Domestic Abuse Bill

Written evidence submitted by the Lloyds Bank Foundation for England & Wales (DAB46)

About Lloyds Bank Foundation for England & Wales

Lloyds Bank Foundation for England & Wales partners with small and local charities to help people overcome complex social issues. Through long-term funding, development support and influencing policy and practice, the Foundation helps those charities make life-changing impact. The Foundation is an independent charitable trust funded by the profits of Lloyds Banking Group as part of their commitment to Helping Britain Prosper.

The Foundation has supported individual local charities tackling domestic abuse for over 35 years through core funding and capacity building. In 2015 we launched a strategic national programme to help the domestic abuse sector develop new approaches and respond to the challenges facing it, investing an additional £4 million over three years. This written evidence draws on the insight, evidence and experience that the Foundation has gained from partnering with domestic abuse charities across England and Wales, as well as working with Lloyds Banking Group to improve the response to domestic abuse amongst customers and colleagues.


1. The Domestic Abuse Bill is a welcome opportunity to create a step-change in response to domestic abuse in England. To make the most of this landmark opportunity, it’s vital that the Bill is well-considered and reflects the views and needs of all victims/survivors, to ensure that it can be as effective as possible, not leaving anyone behind. The Bill is being considered at a particularly important time, as the coronavirus pandemic has resulted in an escalation of abuse, and so it is more important than ever to get it right.

2. Ultimately, the effectiveness of the Bill will depend on funding, both in terms of the funding to implement the Bill (including adequate resourcing for the Domestic Abuse Commissioner) and funding for specialist services to respond to needs.

3. Specialist domestic abuse services provide expert support to victims/survivors, but they need sustainable funding to do so. Specialist services are already underfunded and overstretched. During the coronavirus pandemic, levels of abuse have escalated, and a spike in demand is anticipated after lockdown is lifted. Combined with the growing awareness of domestic abuse as a result of the Bill, the numbers of people seeking support are set to be unprecedented. At the same time, charities have seen their income streams hit, and costs rising. The Bill must ensure sustainable funding for specialist services to cope with these demands.

4. While the statutory duty on local authorities to fund safe accommodation is welcome, its focus on accommodation is too narrow. The statutory duty must be widened to reflect the full range of services needed for victims/survivors, children and perpetrators. There should be ring-fenced funding as, in the context of a local authority funding crisis, community-based services are at risk of disappearing.

5. Domestic abuse services run with, by and for BAME communities provide vital support, yet they are more at risk than ever. It is crucial that funding is ringfenced for these specialist services, particularly in the context of the coronavirus pandemic where these communities have been hardest hit.

6. LGBT+ people face higher levels of abuse and face barriers in accessing support. Their needs must be accounted for in policy and in the commissioning and funding of services.

7. Disabled people face higher risks of domestic abuse, as well as barriers in accessing support. Commissioning of services should reflect the need to make existing services more accessible, but also to provide ringfenced funding for specialist ‘by and for’ services for disabled victims/survivors.

8. The Bill has a significant gap in the response to domestic abuse amongst migrant women. The government should follow the call of the Step Up Migrant Women campaign to create a firewall between reporting and accessing support for domestic abuse, and immigration control. The NRPF restrictions on migrant women should also be lifted, ensuring that they can access lifesaving support following domestic abuse.

9. Tackling perpetrators is vital to preventing and ending the cycle of domestic abuse. Alongside the Bill, there should be a cross-government strategy on tackling perpetrators, as well as well evidenced and quality assured perpetrator interventions.

10. Financial independence can be a barrier to escaping abuse and is key to regaining independence. It’s important to look at where government policies can exacerbate or enable this. For example, split payments of Universal Credit should be provided as default, and the five week wait, which often causes unnecessary hardship for victims/survivors, should be replaced with a non-repayable advance grant.

11. Local welfare assistance schemes can be a lifeline for victims/survivors of domestic abuse – for example, providing support with essential household items when leaving refuge accommodation. However, due to funding pressures, many local authorities have been forced to cut back or even scrap their scheme. There should be statutory funding for local welfare assistance to be provided in every local authority in England.

