Liam Herrick

The commission warns that the proposed amendments fundamentally change Ireland’s homelessness framework by making access to emergency accommodation dependent not only on whether a person is homeless, but also on meeting residency conditions that currently apply to social housing.

IHREC is concerned that the changes could leave vulnerable people without emergency accommodation, increase rough sleeping and disproportionately affect groups already at heightened risk of homelessness.

Chief commissioner Liam Herrick said: “Emergency accommodation exists to protect people from the immediate dangers of homelessness. These amendments risk creating a situation where someone can be recognised as homeless but still be refused a bed because they do not satisfy residency requirements. That represents a significant departure from the long-standing approach to homelessness in Ireland.”

He continued: “The commission is deeply concerned that these proposed amendments could have a disproportionate impact on people who are already among the most vulnerable in our society. Victims of trafficking, victims of domestic, sexual and gender-based violence, members of Traveller and Roma communities, migrants, people leaving institutional care or hospital, and families with children may all face significant difficulties in proving lawful or habitual residence, even where they are in urgent need of accommodation. Any changes to the law must ensure that people experiencing or at risk of homelessness are not faced with additional barriers to accessing the support they need.”

The commission also raises concerns that the proposed appeal mechanism is limited and may not meet fair procedure requirements, noting that appeals would not apply to initial refusals of emergency accommodation based on residency status. IHREC also raised concerns about the Bill being rushed with little time for engagement through the legislative process.