Taking Stock of South African Responses to Homelessness: Advocating for Victim-Inclusive and Protective Policy Reform

Abstract

Homelessness remains a neglected and under-prioritized area of policy intervention in South Africa. Without a national policy framework, homelessness is generally overlooked, resulting in intermittent, fragmented and ineffective responses. The lack of attention has contributed to a concerning rise in both at-risk and street-based homeless populations, who continue to face challenges in accessing effective support. Using document analysis, the paper maps the content of six local homelessness policies. The findings reveal that the documents adhere to a rigid and static framework, thereby failing to capture the complex contextual and conceptual factors associated with homelessness. A notable shortcoming is the limited focus on and response to experiences of victimization. Using the Health Policy Triangle (HPT), the paper aligns the key findings with the four dimensions of the framework to advocate for inclusive, protective and victim-sensitive policy recommendations to aid in the development of holistic and humane responses to homelessness in South Africa.

1. Introduction

Homelessness is a multifaceted phenomenon, and despite ongoing mitigation efforts, it remains a profound challenge, with evidence of persistent growth globally. South Africa currently has no national policy1 on homelessness, which has resulted in the adoption of fragmented approaches in a few cities to address homelessness (Desmond et al. 2017). The constantly evolving landscape of what homelessness entails and who it affects represents one of the leading problems that impede its resolution. Driven by a significant dearth of local research on homelessness (Pophaim and Peacock 2021; Pophaim 2021; Sadiki and Steyn 2021), ideological and practical challenges hinder the development of targeted and sustainable interventions. These challenges perpetuate the inability to accurately contextualize the problem and consequently undermine the feasibility of policies and interventions, which are dependent on the establishment of realistic baselines reflecting a clear understanding of what homelessness entails (De Beer and Vally 2021b; Sadiki and Steyn 2021). The absence of national policy perpetuates the implementation of fragmented and polarized (punitive versus compassionate) approaches that further criminalize, ostracize and inadvertently promote dependency and institutionalization among people experiencing homelessness (Hopkins et al. 2024; Owadally and Grundy 2023). The reality is that people experiencing homelessness face widespread social exclusion and are constantly confronted by extreme poverty, deprivation and marginalization and often exist in a state of absolute vulnerability to crime and victimization (Ellsworth 2019; Pophaim 2022). It is further contended that any intervention directed at addressing homelessness should remain cognizant of this vulnerability and include services and infrastructure that mitigate the negative impact of factors associated with homelessness (De Beer and Vally 2021b). However, despite their detrimental impact, these social injustices are rarely acknowledged or sufficiently addressed in the current policy space.

A notable example is that despite the fact that the homeless are arguably one of the most vulnerable populations in any society, the concept of the homeless victim remains outside of applications of the so-called ‘ideal’ victim and as a result absent from popular consciousness with an ensuing silence in criminal justice, societal and policy responses (Pophaim and Peacock 2021; Pophaim 2021; Scurfield et al. 2004). Shaped by a landscape of counterproductive, poorly implemented and absent policies, interventions are likely to remain ineffective, with the added risk of reducing the overall safety and quality of life of people experiencing homelessness. It is therefore important to analyze, understand and interpret existing policies and their intended purpose. Through this undertaking, an opportunity to ‘take stock’ presents itself, to determine what is available, how it is structured and administered by stakeholders, and, equally importantly, how it is accessed by the intended beneficiaries. In a preliminary scoping review of existing international and local policy and legislative frameworks, it was revealed that homelessness, for the most part, remains policy-adjacent. In other words, most legislation, while addressing related issues, does not explicitly mention or aim to address homelessness, which is problematic for member states and stakeholders who are expected to interpret and remain compliant with international standards and obligations. Furthermore, the review also confirmed that homelessness is indeed context-bound (De Beer and Vally 2021b) as many of the international frameworks depend on strategies that mobilize and require resources that would not necessarily be available or applicable in response to the South African homelessness situation.

Moreover, the preliminary appraisal further exposed the implications of an absent national policy, also revealing that many provinces and cities do not have dedicated policies in place to respond to homelessness and that current provisions are generally considered inadequate (Naidoo 2010). With the continued shortfall of direct responses, homelessness in South Africa continues to exist in what is best described as a policy vacuum (De Beer and Vally 2021a; Groenewald et al. 2023). Amidst the constrained and absent responses, the suggestion to rely on other pieces of national legislation, such as the Constitution of the Republic of South Africa or the Social Assistance Act (13 of 2004), was considered. Although it does not deal with homelessness directly, it was deemed capable of dealing with associated conditions. However, after careful consideration, it was determined that the interventions’ lack of specificity and poor implementation are unlikely to meet the unique needs of people experiencing homelessness (Pophaim and Peacock 2021; Tenai and Mbewu 2020). It was therefore decided to only focus on the direct responses to homelessness on a provincial and municipal level. Accordingly, through an analysis of the selected South African policy responses to homelessness, the paper seeks to explore the current approaches and challenges associated with addressing homelessness in South Africa and provide insight for the development of more effective and inclusive solutions.

2. Current Challenges in Addressing Homelessness

Addressing homelessness remains a daunting and multidimensional task that continues to confront several countries worldwide (Owadally and Grundy 2023). The following challenges can be regarded as the key features that contribute to the complexity of the issue and, as a result, significantly hamper any real progress both practically and within the policy and legislative space.

