- Second report into illegal children’s homes by Children’s Commissioner shows one year on, vulnerable children are still being housed in caravans, holiday camps or AirBnBs – some for as long as three years
- Number of illegal placements costing £1 million per child rises, despite these settings being unable to provide safety or care – at an estimated total cost of £353 million to the taxpayer
- Most children placed in illegal homes have mental health or additional educational needs – more than half have Education, Health and Care Plans
- “This is what failure looks like”: Children’s Commissioner calls for specialist foster care, more children’s homes and a new focus for reforming children’s social care
More than half of children housed illegally by councils have Education, Health and Care Plans, new data from the Children’s Commissioner confirms – as the number of illegal placements costing more than £1 million per child has risen since last year.
One year on from the Commissioner’s first report into local authorities’ use of illegal homes – including AirBnBs, holiday camps and caravans – to accommodate children in care, data shows very little has changed: on 1st September this year, there were 669 children living in illegal homes, down from 764 on the same day last year.
Nearly 60% of these children have complex additional needs or disabilities requiring an Education, Health and Care Plan (EHCP), meaning they likely also receive support from other services beyond social care, while more than one third (36%) are receiving support from child and adolescent mental health services (CAMHS).
Of the 669 children placed illegally, 89 have been living in the same illegal placement for more than one year. While most are over 15, there are some children of pre-school age growing up in illegal children’s homes.
The average duration of these illegal placements is a little over six months. One child was at put in a holiday camp for nearly nine months, another was in a caravan for more than four months and a handful of children remained in an illegal home for more than three years.
The average weekly cost of a placement was more than £10,000 – the equivalent to more than half a million pounds over the course of a year. In total councils across England have spent an estimated £353 million on illegal children’s homes in 2025, of which 36 placements had already cost £1 million each by 1st September.
Today’s data underscores the crisis in children’s social care, with children – many extremely vulnerable or with complex needs – placed in poor quality placements at an exorbitant cost to taxpayers.
Children’s Commissioner Dame Rachel de Souza said:
“This 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.
“I have deep concerns about how frequently these illegal placements are used, 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 highlights some really shocking additional details about the needs and circumstances of the children affected.
“Instead of spending such huge sums on costly crisis care, we should instead be investing in models of children’s social care that prioritise intervening earlier in their lives, keeping children closer to loved ones and ensuring they have stability and support.
“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.”
Today’s report, using the Commissioner’s statutory powers, showed settings – are overwhelmingly run by private providers (89%). They include unregistered children’s homes, council owned or rented houses or apartments, supported accommodation, AirBnBs, holiday camps or activity centres, hospitals or caravans. Most children (61%) were placed in accommodation outside of their local authority, while 39% of placements were within the responsible local authority boundary.
Data from all 153 local authorities in England confirmed:
- Child demographics: The majority of children in illegal children’s homes were older teens – with 51% aged 16 and 17, 46% aged 10 to 15, and the remaining 3.1% being under 10. More than half (56%) were boys.
- Additional needs and vulnerabilities: Three in five children (59%) in illegal children’s homes had an Education, Health and Care Plan (EHCP), and a further 9.7% had special educational needs and/or disabilities without an EHCP. One third (36%) were being supported by CAMHS, with a further 7% on a waiting list for CAMHS support.
- Length of placement: The average length of placement was 184 days – a little over six months – but there was a high level of variation. A small number of placements lasted more than three years. Some extreme examples included a child placed at a ‘holiday camp/activity centre’ for almost nine months and another child in a caravan for more than four months.
- Children at risk: Nearly a third of children (30%) went missing at least once from their placement – known as ‘missing episodes’. By comparison, missing incidents were reported for just 11% of all looked after children in 2025.
- Cost of placements: The average weekly cost of illegal children’s home placements was about £10,500 – a small reduction of 5.7% from over £11,100 last year. While placement costs varied, 36 children were in placements costing more than £1 million each as of 1st September – and the total estimated annual cost to the taxpayer over the course of the year was more than £353 million.
The Commissioner’s own Help at Hand advice and support service has stepped in to help many children in precarious living arrangements. These children are often highly vulnerable with complex needs or disabilities.
Today’s report also confirmed that the proportion of children in illegal children’s homes subject to a Deprivation of Liberty (DoL) court order (32%) was similar to that of last year (31%). Children on a DoL have significant and complex needs , and a court has authorised for their liberty to be restricted – and yet even with this high level of need they are still being placed in illegal homes, often as no registered home will take them.
Children on DoLs are more likely to be girls and tended to have even higher levels of need than other children, with higher numbers of children on a DoL having an EHCP or being in receipt of CAMHS support.
The government’s Children’s Wellbeing and Schools Bill sets out enforcement powers for Ofsted to issue civil penalties against providers of illegal children’s homes, as well as introducing new forms of accommodation designed for children who may be deprived of liberty through amendments to section 25 of the Children Act – but these measures are not yet in force.
The Children’s Commissioner has repeatedly warned about the need for change to the children’s social care system at scale and pace and today’s data adds urgency to her calls for change. Recommendations include:
- Sufficient specialist homes for children who have the highest levels of need, jointly funded by the Department for Education, the Department of Health and Social Care, and the Ministry of Justice, and commissioned through strengthened Regional Care Cooperatives so every child can be placed in a home that meets their needs.
- More foster care and therapeutic homes so no child is left at risk in inappropriate accommodation simply because there is no other option for them. This must include a fully-funded national foster carer recruitment and retention plan, expanded in-house children’s homes – including therapeutic and secure provision – and swift implementation of a cap on excessive profit making in children’s social care.
- Stronger enforcement against illegal children’s homes, giving Ofsted civil penalty powers and ensuring local authorities are held to account through tougher inspections, rapid notifications and clear disincentives to use unregistered settings except in absolute emergencies
- Improving national data and oversight, including by recording every episode of a children’s Deprivation of Liberty (DoL) and ensuring that applications for a DoL order trigger automatic notification, legal representation, regular judicial review, and access to advocacy.
- A clear legal and regulatory framework for welfare-based deprivation of liberty, backed by statutory guidance that defines when restrictions are necessary, safeguards children’s rights and ensures consistent protection wherever a child is placed.
- Delivering wider system reform, including a digital Children’s Plan for every child whatever their needs, a unified inspection framework across children’s services, stable long-term funding, and a cross-sector workforce strategy to ensure all the professionals working with a child can provide high-quality, joined-up support.
