© National Audit Office 2023

Investigation into the Homes for Ukraine scheme

Department for Levelling Up, Housing & Communities and the Home Office

Session 2022-23

17 October 2023
HC 1863

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Report by the Comptroller and Auditor General

Ordered by the House of Commons
to be printed on 16 October 2023

This report has been prepared under Section 6 of the National Audit Act 1983 for presentation to the House of Commons in accordance with Section 9 of the Act

Gareth Davies
Comptroller and Auditor General
National Audit Office

10 October 2023

Investigations

We conduct investigations to establish the underlying facts in circumstances where concerns have been raised with us, or in response to intelligence that we have gathered through our wider work.

This report covers the Homes for Ukraine scheme. The scheme was established in March 2022 and enables people in the UK to act as sponsors and host Ukrainian nationals and their families seeking refuge from the war in Ukraine. People on the scheme are granted three-year visas, and the first to arrive under the scheme will now be halfway through their permitted stay. The report aims to increase transparency by taking stock of what has been achieved to date, for what cost, and what can be learned.

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013945 10/23 NAO

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The National Audit Office study team consisted of:

Rachel Burden, Matthew Conroy, Andrew Ellis, Catherine Hayes, Rosemary Hill, Kate Milne, Tom Tyson and Steph Woodrow, under the direction of Lee Summerfield.

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Key facts

What this investigation is about

The Homes for Ukraine scheme

1 The UK government launched the Homes for Ukraine scheme (the scheme) on 14 March 2022, following the Russian invasion of Ukraine in February 2022. The scheme enables people in the UK to act as sponsors for Ukrainian nationals and their families seeking refuge from the war, with individuals being granted three-year visas to stay in the UK, with full access to public services, benefits, and other support.1 Any adult is able to act as a sponsor providing they pass eligibility checks conducted by the Home Office and local authorities. Sponsors must commit to hosting for a minimum of six months and can claim thank you payments from government for providing suitable accommodation for Ukrainians to live in of £350 per month for the first 12 months, and then £500 for the next 12 months. In addition, the local authority where the sponsor is based receives a one-off payment of £10,500 per arrival (reduced to £5,900 for all arrivals after 31 December 2022) to help with support and integration needs.

2 The scheme is jointly run by the Department for Levelling Up, Housing & Communities (DLUHC) and the Home Office, who established a joint taskforce in March 2022.2 The Home Office primarily leads on operational matters relating to the processing of visas and checks on the suitability of the sponsor. DLUHC leads on all aspects of the scheme from the point of arrival of Ukrainians into the UK, working closely with local authorities and devolved governments.

Our scope

3 The first people to arrive in the UK under the scheme are now halfway through their permitted stay, and the emergency phase of the UK government’s response to the Ukraine refugee crisis has come to a close. This report aims to increase transparency by taking stock of what has been achieved to date, for what cost, and what can be learned. We set out:

how the scheme was set up at speed and the scheme objectives (Part One);

arrival numbers and the checks conducted on applicants and sponsors (Part Two);

the funding provided (Part Three); and

challenges and future risks with the scheme (Part Four).

4 This investigation does not seek to examine and report on the value for money of the scheme.

5 The scheme was developed in collaboration with the devolved governments and  operates across the UK. The Welsh and Scottish governments both chose, with the agreement of the UK government, to act as super sponsors under the scheme.3,4 This enabled Ukrainians to name the Welsh or Scottish devolved government as their sponsor if they did not have an individual sponsor. The Welsh and Scottish Governments then provided interim accommodation until the Ukrainian was able to move into accommodation in the community or the Welsh or Scottish Government, working with local authorities, had matched them into longer-term accommodation. As decisions taken by the devolved governments, these super sponsor schemes fall outside of the scope of this audit.5 However, we do consider central UK government funding provided to local authorities in Scotland and Wales for Ukrainians with an individual sponsor under the UK-wide scheme.

6 The scheme is not the only route into the UK for Ukrainians seeking to escape the war. A Ukraine Family Visa Scheme was launched on 4 March 2022 to enable Ukrainians to join family members in the UK. Additionally, the Ukraine Extension Scheme was created to enable Ukrainians who held temporary permission to be in the UK to extend their stay. There had been 111,800 visa applications under the Family scheme and 24,800 applications under the Extension scheme as at 29 August 2023, meaning both have been much smaller in scale than the Homes for Ukraine scheme, which had 207,200 applications. Neither scheme has received any significant direct public funding, with no tariff funding or thank you payments applicable under them. As such, neither of these two routes are within the scope of this audit.

1 In this report, we often refer to people applying for or arriving on the scheme as ‘Ukrainians’ for ease. However, the scheme is also open to people of other nationalities if they are the immediate family member of a Ukrainian national who has been granted permission under, or is applying to and qualifies for, the Homes for Ukraine scheme.

2 In this report we refer to a joint taskforce between DLUHC and the Home Office. Initially the scheme was managed by a joint Home Office and DLUHC team in March 2022. This was formalised in May 2022 and the Homes for Ukraine scheme moved to a joint Ukraine Humanitarian Taskforce (the taskforce).

3 The scheme operates across the four nations of the UK. Only Scotland and Wales chose to act as super sponsors; there is no equivalent super sponsor arrangement in place in England or Northern Ireland.

4 The Welsh Government paused their role as a super sponsor in June 2022, and the Scottish Government paused their role as a super sponsor in July 2022. The super sponsor route was not open to new applicants after these dates.

5 Audit Wales is currently conducting an audit looking at how the Welsh Government is supporting Ukrainian refugees, with a particular focus on the Welsh Government’s Super Sponsor scheme. It is expected that it will report in Winter 2023-24.

Summary

Key findings

Homes for Ukraine scheme set up and arrivals

7 Since March 2022, 131,000 Ukrainians have arrived in the UK through the Homes for Ukraine scheme (the scheme). The scheme is uncapped in terms of arrivals. Neither the Home Office nor the Department for Levelling Up, Housing & Communities (DLUHC) formally forecast the number of arrivals the UK could expect under the scheme before launching it. Arrivals per week peaked at 8,200 in the week ending 9 May 2022, and have slowly fallen since then, with weekly arrivals now consistently under 1,000 per week, with a total of 131,000 arrivals up to 28 August 2023. The largest concentration of sponsors under the scheme is in the South-East of England and London (paragraphs 2.2 to 2.5, Figure 7 and Figure 8).

8 DLUHC and the Home Office developed and implemented the scheme quickly in response to a crisis, with a clear objective of bringing Ukrainians to safety. A joint taskforce was established that was able to build on the significant public will to help bring Ukrainians to safety. It established a system to channel the UK public’s generosity into sponsorship arrangements: more than 180,000 expressions of interest were received in the first week the government asked people to record their interest in being a sponsor. In total, 73,759 individuals had applied to sponsor a Ukrainian guest under the scheme by 12 September 2023. DLUHC acknowledges that the initial guidance for the expressions of interest was not clear and may have contributed to a drop-out and disengagement of potential sponsors. The first people arrived in the UK on 28 March 2022, just under four weeks after the scheme was announced and five weeks after Russia invaded Ukraine. The programme has since set out a more complete set of objectives, including to help individuals thrive and transition out of sponsorship (paragraphs 1.4, 1.7, 1.10, 1.13, and Figure 3).

9 DLUHC has changed its internal performance metrics for the scheme over time, and aims to meet these by March 2025, but has not set out what level of performance it expects to achieve before then for five out of six of these. DLUHC does not report externally on its performance but in April 2023, DLUHC updated the internal performance metrics it had set in March 2022, setting itself eight key performance indicators, three of which did not have set targets. In September 2023, DLUHC updated its KPIs again, removing five of the existing KPIs, and creating three new ones, to leave itself with six, as set out in Figure 1. It is currently meeting two of the targets, on the completion of safeguarding checks by local authorities and maintaining the prevention of homelessness in line with wider levels of homelessness. DLUHC also has three targets for successfully rematching Ukrainians with new sponsors, supporting Ukrainians into the private rented sector and helping Ukrainians claiming Universal Credit find employment. DLUHC believes it is on track to meet these three targets by March 2025, despite not setting any interim performance targets. Additionally, it has a target to sign up 10,000 people for an English language and wrap-around employment support scheme by August 2024 and as at September 2023 it had signed up 5,400 to that scheme (paragraphs 1.14 and 1.15).

Visa processing and safeguarding

10 By end of July 2023, the Home Office had received more than 182,000 applications, of which 77% were processed within 15 working days, although rates have slowed for more recent applicants.6 The Home Office did not set out target turnaround times for processing scheme visas until April 2023, stating that the focus was simply to process them as quickly as possible. It acknowledges that it was unable to process visas as quickly as it wanted to at the start of the scheme when the need for Ukrainians to escape was most urgent. For applications submitted in March 2022, for example, 18% of applications were processed within five working days. By May 2022 this had increased to 71% within five working days, largely because the Home Office reprioritised many of its visa caseworkers to work on processing Ukrainian visas and brought in 554 staff from other departments. However, since June 2022, the turnaround times have largely taken longer and the number of applications which took, or will take, more than 15 working days to process increased from 19% of applications submitted in June 2022 to 63% in July 2023 (paragraphs 2.7 to 2.10 and Figure 9).

