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Housing policy is a devolved matter and some divergent approaches to homelessness are emerging. All four nations have legislated to introduce a legal duty to secure accommodation for certain homeless applicants but the type of applicant covered and assistance offered differs in each of the nations.

In Scotland there is now a statutory duty on local authorities to find permanent accommodation for all applicants who are unintentionally homeless or threatened with homelessness.

Wales has placed a statutory duty on local authorities to prevent homelessness for people threatened with homelessness, and to help to secure accommodation for all applicants assessed as homeless for a period of 56 days (this is known as the homelessness relief duty). After this period local authorities must secure accommodation for those households deemed to be unintentionally homeless and in priority need.

In Northern Ireland, the duty on the Northern Ireland Housing Executive (NIHE) is to secure accommodation for homeless households (and those threatened with homelessness) who are unintentionally homeless and in priority need. This is also the position in England, although the duty lies with local authorities. The Homelessness Reduction Act 2017 came into force in England on 3 April 2018, meaning that authorities now have new prevention and relief duties along the same lines as those in operation in Wales.

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