The Rt Hon Shabana Mahmood MP, Secretary of State for the Home Department
The Rt Hon Bridget Phillipson MP, Secretary of State for Education
The Rt Hon Steve Reed MP, Secretary of State for Housing, Communities and Local Government
02 February 2026
Dear Ministers
Kent County Council is committed to fully meeting its statutory responsibilities to children and young people under the Children and Families Act 2014. Under the former government, this led to a successful legal challenge to the Home Office to effectively manage the National Transfer Scheme. This action did improve the situation, but we are now writing to you as new ministers of state asking you to consider this issue anew and work with us to develop a proper, sustainable and fair resolution to the challenges
presented to the county by our role as one of the gateways to the United Kingdom.
The unfair, unsustainable, and escalating pressures facing Kent are a result of three interlinked national issues which have remained unresolved by a succession of the previous ministers occupying your offices:
1. The disproportionately high number of looked-after children placed in Kent by other local authorities (particularly London boroughs)
2. The exceptional volume of former Unaccompanied Asylum-Seeking Children (UASC) whom Kent continues to support into adulthood
3. The fact that these issues have inadequate government funding
Kent has long taken pride in supporting vulnerable children and young people. However, the scale of the pressures we face as those former UASC have moved into adulthood, with Kent's number of UASC Care experienced adults remaining the same over a number of
years, is now without precedent and is placing a severe and unfair strain on our services,resources and local communities.
Out-of-Area Placements of Looked-After Children
Kent currently hosts over 1,150 looked-after children placed by other local authorities, with a significant proportion coming from London. Of these, nearly 400 currently have an Education Health and Care Plan. The level of inward placement and net impact on KCC is
exceptional and unsustainable. Whilst KCC welcomes the new guidance which requires Other Local Authorities (OLA) to fund SEND education and transport costs for the children they have placed in Kent, this is but a small step in the right direction and will have a limited impact.
Impact on Kent’s Services
- Education: Kent Special schools are operating at or above capacity, OLA children are displacing local children (for example 1/3 of the pupils at Five Acre Wood Special School are placed by Other Local Authorities) or requiring costly transport and alternative provision, as well as driving demand for Independent school provision.
- Healthcare: NHS and mental health services face significant pressure, particularly from children requiring therapies and those with complex trauma.
- Social Care & Safeguarding: Kent’s Front Door officers and safeguarding teamsare carrying increased caseloads for children for whom we are not the corporate parent. The delivery of urgent and emergency levels of support, together with the significant amount of time taken to source accurate information about the placed children creates operational and coordination challenges.
- Housing: We have evidence of the strain on housing through OLA placing Children in Care in the same areas as KCC, thus competing for housing stock and adversely impacting on the number of regulated placements available for children with highly complex needs.
Regulatory Weaknesses
Compliance with statutory duties requiring placing authorities to consult and notify Kent before making placements is at best inconsistent and sometimes absent altogether. This compromises our ability to plan for safety and sufficiency. Many of the children and families placed in Kent by other local authorities are amongst their most challenging and this is an abdication of their responsibilities.
Our Requests
We ask the Government to:
- Secure the UK’s borders.
- Introduce tighter national regulation of out-of-area placements to prevent any one area—especially Kent—from carrying a disproportionate burden.
- Implement a fair national funding mechanism compensating host authorities for the true cost of supporting other councils’ children.
- Strengthen Ofsted oversight of placement quality and ensure host authorities have the power to challenge unsuitable placements and that those placing out of area cannot achieve good or outstanding ratings for their services.
- Strengthen Housing and Planning Legislation to support LAs in declining permission for change of use to develop children’s homes. Ensure legislationpromotes LAs with Housing Authority make decisions linked to the LA’s sufficiency
strategy on required provision.
Pressures from Former UASC Care Leavers
Kent supports over 1,000 former UASC care leavers, far more than any other authority. These young adults—many with complex needs and limited entitlements—require intensive support.
Inadequacy of Current Funding
Government provides an inadequate level of funding for former UASC Care Leavers aged 18-21 and no funding for those aged 21-25. The Government failed to fund the 21-25 cohort when it introduced extended corporate parenting statutory duties to Care Leavers
aged 21-25, and failed to acknowledge in terms of funding support, the creation of a separate judgement for Care Leavers under the Ofsted ILACS framework with its revised evaluation criteria.
Therefore, Government funding falls dramatically short of actual costs, particularly in the South East’s high-cost housing market. This model does not account for:
- Volume and the complexity of providing housing in a two-tier authority
- High quality accommodation scarcity Immigration-related issues (including no recourse to public funds)
- High caseloads for Personal Advisers arising from former UASC Care Leavers being unable to study and work.
Kent has incurred multi-million-pound unfunded deficits, effectively subsidising what is, fundamentally, a national responsibility. Whilst the recent litigation lowered the impact of this going forward, the present pressure is driven by the very period where the National
Transfer Scheme collapsed as a consequence of lack of interest by the previous governments.
The regulatory and policy position maintained by the Government currently adversely affects Kent residents and especially the Care Leavers themselves meaning that services are impacted as local funding is directed to meet national responsibilities. Kent
acknowledges the importance of robust regulation. Services for children in care were rated “Outstanding”, but the immediate continuation of support into adulthood was rated much lower reflecting the systemic constraints under which KCC operates.
We ask Government departments to recognise these inconsistencies and ensure fair, proportionate assessment of councils operating under exceptional pressure.
Our Requests
We ask the Government to:
- Urgently review and reform the UASC care leaver funding formula, with rates that recognise high-volume and high-cost areas.
- Provide transitional flexibility and coordinated support for Ofsted registration, including accelerated processing.
- Offer emergency and long-term funding to stabilise accommodation and reducereliance on expensive spot placements.
KCC officers are advising other LAs on these areas and we encourage the Government to use this expertise to form a joint taskforce and engage gateway councils in designing a sustainable, national model.
Conclusion
The pressures identified in this letter are to be set against a changing regulatory position. Ofsted (as it is freely and correctly entitled to) now makes a specific finding in relation to care-leaver services. I fully understand why they would want to shine a light on these
services but the Government has not responded in step to ensure that local authorities, particularly Kent, are appropriately funded.
I would therefore direct you to our latest Ofsted report given the judgment and learning from it on these issues are a matter now for Government and I would like to know what you propose to do about the issues set out in this letter.
Kent County Council is legally obliged to support all children and young people in our care—whether placed by us or by other authorities, whether UK-born or newly arrived. However, the current situation is unfair, unsustainable and requires urgent national
intervention.
On behalf of our residents and the vulnerable children and young people we serve, I urge you to:
- Secure the UK’s borders
- Reform national placement policy and funding
- Fully address the exceptional pressures on gateway authorities
- Work with Kent to create a balanced, fair and sustainable system
I would welcome a meeting at your earliest convenience to discuss these matters in detail.
Yours sincerely
Linden Kemkaran
Leader of Kent County Counci
