IHREC said that the proposed measures are likely to result in more people being denied access to social housing assistance and could have particularly severe consequences for victims of trafficking, people who have experienced domestic and gender-based violence, migrant communities, and other vulnerable groups.

Furthermore, the bill would place lawful residence and habitual residence requirements on all adult members of a household seeking social housing support.

According to the commission, the proposed provisions could lead to entire households being denied assistance because of the residency status of one member of that household. The commission has raised concerns that this may amount to a disproportionate interference with private and family life and may be incompatible with Ireland’s obligations under European and international human rights law.

Liam Herrick said: “The practical effect of these proposals could be that vulnerable individuals and families are locked out of social housing support altogether. We are particularly concerned that people who are already facing significant barriers, including victims of trafficking and survivors of domestic violence, may find themselves with nowhere to turn except emergency homeless services.”

The commission also warned that the introduction of a habitual residence condition into social housing law risks replicating problems long identified in the social welfare system, where such requirements have had a disproportionate impact on Traveller and Roma communities, migrants, people experiencing homelessness and victims of violence.

As Ireland’s Independent National Rapporteur on Trafficking in Human Beings, the commission expressed particular concern that the bill contains no exemption for victims of human trafficking. This is despite strengthened obligations under the revised EU Anti-Trafficking Directive, which must be transposed into Irish law next month.

Mr Herrick added: “Victims of trafficking are among the most vulnerable people in our society. Safe and secure accommodation is often the first step towards recovery and protection from further exploitation. It is deeply concerning that the bill, as currently drafted, fails to provide clear safeguards to ensure these victims can access the housing supports they need.”

IHREC called on the government to introduce exemptions or discretionary provisions to ensure that victims of trafficking and victims of domestic, sexual and gender-based violence are not excluded from accessing social housing support.

The commission also highlighted concerns regarding access to emergency accommodation and warned of the need to clarify in the legislation that residency requirements do not apply to applications for homeless services.

In addition, the commission has raised significant concerns regarding the appeals framework established under the bill, including the short 14-day timeframe for lodging appeals, the absence of provision for oral hearings, and the lack of measures to ensure access to legal advice, interpretation and translation services.