11 DLUHC and the Home Office recognise safeguarding as one of the biggest potential risks in the scheme and put in place checks on potential sponsors as well as Ukrainians. Sixty-six per cent of all arrivals under the scheme have been female, and 30% of all arrivals are aged under 18 as of 30 June 2023. Alongside Home Office checks on the potential sponsor and other adults in the sponsor household, local authorities are expected to conduct additional checks. However, the local authority checks do not have to be completed before Ukrainians arrive in the UK. DLUHC felt this risk was tolerable given the desire to help Ukrainians to leave Ukraine as quickly as possible. Some local authorities found guidance they received at the beginning of the scheme, when the number of Ukrainians arriving was highest, was insufficient. This was particularly the case for guidance around expectations for safeguarding and accommodation checks. These local authorities generally consider that the guidance has improved since the beginning of the scheme. DLUHC does not hold comprehensive data on how often guests arrived before all checks were completed. Data recorded by local authorities on DLUHC’s main data system shows that out of around 66,000 checks completed by September 2023, 2,516 safeguarding checks were marked as failed. DLUHC told us not all of these will be due to a safeguarding issue as, for example, some local authorities record failures if a sponsor withdrew from the application. It does not know the true number of safeguarding checks that were failed (paragraphs 2.12 and 2.15 to 2.18, and Figure 10).

12 There have not been many safeguarding issues identified but data on some issues are incomplete. According to DLUHC’s data, fewer than 1% of Ukrainian households participating in the scheme have been rematched due to safeguarding concerns, although DLUHC does not mandate that all rematches are reported to it from local authorities. The taskforce established expert panels to look at individual safeguarding risks, such as modern slavery. The panels concluded that the risks are either moderate or low as far as they can determine from the data available. The panels on adult harm and child harm remarked that the data and evidence on these risks are limited and recommended that DLUHC work to improve the data picture it has on safeguarding issues where possible (paragraphs 2.14 and 2.17).

Scheme funding

13 As at the end of September 2023, the government had provided £2.1 billion of funding for the scheme and DLUHC continues to fund new arrivals and sponsors. DLUHC has provided £1.9 billion of this funding, of which:

£1.14 billion has gone directly to local authorities in the form of tariff funding;

£100 million has gone to sponsors as thank you payments for providing accommodation. Funding through both the thank you payments and tariff payments is ongoing as new people enter the UK; and

£650 million was announced by DLUHC in December 2022 for local authorities through a Local Authority Housing Fund (LAHF) (£500 million) to acquire housing stock, and £150 million for homelessness prevention more widely. This funding aims to assist reducing homelessness for people within the local authority, including those on the Homes for Ukraine scheme. Local authorities must spend any money allocated under these before the end of March 2024.

In addition, the Department for Education has provided £171 million to local authorities to help with education and childcare services for Ukrainian children in England (paragraphs 3.2, 3.6 and 4.16, and Figure 11).

14 Government decided to fund the scheme differently from how it has funded recent schemes for permanent resettlement in the UK. Unlike recent resettlement schemes such as the Afghan Citizens Resettlement Scheme (ACRS), Homes for Ukraine offers temporary rather than permanent resettlement. Government does not incur regular accommodation costs under this scheme because sponsors provide the accommodation. In recognition of this, government decided to offer sponsors thank you payments, initially set at £350 per month, rising to £500 per month once guests have been in the country for 12 months. DLUHC estimates this means that it is paying £6 per person per night (£8 once increased to £500) under the scheme. By comparison, in the Homes for Ukraine scheme business case, the accommodation costs under the ACRS in ‘bridging accommodation’ such as hotels was estimated at £98 per person per night (paragraphs 3.3, 3.6 and 3.7).

15 The scheme tariff funding DLUHC provides to local authorities is a one-off payment whereas under permanent resettlement schemes local authorities get multi-year funding. Each local authority is given £10,500 per Ukrainian arrival with the expectation that that money is used to support the arrival in their first year in the UK. This was reduced to £5,900 for arrivals after 31 December 2022. Under the ACRS, local authorities get £10,500 per arrival in the year Afghan citizens arrive, then a further £6,000 is available in the second year and £4,020 in the third year. The Syrian Vulnerable Persons Resettlement Scheme, another permanent resettlement scheme which ran until 2021, also saw multi-year funding, with central government funding to local authorities for five years (paragraphs 3.2, 3.3 and 4.2).

16 DLUHC did not have sufficient spend data from local authorities in 2022-23 to fully understand how local authorities were using tariff funding. It has asked for these data for 2023-24. Tariff funding provided to local authorities is not ringfenced, meaning local authorities are largely free to use it in the manner they think will best meet local needs. In determining the amount of the tariff payment, DLUHC produced an indicative assessment of how the £10,500 tariff funding might be used by local authorities but did not share this with them, as it wanted to give them flexibility over spending. Instead, it set out high-level expectations on how to spend the money such as undertaking safeguarding checks, homelessness assistance and community integration. DLUHC did not mandate that local authorities report back on what they used this funding for, and few chose to do so voluntarily. It has since mandated such reporting for 2023-24 to better understand how the funding is being used. Local authorities we spoke to appreciated having the flexibility with the funding. As there is no further funding beyond the initial tariff payment, some local authorities told us they have kept some money in reserve due to concerns about further financial pressures that may arise with the scheme (paragraphs 3.4 and 3.5, and Figure 12).

Risks and challenges with the scheme

Completeness and accuracy of data

17 DLUHC awarded a direct contract for the scheme’s main data system following a free trial period, a type of arrangement the Government Chief Commercial Officer subsequently warned against. In order to set the scheme up quickly, in March 2022, DLUHC took up an offer from Palantir, a company on the public sector framework agreement for digital services, to provide six months of free support to create its main data system to manage and monitor scheme data. Following the free six-month trial period, in September 2022, DLUHC signed a 12-month contract with Palantir worth £4.5 million, excluding VAT, without any competitive process. DLUHC stated that it had prioritised delivering the programme over replacing the software but acknowledged that beyond the 12-month contract, it should plan to move away from Palantir given DLUHC assessed at the time it may not be the optimal value solution. In February 2023, the Government’s Chief Commercial Officer, wrote to Palantir noting his concern about the practice of offering services to public sector customers for a zero or nominal cost to gain a commercial foothold, contrary to the principles of public procurement which usually require open competition. In early 2023, DLUHC investigated the feasibility of migrating from Palantir’s system to an alternative platform prior to the end of the current contract. It found a number of potential issues with migrating including that a new system may not be able to be implemented in time, may have quality issues and may cost more due to the start-up costs of a new supplier. DLUHC noted that if a new system was not implemented in time, this may present a risk to the unaccompanied minors scheme and wider safeguarding processes. Given these issues, in September 2023, DLUHC extended the contract with Palantir for a further 12-months, valued at £5.5 million, excluding VAT (paragraphs 3.10 to 3.13).

18 DLUHC elected to only make it mandatory for certain data to be reported by local authorities, which has inhibited its understanding of how the scheme is operating. The main data platform enables certain key scheme data to be shared between DLUHC, the Home Office and local authorities, including data on the subsequent movement of Ukrainians post-arrival. Due to the accelerated timetable for creating the scheme, the platform did not undergo the usual research and testing before it went live. Initial issues such as the way it presented duplicated application data from Home Office systems, and a lack of user testing, led to confusion from local authorities as to how to use the main data platform. DLUHC chose not to mandate some of the data collections to reduce the administrative burden on local authorities. Despite subsequent improvements to the platform following local authority feedback, DLUHC’s decision not to mandate has meant that some local authorities continue to report inconsistently. For example, DLUHC cannot accurately report how many Ukrainians have been rematched under the scheme, or the numbers who have permanently left the scheme (paragraphs 3.10 to 3.14).

19 Local authority data returns on scheme homelessness are voluntary, meaning DLUHC does not accurately know how many people on the scheme are currently experiencing homelessness. Return rates vary, with around 30% of English local authorities regularly not providing homelessness data on the scheme to DLUHC. By the end of August 2023, local authorities had reported to DLUHC that 4,890 households in England on Homes for Ukraine visas had been homeless or come within 56 days of being homeless, 8% of the 65,117 households in England using the visas. Since the start of 2023, at any one time, roughly 600 to 800 Ukrainian households have been living in temporary accommodation in England but DLUHC does not know how many of these households are on the Homes for Ukraine scheme. As more sponsorship arrangements come to an end the risk of homelessness is likely to increase (paragraph 4.12 and Figure 14).

