Draft guidance for undertaking Gypsy and Traveller accommodation assessments - Chapter 1: introduction

This statutory guidance has been produced to assist local authorities in discharging their duties under Part 3 of the Housing (Wales) Act 2014 (“the 2014 Act”). The guidance is published under section 106 of the 2014 Act. Local authorities must have regard to this guidance when carrying out their functions under Part 3 of the 2014 Act.

Local authorities must undertake a Gypsy and Traveller accommodation assessment (“GTAA”) for each review period and submit it to the Welsh Government for approval. Where the assessment identifies an unmet need for mobile home sites, local authorities must exercise their powers in section 56 of the Mobile Homes (Wales) Act 2013 to provide sites for mobile homes so far as may be necessary to meet those needs.

Local authorities remain under a statutory duty to provide the sites that have been identified as being required in their latest approved GTAA, even where they have submitted a draft assessment to the Welsh Government for the subsequent review period.

It is important for local authorities to understand that the GTAA process is separate to and does not replace their statutory duties to help people who are homeless or at risk of homelessness within their area. Under section 55 of the 2014 Act, a person is homeless if they have accommodation, but it consists of a moveable structure or vehicle designed or adapted for human habitation and there is no place where the person is entitled or permitted both to place it and to reside in it.

The assessment of Gypsy and Traveller accommodation needs, and the duty to make provision for sites where the assessment identifies need, are statutory requirements under section 108 of the 2014 Act.

Section 108 defines “Gypsies and Travellers” as:

1. Persons of a nomadic habit of life, whatever their race or origin, including:
   1. persons who, on grounds only of their own or their family’s or dependant’s educational or health needs or old age, have ceased to travel temporarily or permanently, and
   2. members of an organised group of travelling show people or circus people (whether or not travelling together as such); and
2. All other persons with a cultural tradition of nomadism or of living in a mobile home.

A broad definition is necessary to achieve a full understanding of the accommodation needs of these all those who form a part of these communities.

The intention of the above definition is to ensure ethnic Romani Gypsies and Irish Travellers are included, as well as those from any ethnic group who follow a nomadic way of life. The definition also includes Travelling Showpeople. New Travellers could also be captured by the definition if they can demonstrate a cultural tradition of nomadism and of living in mobile homes.

Members of these communities do not necessarily need to demonstrate a continued nomadic habit of life to be considered to be Gypsies or Travellers for the purposes of this assessment. Gypsies and Travellers living in bricks and mortar housing may want to move to a site in the future, and it will be essential for local authorities to also take their needs into account in GTAAs.

The requirement under the 2014 Act is for local authorities to provide suitable and appropriate mobile home sites to meet the needs of Gypsies and Travellers within their area. Gypsies and Travellers should not be pressured into bricks and mortar because of a lack of available local authority sites.

As of publication of this guidance there is a need for 277 pitches to meet the accommodation needs identified within the latest Cycle 2 GTAAs and each Local authority is required to meet those needs.

This guidance was written in 2025, within the third GTAA cycle. The Cycle 3 GTAA covers the period 2022 to 2027. All Welsh local authorities must submit their Cycle 3 GTAA to the Welsh ministers for approval by 24th February 2027.

Future cycles cover the period:

• 2027 to 2032: local authorities must submit their GTTA by 24 February 2032.
• 2032 to 2037: local authorities must submit their GTTA by 24 February 2037.
• 2037 to 2042: local authorities must submit their GTTA by 24 February 2042.

Gypsies and Travellers are recognised racial groups for the purposes of the Equality Act 2010. The accommodation needs of all Gypsies and Travellers must be identified, understood and addressed through the planning framework and housing strategy on the same basis as other sectors of the community.

The Welsh Government’s Anti-racist Wales Action Plan reflects the importance of culturally appropriate accommodation for Gypsy, Roma and Traveller communities. Its goal is “To recognise that safe, culturally appropriate accommodation is necessary in order for individuals to flourish in other parts of their lives and to address the lack of site provision and poor quality of Gypsy and Traveller accommodation in Wales”. The Welsh Government is committed to ensuring equality of opportunity for all sections of the community and Gypsies and Travellers must have the same access to culturally appropriate, safe and suitable accommodation as all other members of the community.

An understanding of Gypsy and Traveller accommodation issues is essential to enable local authorities to make properly planned accommodation provision for the community and avoid the problems associated with ad hoc or unauthorised encampments. A comprehensive GTAA and a clear strategy to meet the need which has been identified will greatly reduce the risk of unauthorised encampments within a local authority, recognising that unauthorised encampments often occur because of the lack of site provision.

Section 102 of the Housing (Wales) Act 2014 requires local authorities to submit their GTAA reports to the Welsh Ministers for approval. Each report must:

• detail how the assessment was carried out
• contains a summary of both the consultation carried out in connection with the assessment, and the responses (if any) it received to
• detail the accommodation needs identified by the assessment

Section 105 of the Housing (Wales) Act 2014, provision of information upon request:

• A local housing authority must provide the Welsh ministers with such information (and at such times) as they may require in connection with the exercise of their functions under this Part.
• The Welsh ministers may exercise their powers under this section generally or in relation to a particular case.

