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Housing policy in a devolved UK – still diverging?

Author: Kenneth Gibb - Director, UK Collaborative Centre for Housing Evidence - University of Glasgow

April 2023


I was talking to a senior person in Scottish housing the other day. I asked her whether she thought housing policy in the UK was diverging or converging? She thought that there were elements of both processes going on at the same time. I think that is probably right.

When one considers that housing is largely, though not entirely, devolved in the three non-English jurisdictions, and that they have held different party control over time, and often different from the UK Governing party, then it's not surprising that ideology and political priorities may differ and be built on over time. This will be reflected in the trajectory of local housing policy. It should not be surprising either if individual nations from time to time also look at what is going on elsewhere and decide to pursue aspects of apparently successful policies, even if that is mediated and moderated by the path dependencies that operate in specific countries.

Let's look at three examples:

In England, the Right to Buy council homes remains a settled policy where debate and contention largely revolve around whether or not councils can receive sufficient income to ensure one-for-one replacement for the property sold to sitting tenants (the answer to that is no). In Scotland, the Right to Buy was first abolished for newbuild council homes nearly 15 years ago, allowing councils to build new social homes.

Since 2016, the Right to Buy has been completely outlawed. This happened with little or any sustained opposition. The same appears to be true in Wales which subsequently followed this move. In this case, policy divergence (plus ideological differences and path dependency) seems to prevent such lessons transmitting from the devolved countries to the UK Government. Equally, Scotland has pursued a long-term programme to develop additional social and affordable housing supply, majoring on new social housing, and has achieved in successive Parliaments, respectively, 30,000 and 50,000 new affordable and mainly social homes. This commitment to grant-funded new social housing delivered by both housing associations and councils means that, in per capita terms, Scotland is building far more social housing than is the case in England. The programme has been sustained over more than two full Parliamentary terms. Admittedly, this programme is now running into difficulties created by external economic shocks but the commitment remains.

However, in the area of tenancy rights, tenancy conditions and the broader regulation of the private rented sector (PRS), it would seem fairer to say that there is evident convergence across the UK. This is particularly true in relation to both levelling the general non-price regulation in the PRS, but also in critical areas such as the weakening or removal of no-fault evictions, moving towards more indeterminate longer-term tenancies, and extended periods of notice to quit. This is apparent when one compares Scotland and Wales, similar moves are underway in Northern Ireland, and now the Renter Reform Bill developing in England seems to be finally pursuing these key elements, too. They are moving at different speeds, and it is not by any means complete convergence in the PRS: Scotland and Wales are actively considering rent control, which remains a step too far for the UK government.

Policy convergence and divergence is not a simple binary yes or no. After all, housing policy is a complex form of multilevel governance. Housing policy involves social security, tax policy, financial regulation, standards, as well as localised policy decision-making. And now, in addition to those reserved matters, the combined authorities in England are being given additional housing powers, or at least opportunities to undertake their own policies.

Perhaps convergence or divergence is too simple a way to think about these things. We see examples of both, and we now also recognise that it's a little bit more complex than simply what devolved governments in Cardiff or Edinburgh choose to do. Nonetheless, it does remind us that there is a laboratory out there where different natural policy experiments, are underway, which may also ultimately benefit housing outcomes in other parts of the UK.