Providing suitable housing

20 Local authorities are employing a range of interventions to try to ensure that Ukrainians have suitable accommodation to move into once initial sponsorships end. DLUHC has committed to pay thank you payments for up to two years of the three-year scheme visas, meaning unless sponsors are willing to host Ukrainians without those payments, or DLUHC extends thank you payments into the third year, other housing solutions will be needed. For the first arrivals under the scheme, thank you payments are currently due to stop in March 2024. Of those Ukrainians surveyed in spring 2023, who had been in the UK for between eight months and just under 12 months, 45% were still in accommodation provided by their initial host. Thirty-four per cent reported that they are now renting, although some local authorities told us that the affluence of some areas with high numbers of sponsors will make it harder for Ukrainians to move into the private rented sector nearby. The local authorities we spoke to described a range of actions they have taken to protect people on the scheme in their area from homelessness using their tariff funding, including rematching and support to rent private sector accommodation. In addition, using the £500 million LAHF funding, 905 additional homes have been acquired by local authorities, and DLUHC is currently forecasting a total of 3,365 being acquired by the end of 2023-24, with 2,880 expected to be used to house Ukrainians (paragraphs 4.2, 4.9, 4.13, 4.16 and Figures 2, 13 and 15).

Future decisions on visas

21 The first people to arrive under the scheme will see their visas expire in spring 2025 and it is not yet clear whether government intends to extend visas. Funding and targeted support will end before this point unless the government chooses to extend it (see Figure 2). The government told us it is keeping the scheme, including any future need for extension, under review. Any decision on the future will be made in good time to implement any new operational processes. Government is conscious of the wishes of the Ukrainian Government to support Ukrainians to return there when it is safe to do so to help rebuild the nation (paragraphs 4.2 and 4.3).

Scheme governance and resourcing

22 DLUHC and the Home Office have reduced the number of staff allocated to support the scheme as it is now past the initial crisis phase. The main taskforce running the scheme was moved into a new directorate within DLUHC in April 2023 to incorporate management of the Hong Kong resettlement route and with the aim of working closely with the Home Office on providing suitable accommodation for those coming to the UK through the Afghan schemes. DLUHC aims to have 100 full-time equivalent (FTE) staff working in that area by the end of March 2024 compared with 161 taskforce staff at the end of 2022. The Home Office has already significantly reduced the number of staff working on visa processing, down from more than 1,000 in June 2022 to 110 as of September 2023 (paragraphs 4.18 and 4.19).

Concluding remarks

23 Between 18 March 2022 and 28 August 2023, the government has successfully supported 131,000 Ukrainians to come to the UK under the scheme, meeting government’s overall objective of bringing Ukrainians to safety. The generosity of the British public in hosting people from Ukraine meant that the government’s taskforce was able to establish the scheme quickly, and government put in place arrangements to manage important risks at the start.

24 The future of the scheme is not yet clear. It is set to run for at least another three years, with three-year visas continuing to be approved daily. Because of the uncertainty for Ukrainians in the UK, government will soon need to make several decisions, including whether to provide thank you payments for the third year of visas, and what additional funding, if any, to provide to local authorities to continue to support the scheme. In making its decision, government will need to also consider the desire of the Ukrainian Government for people to return once it is safe for them to do so. Some Ukrainians now have less than 18 months remaining on their visa, introducing new challenges for individuals and local authorities. Government will also need to carefully monitor the scheme’s key risks, such as safeguarding, and particularly the threat of rising homelessness as more sponsorships end.

6 The 182,000 applications figure does not include withdrawn applications, such as where an applicant has applied more than once and only one of their applications is considered. When we refer to processed applications, we mean applications where the Home Office has concluded an outcome, such as ‘issued’ or ‘refused’.

Part One

Initial set-up of the scheme

1.1 This part of the report looks at the set-up of the Homes for Ukraine scheme (the scheme), including the scheme background, how it works, and its governance and objectives.

The humanitarian response to Russia’s invasion of Ukraine

1.2 Russia’s invasion of Ukraine on 24 February 2022 caused civilian casualties and the destruction of vital infrastructure, forcing millions of people to flee their homes seeking safety, protection and assistance. As of September 2023, 6.2 million displaced people from Ukraine were recorded globally.

1.3 Many countries have offered schemes to provide routes for Ukrainians seeking sanctuary in their countries. Most notably, the EU activated the temporary protection directive on 4 March 2022, which allows displaced persons a residence permit, access to the labour market and housing, medical assistance, and access to education for children. As of July 2023, more than four million people from Ukraine have benefitted from the directive and are able to stay in the EU till 4 March 2024.7

1.4 The UK government set up three schemes to support those who wish to either come to or remain in the UK (see Figure 3). All three schemes allow eligible applicants to live, work and study in the UK and access public funds for up to three years.

Ukraine Family Scheme: Announced on 1 March 2022, the scheme is open for immediate and extended Ukrainian family members of British nationals and people settled in the UK. The scheme was launched on 4 March 2022.

Homes for Ukraine: Also announced on 1 March 2022, the scheme is open for Ukrainian nationals and their family members who do not necessarily have family ties in the UK, if sponsored by someone in the UK. Ukrainians apply for the scheme with a sponsor who can offer them a home such as a spare room or unoccupied residential self-contained unit. The scheme opened for applicants on 18 March 2022.8

Ukraine Extension Scheme: Announced on 29 March 2022 and launched on 3 May 2022, the scheme is accessible to Ukrainians or immediate family members who were previously dependents of those Ukrainian nationals, who had permission to be in the UK between 1 January 2022 and 16 November 2023. This route does not require a UK based sponsor.

1.5 The Homes for Ukraine scheme (the scheme) is the largest of the three schemes with 207,200 applications, as of 29 August 2023 (Figure 4). This compares with 111,800 applications under the Ukraine Family Scheme, and 24,800 applications under the Ukraine Extension Scheme. Under the Homes for Ukraine scheme, sponsors can claim thank you payments from government for providing suitable accommodation for Ukrainians to live in, and the local authority where the sponsor is based receives grant funding to help with support and integration needs (see paragraphs 3.2 to 3.5). Neither the Ukraine Family Scheme nor the Ukraine Extension Scheme have received any significant direct public funding.

How the scheme works

1.6 A Ukrainian looking to apply for the scheme needs to find a potential sponsor in the UK (Figure 5). This can be someone that they already have a connection with, such as a friend or family member, or someone they have not previously met. Many connections were made in the early stages of the scheme through online social media channels. In addition, since May 2022 the Department for Levelling Up, Housing & Communities (DLUHC) has hosted a webpage on gov.uk of recognised providers. These are voluntary and community sector organisations that look to facilitate matches between Ukrainians and willing sponsors in the UK. Government has played no direct role in creating matches and does not know how many people remain interested in becoming a sponsor.

1.7 To gauge the level of public engagement with the scheme, since 14 March 2022, the UK government has hosted a ‘Ukraine Expression of Interest list’ on gov.uk, where members of the public can record their interest in becoming a sponsor. As of 28 June 2023, 248,388 people had expressed interest in becoming a sponsor, with most submissions (181,352) within the first week. DLUHC provided the list of people who had expressed interest to the relevant local authorities on 22 April 2022. However, DLUHC acknowledges that the initial guidance for the expressions of interest was not clear and may have incorrectly raised an expectation that it would proactively match individuals on the list to a guest. This confusion contributed to a drop-out and disengagement of potential sponsors. DLUHC told us that many people may also have chosen not to apply as a sponsor once more detailed guidance and communication was shared and they fully understood what the sponsoring scheme would entail. A total of 73,759 applied to sponsor a Ukrainian guest under the scheme, by 12 September 2023. Of these, only 19,754 (8%) were on the list of 248,388 people who had submitted expressions of interest, as of 28 June 2023.

1.8 Once a Ukrainian has found a potential sponsor, they apply online, with either party able to complete the application form. The Home Office then commences visa checks on the applicant and suitability checks on the sponsor. At the same time, the sponsor’s local authority is notified of the application and is expected to begin safeguarding checks on the sponsor and the suitability of the accommodation being offered (see Part Two of this report for more details on both the Home Office and local authority checks).

1.9 If the Home Office is satisfied with the result of its checks on the applicant and sponsor, then it issues the applicant with appropriate documentation to enable them to travel to the UK. While local authorities do not need to complete checks prior to visas being issued, if they have completed checks and found issues, then the Home Office will consider these prior to issuing the visa. Sponsors are expected to offer accommodation for a minimum of six months, although in reality many relationships have lasted much longer than that, and some have ended before then. Local authorities and the voluntary and community sector can help Ukrainians find alternative living arrangements if sponsorships end, with local authorities also having their usual statutory duties to prevent homelessness (see Part Four for how local authorities are dealing with this).

Initial governance of the scheme

1.10 Central government responsibility for the scheme is split between DLUHC and the Home Office (Figure 6). The Home Office is primarily responsible for elements of the scheme up to people’s arrival in the UK, focusing on the processing of visas. DLUHC is the overall lead for policy and scheme design from the point of people’s arrival in the UK. Local authorities have primary responsibility for implementing the scheme within their areas. In March 2022, DLUHC and the Home Office established a joint ‘taskforce’ to run the scheme;9 in 2023, the taskforce was re-structured and became part of DLUHC, but the division of responsibility for the scheme between DLUHC and the Home Office remains the same (see paragraph 4.19).

