It has been six months since the UK announced its initial response to the humanitarian crisis in Ukraine, allowing those affected by the outbreak of conflict to arrive or remain in the UK under visa-based immigration routes. Three routes were made available:

• The Ukraine Family Scheme, launched 4 March, for those wanting to join or remain with family in the UK;
• The Homes for Ukraine Scheme, launched 18 March, for those wanting to join a sponsor in the UK who could host them for at least six months;
• The Ukraine Extension Scheme, launched 3 May, for those already in the UK with limited leave to remain, who needed to extend their leave.

These visas grant three years limited leave to remain, with the right to work and access to public funds, including mainstream homelessness assistance.

Since the schemes launched, over 134,200 Ukrainians have arrived (as of 4 October 2022), and many more are likely to follow as the conflict continues into the winter months. The response from the legal profession has been overwhelming, with hundreds of immigration lawyers volunteering with the Ukraine Advice Project.

However, real-life case studies and a new report published by the Work Rights Centre, based on survey data with Ukrainians, have found that urgent action is required to prevent parts of the Ukrainian community from homelessness and related hardship. In Scotland and Wales, there were government-backed “super sponsor” schemes which provide a more consistent guarantee of housing to some. But research from JustRight Scotland shows that even within these schemes there is systemic housing instability and a bottleneck where arrivals are unable to move on into independent housing. In England, no similar provision has been attempted.

The Ukraine Schemes to date

According to the latest Home Office statistics, published on 27 September, a total of 219,500 Ukraine scheme visa applications have been received. Of these, 188,700 visas have been granted: 52,800 under the Ukraine Family Scheme and 135,900 under the Homes for Ukraine Scheme. The Homes for Ukraine Scheme is by far the most popular avenue taken by Ukrainians arriving in the UK.

In-country extension applications via the Ukraine Extension Scheme and in-country Ukraine Family Scheme applications are recorded separately. A total of 25,000 applications have been received, with 18,800 granted and a further 5,100 applications awaiting a decision. The approval rates under the respective schemes have generally been high, albeit extension applications have lagged slightly behind new arrivals to the UK.

For immigration lawyers, it may be striking how few Ukrainians have made formal asylum claims from within the UK. Between January and June 2022 only 310 asylum applications were registered for Ukrainians and only 91 after the launch of the Ukraine Extension Scheme on 3 May. Given that no renewal or extension route has yet been announced for Ukraine Scheme visas, it may be that more Ukrainians should be considering claiming asylum, taking into account the latest Home Office Country Policy and Information Notes on Ukraine.

Homelessness: the big issue

The Ukraine scheme visas can last for three years, but no housing has been put in place to match that period of leave to remain. This has created a cliff edge for homelessness.

Under the Homes for Ukraine Scheme, the initial six-month hosting deadline has come to an end for the first cohort of arrivals, and many sponsors are unable or unwilling to continue their current arrangements. The government’s recent plea for more sponsors to come forward has also had little success. Statistics indicate that for those sponsors who initially wanted to host Ukrainian guests for six months, 23% are planning not to continue hosting arrangements. This is perhaps unsurprising. The £350/month “thank you payments” for sponsors do not vary with the size of Ukrainian families hosted and are not objectively connected to the costs of hosting. Since the scheme launched, increases in energy costs, inflation, and the cost of living more generally have further eroded the value of the payments.

A key factor underpinning the vulnerability of Ukrainians who arrived under this scheme is that it was never intended to create formal tenancy rights. Without status as tenants, individuals have no formal protection from eviction, even during the initial six months of hosting they were offered. Indeed, 5% of Homes for Ukraine survey respondents in the Work Rights Centre report were at imminent risk of eviction, and 11% were living in overcrowded conditions.

The risks of homelessness are even more acute for Ukrainians who arrived under the Ukraine Family Scheme. Family members do not receive any support payments and visas can be granted with no guarantee of housing. Among the Work Rights Centre survey respondents, almost half (47%) of those who had status under the Ukraine Family Scheme reported living in overcrowded accommodation, and 13% reported being threatened with eviction.

The concern around homelessness is now also evident in the government’s official statistics. In the period from 3 June to 26 August, there was a 137% increase in the number of homeless Ukrainian households, with the number jumping from 660 to 1565 households in a matter of months. And the latest statistics worryingly suggest that as many as 69% (or 1080 households) included dependent children.

The picture for Homes for Ukraine visa holders in Scotland or Wales with a government-backed “super sponsor” offer is more positive because housing of some kind is guaranteed. However, the JustRight Scotland report shows that there is a risk of long-term stay in hotels, a lack of quality control, issues of overcrowding and additional needs not being met. Hundreds of Ukrainians in Scotland are being housed on cruise ships where many rooms have no access to natural light. People in Scotland also reported being dispersed to local authorities on a no-choice basis, which could take them away from family and the community that has become important to their integration.

