Local Housing Strategy guidance 2026: equality impact assessment

Executive summary

Section 89 of the Housing Scotland Act 2001 places a statutory duty on every local authority to prepare and submit a Local Housing Strategy (LHS) to Scottish Ministers.

This Equality Impact Assessment (EQIA) is undertaken on guidance (not policy) prepared by Scottish Government to support local authorities with the development of a LHS.

The aim of the LHS guidance is to support local authorities with the development of a LHS and for this to be developed working collaboratively with local communities and a stakeholders, be evidence-based, including findings from the Housing Need and Demand Assessment as well as any other local evidence gathered; and for there to be links to Scottish Government national priorities, plans and targets as well as local priorities and plans that can contribute to the delivery of the following National Outcomes:

• We live in communities that are inclusive, empowered, resilient and safe.
• We tackle poverty by sharing opportunities, wealth and power more equally.
• We have a globally competitive, entrepreneurial, inclusive and sustainable economy.
• We respect, protect and fulfil human rights and live free from discrimination.
• We grow up loved, safe and respected so we realise our full potential.
• We value, protect and enhance our environment.
• We are healthy and active.

All local authorities are required to prepare a EQIA when preparing a LHS and to include information in their LHS how the findings have helped inform priorities and outcomes. As part of annual review of progress with delivery of LHS priorities and outcomes, local authorities are encouraged to consider ongoing monitoring and evaluation around how well equality objectives are being met. LHS priorities are expected to be aligned with priorities included in local authority Strategic Housing Investment Plans which are prepared annually. Feedback is provided to all local authorities in relation to their Strategic Housing Investment Plans. A LHS prepared by a local authority will include its strategic vision for housing together with priorities and outcomes that it aims to achieve and therefore in that regard it affects everyone living or with the intention of living in the local authority area the LHS relates to.

The nine protected characteristics considered as part of this EQIA were; age, disability, pregnancy and maternity, sex, sexual orientation, gender reassignment, marriage/civil partnership, race, and religion or belief.

Equalities is central to the development of a LHS, as such the LHS guidance includes a strong focus on them, requiring local authorities to prepare a EQIA. As part of annual review of progress with delivery of LHS priorities and outcomes, local authorities are encouraged to consider ongoing monitoring and evaluation around how well equality objectives are being met. The LHS Guidance requires local authorities to consider and address the needs for all people within their community regardless of age and provide appropriate housing and support. It also requires local authorities to demonstrate consideration has been given to range of groups including disabled people, ethnic minorities, lesbian, gay, bisexual and transgender people, and Gypsy/Travellers amongst others.

The LHS guidance prepared by the Scottish Government supports local authorities with preparing a LHS. All local authorities are required to prepare a EQIA to inform and enable local authorities to set local priorities and outcomes in relation to housing and housing related services. This will include consideration of all protected characteristics.

This Equality Impact assessment has considered the potential effects of the LHS guidance on groups with protected characteristics. This analysis is presented below in the Key Findings section. The findings are based on engagement with local authorities through Scotland Housing Network LHS Group and feedback and desk-based research.

This identified a potentially negative impact identified through the Heat in Buildings Strategy Impact Assessment in relation to disabled groups who may have requirements for higher heating temperatures and longer heating hours. It also highlighted that the strategy could impact on a high percentage of Scotland’s population, especially older people, disabled people or those with a long-term health condition where it is suggested that these groups may spend more prolonged periods at home and have a higher likelihood of experiencing fuel poverty.

This impact is mitigated in the LHS guidance which includes a strong focus on fuel poverty requiring local authorities include a summary of the work that is being done locally to ensure, that across all tenures, “so far as reasonably practicable, persons do not live in fuel poverty” with consideration of the four drivers of fuel poverty. Local authorities are also required to include a summary in their LHS of any programmes or actions related to housing arising from a local authority’s Local Heat and Energy Efficiency Strategy including an explanation around how these have influenced the development of climate change, heat decarbonisation, energy efficiency, and/or fuel poverty policies.

A potentially negative impact in Inclusion Scotland's Disabled People’s Views of the Fairer Scotland for Disabled People Delivery Plan^[1] (2020) states that there is not enough accessible housing and disabled people are still living in unsuitable accommodation which does not meet their needs. This impact is mitigated in the LHS guidance which includes a strong focus on specialist provision housing and requires local authorities to include a summary of current levels of specialist provision housing, gaps in provision and future need for provision together with plans for addressing this. It also requires local authorities to have in place wheelchair accessible housing targets and to include information on progress with delivery of targets. The LHS guidance includes strong links to National Planning Framework 4 which supports the delivery of good quality homes, particularly those that improve affordability and choice, including accessible, adaptable and wheelchair accessible homes.

The report ‘Housing and Disabled People – Scotland’s Hidden Crisis’ suggests that local authorities are making decisions about current need and future demand for accessible houses based on very limited data.

A Housing Need and Demand Assessment is required to be undertaken as part of the Local Housing Strategy process. This includes a focus on specialist housing provision including housing for disabled people. Local authorities can augment Housing Need and Demand Assessments with robust additional data and research where this exists. For example, City of Edinburgh Council commissioned an accessible housing study in 2022 and Scottish Borders Council prepared a paper on Particular Housing and Specialist Housing Provision. Local authorities as part of their consultation in developing a LHS are required to engage widely with communities including young people, older people, groups who are harder to reach and organisations including disabled organisations and Integration Authorities.

A potentially negative impact identified in the Housing needs of minority ethnic groups: evidence review was people from minority ethnic communities are more likely to rent privately or be owner/occupiers, often in poorer quality housing stock. This impact is mitigated in LHS guidance with local authorities required to include information in a LHS on what mechanism(s) is in place to monitor below tolerable standard levels and what powers and actions the local authority uses to address below tolerable standard properties. Local authorities are expected to include information in their LHS on how their Scheme of Assistance will be used to address substandard private housing, implementing the Below Tolerable Standard strategy as appropriate.

Every LHS is submitted to Scottish Government for review and there are robust review mechanisms in place to monitor that an EQIA has been carried out by a local authority to inform the development of a LHS. Local authorities are required to undertake an annual review of progress of delivery of LHS priorities and outcomes, including ongoing monitoring and evaluation around how well equality objectives are being met.