1.11 The scheme’s main decision-making body at official level is the programme board. This board consists of DLUHC and Home Office officials and includes representatives from the Department for Education (as required for input on child safeguarding issues), and the Government Internal Audit Agency (GIAA). To support the programme board, officials set up groups including:

a cross-government steering group, including representatives from more than 10 government departments; and

advisory groups with representatives from outside of UK central government, including local government, charities, and the devolved governments, in recognition of the important roles they have in the scheme.

1.12 In a report issued in April 2023, the GIAA found the scheme overall had a clear governance structure in place, with a clarity of focus and understanding of its role across the programme.

Scheme objectives

1.13 Given the pace required to establish the scheme, DLUHC and the Home Office chose not to prioritise putting detailed objectives in place at the start of the scheme. Instead, it was launched with the stated intention to “allow individuals, charities, community groups and businesses in the UK to bring Ukrainians to safety”.10 DLUHC set out internal programme objectives in March 2022, with further refinement in December 2022. These are to:

facilitate sponsorship of people arriving into the UK via the scheme;

ensure people sponsoring and being sponsored are safe and secure in their sponsorship arrangements;

provide people arriving under the scheme with the support needed to thrive in the UK, enable them to live, learn, work and be healthy;

help individuals under the scheme to transition to independent living post-sponsorship, including support to return home; and

support the taskforce’s current and future mission, including alignment with other refugee cohorts.11

1.14 DLUHC set out six internal performance metrics in March 2022 to monitor the roll-out of the scheme. These covered areas such as numbers of visas granted and arrivals under the scheme, number of checks completed by local authorities and number of thank you payments made to sponsors. However, none of the metrics had targets. In April 2023, DLUHC revised these to eight internal key performance indicators (KPIs), but three of these did not have set targets.

1.15 In September 2023, DLUHC updated these KPIs, including removing five of the existing metrics, and creating three new KPIs, leaving itself with six (see Figure 1 in the Summary). It is currently meeting two of the targets it set, on the completion of safeguarding checks by local authorities and maintaining the prevention of homelessness in line with wider levels of homelessness. DLUHC also has three targets for successfully rematching Ukrainians with new sponsors, supporting Ukrainians into the private rented sector and helping Ukrainians claiming Universal Credit find employment. DLUHC believes it is on track to meet these three targets by March 2025, despite not setting any interim performance targets. Additionally, it has a target to sign up 10,000 people for an English language and wrap-around employment support scheme by August 2024 and as at September 2023 it had signed up 5,400 to that scheme.

7 The European Commission has stated that if the reasons for temporary protection persist beyond 4 March 2024, it may propose to extend the temporary protection by up to another year until 4 March 2025.

8 The scheme operates across the UK with any adult able to act as a sponsor providing they pass suitability checks as part of the application process. The Welsh and Scottish governments both chose to act as super sponsors under the scheme, enabling Ukrainians to name them as their sponsor if they did not have an individual sponsor.

9 In this report we refer to a joint taskforce between DLUHC and the Home Office. Initially the scheme was managed by a joint Home Office and DLUHC team in March 2022. This was formalised in May 2022 and the Homes for Ukraine scheme moved to a joint Ukraine Humanitarian Taskforce (the taskforce).

10 Although charities, community groups and businesses have been involved in offering support in various ways under the scheme, the taskforce has never allowed these organisations to take on formal sponsorship roles as it believes that individual sponsorships lead to more sustainable relationships.

11 The taskforce’s mission had not yet been developed when the objectives were set out in December 2022. This objective was made redundant when the taskforce was moved into a new directorate in April 2023.

Part Two

Arrivals under the scheme

2.1 This part of the report looks at the number of people who have arrived under the Homes for Ukraine scheme (the scheme) and the checks and processes that the Home Office and local authorities undertake on applicants and sponsors.

Arrival numbers

2.2 By 28 August 2023, 131,000 Ukrainians had arrived in the UK under the scheme. The government announced from the outset that the scheme would be uncapped in terms of arrivals. Neither the Home Office nor the Department for Levelling Up, Housing & Communities (DLUHC) produced formal forecasts for potential arrivals under the scheme prior to the scheme launching. They told us this was due to limited evidence prior to launch. While the Home Office did some analysis of potential arrivals after the scheme launched these were models for helping with operational planning rather than a more definitive forecast.

2.3 The first people arrived on 28 March 2022, just under four weeks after the scheme was announced. Arrivals per week peaked at 8,200 in the week ending 9 May 2022, and have slowly fallen since then, with weekly arrivals now consistently under 1,000 per week (Figure 7). The pattern of arrivals will be dependent on a number of factors, including how quickly the Home Office is able to issue visas.

2.4 England has seen the largest concentration of Ukrainian arrivals who are sponsored by individuals, with 171 average arrivals per 100,000 of population as of 8 August 2023. This compares with 121 in Wales, 93 in Scotland and 63 in Northern Ireland. The Welsh and Scottish Governments have also sponsored a further 23,398 arrivals under the super sponsor pathway as of 8 August 2023.12

2.5 The largest concentration of Ukrainian arrivals who are sponsored by individuals under the scheme has tended to be in the South-East of England and London, although it is Derbyshire Dales in the East Midlands that is the local authority with the highest proportion of arrivals per population (Figure 8). The local authority with the largest number of arrivals is Buckinghamshire (1,689).

Visa processing

2.6 The Home Office is responsible for the processing of scheme visas to enable Ukrainians to enter the UK. It is responsible for checking:

Ukrainian applicants – against standard visa eligibility criteria and security checks; and

the potential sponsor and all adults in the sponsor household – making suitability checks against relevant databases.

Visas are only issued if there are no adverse results to indicate that the UK-based sponsor or applicant do not meet the eligibility or suitability criteria.

2.7 The Home Office did not originally set out target turnaround times for processing scheme visas, stating that the focus was simply to process them as quickly as possible.13 It told us that not having a target meant that the data it collected on its operational processing of these visas are not as good as it collects for other visa processes. It was not until August 2022 that any robust analysis of the data on turnaround times was conducted by the Home Office. In April 2023, the Home Office set out a target internally to process all straightforward applications within 15 working days, in line with other visa target times.14

2.8 The Home Office acknowledges that it was unable to process visas as quickly as it wanted to at the start of the scheme when the need for Ukrainians to escape was most urgent. In March 2022, the first month that applications were open, of the 26,000 applications received, 18% were processed within five working days and 21% took, or will take, more than 15 working days (Figure 9).15

2.9 The Home Office tried to improve the speed and ease in processing applications and to improve the application processes for applicants over time. It did this in three main ways:

Deferring biometrics collection – Prior to Russia’s invasion of Ukraine, the standard process for applying for a visa to the UK required attendance at a visa application centre (VAC) for the applicant to give their biometrics before they came to the UK. These VACs, however, had a finite number of time slots to enrol biometrics and limited the number of applications that could be processed. On 10 March 2022, the Home Secretary announced that attendance at a VAC would no longer be required for Ukrainians with valid international passports. Instead, Ukrainians can apply online, uploading a scan of their passport, and can give their biometrics after they arrive. This meant that staff at VACs across Europe could focus their efforts on helping Ukrainians without passports.

Increasing resourcing levels – at one point the Home Office had moved just over 400 of its staff processing other visa types onto Ukraine schemes as well as bringing in staff from other government departments. It grew from a minimum of 165 staff working on the scheme in March 2022, to over 1,000 by June 2022 working across all the Ukraine schemes. This included 554 officials from HM Revenue & Customs (HMRC) and the Department for Work & Pensions (DWP).

Rolling out new digital systems – the Home Office’s existing digital system for visa processing required several time-consuming workarounds and as a legacy system it could only be used at three Home Office locations, limiting the number of staff who could work cases. On 18 May 2022, the Home Office implemented a new application pathway which allowed for a more digital journey for applicants as, for example, they were able to provide biometric information online rather than having to provide it after they arrived in the UK. It also allowed caseworkers to process cases on laptops, rather than being limited to office space at the three Home Office sites, expanding the numbers that could work on cases.

2.10 These measures did contribute to improved turnaround times initially, with April and May 2022 seeing 95% and 87% of cases processed within 15 working days respectively. Overall, of 182,620 applications received by July 2023, the majority (77%) were processed within 15 working days. However, the turnaround times have largely taken longer since June 2022, and the number of applications which took, or will take, more than 15 working days to process increased from 19% of applications submitted in June 2022 to 63% in July 2023.

2.11 The Home Office told us of several issues that it believes have contributed to slower turnaround times. These include technical changes to the application process, an influx of applications when the Scottish Government announced they would be pausing the super sponsorship scheme and the impact of staff being moved back to other roles. The Home Office also deferred some cases, which caused delays. This was often as they were awaiting policy decisions on areas such as whether to accept unaccompanied minors, what to do with an applicant if their sponsor fails checks or how to manage applications from non-Ukrainians who were living in Ukraine. If deferred cases are excluded, of 135,539 applications received by July 2023, 90% were processed within 15 working days.

Approach to safeguarding

2.12 The profile of Ukrainian people arriving into the UK under the scheme is largely women and children, with 66% of all arrivals female and 30% of all arrivals aged under 18 as of 30 June 2023 (Figure 10).

