Currently, HAP limits are insufficient to access private rented accommodation for many on low incomes. It fails to provide security of tenure and cannot meet the needs of people who want to live with a sense of security regarding their long-term accommodation need. The HAP limits were last reviewed in July 2016 while the national average rent has increased 45% between then and Q1 2022.
Threshold welcomed the increase to the discretionary rate which can be paid by the Local Authorities and the increase of the single person’s rate to that of couples, in July 2022. Nevertheless, an increase of the HAP base rates is still necessary to ensure all people can access housing, from which they can build a home, a sustainable life and live with dignity.
While there may be concern that increasing the HAP limits could potentially create an increase in the rental floor resulting in rent increases for all tenants, the rent certainty measures, the Rent Pressure Zone (RPZ) legislation and the new inspection and sanction regime of the RTB can help prevent such unintended consequences. Continuing to keep the HAP limits low does not keep de facto rents low, it simply masks the problem, as tenants simply must find the additional money. Government policy is in effect pushing some households into debt and rent arrears. This can ultimately put private renters at risk of homelessness. This too can have an impact on landlords who may be struggling to pay a mortgage, creating a distrust of HAP and possibly cause landlords who experience difficulties with HAP to leave the market.
Threshold supports the ESRI’s recommendation to link the HAP rates to the rents on new tenancies in the relevant Local Authority (Low Income Renters and Housing Supports (2022), https://www.esri.ie/system/files/publications/RS141_1.pdf). This is proposed to ensure affordability and that a share of rental properties is available within the limits, for those reliant on HAP. As highlighted in the ESRI’s report, an incredibly small proportion of homes advertised for rent fall within the HAP limits.
In addition, Threshold recommends a review of HAP and its interaction with the private rented sector to determine the next steps for HAP, given the changing landscape of housing and renting in Ireland, particularly since HAP was first introduced. The length of time to process applications, the payment of rent from the date the application is processed as opposed to the date the tenancy commenced, the payment of rent in arrears, and the non-payment of a deposit all need to be addressed to reflect the realities of the private rental market. The roll out of an information and awareness raising campaign to educate landlords on HAP and the equality legislation is recommended. An investigation into landlord and agent refusal to accept HAP should also be included in a review of HAP.