12. Employers, businesses and the community all have important roles to play in raising awareness of abuse and ensuring people know where to find help. Providing 10 days of paid leave for employees who are victims/survivors of domestic abuse would be an important step in achieving this, following the example of New Zealand.

13. The Government could take learning from the approach in Wales – such as embedding approaches where public services ask about domestic abuse and take action to ensure victims/survivors can access specialist support. New commissioning guidance to accompany the Bill in England should reflect that developed in Wales, with an emphasis on the importance of specialist services.

Sustainable funding for specialist services

The Domestic Abuse Bill is a welcome opportunity to create a step change in the response to domestic abuse in England. A number of measures in the Bill are set to increase awareness of domestic abuse which is predicted to lead to increase in victims/survivors seeking support. When victims/survivors come forward, it is critical that they are able to access support. Support is most effectively provided by specialist domestic abuse services – as with specialist sexual abuse services, there is evidence to show that survivors value specialist provision [1] – so it is vital that these services have the resources to meet need. Central to this is securing sustainable funding, both in terms of providing the range of support needed by victims/survivors and children, as well as services to challenge perpetrators. The impact of the Bill in practice depends on adequate funding for the services that can provide specialist support for those affected by domestic abuse.

This funding is critical because research by Women’s Aid shows that the domestic abuse sector is already underfunded, with 64% of refuge referrals last year forced to be declined because of a lack of resources, with funding cited as the biggest challenge facing services [2] . If this was the case before the coronavirus pandemic, it is only likely to worsen. Domestic abuse charities have found that abuse has escalated during lockdown [3] . Many of the Foundation’s grant holders have seen a rise in referrals for high risk victims, and are anticipating that there will be a spike in demand for support from medium and lower risk victims/survivors after lockdown restrictions are eased, when those who have been unable to reach support may have more opportunities to do so.

At the same time as demand is rising, charities have seen their income hit significantly by the coronavirus crisis. Income streams such as trading and fundraised income have disappeared overnight. At the same time, they have transformed services to deliver support remotely where possible, which requires significant costs in digital support and staff time. Given that many domestic abuse charities were already citing funding as their most pressing challenge before this crisis, it leaves them in a precarious position to be able to continue providing their vital and life-changing services at a time when they are never more needed.

Furthermore, in the context of coronavirus, many refuges are unable to run at capacity because of the need to operate with social distancing. This challenge is compounded by a lack of move-on accommodation, preventing charities from taking new referrals. We welcome government’s announcement that domestic abuse victims/survivors will be given priority for housing – but this also depends on sufficient levels of housing that can be accessed.

Many of the points raised in this submission underpin the need for sustainable funding for specialist domestic abuse services. While there is certainly a need for raising awareness and improving the pathways into support for victims/survivors, this is only effective if there are services there to refer people to. Specialist services are best placed to provide the holistic, tailored, expert support that victims/survivors need to move forward in their lives – but as it stands, they do not have the sustainable funding to meet this demand, and it is vital that this comes alongside the Bill.

The Statutory Duty on Local Authorities

The statutory duty on local authorities is a welcome inclusion in the Bill. However, the duty is currently too narrowly focused on accommodation-based services, posing a risk that victims/survivors will not be able to access important community-based support, and resulting in a worsening of the postcode lottery of who can or can’t access support. Survivors access support in a range of different ways, so a focus on such a narrow type of activity will only benefit a certain group of survivors, and risks leaving many others without services due to a lack of funding. The focus on accommodation based support may also force people to leave their homes in order to access support, which can leave victims at heightened risk – rather than being able to access community-based support which may be safer in some situations. This also places emphasis on the victim to leave their home to seek support rather than on the perpetrator to tackle their behaviour.

Expanding the duty is particularly important given the funding pressures faced by local authorities. They have been under growing financial strain in recent years. The coronavirus crisis has only exacerbated the demands on stretched budgets, with a number of local authorities being forced to consider issuing Section 114 notices. In this context, there will be little budget left for local authorities to prioritise non-statutory spending. As such, community-based domestic abuse services that were previously funded by local authorities are at risk of being lost altogether if there is only a duty to fund accommodation-based support.