2.13 The profile of arrivals meant that those arriving on the scheme may be more vulnerable to exploitation or abuse, and DLUHC and the Home Office recognise safeguarding as one of the biggest potential risks in the scheme. The taskforce put in place a Safeguarding Strategic Advisory Board (SSAB) from June 2022 to provide assurance on the scheme’s approach to safeguarding. The SSAB membership included taskforce members as well as individuals from other government departments, arm’s-length bodies and voluntary organisations with an interest in safeguarding issues. The SSAB found that the scheme’s overall approach to mitigating safeguarding issues was well constructed and has strengthened over time.
It identified four key risk areas which the taskforce has subsequently focused its attention on:

modern slavery (including labour exploitation);

violence against women and girls;

child abuse and neglect; and

adults at risk of abuse due to care and support needs.

2.14 The taskforce convened expert panels, made up of taskforce members and individuals from other public bodies or charities with strong experience of safeguarding issues, to investigate these four areas in more detail. These panels concluded that the threat from modern slavery was low and moderate for the other three areas. The panels sought out evidence of safeguarding harms, however, the adult harm and child harm panels found that the data on the risks were limited. In January 2023, the SSAB made 14 recommendations to try to strengthen the controls around safeguarding, all of which were accepted by the taskforce. Common themes in the recommendations were on improving the data available to monitor safeguarding issues where possible and improving or clarifying guidance and communications to those involved in the scheme. The taskforce assessed that it had implemented 10 of these recommendations by July 2023.

2.15 Following checks undertaken at the visa stage, primary responsibility for ensuring the safeguarding of people on the scheme sits with the relevant local authority. They must confirm to DLUHC on the scheme’s main data system that they have conducted the following checks:

Disclosure and Barring Service (DBS) check on the sponsor and other residents aged 18 or over in the household.16

Accommodation checks – both the existence of the accommodation and its suitability.

Welfare checks – in-person check once the guest has arrived.

Safeguarding – confirmation of the completion of the other checks above.

2.16 One of the key decisions taken early in the scheme was to allow the Home Office to approve visas before local authorities might have completed all their safeguarding and accommodation checks on the sponsor. This was acknowledged as presenting a potential safeguarding risk but one that was seen as tolerable given the desire to get Ukrainians out of Ukraine and away from dangerous situations as quickly as possible. Local authority checks do need to be completed before tariff payments are issued, and DLUHC expects them to be completed as soon as possible. DLUHC does not hold accurate data on how often guests arrived before all checks were completed or how long it took local authorities to complete their checks. DLUHC told us that it did not seek to collect data on the number of checks completed before guest arrivals as the policy allowed for visas to be issued before checks were complete.

2.17 Some local authorities told us this ordering of checks presented problems for them if the visa was issued only for them to conclude that the sponsor was not suitable as a result of failing one of the checks listed above. Data recorded by local authorities on DLUHC’s main data system show that out of around 66,000 checks completed by September 2023, 2,516 safeguarding checks have been failed. DLUHC told us not all of these will be due to a safeguarding issue as, for example, some local authorities record failures if a sponsor withdrew from the application. It does not know the true number of safeguarding checks that were failed. While the Home Office, working with Border Force, will seek to identify those individuals arriving into the UK where a safeguarding check has been failed, there have been a small number of instances where individuals have arrived and the local authority has had to move them into temporary accommodation as a result. Local authorities have recorded 282 households (less than 1% of total households), as of 5 September 2023, that have been successfully rematched due to safeguarding concerns in their previous accommodation.

2.18 While local authorities were broadly supportive of the scheme’s aims from the outset there was some concern about early communications and guidance provided to them, particularly around these checks. Some local authorities told us that they would have preferred much more prescriptive guidance from DLUHC about what was expected through the accommodation checks and that the guidance has been updated on several occasions to add clarity. DLUHC told us that there were some statutory requirements on accommodation checks already in place and that it wanted to give local authorities freedom to use their own expertise and experience in inspecting properties. Local authorities also told us they were unclear how Home Office checks, conducted as part of the visa process, interacted with the checks they were conducting.

Unaccompanied minors

2.19 At the outset of the scheme, the rules forbade unaccompanied minors matching with sponsors and travelling to the UK.17,18 However, by May 2022, the Home Office had received around 1,000 applications from unaccompanied minors that it chose to defer making a decision on rather than rejecting. There were also cases where Ukrainian parents were bringing their children to the UK having found a sponsor, and then leaving their children with that sponsor in the UK to allow them to return to Ukraine.

2.20 In recognition of this demand for unaccompanied minors to be included in the scheme, the government changed the scheme rules in June 2022 to create a recognised pathway for unaccompanied minors to travel under the scheme. Applications opened for the pathway in July 2022. Acknowledging that this created additional safeguarding concerns, the taskforce mandated that all local authority checks would have to be carried out before the visa application was approved and recorded on the scheme’s main data system. Additionally, the sponsor and any other household members aged 18 or over would have to undergo an enhanced DBS check. As of 22 September 2023, 356 unaccompanied minors19 were currently on the scheme, and 182 were on the scheme but have since turned 18.

12 If arrivals under the super sponsor pathway are included, Scotland and Wales have the largest concentration of Ukrainian arrivals per population across the UK with 462 and 224 per 100,000 population respectively. Arrivals under the super sponsor pathway are not included in Figure 8.

13 When discussing the time taken to process a visa, this is referring to the time taken to make a decision on the application, for example the decision to accept or reject a visa. This does not include applications which have been withdrawn, including those where an applicant has applied more than once and only one of their applications is considered.

14 The 15-day processing time target only applies to straightforward cases, as is standard practice for other visa routes. Data used for the analysis in this section includes deferred cases which would not be subject to the target (see paragraph 2.11).

15 As of 11 September 2023, there are 14 applications that are still unresolved from March 2022. In our analysis we have categorised these as “more than 15 working days”.

16 For sponsors for adult arrivals on the scheme, local authorities are expected to undertake Basic DBS checks. These contain details of convictions and conditional cautions that are considered to be unspent under the terms of the Rehabilitation of Offenders Act (ROA) 1974. Some local authorities also chose to undertake Enhanced DBS checks for sponsors for adult arrivals. These contain details of spent and unspent convictions, cautions, reprimands and warnings that are held on the Police National Computer may also contain non-conviction information supplied by relevant police forces. Enhanced DBS checks were required for sponsors for minors arriving on the scheme.

17 An unaccompanied minor is defined as a child who is not travelling with or joining their parent or legal guardian.

18 DLUHC decided not to allow unaccompanied minors under the scheme with agreement from the Ukrainian Government.

19 The 356 unaccompanied minors currently on the scheme comprises 223 who applied via the Homes for Ukraine eligible minors route and 133 who were re-classified after their arrival in the UK as, for example, they had been left in the UK with a sponsor because their parent had subsequently left the country.

Part Three

Scheme funding

3.1 This part of the report looks at the central government funding that has been provided for the Homes for Ukraine scheme (the scheme).

Total scheme funding

3.2 Total central government funding for the scheme was £2.1 billion by the end of September 2023 (Figure 11). The Department for Levelling Up, Housing & Communities (DLUHC) has provided £1.9 billion of funding for the scheme, of which the majority (£1.1 billion) has gone to local authorities as tariff funding. This is the funding that is provided to local authorities for each Ukrainian on the scheme with the expectation that the money is used to support them in their first year in the UK. This was initially set at £10,500 per Ukrainian, although that was reduced to £5,900 for all arrivals after 31 December 2022.20 DLUHC estimates that with new arrivals in 2023-24 it will spend a further £140 million on tariff funding for local authorities.

3.3 DLUHC told us that the initial tariff funding of £10,500 was determined following considerations of the costs involved for local authorities, and to provide parity with what is given to local authorities hosting Afghans through the Afghan Citizens Resettlement Scheme (ACRS). However, tariff funding for Homes for Ukraine, a temporary resettlement scheme, is a one-off payment whereas ACRS, which is a permanent resettlement scheme, has funding attached to it in years two and three (£6,000 and £4,020 respectively).

3.4 DLUHC produced an indicative assessment of how the £10,500 might be used by local authorities but did not share this with them as it wanted to give local authorities freedom to spend the money however they saw best (Figure 12). Instead, it published grant determination letters and guidance which set out categories that it expected the funding to be used on, such as safeguarding checks, homelessness assistance and community integration. Local authorities that we spoke to generally told us that they appreciated this freedom and did not generally cite concerns over lack of guidance as to what to spend the money on. Local authorities were more concerned over the lack of clarity on whether further funding would be provided. Some local authorities told us that as a result they have not spent all the tariff funding they were given, choosing to hold amounts in reserve in case of further pressures arising.

3.5 DLUHC did not initially mandate that local authorities had to report back on how they were spending the tariff funding. In 2022-23, local authorities were not reporting back such information consistently to DLUHC, which meant it did not have much visibility as to how the funding was being used. For 2023-24 DLUHC has mandated local authorities provide information on how they have used tariff funds. It took the decision to reduce the funding to £5,900 before it started mandating this information from local authorities but said that the main reason for reducing the funding was because it felt that many of the initial start-up and administrative costs would no longer be incurred. It also told us that the reduction factored in its estimate that around 15% of Ukrainians have left sponsorship and, for example, returned to Ukraine or moved into the private rental sector. DLUHC’s indicative areas of spend of the £10,500 tariff initially contained £3,181 labelled as discretionary spend and this has been reduced to nil in the revised £5,900 tariff (see Figure 12).