2.1. Uncontrollable Growth and Flawed Population Data

According to reports from the United Nations and the World Economic Forum, the global population of people experiencing homelessness is currently situated between 100 and 150 million people, with as many as 1.5 to 1.8 billion people currently residing in inadequate housing conditions, marginally at risk of chronic homelessness (Awad 2023; Homeless World Cup Foundation 2022; Olufemi 1998, 2000; United Nations 2025). Locally, there is a lack of official and comprehensive estimates that fully document the true nature and extent of homelessness. Consequently, academics and other stakeholders primarily rely on unofficial voluntarily generated estimates produced by individual researchers and organizations (Obioha 2022).

In the late 1990s, it was estimated that there were 3 million people experiencing homelessness, and in 2000, approximately 8 million informally housed individuals, which is most likely a reflection of the application of broad definitions, the lack of homogeneity and the many pathways into homelessness (Makiwane et al. 2010; Olufemi 2000). The Human Sciences Research Council (HSRC) provided estimates on the South African homeless population, which placed it between 100,000 and 200,000 individuals (Cross et al. 2010). These figures have since set the precedent and have subsequently been widely cited in several academic and policy publications (Desmond et al. 2017; Obioha 2022; Pophaim 2021; Rule-Groenewald et al. 2015; Stonehouse et al. 2023; Tenai and Mbewu 2020). Notably, both global and local population estimates remain widely contested and are considered stark underestimations, as many experts are of the opinion that the accuracy needs to be tested due to the fact that conclusions for research on homelessness are usually based on assumptions because of their constant mobility (Awad 2023; De Beer and Vally 2021a; Tenai and Mbewu 2020). Within these opaque parameters, the 2022 South African Census reported a combined total of 55,719 people experiencing homelessness (Stats SA 2023), which is still considered a significant underestimation considering prior estimates, the fact that only roofless and shelter-based persons were counted, the current dire socioeconomic condition, and the sheer visibility of poverty and street homelessness in South Africa.

Determining the magnitude of homelessness is a crucial step in resolving it, yet there have never been formal statistics on homeless and traveling populations, who do not have a fixed shelter (Cross et al. 2010). Viable interventions can most effectively be constructed when there is a clear understanding of the nature and extent of homelessness, which, through an established baseline, demarcates the scope and area for redress (De Beer and Vally 2021b; Sadiki and Steyn 2021). Although it is important, the over-quantification of the problem could prove detrimental to the well-being of people experiencing homelessness, as the continued misrepresentation could result in the sustained under-prioritization and intermittent attention it receives through a combination of punitive, compassionate, institutionalized and the less frequently used developmental approaches (Hopkins et al. 2024). Meanwhile, more immediate needs and experiences such as protection from exploitation, harassment and victimization continue to fall by the wayside.

2.2. Conceptual Dilemmas and Knowledge Gaps

Homelessness is a complex concept to define, with very little consistency and universality in both its understanding and application across various contexts, regions and countries (Frazer and Kroll 2022; Obioha 2022). In the absence of a universally agreed upon definition, governments and organizations use different understandings of homelessness, which by default impact the level, type and quality of interventions and who is eligible for support (Obioha 2022). To provide efficient support, a clear understanding of the varied pathways, different types and consequences is needed. Without a clear understanding, there remains a risk that policymakers will default to generic interventions that may work for a few but will be inappropriate for many others (Desmond et al. 2017), further exacerbating the issue related to the precise scope and quantification of homelessness. This means that policies need to be evidence-based and contextually sensitive to the diverse needs of the population (Desmond et al. 2017). The most basic and widely accepted definitions and much of what is known about homelessness are primarily based on observations and the replication of research conducted in developed settings such as North America and Europe (ETHOS definition of homelessness, for example). However, considering the dynamic nature of homelessness, which makes it rather context-bound, it remains problematic to assume that extant definitions are applicable and transferable to a rather diverse South African context (De Beer and Vally 2021b). Consequently, homelessness continues to be seen as a social welfare or structural problem, while several human rights violations remain overlooked as the complex interplay between the pathways, consequences and pathways out of homelessness is rarely acknowledged in policy and intervention measures (De Beer 2021; Hopkins et al. 2024; Muleya and Mlilo 2023). In the development of a green paper on homelessness, the importance of a working definition is noted, which would ensure the creation of clear directives in terms of what homelessness entails (Groenewald et al. 2023). However, based on how homelessness defies singular definitions, its dynamic nature and how it affects each individual differently, the reality may be that we need to steer away from static and universal working definitions and instead embrace the fact that a range of definitions may be needed to underpin interventions and policy development, to ensure that the complexities are fully captured and translated into meaningful impact, with sustainable and longer-term outcomes (Hopkins et al. 2024; Kriel 2017; Tenai and Mbewu 2020). Employing accurate and more widely applicable definitions within the policy space could enhance the specificity of the required stakeholders, resources and interventions.