The government lacks a plan for mitigating the risk of homelessness

Many Ukrainian arrivals are making their way independently. And many more might be able to with some initial support to get started. The six-month housing cliff edge for people living with hosts could have been mitigated if people had the right support to prepare for it.

The Work Rights Centre report found that councils have the option to assist Ukrainian families facing homelessness, with host mediation, rematching, temporary accommodation, or offers of settled accommodation. However, many local authorities struggled to offer any settled accommodation at all, relying instead on pleas to sponsors to continue hosting, or on temporary accommodation. And this requires families, who have already been displaced by conflict, to again present to their local council as homeless on the day of their eviction. Even then, they will often only be offered temporary accommodation of a very basic kind, potentially away from their local area. Families lose the community they have been integrating into, and children are forced to move schools yet again. Leaving housing planning until Ukrainian visa holders become homeless causes massive unnecessary distress.

The Guidance for Local Councils is unhelpfully vague. Refugees at Home, a charity involved in Ukrainian-host matching, recently scaled back its role in rematching, noting that the process is “too bureaucratic”, and that ”there’s no mechanism for one local authority to talk to another”.

People arriving from Ukraine who cannot find housing themselves need access to intensive, front-loaded casework. The current sponsor guidance asks sponsors to “consider hosting their guests for as long as you can”. If Ukrainians have not found their own housing, the guidance encourages sponsors to assist them in finding new hosts. The kind of housing planning needed, requires professional input, involving proactive support, understanding rights and housing options, and developing a realistic and managed plan. Significantly, there is currently no process to support Ukrainians into independent privately rented accommodation.

Ukrainians need support to transition to the private rental sector

A worrying 71% of Ukrainians who responded to the Work Rights Centre survey had very little or little confidence in their ability to rent a property in the private sector if they had to do so within a month. A total of 70% of respondents referred to the high cost of renting, and 40% also referred to unaffordable deposits. It should be obvious that it is not realistic to expect people who have arrived from a conflict zone, without accessible savings or references, to obtain a private tenancy.

The government can prevent homelessness and improve refugee integration

In the short term, practical measures are required to discourage evictions, and manage homelessness. Although not exhaustive, this could include harmonising and improving payments under the Ukraine schemes. The one-off payments to guests and thank you payments to hosts under the Homes for Ukraine Scheme should be extended to the Ukraine Family Scheme. It should also be adjusted with the cost of living and the size of refugee families. Using the flexibility of local government funding to support refugees into the private rental sector could be achieved by piloting deposit guarantee schemes, and by allowing Ukrainians to transfer the £350 thank you payments from sponsors to prospective landlords.

The government also needs a long-term refugee integration strategy. This is not a new concept. In 2017, the All-Party Parliamentary Group on Refugees recommended that the government should develop a “National Refugee Integration” strategy that would apply to all refugees in the UK. In fact, Scotland has already implemented the “New Scots” strategy, which focuses on allowing refugees and asylum seekers to “rebuild their lives from the day they arrive”.

Keeping open the Ukraine visa schemes

The need to safeguard arrivals and provide a proper programme of support does not undermine the importance of the Ukraine visa schemes. Since these visa schemes launched, they have offered a lifeline to thousands. The fact that Ukrainians arrive with a visa grant already in place goes a considerable way towards promoting independence and allowing visa applicants to make an informed choice about their future.

Local authorities only have access to a certain amount of temporary housing at a time, and the housing issues in the UK are not unique. For example, Poland has taken in more than two million Ukrainian refugees and has seen an impact on the housing markets as a result, including an increase in rent prices. Shortcomings in the housing and integration aspects of the Ukraine visa schemes should not detract from the learning this scheme offers by modelling a “safe and legal route” for refugees to reach the UK.

Conclusion

As we write this, a Ukrainian family is likely anxiously waiting for a response from the local authority’s homelessness team. Another is breathing a sigh of relief after narrowly avoiding eviction. Many more are likely looking to escape Ukraine, as the Russian invasion shows no sign of abating. What is certain, is that the UK government cannot respond to a humanitarian crisis by relying upon the goodwill of sponsors alone. We need urgent action to avoid homelessness this winter, and a real strategy to address the long-term needs of those fleeing to the UK. Without it, there is a risk that the government and local authorities will be dealing with these same pressure points again and again.

The Work Rights Centre report: “Six months on” evaluates the UK’s response to the humanitarian crisis in Ukraine, and how the government can better protect refugees moving forward. JustRight Scotland’s ‘Reflections on the Ukraine Scheme in Scotland’ explores feedback and recommendations from Ukrainians arriving in Scotland.

This article was co-authored by Dora-Olivia Vicol (CEO) and Adis Sehic (Policy and Research Officer) who lead on research at the Work Rights Centre, a charity dedicated to helping migrants exit precarious employment, secure their immigration status, and improve their social mobility more generally.