The Welsh ministers may approve the assessment as submitted, approve the assessment with modifications, or reject the assessment. If a GTAA is rejected, the local authority must either revise and resubmit its assessment for approval or undertake a new assessment.

The Welsh ministers will assess each report to ensure it is robust, complies with each of the requirements of the 2014 Act, shows that the local authority has had due regard to this guidance and that the calculation of needs is evidence based and reached after proper consultation with relevant individuals.

Local authorities must provide Welsh ministers with any information they require in connection with the exercise of their functions under Part 3 of the 2014 Act. The Welsh ministers may ask for such information as they may require generally or in relation to a particular case.

In order to help ensure that the Welsh ministers have all the information they need to approve a GTAA, it is strongly recommended that local authorities submit their full GTAA, together with any other relevant evidence, to demonstrate that the assessment undertaken is vigorous and has accurately identified the accommodation needs of Gypsies and Travellers both residing in and resorting to their area and their plans to address that need.

When providing details of the accommodation needs identified, it is recommended that local authorities provide a breakdown in the form set out in Annex 5. Local authorities must also set out a plan to explain how they intend to address the identified accommodation needs.

Once an assessment has been approved by Welsh ministers, it must be published by the local authority, preferably on their website. It is recommended that local authorities publish the accommodation assessment on their website and provide feedback to the participants in the consultation to ensure they understand how their views have been considered and what the next steps will be.

Gypsies and Travellers will typically form only a very small percentage of the population as identified by the Office for National Statistics in any given area. The known total may not include the members of these communities who declined to self-ascribe their ethnicity for fear of discrimination, stronger affiliation with other ethnicity categories (e.g. White Irish) or for other reasons, though attempts are made by the Office for National Statistics to gain more understanding of these issues.

Gypsies and Travellers may be living in bricks and mortar or on local authority or private mobile home sites. It is imperative local authorities assess the needs of the nomadic population as part of the GTAA process.

Some of those living in bricks and mortar may have moved from living in mobile homes due to the lack of legal alternatives, possibly because the local authority where they reside had not provided enough site accommodation. The GTAA will assess whether individuals or families living in bricks and mortar due to limited alternative provision wish to move back to a local authority site when pitches become available.

The needs identified in the GTAA process should be mainstreamed within the local housing strategy. Under section 107 of the 2014 Act, where a local housing authority is required under section 87 of the Local Government Act 2003 to have a strategy in respect of meeting the accommodation needs of Gypsies and Travellers residing in or resorting to its area, the local housing authority must have regard to the guidance given by the Welsh ministers in preparing its strategy.

A lead agency should be identified to take the GTAA process forward, ensuring key progress targets and milestones are met. This should normally be the local housing authority as the strategic housing body.

The GTAA requires an in-depth Census style survey with both primary and secondary data collection.

A ‘primary’ data collection such as a survey is required to assess the needs of Gypsy and Traveller communities due to their small population size and particular accommodation needs. Using existing statistics (or ‘secondary’ data) alone to assess their accommodation needs would be unlikely to yield results which are statistically robust. This is partially due to the small size of these communities and because very little existing data exists regarding the accommodation requirements of these communities in each local area.

As a result, the GTAA will require a primary survey to be undertaken directly with the Gypsy, Roma and Traveller population (acquired through a census-style approach), in addition to a review of the available existing data. This process will be explained in more detail in Chapter 2.

Section 101 of the 2014 Act expressly requires a local housing authority to consult such persons as they consider appropriate when carrying out an assessment of the accommodation needs of Gypsies and Travellers residing in or resorting to their area. Under section 102, the assessment report must detail how their assessment was carried out and contain a summary of the consultation carried out in connection with the assessment, and the responses received. If the Welsh ministers consider that the local authority has failed to carry out a proper consultation, their assessment may be rejected. It is therefore very important for local authorities to ensure their consultation is thorough and effective.

Local authorities must determine who they consider it is appropriate to consult. This is expected to include the various communities within the scope of the definition of Gypsies and Travellers so that their needs can be properly assessed.

Most local authorities have sought to consult Romani Gypsy and Irish Traveller communities in their area when undertaking GTAAs. However, often this has been restricted to those living on local authority or private sites with planning permission. The needs of those on private sites without planning permission, using unauthorised encampments and those living in bricks and mortar housing must also be assessed through direct consultation, together with those who resort to the local authority area.

In some parts of the country, New Travellers form a significant minority of the travelling population. Their needs must also be assessed by the relevant local authorities alongside those of the more traditional Gypsy and Traveller groups.

The needs of Travelling Showpeople must also be considered as part of the GTAA, as this group may, for example, need winter quarters within a local authority area.

