startnewlife Mendee CIC · London

Personal Housing Plan (PHP)

Updated: 2 May 2026
In short

Personal Housing Plan (s.189A Housing Act 1996, in force from 3 April 2018) = a written document the council MUST draw up with every eligible applicant. Must contain steps for the council (not just for you) and be regularly reviewed. PHP is the strongest practical tool against the council. Reviewable under s.202(1)(ba)/(bb).

What is a PHP

PHP = a written document the council prepares with you after the s.189A assessment. It's a roadmap for preventing/relieving homelessness.

Trigger: the council must provide an assessment as soon as it accepts an application for prevention or relief duty. The PHP is the final artefact of that assessment.

What must be in the PHP (s.189A(4)–(6))

1. Steps for the applicant

Steps you must take. Must be reasonable in light of housing market, your resources, circumstances.

2. Steps for the authority

Steps the council MUST take. If the PHP has no steps for the council, it's a breach. The council can't dump all the work on you.

3. Mandatory vs recommended

PHP must clearly distinguish mandatory steps (required — failure can lead to s.193B notice) and recommended (advisable, not required).

4. Written + given to you

No oral discussions. No «you'll get letters along the way». A WRITTEN document, copy in your hands.

5. Kept under review (s.189A(9))

If circumstances change (got work, lost work, baby born, health worsened, evicted from current home), the plan is updated.

Agreement (s.189A(7))

The council must «try to agree» the PHP with you. If agreement isn't reached:

  • Council must record reasons why no agreement
  • Give you a copy of their proposal + your proposals

«We discussed it orally» = unlawful. Must be a written record.

Common failures (LGSCO patterns)

No PHP issued at all or issued months late
Only applicant steps, the box for authority steps is empty or boilerplate («we will provide advice»)
Generic copy-paste PHPs ignoring assessment findings
Not reviewed when duty changes (prevention → relief → main) or circumstances change
Unrealistic steps — e.g. PRS search at LHA in central London where no such housing exists
Verbal only — no written copy
No translation / accessible format for non-English speakers, disabled — breach of Equality Act 2010 reasonable adjustments + PSED s.149
s.193B notice for non-cooperation when applicant didn't understand / didn't agree to the steps
⚠️ s.193B notice — what it is and how to defend

If the council considers you have «deliberately and unreasonably refused to cooperate», it can issue a s.193B notice → ends prevention/relief duty (and in non-priority cases, main duty doesn't arise at all).

Defences (s.193B(4)–(7)):

  • There must be a prior written warning identifying the conduct + explaining the consequences
  • Reasonable period to comply after the warning
  • Council must consider your particular circumstances and needs
  • Notice — in writing with reasons
  • Right to s.202 review

If the PHP was unreasonable / never properly agreed, the s.193B notice cannot be lawful. Strong basis for review.

How to challenge a poor PHP

  1. Request a written revision under s.189A(9) — name the specific changed circumstance or unreasonable step
  2. Stage 1 corporate complaint — exhaust both stages
  3. LGSCO complaint after exhaustion. Tariff: £150-500 for PHP failures
  4. s.202 review: PHP steps directly reviewable under s.202(1)(ba) (s.195(2) prevention) and s.202(1)(bb) (s.189B(2) relief). Also any decision ending duty including s.193B notice
  5. s.204 County Court appeal on a point of law within 21 days of review decision
  6. Judicial review in High Court — only route to challenge the assessment OR PHP itself outside the s.202 catalogue (e.g. failure to produce PHP at all). 3-month longstop.
🛂 For Ukraine Scheme and other refugees

Some councils mistakenly treat Ukraine Scheme guests as «rematched» rather than homeless. You are entitled to a full s.189A assessment + PHP from day one. Same for all eligible immigration statuses.

📚 Norton v Haringey [2025] EWCA Civ 746

Court of Appeal confirmed: s.189A creates an imperative duty to assess + produce a PHP. Failure is unlawful. Recent case — strong argument in any review / complaint in 2026.

Frequently asked questions

What must a PHP contain?

Steps for the applicant AND steps for the council (s.189A(4)–(6)). Mandatory steps (required) vs recommended (advisable). PHP must be in writing, agreed with you, regularly reviewed.

No PHP issued — what to do?

Stage 1 complaint (corporate complaints). LGSCO regularly awards £150-500 for PHP failures. Also — s.202(1)(ba)/(bb) review of the steps in prevention/relief duty.

PHP contains unrealistic steps — what to do?

Request a revision (s.189A(9)). If the council refuses, s.202(1)(ba)/(bb) review. Example: «find PRS housing» in an area where there's no rental at LHA — unrealistic.

What if the council threatens an s.193B notice for «non-cooperation»?

There must be a prior written warning + reasonable period to comply (s.193B(4)–(7)). The notice must address your particular circumstances. You can s.202(1)(bb) review the notice itself.

I don't speak English — must they translate?

Equality Act 2010 + Code Ch 1+11 — reasonable adjustments. Translation / interpreter / accessible format are required. They cannot demand that you bring your own interpreter.

Sources: legislation.gov.uk · Housing Act 1996 s.189Alegislation.gov.uk · Housing Act 1996 s.193Bgov.uk · Code Ch 11 (PHP)Shelter · Personal Housing PlansNearly Legal · Cascading unlawfulness Updated 24 Apr 2026
⚠️ StartNewLife is an information project — not regulated by the IAA (Immigration Advice Authority). We do not provide immigration advice within the meaning of Section 84 of the Immigration & Asylum Act 1999. All content is general information only and does not replace advice from a regulated lawyer (IAA / SRA / BSB) about your specific case.