Thank you payments

3.6 By end of March 2023, DLUHC spent £100 million on thank you payments, the payments made to sponsors to recognise their role in providing accommodation to Ukrainians. When the scheme was launched in March 2022, these payments were set at £350 per month, with one payment per sponsor household, regardless of how many Ukrainians were staying with them. In recognition of the cost-of-living pressures and to incentivise sponsors to continue in their role, DLUHC announced in December 2022 that this amount would increase to £500 per month once Ukrainian guests have been in the country for 12 months or more. Based on current forecasts, DLUHC estimates it will spend a further £177 million on thank you payments up to the end of 2025-26.21

3.7 Government does not incur regular accommodation costs under this scheme because sponsors provide the accommodation. The thank you payments acknowledge the generosity of sponsors who have provided accommodation and support to guests. In the business case for the scheme, the taskforce assessed that this made the accommodation costs of the scheme much better value for money than those of recent resettlement schemes that have incurred significant ‘bridging accommodation’ costs where refugees are initially accommodated in hotels and other forms of temporary accommodation ahead of finding permanent accommodation with local authorities. Thank you payments equate to costs of £6 per person per night (£8 once increased to £500 after 12 months) compared with £98 per person per night for Afghans being hosted in hotels.22 This calculation, however, does not factor in additional funding that is available under both schemes, for example, funding that has been given to local authorities through the Local Authority Housing Fund (LAHF) (£500 million) and for homelessness prevention (£150 million) (see paragraph 4.16).

3.8 The biggest fraud risk that officials identified with the scheme is that sponsors claim thank you payments that they are no longer entitled to because the Ukrainian guests are no longer living at their accommodation. Responsibility for detecting fraud lies with the local authorities, with DLUHC guidance recommending at least one in-person check at the six-month mark to check that the guests are still living with the sponsor, although this is not mandatory and not all local authorities run this check on every sponsorship arrangement. Based on the checks they have conducted, local authorities report low levels of fraud and error, with data between December 2022 and March 2023 suggesting that just 0.003% of thank you payments were fraudulently claimed and a further 0.8% claimed in error. The Cross Government Complex Grants Advice Panel recommended monthly declarations by local authorities that Ukrainian guests are still living with the sponsor but DLUHC elected not to proceed with this control so as not to overburden local authorities. DLUHC told us that through engagement with local authorities, it found many have robust counter-fraud practices in place which are tailored to the local area.

Official Development Assistance

3.9 £1.1 billion of scheme funding, up to the end of March 2023, is estimated to count as Official Development Assistance (ODA) with DLUHC estimating that £880 million of its funding counts as ODA (see Figure 11).23 This spend counts towards the UK government target of ODA expenditure, which is currently set at 0.5% of gross national income.24 DLUHC has had to assess what proportion of the tariff spend by local authorities was ODA expenditure. For example, spend on fraud checks would not count whereas spend on adult social care would count. It initially assessed that 69% of all tariff spend would count as ODA expenditure. Following advice from the Foreign, Commonwealth & Development Office (FCDO) and wider guidance on ODA, DLUHC has reduced its estimate of the percentage of qualifying ODA expenditure to 53%.

Digital funding

3.10 At the outset of the scheme, DLUHC identified a need to share data between itself, the Home Office and local authorities, including data on the subsequent movement of Ukrainian’s post-arrival. DLUHC chose to take up an offer from a company called Palantir to use its data system on a pro-bono basis for the first six months, with Palantir waiving an estimated fee of £3.25 million. This agreement did not contain any obligations that would have locked DLUHC into working with Palantir beyond the first six months. DLUHC told us that this decision was because of the pace at which it intended to launch the scheme, with Palantir able to help establish the data system in nine days.

3.11 In September 2022, following the end of the six-month free trial period, DLUHC directly awarded a 12-month contract to Palantir worth £4.5 million, excluding VAT. DLUHC justified this as in the first six months of the scheme it did not have sufficient time and resources to develop a new data system while implementing Palantir’s system. It said it had invested time training local authorities in how to use it and in meeting changing user requirements at local level. DLUHC stated that if it removed Palantir’s system at that point, it would create safeguarding risks and significant disruption for DLUHC and local authorities as they had no alternative, secure system which could replace it.

3.12 DLUHC officials sought and received ministerial approval for this approach. DLUHC officials acknowledged that the department should plan to move away from Palantir given the cost of the contract, which was perceived to be higher than other possible solutions. In February 2023, the Government’s Chief Commercial Officer wrote to Palantir noting his concern about the practice of offering services to public sector customers for a zero or nominal cost to gain a commercial foothold, contrary to the principles of public procurement which usually require open competition. This advice was copied to senior digital and procurement officials in government alongside confirmation that free trial contracts should be avoided by government customers and only used in exceptional circumstances. In May 2023, DLUHC acknowledged that while it had not met its obligations under Public Contract Regulations in directly awarding the contract in September 2022, this was justified based on the continuing need to have a digital system to support the scheme.

3.13 In early 2023, DLUHC investigated the feasibility of migrating away from Palantir’s system prior to the end of the 12-month contract, which expired in September 2023. It found that migrating to a new system would be challenging as it would either require a long-term commitment from DLUHC to create and maintain its own system or it would have to incur new costs as a consequence of migrating data to a new commercial off-the-shelf system, which may not be able to be implemented in time and may have unknown quality issues. DLUHC noted that if a new system was not implemented in time, this may present a risk to the unaccompanied minors scheme and wider safeguarding processes. Given these challenges, in September 2023, DLUHC extended the contract with Palantir for a further 12 months, valued at £5.5 million, excluding VAT. DLUHC will need to decide how it proceeds after that point as the scheme will still be ongoing in September 2024.

3.14 The initial arrangement was put in place to help get the scheme up and running quickly. Consequently, the system did not undergo the usual research and testing that would be involved for the roll-out of a new digital system. There were initial issues such as the way it presented duplicated application data received from Home Office systems, and confusion from local authorities as to how to engage with the main data system. DLUHC also only mandated that local authorities provide data on the outcomes of safeguarding checks, with other data on scheme outcomes voluntary. Many local authorities therefore chose to only report on what was mandatory and developed their own processes for managing voluntary data rather than using DLUHC’s system to provide the information DLUHC hoped to receive. Consequently, DLUHC recognise that data on an issue like rematching, which is not mandatory for local authorities to submit if the rematch occurs within the same local authority, does not provide a complete and accurate picture of where Ukrainian people on the scheme are now living. While DLUHC has improved the platform and resolved many of its early issues following local authority feedback, it does not plan to mandate that local authorities provide more data at this stage, as it considers that the administrative burden this would impose on local authorities would be disproportionate.

20 The exception to this is for unaccompanied minors arriving under the scheme, where year-one tariff funding has been kept at £10,500.

21 This forecast does not account for any new arrivals after March 2024.

22 The Homes for Ukraine scheme differs from resettlement schemes, such as the Afghan Citizens Resettlement Scheme, as they are aimed at different cohorts with different demands. The Homes for Ukraine scheme is also intended only for temporary sanctuary, rather than permanent resettlement.

23 In line with government guidance, the Department for Education has estimated that all of its £171 million of grant funding for education and childcare services in England counts as ODA, as shown in Figure 11.

24 ODA is measured on a calendar year basis, therefore the spend up to March 2023 is split across both 2022 and 2023.

Part Four

Future of the scheme

4.1 This part of the report looks at future risks and challenges in the Homes for Ukraine scheme (the scheme) that will need to be managed and how government is addressing them. These include: future decisions on permission to remain after the initial three-year visa periods end; the future operation of the scheme for new applications; providing suitable housing for people on the scheme and preventing homelessness; scheme governance and resourcing going forward; and learning gained from the scheme.

Future decisions on visas

4.2 Scheme visas are valid for up to three years, meaning that the first people to arrive under the scheme will see their visas expire in March 2025. Funding and targeted support for those earlier arrivals will end before this point unless the government chooses to extend it: Local authorities receive tariff funding in the first year after the guest’s arrival only, and hosts can receive thank you payments for a maximum of two years. In comparison, under the Syrian Vulnerable Persons Resettlement Scheme, which ran until 2021 and was designed for permanent resettlement rather than temporary safety, central government provided funding to local authorities for five years. Under the Afghan Citizens Resettlement Scheme and Afghan relocation and assistance policy, it provides funding to local authorities for three years. The Department for Levelling Up, Housing & Communities’ (DLUHC’s) work to learn lessons from previous resettlement schemes indicated that cohorts of resettled people are likely to have longer-term needs that extend beyond their first year or two in their host country.25 Some local authorities told us that consequently they have chosen to hold some of their tariff funding in reserve to meet these potential future needs (see paragraph 3.4).

