant for disabled people, who may face additional barriers compared to non-disabled people if lunch is not provided within their accommodation.

To mitigate potential barriers around physical access to food for all displaced people, including disabled guests, the Scottish Government worked with welcome accommodation providers to ensure that, wherever possible, displaced people had the option to purchase lunch directly from their accommodation, ideally at a reduced price. For example, guests on the passenger ships MS Ambition and MS Victoria could purchase lunch for £3 from the ship’s restaurant.

At the request of local authorities, shuttle buses could also be arranged to enable displaced people to access affordable lunchtime meals from alternative food outlets. In some cases, welcome accommodation provided access to food storage facilities and basic food preparation spaces, allowing displaced people to store and prepare light meals themselves.

From August 2024, a dinner contribution charge of £3 was introduced, with the Scottish Government continuing to subsidise the remaining cost of the meal.

Prior to implementation, it was identified that introducing any financial contribution could have a greater impact on households with lower incomes, with a higher likelihood of lower income among some people who share protected characteristics such as age, sex, and disability.

To mitigate this risk, the Scottish Government analysed a range of data to determine an affordable contribution for displaced people in welcome accommodation. This included the average proportion of UK household income spent on food and the likely minimum income from benefits. Benefit entitlement was used as a proxy for income, as it was not possible to assess affordability individually based on employment or savings. Based on this analysis, a charge of £3 was set as an amount considered affordable for most displaced people.

To safeguard new arrivals who may not immediately access benefits, the dinner contribution charge is waived for the first six weeks in welcome accommodation. In addition, local authorities have discretion to waive the charge where they assess it is necessary for safeguarding reasons, including cases where affordability is a barrier.

Assessment of impact of policy changes to date

Following the introduction of these changes, the Scottish Government has continued to engage with stakeholders to monitor the impacts on Ukrainians in welcome accommodation, including any that relate to protected characteristics.

To date, there is no evidence that the Offers of Accommodation policy has had a differential impact based on protected characteristics in terms of the likelihood of displaced people accepting or declining offers. However, there is anecdotal evidence that some disabled people may spend longer in welcome accommodation than non-disabled people before receiving an offer, due to the limited availability of suitable properties.

The Scottish Government continues to work closely with local authorities to identify appropriate properties and reduce this impact as far as possible, including by encouraging applications to the Ukraine Long-Term Resettlement Fund for properties that may be suitable for disabled guests.

In relation to changes to concessionary meal provision, there is currently no evidence that the impact has been different or more significant for any specific protected characteristic. To date, only a small number of cases have required the dinner contribution charge to be waived for safeguarding reasons, including medical or dietary needs, indicating that exemptions are being applied appropriately where necessary.

The Scottish Government will continue to work closely with stakeholders to monitor and evaluate the impact of these policy changes and will update this EQIA as required.