Guidance

Guidance on Replacement Properties

Updated 20 May 2026

Applies to England

1. Context: Rough Sleeping Accommodation Programme

1.1. The Rough Sleeping Accommodation Programme (RSAP) launched in 2020 and was established to provide high‑quality ‘move‑on’ accommodation and support for people who are sleeping rough or at risk of returning to rough sleeping. To date, the programme has expanded the housing stock available to local councils across England to support vulnerable people sleeping rough. Through RSAP, councils and Registered Providers have delivered dispersed self-contained homes accompanied by tailored support to help individuals recover from rough sleeping.

2. Purpose of this guidance

2.1. This purpose of this guidance is to assist local councils in managing properties funded through RSAP that were delivered through Homes England or using Section 31 Capital Grant direct from the Ministry of Housing, Communities and Local Government (MHCLG). The guidance sets out expectations on:

• how Replacement Properties should be managed
• when MHCLG needs to be informed
• when Homes England needs to be informed

2.2. The aim is to support local councils and Registered Providers to manage assets confidently and ensure that the use of Capital funded homes continues to align with programme requirements and Homes England contractual agreements.

3. What is a Replacement Property?

3.1. A Replacement Property is when a property funded by RSAP is replaced by another equivalent property because the original can no longer be used for the intended programme purpose.

3.2. Example reasons for requiring a Replacement Property include situations where the property is no longer suitable for the intended cohort or cannot safely meet an individual occupant’s needs. This may happen, for example, if the property becomes associated with serious anti-social behaviour or criminal activity, rendering it unsafe for further use.

3.3. The RSAP prospectus (updated March 2026) outlines at paragraphs 73 and 74 what local councils should do if an instance occurs where a Replacement Property is required.

If an applicant wishes to use units funded via this programme for a purpose other than accommodating the Eligible Cohort, or not in accordance with the parameters set out in this prospectus, the Capital grant should be recycled into an alternative, equivalent property (property swap).

When recycling Capital grant into an alternative property, local councils and Registered Providers should consider this guidance.

4. Advice for managing Replacement Properties

4.1 When identifying a Replacement Property, local councils and Registered Providers should consider a few broad parameters to ensure the new unit remains suitable for the intended cohort and aligned with the purpose of the original investment.

4.2. Parameter 1: Comparability: Replacement Properties should, where possible:

• be as close to like-for-like as possible to the original property in terms of property type (house/flat), property layout, property valuation, self-contained status, number of bedrooms and internal floor area
• retain tenure and occupancy suitability, including affordability at the intended rent level and service charge and the same (or stronger) security of tenure
• meet or exceed quality and safety expectations, such as the Decent Homes Standard
• any differences should be at the benefit of the target cohort (for example, safer layout, better amenity)

4.3. Parameter 2: Location Replacement Properties should be in a suitable location for the client group and at least as compatible with programme objectives as the original. Things to consider include:

• proximity to commissioned support and essential services (health, substance misuse and mental health services). Where support is outreach-based, consider that travel times are practical and safe
• suitability of the neighbourhood and risk management. Where a swap is driven by safety/anti-social behaviour concerns, record how the new location mitigates those risks
• access and connectivity to public transport, shops and community amenities to promote stability and tenancy sustainment
• any significant changes to the location of a property should be at the benefit of the target cohort

4.4. Local councils and Registered Providers should take these considerations for a Replacement Property into account and satisfy themselves that the proposed property still meets the conditions of the Capital grant.

4.5. If there are any queries, local councils and Registered Providers can contact MHCLG at HRSFunding@communities.gov.uk or the Homes England Historical Grants team at Grant_notifications@homesengland.gov.uk for advice.

5. Notification of Replacement Property

5.1. Dependent on the route in which funding was paid, local councils and Registered Providers should notify MHCLG or Homes England of any occurrence of a Replacement Property.

Homes England Capital Funded Units

5.2 Local councils and Registered Providers who received funding via Homes England should notify Homes England of any changes to or disposals of funded properties using the Historical Grant Notification Form within 10 days of the grant liability transferring to the new property.

5.3. Local councils and Registered Providers must complete a Historical Grant Notification Form with details of the original and replacement properties and return to Grant_Notifications@homesengland.gov.uk

5.4. Registered Providers must also show the change of properties on their annual Recycled Capital Grant Fund Return. If a Registered Provider does not currently operate a Recycled Capital Grant Fund pot the Historical Grants Team will provide support in setting one up.

5.6. For further detail see section 3.9 in the Capital Funding Guide Specialist Homes chapter.

Section 31 Grants

5.7. Local councils are responsible for managing Replacement Properties locally, working with providers. Local councils do not need to seek MHCLG approval for a property swap should they be satisfied they have considered the above parameters, but should update MHCLG when an instance occurs at HRSFunding@Communities.gov.uk

5.8. MHCLG keeps a register of RSAP properties funded with Section 31 Capital Grant. To ensure this is kept up to date, Local councils must inform MHCLG of any property swaps within 30 days of the grant liability transferring to the new property, providing the Department with the old and new address of the new property, grant value and grantee details. Notifications should be sent to HRSFunding@communities.gov.uk.

6. Local Record Keeping, Documentation and Audit Trail

6.1. For Section 31 funded units, Local councils should keep adequate records of properties which hold RSAP Capital grant funding.

6.2. Local councils and Registered Providers should keep records of which properties hold RSAP capital grant paid by Homes England up to date.

7. What to do if a Replacement Property cannot be found or I want to dispose of a funded property?

7.1. If an equivalent property cannot be sourced and the funded property is either disposed of or used for another purpose e.g. General Needs, this would trigger a repayment of Capital grant to MHCLG or Homes England.

7.2. For Homes England funded units, providers should contact the Historical Grants team at Grant_notifications@homesengland.gov.uk. Historical Grant Notification Forms must be completed and returned to Grant_notifications@homesengland.gov.uk no less than 10 business days prior to a disposal taking place.

7.3. For Section 31 funded units, local councils should contact HRSFunding@Communities.gov.uk.