4.3 The government told us it is considering any future need for an extension, and any new operational processes it might need as a result. It is conscious of the wishes of the Ukrainian Government to support Ukrainians to return there when it is safe to do so to help rebuild the nation. To avoid unintended consequences, such as creating perverse incentives for people to migrate between host countries, the design of the UK’s future policy in this area, and the timing of changes, will also need to take into account the approaches taken by other host countries.

4.4 Many Ukrainians in the UK would find more certainty helpful as they try to map out their future. Local authorities have reported to DLUHC some cases of individuals being turned down by employers and educational establishments due to the length of their visas. According to an Office for National Statistics (ONS) survey conducted between April and May 2023, 52% of Ukrainians in the UK say that they would like to continue to live in the UK, even when they feel it is safe to return to the Ukraine. Of those who did not know where they intended to live (19%), the most common reason, given by 60% of those who are unsure, is wanting greater clarity on visa options for staying in the UK.26

Future scale of the scheme

4.5 The scheme is uncapped, so the number of future arrivals will depend on how many potential hosts volunteer, how many Ukrainians wish to seek sanctuary in the UK, and the effectiveness of the host-guest matching process. Demand from Ukrainians for the scheme has been steadily declining but future demand may rise or fall depending on the course of the war in Ukraine. The Home Office estimates, for planning purposes, that between 12 June 2023 and 31 March 2024, around 20,000 people may arrive in the UK under the scheme.

4.6 DLUHC accepts that the supply of potential sponsors has diminished since the scheme first launched and that it has a role to play in trying to ensure there are sufficient sponsors in the future. According to an ONS survey in November 2022, those who have acted as sponsors have generally had a positive view of how the scheme has been managed. Just over half, 53%, said they were either fairly satisfied or very satisfied with the scheme management compared with only 27% fairly dissatisfied or very dissatisfied.27

4.7 In July 2022, DLUHC officials raised concerns with the Minister for Refugees that the existing sponsor pool was insufficient to meet the demand required, particularly as existing sponsorship arrangements come to an end and many guests seek a rematch. DLUHC used a mix of communications activity to raise awareness of the scheme and then to communicate the need to recruit additional hosts, including two paid-for social media campaigns. Local authorities and voluntary sector organisations also recruit their own potential sponsors. As at July 2023, DLUHC assessed that there remained a medium risk that a shortage of sponsors would occur.

4.8 In addition to potential new applications, as of 28 August 2023, there were around 38,000 Ukrainians who have been issued visas under the scheme but have not yet travelled to the UK. A further 40,000 people who had previously arrived in the UK under the scheme and the Ukraine Family Scheme were currently outside the UK as of 12 June 2023. The government does not know how many of this group have permanently left the UK. These Ukrainians therefore have the right to travel to the UK immediately should they wish to.

Providing suitable housing

4.9 Due to the incomplete data that DLUHC receives from local authorities (see paragraph 3.14) it relies on other data sources to understand where Ukrainians who arrived under the scheme are now living. ONS survey data from February–March 2023 suggests that around half of Ukrainians who arrived in the UK under the scheme in its first three months of operation are still living with their original host (Figure 13). Of those first arrivals, 34% reported that they were renting, either through a private landlord (28%) or through some other provider such as a housing association (6%). A further 11% have been re-matched and moved into accommodation provided by their new host and 4% reported living in temporary or emergency accommodation provided by the council.

4.10 UK sponsors were asked initially to provide accommodation for a minimum of six months only. In November 2022, 63% of sponsors intended for their hosting arrangement to end in one year or less. DLUHC acknowledges there will need to be other housing solutions available. It has a target to support 60% of Ukrainians leaving sponsorship into independent accommodation. As at 12 September 2023, that figure was 44% (Figure 1). It has not clarified whether it expects people on the scheme to have moved out of their accommodation with sponsors by the end of the second year; it expects them to stay but does not intend to continue making thank you payments; or whether it will extend thank you payments into the third year. Local authorities told us that when sponsorships end, many Ukrainians will struggle to move on to other homes in their local authority due to high house and rental prices in the areas where sponsors typically live.

Homelessness

4.11 The taskforce acknowledged the risk of homelessness under the scheme from its inception. As a sponsorship scheme like this had not happened before, DLUHC did not know how many people might become homeless. DLUHC’s initial planning assumption was that 50% of sponsorships could breakdown, leading to homelessness. The indicative costings of the initial tariff funding to local authorities assumed just over £1,000 per Ukrainian on the scheme could be used for dealing with homelessness as a result, although this detail was not shared with local authorities (see Figure 12 in Part Three).

4.12 DLUHC does not accurately know how many people on the scheme are likely to become homeless soon or have already experienced homelessness. DLUHC receives incomplete data returns from local authorities on homelessness but believes it is sufficient to track trends and respond accordingly with policy interventions. Around 30% of English local authorities regularly fail to provide homelessness data on the scheme to DLUHC. The data that are available show that:

between 24 February 2022 and 31 August 2023, 4,890 households in England on Homes for Ukraine visas have at some point been homeless or came within 56 days of being homeless (Figure 14). This equates to 8% of the 65,117 groups in England to have arrived under the scheme. The data do not show for how long people on the scheme were at risk of homelessness or experienced homelessness, nor how many people on the scheme are currently affected; and

since the start of 2023, at any one time, roughly 600 to 800 Ukrainian households (whether on Homes for Ukraine visas or resident in the UK through a different path) have been living in temporary accommodation in England.

An ONS survey in spring 2023, of people on the scheme who arrived before 15 June 2022, suggested that 4% of people in this group were living in temporary or emergency accommodation provided by the council or did not have anywhere to live.

Local authority actions

4.13 Should their housing situation break down, people on the scheme will fall within the statutory homelessness services run by local authorities. The local authorities we spoke to described a range of actions they have taken to protect people on the scheme in their area from homelessness using their tariff funding (Figure 15). This included topping up thank you payments in 2022 to encourage hosts to continue arrangements, before government took the decision to increase these to £500 per month for Ukrainians in the country for more than 12 months.

4.14 In some cases, local authorities will seek to prevent homelessness by rematching guests with new hosts. Central government allowed local authorities to make re-matches from May 2022, and it has since become an increasingly important part of the scheme. Local authorities often work with the support of the voluntary and community sector to facilitate these rematches. One of the scheme’s key performance indicators is that 80% of guests who ask for a rematch from their local authority are successfully rematched. In September 2023, 72% of requests for rematches up to that month had been successfully achieved.

Central government actions

4.15 In addition to encouraging rematching, from late summer 2022, as the first sponsorship arrangements approached the six-month mark, the taskforce started preparing interventions to mitigate the risk of high or overwhelming demand for homelessness services. Analysis at that point suggested that unless further interventions were put in place to support rehousing of Ukrainians once their sponsorships end, up to 20,000 households (43,000 individuals) may need temporary or emergency accommodation by 2027 at a total cost of £1 billion (also by 2027).

4.16 In December 2022, DLUHC announced a total of £650 million of funding for local authorities across two funds to assist with homelessness, including those at risk in the Homes for Ukraine scheme, which they must spend by the end of March 2024:

The ‘Local Authority Housing Fund’: £500 million of capital funding, allocated based on the number of Ukrainian arrivals per local authority and wider local housing pressures. Local authorities are expected to use it to obtain and refurbish property, to provide sustainable housing for people who are in England under the Afghan or Ukraine schemes and are unable to secure their own accommodation.28 DLUHC expects local authorities to obtain 3,365 homes with the funding, with up to 2,880 of those being used to house Ukrainians.29 As of 8 August 2023, 905 homes have been acquired, of which 93 are occupied.

£150 million to help prevent homelessness, to be distributed to local authorities across the UK. 30 Local authorities can use it for a wide range of actions to support Ukrainians into sustainable accommodation, including to support them to access the private rented sector, for employment support, to pay for temporary accommodation, and to encourage hosts to continue to house their guests.

4.17 The taskforce also developed contingency plans to help local authorities to procure emergency accommodation, such as hotels, should standard homelessness services be overwhelmed by the number of people on the scheme presenting as homeless in winter 2022-23. It did not need to use this emergency measure.

Scheme governance and resourcing going forward

4.18 Both DLUHC and the Home Office are conscious of the need to stay flexible enough to scale up the scheme again should the conflict in Ukraine escalate, while using their resources efficiently given the number of people arriving is currently low. Both departments have reduced the number of full-time-equivalent (FTE) staff working on the scheme. At the end of 2022, DLUHC had 161 FTE working on the scheme. By the end of March 2024, it is aiming to reduce the number of staff working on the scheme and other resettlement routes to 100. The Home Office reduced the number of people processing visas even more significantly, down from more than 1,000 in June 2022 to 110 as of September 2023. From May to July 2023, visa processing times were often longer than the targets the Home Office had set, with 57% of applications submitted in those months meeting the target of 15 working days.31

4.19 The scheme was originally run by a standalone taskforce team, made up of Home Office and DLUHC officials, which worked only on this scheme and reported directly into the DLUHC Executive Team (see paragraph 1.10). In April 2023, the taskforce became part of DLUHC’s Social Housing and Resettlement Directorate, within the ‘Regeneration portfolio’. The Home Office is still represented on the scheme’s programme board, other governance groups and has its own Ukraine Strategy and Escalation board. The Social Housing and Resettlement Directorate has a broader role, including management of the Hong Kong British National (Overseas) scheme and working with the Home Office on providing suitable accommodation for those coming to the UK through the Afghan schemes.32

Learning from the scheme

4.20 Stakeholders we have spoken to are generally positive about the scheme and want lessons to be learnt for potential future refugee crises. Ministers confirmed in July 2023 that government is considering whether it is possible to create a comparable scheme for housing Afghan refugees.

