Commonweal report sheds light on illegal, unregistered Children’s Homes

Commonweal Housing has published a report, written by researchers at Public First, investigating the growing use of unregistered children’s homes in the UK, and the drivers for their increased use. It has been covered in the Guardian here.

A webinar about the report and unregistered children’s homes is being hosted on the 21^st of May at 10am. Please register here.

Hidden Children.pdf

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We commissioned the research after hearing concerns about decommissioned supported housing facilities being put to use as unregistered (and therefore illegal) residential children’s care homes.

The use of illegal Children’s Homes has grown enormously, and is poorly understood:

• Cases of unregistered children’s homes (UCH) rose by more than 370% between 2020/21 and 2024/25.

• Some individual placements are costing up to £40,000 per week.

• Senior practitioners describe unregistered placements moving from something they might see “once every six months” to something that crosses their desk “at least once a week”. These cases tend to involve extremely vulnerable children with complex needs.

Researchers spoke to frontline key workers, Directors of Children’s Services, and sector experts as part of the study. A local authority typically uses an illegal home when lawful options are not available fast enough. Growth in their use has correlated with three long-term trends:

• Rising complexity - children more likely to be involved with gangs, county lines, serious violence, exploitation, or experience severe mental health crises. Many have been through the criminal justice and health sectors, or experienced breakdowns at home or in foster placements.

• Shortage of specialist, secure, supported placements for those who pose/face serious risks.

• Poor market incentives; providers fear taking high-risk children will destabilise existing homes and damage Ofsted ratings. Many would rather leave beds empty than accept a teenager linked to gangs, repeatedly going missing, or presenting extreme behaviour.

When homes give 28 days’ notice, or when children must leave a paediatric ward at short notice, councils may resort to organisations or placements operating outside the law. Even if they provide good-quality care, they are invisible to national regulators.

Practically, these settings may comprise a small local authority-staffed unit in a council house. Improvised arrangements are also common - children have been placed in Airbnbs, holiday lets, hotels or apartments, supervised by agency staff who may have minimal training. 2:1 staffing ratios are common, as many of the affected children are high-risk. The problem is not that every unregistered home is bad. It is that the system cannot reliably tell the difference.

These arrangements are usually described as short term - something to get through the weekend or the next few weeks - but many last far longer: on average around six months, but some can last years. Costs of £20,000 per week per child are not unusual. Sometimes it may be twice this.

The Government is taking this seriously. It has outlined several measures to improve the regulation and commissioning for children’s placements, and to remove barriers to creating affordable provision. Other measures, however, may miss the mark. Increasing Ofsted’s powers to fine unregistered providers, for example, are well intentioned. But this is not an enforcement problem. It could even make the problem harder to identify. Treating this as a compliance issue misses the wider context: a children’s social care system that is financially and operationally stretched to breaking point, with the most extreme cases absorbing extraordinary sums and risk.

While writing this report, researchers detected an uneasy professional climate. Many expressed considerable uncertainty about the legality of (and the legal responsibility for) these practices. This, matched with profound systemic pressures, has created a perverse situation in which well-meaning practitioners engage in potentially harmful commissioning about which they cannot speak with frankness and transparently. Frankness and transparency are, however, the only ways to address this problem constructively.

Responding to unregistered homes demands a change in tone from the top of the system. Ministers and regulators must be constructive and empathetic, and recognise that assigning blame for individual decisions taken under extreme pressure is neither practical nor – ultimately – in the best interests of children.

Summary of recommendations

• Improve national data collection on unregistered placements, using shared datasets between Ofsted and local authorities

• Separate the registration of providers from the registration of physical locations

• Enable Ofsted to recognise relevant CQC-registered placements to avoid duplicative regulation

• Amend Regulation 44 processes to remove perverse incentives that discourage placements from accepting high-needs children

• Strengthen the role of Regional Care Cooperatives in commissioning high-cost, low-frequency placements

• Issue national guidance to local authorities encouraging them to assess the advantages and disadvantages of sequential sourcing where children have complex needs or urgent timelines

• Explore partnerships with Housing Associations to increase safe, emergency accommodation capacity

The report can be accessed HERE.

A webinar about the report and unregistered children’s homes is being hosted on the 21^st of May at 10am. Please register here.