2.3. Experiences of Victimization

Due to their position in society, the homeless are often placed outside of the scope of what is regarded as an ‘ideal’ victim (Pophaim and Peacock 2021). To be homeless means that an individual is confronted by an increased and disproportionate level of vulnerability and exposure to violence and crime compared to the housed population (Ellsworth 2019; Pophaim 2021). The negative treatment against the poor and homeless is further confirmed through the established term Aporophobia, which refers to preconceived attitudes and beliefs that result in the ill-treatment and victimization of those who find themselves in precarious socioeconomic positions (García Domínguez and Vander Beken 2024). For context, people experiencing homelessness are reported to be 13 times more likely to experience violent crime and 47 times more likely to be victims of theft, with an estimated range of between 14% and 21% compared to 2% of the housed population (Meinbresse et al. 2014; Scurfield et al. 2004). These statistics are comparable to local studies which reported that at least half of their respective samples reported experiences of victimization (Meinbresse et al. 2014; Mthembu 2023; Pophaim 2019; Sadiki 2016). Furthermore, the enduring legacy of apartheid has left many communities in a continuous and vicious cycle of social challenges, characterized by past and present trauma. These communities are rife with issues related to violence and gangsterism, childhood adversity and adverse domestic conditions, alcohol and substance abuse disorders, mental and physical health challenges, and crime and incarceration, all of which can be regarded as active pathways into homelessness and prominent risk factors for victimization. The prevalence of victimization is indicative of the glaringly apparent negligence of the homeless victim, reflected by absent protective and inclusive policy and legislation (Pophaim 2021), which is another unfortunate byproduct of a limited understanding and anecdotally driven responses. This is furthermore illustrated by the exacerbating impact of the often punitive governmental and societal responses to homelessness.

2.4. Global and Local Directives Criminalizing Poverty and Homelessness

With the current state of homelessness worldwide, many governments have entered crisis management to alleviate the immense pressure to respond to the increase in visible homelessness (Owadally and Grundy 2023). Punitive measures have been the dominant approach in most contexts as they provide immediate results through the removal of homeless groups, with little to no consideration of the gross human rights violations and further detrimental effects thereof for people experiencing homelessness (Owadally and Grundy 2023). With these criminalizing practices, there is a considerable lack of humanity, shrouded in undignified harassment, the inconsistent application of by-laws, fines, arrests, repeated encampment evictions, destruction of structures and loss of property. This underscores a constant reminder of underlying negative perceptions about homelessness, which further increases the effects of discrimination and stigma, thereby significantly compromising their quality of life. The adoption of oppressive and punitive practices results in a grave loss of trust in available networks, as the homeless often feel that they have less access to support due to fractured relationships with local government and service providers (Hopkins et al. 2024). Moreover, such practices often result in a considerable degree of isolation, which heightens the vulnerability to victimization of people experiencing homelessness.

On the other hand, compassionate responses, such as handouts, can be regarded as a way in which entitlement and dependency are fostered. When essential services are readily available, some individuals may become accustomed to life on the streets and see little value in committing to accessing pathways out of homelessness. Balancing the punitive and compassionate responses may lead to a heightened rate of institutionalization, which comes with its fair share of challenges for both society and the person experiencing homelessness. Forcefully moving individuals into shelters and safe spaces before they are willing and ready, without a viable developmental strategy to keep them safe and off the street, is another aspect that needs to be reconsidered moving forward.

2.5. Lack of Governance and Continued Risk of Implementation Failure

As outlined in the preceding sections, effectively dealing with homelessness is a complex matter that requires careful consideration and input from as many stakeholders as possible. Although policy development processes claim to consult stakeholders and people experiencing homelessness, the design and implementation maintain a characteristically top-down approach, which may be further perpetuated by the country’s aspirations to standardize policy formulation across all spheres of government (The Presidency of the Republic of South Africa 2020), a process that may seem positive but could prove ineffective if it is simply performed to meet standards of compliance and obligation without due consideration of the needs of the intended beneficiaries.

The government acknowledges that there is no clarity at a national level in terms of who the lead department dealing with homelessness (Waters 2020). Additionally, concerns around the lack of political will are further evidenced by the minimal support and follow-through in most governmental initiatives directed at addressing homelessness (Batchelor-Hunt 2023; De Beer and Vally 2021a). Moreover, corruption is another element to consider, as its presence could negatively impact the ability to render services to beneficiaries in an already compromised and under-prioritized context (Mabeba 2021). Comparing the two scenarios reveals the unfortunate reality in addressing homelessness. Even if there were effective policies, there is no determined vessel guaranteeing their successful implementation, which means that we are confronted by a twofold drawback in terms of policy and practice.

Policies and their subsequent interventions are usually framed by mainstream legislation and services, without the required sensitivity and inclusionary consideration for vulnerable segments of the population who must overcome significant barriers rooted in stigma and power differentials. In the absence of national policy, the dearth of local research and constrained stakeholder engagement, the uncoordinated provincial and municipal responses to homelessness will most likely continue to fail at the implementation stage. Considering the outlined challenges, an analysis of the current draft and active policy responses to homelessness is warranted and much needed, to identify the strengths and weaknesses, to develop more victim-inclusive, accessible and targeted solutions for people experiencing homelessness.

3. The Policy Analysis Strategy and Methods

Document analysis was used to assess the contents of the local homelessness policies. The method entailed a systematic procedure of identifying and evaluating the documents, which included both printed and electronic material. Like other analytical methods in qualitative research, document analysis allowed for the content to be examined and interpreted to elicit meaning and gain a better understanding of the current responses. Through this process, the researcher was able to formulate practical and valuable recommendations for the creation of more inclusive and protective policy responses (Bowen 2009). The policy documents were searched for online, using various keywords including ‘policy responses to homelessness in South Africa’, ‘homelessness policies’, South African policy responses to homelessness and ‘South African homelessness strategy’.