It is vital that the statutory duty is extended to cover the full range of services needed to support people affected by domestic abuse, not just accommodation. This concern has also been raised by the Government’s Victims Commissioner, Vera Baird, and Domestic Abuse Commissioner, Nicole Jacobs, calling for the statutory duty to cover ‘all domestic abuse services, including for children and behaviour-change programmes for perpetrators’ [4] . The Foundation supports SafeLives’ #Invest2EndAbuse [5] campaign on this issue, and supports the amendment proposed by Barnardo’s to widen the statutory duty.

Ensuring everyone can access support

Alongside the need for an adequate quantum of funding in the statutory duty, attention also has to be turned to how funding is distributed. It is vital that funding reaches specialist services so that all survivors can access the support they need – whatever their background, circumstances or needs. Doing so requires ring-fenced funding and processes that are accessible to smaller, specialist services.

BAME victims/survivors

It must be recognised that different communities will have different experiences and services need to be able to respond in the way that is most appropriate for that community – one size cannot fit all when it comes to delivering domestic abuse support. It is vital that resources reach specialist services run with, by and for specific BAME communities, as they are best placed to provide tailored, understanding support to victims/survivors. These are expert, specialist services which are designed and delivered by and for the users and communities they aim to serve [6] , and have an in-depth understanding of the dynamics of abuse. Survivors are more than three times more likely to self-refer into a BAME-led service than to get help from the national domestic violence helpline [7] .

Organisations supporting BAME communities are at greatest funding risk, are typically smaller and are often disadvantaged in commissioning processes. This has been exacerbated as they have also been disproportionately affected by the coronavirus crisis, leaving their vital services at risk as they are hit by ‘dual pandemics’ [8] . Smaller BAME charities are at greatest risk of closure in current context [9] . The government have stated their ambition that this Bill should help all victims/survivors – in order to do so, it must ensure that BAME ‘by and for’ services and organisations are recognised with ring-fenced funding to ensure resources reach them and they can continue their vital support.

LGBT+ victims/survivors

LGBT+ people are also at particular risk of experiencing domestic abuse and face significant barriers in accessing support. As highlighted by Galop [10] , the Bill must recognise and respond to the needs of LGBT+ people through any funding, policy or commissioning arising from it, including the work of the Domestic Abuse Commissioner, and ensure that specialist LGBT+ services have sustainable funding and are able to expand so that more survivors have access to the support they need.

Disabled victims/survivors

Disabled women are more likely to experience domestic abuse [11] than non-disabled women, and they also face significant barriers in accessing safe, appropriate support. The commissioning of services should reflect the need for specialist support. Existing support and information needs to be made more accessible. The Foundation has supported work to better understand how services need and can adapt to both physical [12] and learning [13] disabilities. There is a need for this work to be expanded alongside developing more specialist user-led services supporting disabled survivors. Ring-fenced funding needs to be provided for specialist services for Deaf and disabled survivors

Migrant victims/survivors

One of the gaps highlighted most clearly in the previous iteration of the Domestic Abuse Bill was the lack of provision for those with insecure immigration status. The Government has stated its ambition to support all victims of abuse – it should not matter where they are born. Too often, a victim/survivor’s immigration status is used as a tool for further abuse, and prevents them from seeking life-saving help. As outlined in the recent letter from the Domestic Abuse Commissioner and Victims Commissioner: ‘The Domestic Abuse Bill must help all victims, regardless of their immigration status. To do otherwise contravenes the Istanbul Convention – to which the UK is a signatory – which stipulates non-discrimination in the provision of services.’ Every victim should be treated first and foremost as a victim, regardless of their immigration status.

The Foundation supports the Step Up Migrant Women campaign [14] , led by Latin American Women’s Rights Service, which calls for a firewall to be created between seeking protection and support from abuse, and immigration control. This was endorsed in the conclusions and recommendations of the report from the previous Domestic Abuse Bill committee:

61. We recommend that a more robust Home Office policy is developed to determine the actions which may be taken by the immigration authorities with respect to victims of crime who have approached public authorities for protection and support. We support the recommendation of the Step Up Migrant Women campaign to establish a firewall at the levels of policy and practice to separate reporting of crime and access to support services from immigration control. (Paragraph 251) [15]

Failing to introduce a firewall will lead to greater physical and emotional costs of abuse, as victims/survivors are left unable to seek support, and perpetrators will go unchallenged – meaning the Bill will fail to meet its objectives of providing support to all victims of domestic abuse.

