Today Public First publishes Hidden Children: An investigation into Unregistered Children’s Homes. Commissioned by Commonweal Housing, the report examines the growing use of illegal, unregistered care placements within England’s social care system.
The report finds that hundreds of children in care – often those with the most complex and acute needs – are now living in unregistered placements that sit entirely outside Ofsted’s regulatory framework. These placements are unlawful and often leave children in wholly inappropriate settings like hotels, holiday lets and other improvised accommodation supervised by minimally trained staff, yet are increasingly used as a routine response to systemic pressures.
Confirmed cases of unregistered homes have risen by more than 370% since 2020/21, but data remains incomplete and heavily reliant on voluntary reporting. Snapshot data from the Children’s Commissioner suggests hundreds of children are in such placements on any given day, indicating that official figures significantly understate the true scale.
The research combines a rapid review of existing evidence with testimony from interviews with policymakers, practitioners and sector experts.
We found three key pressures driving this trend: the rising complexity of need; shortages of suitable specialist provision for high-risk children; and market and regulatory incentives that discourage providers from accepting the most complex cases. These pressures force local authorities into a stark choice: place a child in an illegal but staffed setting, or leave them in a police cell, hospital ward or unsafe environment. In many cases, the unavailability of places means authorities are left compelled to break the law to keep children safe.
Often intended as short-term solutions, placements last on average around six months, with some extending beyond a year. Costs can range from £20,000 to £40,000 per week per child, placing significant additional pressure on already stretched local authority budgets.
The report argues that current policy responses focusing primarily on enforcement are unlikely to resolve the issue and that unregistered homes should be understood not simply as a compliance failure, but as a structural feature of a system that lacks sufficient capacity and flexibility.
The report recommends:
- Improving national data collection on unregistered placements, using shared datasets between Ofsted and local authorities.
- Separating the registration of providers from the registration of physical locations.
- Amending certain regulations to remove perverse incentives that discourage placements from accepting high-needs children.
- Exploring partnerships with Housing Associations to increase safe, emergency accommodation capacity.
This report represents one of the first comprehensive attempts to document and analyse the use of unregistered children’s homes in England. It is intended as a starting point for further research and reform, with the ultimate aim of ensuring that no child is placed beyond the reach of oversight, accountability and care.
Download the full report here.