To ensure that an exhaustive list of policies could be established, news and academic articles were consulted to determine where policies have been drafted, approved and implemented. All the documents included in the analysis were available in the public domain; therefore, no permission was required from gatekeepers or under copyright laws (Oriakhogba 2023). Once a thorough search was conducted, the researcher confirmed that in the absence of a national policy on homelessness, only one province, three cities and one municipality, to varying degrees, have engaged in the development and implementation of policy responses to homelessness (De Beer and Vally 2021a; Groenewald et al. 2023). Accordingly, the six documents from these regions were included in the analysis. The selection criteria were supplemented by the application of four elements to ensure relevance, namely authenticity (documents were retrieved from official government websites), credibility (the policies were formulated by trustworthy sources and obtained from reputable sources), representativeness (the documents were specifically direct responses to homelessness to identify potential gaps and provide valuable recommendations) and meaning (all documents could contribute to an improved understanding of the local policy responses) (Birkan Özkan 2023). While searching for policies, various versions of the same documents were found; however, to maintain reliability and relevance, the most recent versions were used. The policy documents included in the final sample were as follows:

• The Gauteng City Region Strategy on Adult Street Homelessness (2021–2024);
• The City of Johannesburg Policy on Homelessness (2024);
• The Street Homelessness Policy for the City of Tshwane (2015);
• The City of Cape Town’s Street People Policy (2013);
• The Stellenbosch Municipality Draft Street People Policy (2018);
• The City of Cape Town Draft Strategy to address Rough Sleeping (2024).2

Once the documents were sourced and selected, the researcher proceeded to read and interpret the contents. This iterative process combined elements of content and thematic analysis (Bowen 2009). Due to the low number of policies, it was decided that a manual analysis would be appropriate; this allowed for a more nuanced interpretation of the policies. The documents were read repeatedly, and it was discovered that they all essentially covered similar aspects, with slight differences in the names of headings and the placement of information. The analytical procedure entailed an element of familiarization through the side-by-side comparison and scrutiny of all the documents, with careful notetaking to determine which elements were found in all the policies selected for the analysis. Following this, eight themes were identified using a combination of the headings that were found in the majority of the documents, and the policy content was categorized based on likeness and relevance to each theme (Bowen 2009). Once the themes were established and the content mapped out, the main findings were critiqued and aligned with the four dimensions of the HPT developed by Walt and Gilson (1994), which include the content, actors, context and process (Walt and Gilson 1994). Although the HPT was initially designed for the analysis of health sector policies, its relevance extends beyond this sector (O’Brien et al. 2020). Additionally, health policy research is primarily criticized for focusing more on the policy content, which appears to be the case with policy research in general, whilst neglecting the actors, context and processes (O’Brien et al. 2020). Like other research in the Criminology and Victimology space, to foster a thorough understanding of the policies, the four dimensions of the HPT were integrated with the findings from the policy analysis to generate transformative insights (Nunlall 2022), which will be used to guide recommendations for the development of more inclusive, protective and holistic policy responses to homelessness. Combining the document analysis with the dimensions of the HPT proved useful as it allowed for the identification and sensible alignment of the shortcomings present in the respective policy responses to homelessness in South Africa, by focusing on the following:

• Content, which is essentially what the policy is mainly about and reflects all the other elements, covering aspects of objectives, legislation and other guidelines.
• Actors, which include influential figures who actively contribute to the formulation and implementation of the policy.
• Context, which refers to systemic factors and the social, economic, political, cultural and environmental conditions under which the policy will be implemented.
• Process, which includes how policies were initiated, developed, communicated, implemented and evaluated.

The addition of the HPT allowed for an integrated discussion that facilitated a thorough understanding of the policy documents. Its application generated alignments to the four dimensions of the framework to support and drive improvements in both the development and implementation of future policy responses, moving towards more inclusive, protective and holistic responses to homelessness (Nunlall 2022; O’Brien et al. 2020; Walt and Gilson 1994).

Findings from the Policy Analysis

Based on the themes established through the analysis process,

Table 1. Thematic overview of policy analysis.

	Theme	Description
1	Conceptualization of key terms	Explores the identification and definition of key terms
2	Contextualization, background and problem statement	Examines the use of the existing literature to contextualize and problematize homelessness
3	Strategic framework	Assesses how the documents have mapped out the respective vision, goals and objectives
4	Regulatory context	Evaluates the consideration of relevant legislative and policy frameworks the policy will be aligned with
5	Policy parameters and scope	Defines the limits of the policy in terms of what it aims to address and who it aims to cover
6	Relevant actors’ roles and responsibilities and institutional arrangements	Examines the list of stakeholders and their respective duties in the context of the policy and its intended intervention
7	Implementation and action plans	Examines how the policy will be implemented and put into action
8	Monitoring, evaluation and policy review	Details provisions made for policy monitoring, evaluation and review processes

provides an overview of the eight themes and the relevant descriptions. The policy analysis section will be followed by a descriptive appraisal of the policy content within the context of the four dimensions of the HPT.

4. Discussion of Findings and Alignment with the Dimensions of the Health Policy Triangle (HPT)

By mapping out the policy content and placing it into the relevant themes (see Appendix A,

Table A1. Thematic representation of the content in the South African policy responses to homelessness.