Due to the conditions of No Recourse to Public Funds (NRPF), women with insecure immigration status are also least able to access refuge and are faced with an impossible decision of homelessness and destitution, or staying with their perpetrator. The Istanbul Convention requires support to be available for all women, regardless of their immigration status. As such, the NRPF restrictions on migrant women should be lifted, ensuring that they can access the refuge, welfare support and legal protection that they need.

Furthermore, the Foundation supports the call of the coalition of organisations led by Women’s Aid to extend the eligibility of the Domestic Violence Rule so that all women are eligible to apply for indefinite leave to remain and the Destitution Domestic Violence Concession, which should be extended to at least six months – recognising the barriers that migrant women face in obtaining safe accommodation, support and legal representation needed to make applications within the three month period, and the time this can take.

Holding perpetrators to account

To have a significant impact on domestic abuse, attention must also be turned to stopping abuse. Alongside providing support for victims/survivors, there must be well-evidenced, consistent interventions to tackle perpetrators, ending the cycle of abuse. The Domestic Abuse Protection Orders in the Bill need to go hand in hand with well-evidenced and quality assured preventative services, such as behaviour change programmes.

The Foundation is one of the leading partners in the Drive programme, which demonstrates the impact that high quality perpetrator interventions can have in practice. Over three years of working with high-harm perpetrators, the Drive programme led to an 82% reduction in physical abuse and an 88% reduction in sexual abuse. The programme involves close working with IDVAs to support their work with victims, alongside and coordinated with perpetrator interventions. The Government’s support announced in the 2020 Budget is welcome, but availability of access to quality perpetrator programmes is still very limited. It is vital that, where perpetrator interventions are commissioned, they are well-evidenced and quality assured, to ensure that the safety of victims/survivors is paramount. As such, we support Respect’s proposed amendment to the Bill on quality assurance for perpetrator work.

The Foundation supports the call to action [16] , led by Respect along with almost 80 other organisations and launched in January at the APPG on Perpetrators of Domestic Abuse, for a cross-government strategy on tackling perpetrators to be published alongside the Bill. The strategy should include:

1. Criminal justice system and other public and voluntary services trained, and working together to hold perpetrators to account 

2. Proven interventions for all perpetrators available everywhere; and education to prevent and raise awareness of abusive behaviours.  

3. Regulation to ensure all programmes are high quality and safe; and ongoing research to evaluate what we are doing.

4. Investment – a perpetrator strategy requires funding, but done well, it will save money in policing, justice and health costs. 

5. Leadership to make it happen.

Financial support for victims/survivors

Access to money is often used as a tool of financial and economic abuse, but it is also crucial for enabling victims/survivors to reach safety and recover from abuse in the longer term. Issues with Universal Credit are often raised by charities funded by the Foundation as one of the biggest challenges facing the clients they work with. As Universal Credit is only paid to one member of a household, this can be a significant barrier from being able to escape abuse. Split payments are available on request, but it is often impossible for those in an abusive situation to access this without putting themselves in a potentially dangerous situation. While the Government have focused on raising awareness of split payments, this will not address the issue, because the act of requesting a split payment is an example of a victim/survivor exerting power, which can expose them to increased abuse. Split payments of Universal Credit should be the default option, to safeguard against financial abuse and give survivors the financial independence to enable them to leave.

The five week wait for Universal Credit is also raised consistently by charities funded by the Foundation as a cause of hardship amongst those who are escaping or trying to recover from abuse. The prospect of five weeks without any income may deter some victims from leaving the perpetrator as they may not have the financial independence to do so. Many survivors apply for Universal Credit for the first time when they leave the perpetrator. At a time when survivors are trying to get back on their feet, the wait leaves them with no money to cover basic living costs, pushing them into further debt when they are in a vulnerable situation, even running the risk of having to return to a perpetrator simply to survive financially. Victims/survivors often leave with nothing, without access to savings or any funds at all. The five week wait should be ended for all claimants, but as a priority it should be ended for those in situations of domestic abuse, or advance payments should be provided as a non-repayable grant.