4.21 In early 2023, DLUHC carried out an exercise to identify the lessons of the scheme’s sponsorship model. It made recommendations to government on the running of the current scheme, and on the design of any future emergency sponsorship schemes. DLUHC is also developing a ‘playbook’, drawing primarily on the lessons from Homes for Ukraine, to aid officials in future to design any future emergency sponsorship schemes.

4.22 DLUHC has not yet decided whether to carry out an evaluation of the scheme. It originally planned a process-focused evaluation, which it intended to complete by autumn 2023, but it paused work on this in spring 2023. It now expects to decide on whether to commission an evaluation, and what its focus would be, in late 2023.

25 The Homes for Ukraine scheme is not a resettlement scheme, providing only temporary sanctuary, and therefore is different from other schemes such as the Afghan Citizens Resettlement Scheme.

26 Office for National Statistics, Visa holders entering the UK under the Ukraine Humanitarian Schemes: 27 April to 15 May 2023, 7 July 2023. Available at: www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/internationalmigration/bulletins/visaholdersenteringtheukundertheukrainehumanitarianschemes/27aprilto15may2023

27 Office for National Statistics, Experiences of Homes for Ukraine scheme sponsors – follow-up, UK: 21 to 28 November 2022, 16 December 2022. Available at: www.ons.gov.uk/peoplepopulationandcommunity/populationandmigration/internationalmigration/bulletins/experiencesofhomesforukraineschemesponsorsuk/21to28november2022

28 Housing is a devolved matter, and the budget for the Local Authority Housing Fund comes from DLUHC underspends on England-only activity, therefore the Local Authority Housing Fund is England-only.

29 DLUHC expects £131 million of the funding to be spent to obtain 485 larger properties, with at least four bedrooms, to accommodate Afghan families currently living in ‘bridging accommodation’ such as hotel rooms.

30 The £150 million was distributed between all nations of the UK in proportion to their number of Homes for Ukraine arrivals. The UK government allocated £109 million of the total to local authorities in England; this was delivered via a top-up to the existing Homelessness Prevention Grant. In the devolved nations funding was transferred to the Scottish and Welsh Governments and the Northern Ireland Executive to distribute.

31 This 57% figure is excluding applications which have been deferred as the Home Office target of 15 days to process only applies to straightforward cases, as is standard practice for other visa routes. Between May to July 2023, 46% of the 10,700 applications submitted were deferred, not including those withdrawn.

32 The Hong Kong British National (Overseas) scheme is a resettlement route available to people from Hong Kong who have British National (Overseas) status and their close family members. The visas issued under the scheme permit them to come to live in the UK for up to five years. They can then apply for permanent settlement.

Appendix One

Our investigative approach

Scope

1 By 28 August 2023, 131,000 Ukrainians had arrived in the UK under the scheme. The scheme has been jointly run by the Department for Levelling Up, Housing and Communities (DLUHC) and the Home Office, who established a joint taskforce in March 2022. The Home Office has primarily led on operational matters relating to the processing of visas while DLUHC has led on all aspects of the scheme from the point of arrival of Ukrainians into the UK, working closely with local authorities and devolved governments.

2 Our scope was:

to examine how the scheme was set up at speed;

to bring transparency around the total funding commitments made through the scheme; and

to look at the risks and challenges that need to be managed as the scheme moves forward.

3 The scheme is not the only route into the UK for Ukrainians seeking to escape the war. A Ukraine Family visa scheme was launched on 4 March 2022 to enable Ukrainians to join family members in the UK. Additionally, the Ukraine Extension Scheme was created to enable Ukrainians who held temporary permission to be in the UK to extend their stay. There had been 111,800 visa applications under the Family scheme and 24,800 applications under the Extension scheme as at 29 August 2023, meaning both have been much smaller in scale than the Homes for Ukraine scheme. Neither scheme have received any significant public funding, with no tariff funding or thank you payments applicable under them. As such, neither of these two routes are within the scope of this audit.

4 This investigation does not seek to examine and report on value for money. Our findings were based on analysis of evidence we collected between May and October 2023.

Methods

5 In examining these issues, we drew on a variety of evidence sources including interviews, data analysis and document review.

Interviews

6 We undertook 29 interviews with 17 different organisations, and a roundtable interview with a further nine organisations. We used information from these interviews to build our understanding of the relevant topics and to inform further interview and document requests and follow-up questions. Interviewees were often identified by the organisations themselves and were selected based on the fit between their job role and expertise and the focus of each interview.

7 Almost all our interviews were conducted virtually using Microsoft Teams. We did not record the interviews. We took a note of each interview.

8 We interviewed key individuals from DLUHC and the Home Office to establish how the scheme was set up and managed. These interviews covered: visa processing, scheme governance, safeguarding, digital systems used for managing the scheme, funding, data collection and monitoring of the scheme and the future of the scheme.

9 We also interviewed representatives from 10 local authorities. We used sampling criteria to select which local authorities we would interview out of the 374 local authorities in total. These criteria were:

regional spread – We selected one local authority from each of the nine English regions, as well as one from Scotland, and one from Wales. We tried to contact two local authorities in the West Midlands but did not hear back. This meant we were not able to include that region in our sample;

number of people on the scheme per 100,000 people in a local authority – We chose local authorities which represented a range of those with the highest proportion of people on the scheme per 100,000 in a region, and those with a lesser rate;

geographic area – We chose local authorities which differed by dominant geography and whether most of the area is urban or rural; and

types of local authority – Local authorities are divided into: Non-metropolitan District, London Borough, Metropolitan District, Unitary Authority, and Council Area. In our sample we have selected a range of local authorities that cover each of these areas.

10 The local authorities we met with were:

Buckinghamshire Council

South Cambridgeshire District Council

Monmouthshire County Council

Sunderland City Council

Derbyshire Dales District Council

South Hams District Council

Hull City Council

Angus Council

Preston City Council

Camden Council.

11 The topics covered in interviews with local authorities included: creation of the scheme, ongoing relationship with DLUHC, funding, homelessness and the checks conducted by local authorities. We also met with the Local Government Association and the Convention of Scottish Local Authorities to further understand the views of local authorities, and to ensure our findings from the 10 interviews were reflective of local authorities’ views across the UK.

12 We conducted a roundtable interview with nine Voluntary and Community Sector (VCS) organisations, some of which are recognised providers. We used information from these discussions to inform our interviews and data requests with DLUHC and the Home Office, and to understand and report on the set-up and management of the scheme. The VCS who attended were:

Citizens UK

Sanctuary Foundation

Love Bristol

Opora

Refugees at Home

Reset UK

St John of God Hospitaller Services

The Pickwell Foundation

Ukraine Sponsorship Pathway UK (USPUK).

13 We also carried out interviews with the Office for National Statistics (ONS) to understand its survey data on sponsors and arrivals on the scheme, and the Association of Ukrainians in Great Britain to understand its views on: the background of the scheme, how it was managed by DLUHC and the Home Office, and the opinions of Ukrainians on the scheme.

14 Audit Wales are currently conducting an audit looking at how the Welsh Government is supporting Ukrainian refugees, with a particular focus on the Welsh Government’s Super Sponsor scheme. We have engaged with Audit Wales to share details about our respective work, and other relevant information which we have gathered over the course of our studies. Audit Wales are due to report in Winter 2023-24.

Document review

15 We reviewed more than 300 documents which were provided by DLUHC, the Home Office, ONS and the Local Government Association. These included:

governance documents such as programme board and cross-government meeting papers and minutes;

relevant business cases, including for the scheme and for the Local Authority Housing Fund;

documentation on scheme governance and management;

briefings for ministers on the scheme, including on policy decisions for the design of the scheme, requirements for visa processing and on the unaccompanied minors route;

published guidance for the scheme, including guidance for applicants and sponsors;

documentation on visa processing by the Home Office including capacity of the teams and the checks required; and

monitoring data dashboards on arrivals to the scheme and homelessness.

Data analysis

16 We analysed a range of data provided by DLUHC and the Home Office, and published data including:

data on applications and arrivals on the scheme, which allowed us to understand the scale of the scheme, and to detail when arrivals moved to the UK and where in the UK their sponsors lived;

data on visa processing times, which allowed us to determine how long people were having to wait for a response on their visa applications;

survey data from the ONS, which allowed us to understand the opinions and outcomes of Ukrainians and sponsors on the scheme;

homelessness data, which allowed us to understand the risk and likelihood of homelessness on the scheme; and

funding data, which allowed us to assess how much had been spent on the scheme so far.

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