	Theme 1: Conceptualization of key terms	Theme 2: Contextualization, background and problem statement	Theme 3: Strategic framework	Theme 4: Regulatory context	Theme 5: Policy parameters and scope	Theme 6: Relevant actors’ roles and responsibilities and institutional arrangements	Theme 7: Implementation and action plans	Theme 8: Monitoring and evaluation (M&E) and policy review
Presentation of information in the policy documents
The Gauteng City Region Strategy on Adult Street Homelessness (2021–2024)	Designated section titled “Definitions”. The strategy conceptualizes 29 key terms in a glossary list. List of acronyms.	Homelessness is contextualized in seven sections in the document. Background Situational analysis Current interventions Causes Challenges Patterns Types The strategy refers to three theoretical models that explain homelessness.	The strategic framework is outlined in four sections: Vision and mission Objectives Principles Pillars of the strategy	Eight legal frameworks and policies are cited.	No reference made to the scope of the strategy or parameters.	Calls for a multi-sectoral, integrated and strong coordinated structure to bring stakeholders together. Local municipality and 11 government departments/ agencies and NPOs are listed stakeholders with assigned roles and responsibilities.	As part of the “service package for the homeless”, seven key areas in intervention services are identified. Outlines its implementation plan through an intake process flow diagram.	Implementation and monitoring vests with the Gauteng Homelessness Forum, guided by provincial and regional DSD and Health. Five-year implementation plan. M&E involves continuous data collection, reporting and evaluation of all activities at all levels. No review period has been set.
	Theme 1: Conceptualization of key terms	Theme 2: Contextualization, background and problem statement	Theme 3: Strategic framework	Theme 4: Regulatory context	Theme 5: Policy parameters and scope	Theme 6: Relevant actors’ roles and responsibilities and institutional arrangements	Theme 7: Implementation and action plans	Theme 8: Monitoring and evaluation (M&E) and policy review
Presentation of information in the policy documents
The City of Johannesburg Policy on Homelessness (2024)	Designated section titled “Glossary of terminology” conceptualizes 36 key terms. Contains a preamble. List of abbreviations and acronyms.	Homelessness is contextualized in the introduction, in the context and background section. Homelessness is further contextualized as a policy problem under the strategic intent and desired outcomes section.	Outlined in the “Strategic Intent and Desired Outcomes”. After the policy problem statement, the section provides additional details relevant to the strategic framework in three sections: Purpose Goals Policy Statement and Intent—Desired Policy Outcomes	Twenty-three international, national, provincial and municipal frameworks are referred to under the “Regulatory Framework” section.	The policy scope and application are outlined with reference to the implementation cohort and intended beneficiaries of the policy and its subsequent interventions.	The policy identifies the DSD and 6 other departments, with 3 subdivisions under public safety, as the key stakeholders and assigns their roles and responsibilities in the context of the policy implementation. Another 8 external stakeholders and their roles and responsibilities are outlined. Public consultation was outlined as an integral part of the policy development process.	The DSD will be responsible for developing implementation and action plans. In line with its implementation, 13 directives and interventions are listed and described. An additional 12 critical factors are listed to ensure the successful implementation of the policy. Only policy that deals with “delegation of authority” and “the contravention of the policy”.	M&E framework aligns with national standards. Evaluation will be based on 7 key areas to assess the annual performance. Set for review every 3 years or when instructed by political principals.
	Theme 1: Conceptualization of key terms	Theme 2: Contextualization, background and problem statement	Theme 3: Strategic framework	Theme 4: Regulatory context	Theme 5: Policy parameters and scope	Theme 6: Relevant actors’ roles and responsibilities and institutional arrangements	Theme 7: Implementation and action plans	Theme 8: Monitoring and evaluation (M&E) and policy review
Presentation of information in the policy documents
The Street Homelessness Policy for the City of Tshwane (2015)	Designated section defines homelessness, its categories and “home”. Glossary list indicated on the content page, but missing from the publicly available version. No list of abbreviations and acronyms.	Homelessness is contextualized in two sections: Introduction, background and purpose Statement of Issues (context of homelessness and institutional challenges)	Three sections dedicated to strategic framework: Purpose (included with introduction and background) Points of departure and guiding principles Vision, mission, aim, objectives and priorities	The points of departure and guiding principles section refers to the Constitution and the Tshwane 2055 Strategy. Policy analysis and its legal framework consulted an additional 32 plans, policies and legislative frameworks.	No designated section referring to the parameters or scope of application, but it does refer to key exclusions under its definition section, which is indicative of its intended scope and application: “…This Policy is focusing on street homelessness and not on people living in informal settlements or sub-standard housing, although there are close links between these living conditions.”	Proposes institutional arrangements involving local government, civil society, private sector and institutions of higher education to facilitate successful implementation. Stakeholders include Tshwane partnership for the homeless, an interdepartmental task team: City of Tshwane, Tshwane Homelessness Forum, the academic community, the private sector and the 5 government departments.	The policy action plan flows from the policy directives (priorities). It sets out 5 priority areas and tabulates the programs, strategic indicators and responsible actors for implementation. Proposes a methodology for implementation of 7 elements to ensure effective responses rooted in a community of practice model. Provides detail on resources and funding for implementation.	Quarterly, annual and biennial reviews in consultation with other stakeholders. Policy review after 2–3 years, informed by the methodology and shared learning that takes place within the Community of Practice. Aims to assist in the development of coherent provincial and national frameworks.
	Theme 1: Conceptualization of key terms	Theme 2: Contextualization, background and problem statement	Theme 3: Strategic framework	Theme 4: Regulatory context	Theme 5: Policy parameters and scope	Theme 6: Relevant actors’ roles and responsibilities and institutional arrangements	Theme 7: Implementation and action plans	Theme 8: Monitoring and evaluation (M&E) and policy review
Presentation of information in the policy documents
The City of Cape Town’s Street People Policy (2013)	Designated section for definitions. Twenty key terms in a glossary list. List of abbreviations and acronyms.	Contextualizes homelessness in a section titled “Problem Statement”.	Three sections related to its “Strategic Framework”: Desired outcome Strategic intent - Integrated Development Plan - City Development Strategy - Social Development Strategy Policy directives	Cites 4 instruments in a section titled “Regulatory Framework”.	Section titled “Policy Parameters” that provides details regarding its exclusions, intended scope and application.	Provides key responsibilities for the Street People Program, SDECD Directorate and the Displaced People’s Unit, Safety and Security as stakeholders. Provides a list of 10 internal stakeholders and 8 external stakeholders who will be consulted.	Guided by 7 broad policy directives, implemented in collaboration with stakeholders. MOUs will be signed and put in place to ensure quality service delivery.	Annual implementation plans to track achievement of objectives over short-, medium- and long-term intervals. Tools will be used by the internal monitoring team to regularly report on policy performance. Stakeholders can initiate efficacy checks. Policy review and updated every 2 years or if evidence is provided that the outcomes are not being met.
	Theme 1: Conceptualization of key terms	Theme 2: Contextualization, background and problem statement	Theme 3: Strategic framework	Theme 4: Regulatory context	Theme 5: Policy parameters and scope	Theme 6: Relevant actors’ roles and responsibilities and institutional arrangements	Theme 7: Implementation and action plans	Theme 8: Monitoring and evaluation (M&E) and policy review
Presentation of information in the policy documents
The Stellenbosch Municipality Draft Street People Policy (2018)	Designated section for 13 definitions. “Home” is defined in the problem statement section. List of abbreviations.	Contextualizes homelessness in a “Problem Statement”.	Five sections relate to its Strategic Framework: Purpose and focus Desired outcomes Declaration Policy and strategic intent Policy directives	Cites 5 instruments in a section titled “Regulatory Framework”.	Includes a section titled “Policy Parameters” that provides details regarding its exclusions, intended scope and application.	Roles and responsibilities provided for the Community Development section, Community and Protection Services Directorate (main implementer) and Protection Services Department. An additional 6 internal and 10 external stakeholders (without roles and responsibilities). Roles and responsibilities of 7 categories of stakeholders provided.	No designated section that outlines implementation or action plans; however, in the policy directives section, it provides details regarding 4 strategies, guided by possible actions, and a blank column intended to indicate the relevant role players for the specified actions.	No details regarding M&E. To be reviewed and updated every 2 years or if evidence shows that the outcomes are not being met. The Community Development Section may be consulted regarding the efficacy of the policy and the extent to which it is reaching its aims.
	Theme 1: Conceptualization of key terms	Theme 2: Contextualization, background and problem statement	Theme 3: Strategic framework	Theme 4: Regulatory context	Theme 5: Policy parameters and scope	Theme 6: Relevant actors’ roles and responsibilities and institutional arrangements	Theme 7: Implementation and action plans	Theme 8: Monitoring and evaluation (M&E) and policy review
Presentation of information in the policy documents
City of Cape Town Draft Strategy to address Rough Sleeping (2024)	Designated section for 11 definitions. Additional definitions provided in the background section for homelessness, rough sleepers (categories and demographic factors). List of acronyms. Executive summary.	Homelessness and, more specifically, rough sleeping contextualized in 4 sections: Introduction Background Contextual issues Problem statement subdivided into 5 domains: Legal and regulatory alignment Institutional responsibilities Socio-economic and community issues Data scarcity Funding and resources	The Draft Strategy has four sections related to the strategic framework: Strategic context Desired outcome, principle and objectives, further subdivided: - Vision - Principles - Objectives Strategic shifts Approach of the strategy	Legal and Regulatory Context refers to constitutional guidance on provisions related to homelessness and lists a total of 27 considerations which fall within a national, provincial and local government context.	Demarcation of policy intent, further providing details of what actions fall within and outside of the scope of implementation.	No designated section for stakeholder identification and role allocation. However, as part of its implementation plan, it outlines its strategic focus and aligns it with specific departments and stakeholders, clearly demarcating their roles and responsibilities.	Three strategic focus areas involve prevention, support and reintegration and utilization of non-city actors. Each focus area deals with the problem areas identified in the problem statement; the document outlines its intended measures to address the problematic areas and aligns each area with the relevant stakeholders and their required contribution.	Plans to develop M&E components. Regular evaluations and reporting will ensure that the strategy fulfils its intended purpose. To be reviewed every 5 years, or as deemed necessary.