Local Welfare Assistance schemes, at best, can be a lifeline to survivors of domestic abuse. For example, after leaving a refuge, survivors are often left with no resources to furnish new accommodation for them and their family. Support can be provided through Local Welfare Assistance towards essential household goods to start a new home. However, since local welfare provision was made discretionary for local authorities, in the context of massive budget cuts, access to support has been stripped back, and in some places has disappeared altogether. With the coronavirus pandemic causing an unprecedented income shock to many individuals and families, it is more important than ever to have a strong safety net, and this is felt most keenly by those affected by abuse. This safety net is broken in many areas.

Too often, charities, such as those that the Foundation supports, have to step in fill the gaps. While the Foundation is supporting the Coordinated Community Support Programme [17] to improve the coordination of crisis support between voluntary sector and local government provision, it is not enough to expect charities to pick up the pieces. One charity supported by the Foundation reported that, when a mother had to flee abuse with her 8 month old daughter, her Universal Credit claim had not yet come through and she had no money to get the essential items she needed for a new home. An employee of the charity brought a cot, clothing and kitchen items from her own home to ensure she and her daughter had enough to get by. This is not a sustainable solution - an effective local welfare assistance scheme should provide for situations like this. The Foundation supports the amendment proposed by the Children’s Society, calling for a Local Welfare Assistance scheme in every local authority in England, to provide vital support to victims/survivors of abuse and others in need.

Pathways to support – the role of employers, businesses and communities

Employers and businesses undoubtedly have a role to play in tackling domestic abuse - raising awareness, ensuring everyone knows how to spot the signs of abuse and where to signpost people for support. There are lots of existing resources, initiatives and good practice taking place to ensure this. The Foundation is a member of the Employers Initiative on Domestic Abuse (EIDA), which includes over 300 employers, and provides resources, toolkits and learning opportunities to help businesses better support their staff. Given the importance of financial independence in escaping from abuse, and the turmoil that it can cause in preventing victims/survivors from maintaining a job, one measure which could make a significant difference would be a period of paid leave for employees experiencing domestic abuse. Providing 10 days’ paid leave to survivors/victims of domestic abuse is a measure which was already introduced in New Zealand, and is seen as good practice. It is also a useful prompt for businesses to consider their response domestic abuse, and provides a greater assurance to victims that they will be supported if they disclose abuse.

There are also a number of initiatives aiming to improve responses from communities and those working in public services – such as the Champions Networks [18] led by Reducing the Risk and funded by the Foundation. Expanding these schemes to improve the response to domestic abuse across the community and public services would help to ensure that victims/survivors can disclose abuse and be supported to access expert help.

These are all vital initiatives to improve pathways to support. However, it’s important to recognise that their role is to ensure people know where to get help, rather than provide it directly. For example, Lloyds Banking Group, the Foundation’s own funder, recognise in their approach to domestic abuse that colleagues do not have to have all of the answers to be able to be helpful in responding to signs or disclosures of abuse – but they do need to be able to signpost people to specialist services with the expertise to provide life-saving support.

If these initiatives exist to raise awareness and signpost people to expert support, they will only be effective if specialist support services for victims/survivors have sustainable funding – to cope with current capacity challenges, as well as any additional demand that comes as a positive outcome of the measures to raise awareness.

Devolved nations

While the Bill only covers England, there is useful learning that can be taken from the approach to domestic abuse in Wales – such as ‘Ask and Act’, recognising the role of public services in identifying and responding to abuse. The commissioning guidance [19] produced alongside the VAWDASV Act (2015) also provides a good blueprint for recognising the importance of specialist services.

June 2020






[6] Imkaan, The Alternative Bill: From the Margin to the Centre

[7] Imkaan: From Survival to Sustainability


[9] Ubele Initiative – Impact of Covid-19 on the BAME community and voluntary sector


[11] Stay Safe East

[12] We Matter Too, Ann Craft Trust:

[13] Toolkit for supporting people with learning disabilities who experience domestic abuse:




[17] Coordinated Community Support programme:




Prepared 11th June 2020