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Last year, for the first time, I shone a light on children placed in illegal homes – isolated, left without appropriate care, and often at increased risk of harm. These so-called ‘homes’ include caravans, holiday rentals, or AirBnBs, usually under the ownership of private companies with no formal inspection or scrutiny.

That first report showed there were hundreds of children living in these illegal homes. Now, 12 months on, too little has changed.

Data gathered by my team shows as of 1st September 2025 hundreds of children in care are still being housed illegally by local authorities. If it were simply a numbers game, this report might offer a glimmer of hope: on that day, there were 669 children in illegal homes, a decrease from 764 last year.

But the costs of these placements remain staggeringly high, with an average weekly cost of £10,500. Over the past 12 months, councils have spent an estimated £353 million putting some of the country’s most vulnerable children in settings that cannot come close to meeting their needs. In some cases, they put them at increased risk of harm.

Not only does this data throw up deep concerns at the continued prevalence of these placements – despite it already being against the law, as well as a focus of the government’s Children’s Wellbeing and Schools Bill, currently moving through Parliament – it also highlights some really shocking additional details.

Some of the children were also included among the data last year. That means not only were they living in deeply inappropriate, illegal settings 12 months ago, but they were still there on 1st September this year. It means that within that time, no one at the local authority responsible for their care had found a legal, safe solution for their care – either because none were available, or because no one had tried hard enough.

That is what failure looks like in children’s services: when a lack of good options is what dictates the quality of care given to a child with complex needs. It is indicative of wide failings across an entire system that there are any children at all in these unregistered homes, much less hundreds. There have been attempts to fix separate parts of this system in disjointed ways: we have reduced the number of children in youth custody, moved disabled children out of institutions, and made efforts to avoid children being admitted to inpatient facilities – all important, with some measure of success, but ultimately resulting in children being shunted into different places, including these illegal homes. 

There is also alarming evidence of other worrying trends in this year’s data. More children this year than last year are in illegal placements that had each already cost more than £1 million by 1st September. These ‘million-pound children’ are not only receiving a deeply concerning form of care, but their placements represent a huge expense that could have instead been spent on earlier intervention, keeping them closer to loved ones and ensuring stability in their lives.

The use of holiday camps and activity centres to accommodate children illegally has also risen from last year, putting children in placements with minimal facilities. And unchanged from last year, the majority of placements are still outside the child’s home local authority, placing them far from family and support services.

Last year, my report showed that though most children in illegal homes are older teenagers, some pre-school age children were included in the figures. Shockingly, this remains the case a year on.

Using my statutory data powers to collect this information is essential to identify the scale of the problem. But through the work of my own Help at Hand advocacy service, I am already keenly aware of the day-to-day impact this has on children, through the children my team speak to in precarious living arrangements. Far too frequently my team are required to step in to support to a child who has been placed in an unregistered placement as an emergency or crisis measure. This report includes examples of these, as well as examples of children left in illegal placements for lengthy periods, or moved from one place to another without any improvement in their circumstances.

One girl, Summer, was moved between four different homes in six months before being placed in an illegal children’s home, surrounded by staff who spoke limited English, without facilities to wash and left to support herself with meals and finances as though she were an adult.

Another, Amelia, whose increasingly destructive behaviour made it impossible for her to live at home with her parents, has lived in every kind of illegal placement: caravans, hotels and rented holiday accommodation. Unsurprisingly, none have helped her with her behaviours.

In the year since I published my first report on the use of illegal children’s homes, there have been some notable opportunities for change. Primarily, the Children’s Wellbeing and Schools Bill introduced to Parliament shortly after that first publication in December 2024, includes important measures that – if successful – will strengthen oversight, including new enforcement powers for Ofsted to issue civil penalties against providers operating unregistered children’s homes. It also amends Section 25 of the Children Act to create new forms of accommodation where children can be deprived of liberty when necessary to keep them safe. However, these provisions are not yet in force – and there remains a need for clarity over how swiftly they will bring about change, as well as a question over whether a fine will act as sufficient deterrent to force multi-million-pound private companies to change their business practices.

Moreover, children will continue to be placed in settings that lack proper oversight and fail to meet their needs if no other options are available to local authorities. Children’s social care needs robust investment in models of early intervention and therapeutic support, instead of relying on costly crisis placements. That means a plan for recruiting specialist foster carers, rapidly increasing the number of high-quality children’s homes and better join-up between services including a commissioning strategy that considers children with high or complex needs who require the support of multiple services

Without these things, children will continue being failed.

The evidence set out in this set of data shows paints a stark picture – but finding long-term solutions for a group of children this size should be eminently possible. It requires ambition for their futures and a system designed to keep these children with their families, or in alternatives capable of providing genuine care and love – not simply moving them from one unacceptable form of institution to another. It will require a fundamental shift in how we think about risk – and what that means in a vulnerable child’s life. We can no longer pretend that locking child in a flat under constant observation, or putting them in a caravan without proper facilities, is the ‘risk averse’ option. It is deeply risky, deeply harmful and cannot continue.

These 669 children must be the bellwether for the whole system. Getting it right for them will mean getting it right for all children in care.