), it became evident that the documents have a similar structure and approaches to addressing homelessness in the respective geographies. Following the policy analysis and identification of strengths and weaknesses, the alignment with the HPT allowed for an improved understanding of the local homelessness policy space to provide valuable recommendations to advocate for the creation of inclusive and protective responses (Nunlall 2022). The following discussion also demonstrates how the four dimensions of the HPT interact dynamically and how they can be used to reveal the cyclical pattern of homelessness and its resolution. The context explains where the need for the policy originated and under which conditions it will be implemented, while the origin of the need for policy directly informs the content, and the content shapes the context in which the policy will be implemented. Jointly, the content and the context will lead to the mobilization of the relevant actors, whose ability to incite change will be influenced by the policy content guiding them and the context in which they are expected to function. Lastly, the process dimension will address the ways in which the policies were initiated, developed, communicated and implemented, which are directly influenced by the context, content and actor dimensions.

4.1. Context

The context dimension encompasses the origin of the need for policy intervention in conjunction with the systemic, social, economic, political, cultural and environmental factors under which the policy will be implemented (O’Brien et al. 2020; Walt and Gilson 1994). Homelessness remains a seemingly permanent and prominent fixture in many contexts around the world. Accordingly, the UN has called for all member states to commit to the eradication of homelessness by 2030 (United Nations 2016; Pophaim and Peacock 2021). South Africa, notorious for its dire socioeconomic conditions and levels of inequality, is not exempt from this reality; the threat of homelessness continues to be a looming presence in the lives of many citizens (De Beer and Vally 2021b; Mashau 2017; McKeever 2024; Pophaim and Peacock 2021). As a UN member state, South Africa is legally obligated to consult, integrate and uphold the overarching frameworks around social justice, encompassing human rights values and the Sustainable Development Goals (SDGs).