When assessing GTAA reports, the Welsh Ministers will pay particular attention to the extent to which local housing authorities have demonstrated that they have consulted directly with members of all the Gypsy and Traveller communities residing in or resorting to their area. Reviewing data sources (as outlined in Chapter 2) and liaising with Gypsy and Traveller support organisations Annex 2 to identify and engage with community members may support this aim but does not replace the need for direct consultation with those whose needs are being assessed.

An interview log must be kept by local authorities to demonstrate to the Welsh Ministers the assessment process has made every effort to engage with all known Gypsies and Travellers in the area. The log of interviews must clearly state if repeated efforts to engage with community members have failed and give reasons for non-participation where available. A draft interview log has been provided at Annex 4.

Welsh ministers may request this interview log when considering whether to approve or reject local authority GTAAs, if it is not submitted in the first instance.

To ensure the estimate of pitch need in a GTAA is robust, it is essential to secure a successful consultation with community members. Local authorities are advised to follow the ‘engagement checklist’ to ensure they reach as many community members as possible.

Section 103 of the 2014 Act makes it clear that if a local housing authorities approved assessment identifies needs within the authorities area for sites on which mobile homes may be stationed, the authority must exercise their powers in section 56 of the Mobile Homes (Wales) Act 2013 so far as may be necessary to meet those needs:

Provision of local authority pitches and sites is likely to be the most effective long-term solution to meet the accommodation needs of Gypsies and Travellers, but local housing authorities may also wish to consider securing pitches on sites operated by registered social landlords or private Gypsy and Traveller sites.

If a need for Gypsy and Traveller pitches is identified, the local authority must consider how to make the necessary provision and whether to use their powers under section 56 of the Mobile Homes (Wales) Act 2013 to provide sites for mobile homes.

The following groups may be particularly likely to give rise to pitch need.

Mobile home dwelling households:

• who have no local authority or private sites anywhere on which to reside
• whose existing site accommodation is overcrowded or unsuitable and are unable to obtain larger or more suitable accommodation
• who contain households who need to set up separate family units but who are unable to access a place on a local authority site or develop their own private site

‘Bricks and mortar’ dwelling households:

• whose existing accommodation is overcrowded or unsuitable (‘unsuitable’ in this context includes unsuitability by virtue of cultural aversion to bricks and mortar accommodation)
• which contain concealed households who are unable to set up separate family units and who are unable to access suitable or appropriate accommodation

It is essential to recognise that the shortage of local authority sites and potential local opposition to site planning applications, as well as financial pressures, may prevent Gypsies and Travellers from being able to exercise their free choice in the accommodation market and there may, in fact, be no suitable ‘local accommodation market’ available to them.

The requirement of the assessment is to provide data which will accurately identify Gypsy and Traveller accommodation needs.

The completed GTAA should equip local authorities with all the relevant data to inform their local housing strategy and Gypsy and Traveller site provision policies in their Development Plan.

Where a local authority has identified a need for additional sites, the GTAA should also set out how they will meet those needs and within which timescales.

The GTAA should state whether the local authority intend to exercise their powers under section 56 of the Mobile Homes (Wales) Act 2013 to meet the identified needs and include such other information as may be relevant to demonstrate how the authority will otherwise meet their duty to provide the required accommodation.

The assessment aims for Gypsies and Travellers will be the same as for other sectors of the community, that is, to identify outstanding need. However, the severe shortage of culturally appropriate Gypsy and Traveller accommodation will mean the process for undertaking the review is substantially different. Unlike other sectors of the community, Gypsies and Travellers may reside in the following types of accommodation:

• local authority sites
• private sites with planning permission
• private sites without planning permission
• bricks and mortar
• transit or temporary/negotiated stopping places
• unauthorised encampments

The accommodation needs of Gypsy and Traveller communities may differ from the rest of the population because of:

• their nomadic or semi-nomadic pattern of life
• the caravan-dwelling culture
• potential movement between housing and caravans
• the incidence of unauthorised encampments
• patterns of extended family living

Potential movement between different local authority areas may have the following implications for carrying out an assessment:

• the possibility of needing to work on a regional level in both carrying out assessments and delivering solutions to site provision
• the timing of the GTAAs will need to be considered
• different questions may need to be asked
• different data sources may need to be used

It is important to consider how:

• to identify and engage with those to be consulted
• how interviewers put questions to community members

If an authority has little knowledge of, or reliable data on, Gypsies and Travellers, it is even more important that groups supporting these communities are engaged to ensure the assessment is as accurate as possible. 

The process must be redone at the very least every 5 years to ensure the evidence remains up-to-date and robust. Local authorities can undertake GTAAs more frequently than this if they choose to do so.

It is also recommended local Councillors are made aware of the requirement to conduct a GTAA, meet the needs identified and of this guidance. Providing Gypsy and Traveller sites can be a complex issue within wider communities, and it may be helpful to ensure Council members are fully briefed and understand the statutory duties at an early stage.