Accordingly, the Constitution of the Republic of South Africa (1996) stipulates that people’s needs must be responded to and that the public must be encouraged to participate in policymaking. To address these challenges, the South African government has several policy levers at its disposal to promote the creation of employment opportunities and improve the socioeconomic conditions for its citizens (The Presidency of the Republic of South Africa 2020). Despite the visibility and continual rise of homelessness in South Africa, active responses remain invisible in government policy (De Beer and Vally 2021c). The COVID-19 pandemic exposed remnants of apartheid capitalism, revealing the historic political and institutional fault lines and demonstrating just how neglected homeless populations are and how many cities were unable to produce rapid responses or sustain collaborative solutions that took place during the hard lockdown (De Beer and Vally 2021a; Pophaim 2022). People experiencing homelessness were disproportionately affected by the pandemic, and the need for many of the previously discussed solutions became even more apparent (Casey and Stazen 2021). Confronted by a bleak contextual environment, the development of South African policy responses to homelessness remains constrained and under-prioritized.

In the absence of a national homelessness policy framework, only one province, three cities and one municipality have attempted to introduce policy responses, all at varying degrees of implementation, widely considered uncritical and largely ineffective. Due to this large implementation gap, homelessness continues to exist in what is best described as a policy vacuum (De Beer and Vally 2021a; Groenewald et al. 2023). The implications of the broader systemic issues are further compounded by the dearth of local research, which hampers the much-needed understanding for improved responses (De Beer and Vally 2021b; Sadiki and Steyn 2021). Concerningly, perhaps the most significant drawback is the general absence of government as a pivotal stakeholder, illustrated by the lack of political will and general support (Batchelor-Hunt 2023; De Beer and Vally 2021a, 2021b; Sadiki and Steyn 2021), which has detrimental effects on the prioritization and resolution of homelessness in South Africa.

With no national policy and the issue still at the green paper stage, homelessness currently receives little to no attention in annual budgets and planning within government departments, which is indicative of a combination of poorly contextualized accounts of the extent of homelessness and broader systemic issues. Street Homelessness Policy for the City of Tshwane, for example, was approved, four years later (in 2019), with no budget allocated for its implementation (De Beer 2020; De Beer and Vally 2021a). Furthermore, the constrained contextual environment and broader systemic issues inevitably cascade down to the grassroots level, negatively shaping realities and responses. In the absence of government support, South African communities must navigate adverse realities characterized by a non-profit sector with limited resources, high unemployment rates, a housing crisis, high rates of corruption and poorly implemented policies and legislation (De Beer and Vally 2021b; Marutlulle 2021; Naidoo 2010; Pophaim and Peacock 2021; Trading Economics 2024). Homelessness is a highly politicized matter and often reflects a specific political orientation, instead of the reality of deprivation (Sadiki and Steyn 2021). This position greatly impacts how homelessness is perceived and addressed and is currently reflected in a highly polarized manner, presented in a mixture of punitive, compassionate and the less frequently used developmental approaches (Hopkins et al. 2024; Owadally and Grundy 2023). The implications will be expanded on in the subsequent sections; however, it is important to highlight that the context in which the policies are implemented is characterized by a host of practical and ideological barriers, including the presence of negative perceptions and stereotypes that tend to constrain service delivery even more and often lead to unsavory interactions between service providers and people experiencing homelessness (Mahlangu and Kgadima 2021; Muleya and Mlilo 2023; Weng and Clark 2018; Wentzel and Voce 2012), which is a cause for concern as it directly impacts the well-being and infringes on the rights of people experiencing homelessness. Furthermore, the importance of this section cannot be overstated, as most of the policy documents have ambitiously established directives that fail to consider the constrained and limited contextual environment, which is one of the harsh realities of contemporary South African society.

4.2. Content

The content forms the heart of the policy and essentially includes what it is about, while covering the objectives, legislation and other guidelines that directly inform and shape the policy directives and interventions (O’Brien et al. 2020; Walt and Gilson 1994). Although policy content does not have to be overly prescriptive, it must clearly outline the intended scope and reach and should therefore be free of ambiguities. Health policy research is often criticized for overemphasizing the content while overlooking the actor, context and process dimensions that shape and provide an improved understanding of why policy outcomes fail to emerge (O’Brien et al. 2020; Walt and Gilson 1994). In an effort the mitigate this, the current analysis aims to provide an integrated alignment of the content with the other dimensions of the HPT to provide critical and valuable policy recommendations.

4.2.1. Contextualization of the Policy Problem

The analysis revealed both strengths and weaknesses in terms of the contextualization of homelessness as a policy problem, as all of the documents framed the issue in varying degrees of comprehensiveness. The Street Homelessness Policy for the City of Tshwane included a section on the institutional and contextual challenges that could potentially hamper effective implementation; consequently, these considerations did not extend to the operational sections of the document. Similarly, the Gauteng City Region Strategy on Adult Street Homelessness outlined the challenges of homelessness, which are not prevalent in the framing of interventions. Stemming from the general dearth of local research on homelessness (Pophaim and Peacock 2021; Pophaim 2021; Sadiki and Steyn 2021), a recurrent limitation in the policies is that the contextualization sections are mainly informed by outdated information and unofficial population estimates.

Concerningly, the outdated and narrow portrayal of the problem could significantly impact the quality and contemporaneity of the contextualization of homelessness and impede the ability to develop effective evidence-based policies and interventions (Obioha 2022). The City of Cape Town Draft Strategy to address Rough Sleeping highlights data scarcity as a shortcoming within the homeless or rough sleeping sector; however, the notable lack of accurate data and failure to acknowledge it in the other documents will likely result in an unclear understanding of the problem. The implication of the shortcoming, amongst others, is that an adequate baseline cannot be established to inform budget and resource allocations (De Beer and Vally 2021b; Sadiki and Steyn 2021). The Street Homelessness Policy for the City of Tshwane serves as a clear illustration, attributed to broader systemic issues, inaccurate contextualization or both; the policy was only approved four years following the publication of the revised version (in 2019), without a budget allocated for its implementation (De Beer 2020). It is surprising and concerning that although data scarcity is repeatedly framed as a problem, policy development seemingly proceeds without efforts to address the problem. Despite its importance and without disregarding its inherent value, the quantification of homelessness requires a delicate balance, since the accuracy of the population size can provide a better understanding of the extent; the risk remains that the over-quantification might mask the variation present in the population (Desmond et al. 2017). Failing to consider this balance would perpetuate the dominant view that the homeless are a homogeneous group that does not require a more nuanced approach.

Maintaining this course of action means that policymakers will continue to default to generic policy interventions and not progress to the evidence-based, contextually sensitive responses that are required to meet the diverse needs of people experiencing homelessness (Desmond et al. 2017; Groenewald et al. 2023). The policy documents note the generally accepted pathways into homelessness, but if left up to interpretation, could result in a prescriptive application and restrictive conceptualization of homelessness and misdirect the eligibility for the interventions outlined in the policies (Obioha 2022). To illustrate the importance of comprehensiveness, the City of Cape Town Draft Strategy to address Rough Sleeping attempts to localize the problem and direct the policy and intervention to people who are sleeping rough. The strategy cites local and precise data as an inherent challenge but proceeds by contextualizing rough sleeping as a category of homelessness. As part of the public commentary process, the strategy has received criticism for being less concrete about addressing homelessness (GroundUp and Hirsch 2024), considering that it is the intended replacement for the City of Cape Town’s Street People Policy. Rough sleeping is merely a manifestation of homelessness and is not necessarily the most representative category, and therefore, limiting a strategy to just one category may be considered failing to holistically address the issue of homelessness (United Nations 2025), which is especially problematic considering the preventative stance the City of Cape Town Draft Strategy to address Rough Sleeping assumes.

All the policies, besides the City of Cape Town Draft Strategy to address Rough Sleeping, refer to the distinct rural and urban dynamics of homelessness. However, the contextualization and intervention are primarily focused on the street-based urban population, which could serve as a critique for the holistic intent of the City of Cape Town Draft Strategy to address Rough Sleeping, meaning that it is only concerned with addressing the publicly visible portion of the population, which contradicts its preventative stance but coincides with the focus on those who are sleeping rough. Contextual factors related to beneficiary and service provider consultation are another aspect that requires improvement. Most of the information presented is based on secondary and structurally informed data and lacks the reflective expertise of stakeholders and the lived experiences of the intended beneficiaries. A final consideration in terms of the contextualization of the problem is the silence around the victimization and disenfranchised status of people experiencing homelessness. Confronted by social exclusion, marginalization and victimization, any intervention directed at addressing homelessness is expected to remain cognizant and include services and infrastructure that mitigate these barriers (De Beer and Vally 2021b; Ellsworth 2019; Pophaim 2022). Four of the policies explicitly mention vulnerability to harm and discrimination; however, it is insufficiently elaborated on and not reflected in the policy aims and interventions. The issue of vulnerability and experiences of victimization is often overshadowed by the vulnerability of at-risk populations, who may end up on the street. Additionally, the counter-narrative, which is their involvement in criminal activities, usually outweighs considerations around the victimogenic traits that are inherently associated with homelessness.

To illustrate the importance of its contextualization, experiences of victimization lead to an increase in vulnerability, which is often associated with existing challenges of disenfranchisement and stigmatization. This is further substantiated by the City of Johannesburg Policy on Homelessness, which defines vulnerable persons as “…segments of society that are at a higher risk of experiencing harm, discrimination or marginalization…These individuals often face barriers in accessing resources, service and opportunities that can further exacerbate their vulnerability”. The presence of these negative outcomes could essentially hamper access and delivery of services and the general efficacy of the policy outcomes. While the policies do show awareness related to the vulnerability and experiences of victimization amongst the homeless, the issue of inclusivity would depend on whether the policy and its interventions consider and accommodate the diverse needs and circumstances of the affected individual(s).

4.2.2. Defining and Conceptualizing Key Terminology

The conceptual layout differs significantly between policies; for instance, some policies include an executive summary, a preamble and introduction, while others are not as detailed. Similarly, some policies provide an extensive glossary, while others only have a few key terms. The use of these introductory tools could prove useful as it enhances the impact, readability and usability of the document. In a complex environment such as this, it may be useful to standardize the introductory tools used in policies related to homelessness, thereby ensuring that there is no misinterpretation or misalignment regarding important concepts related to the phenomenon itself, service providers and the range of services offered across different regions. It is to be expected that some regional or contextual differences may influence the definitions slightly, but the standardization process can accommodate flexibility without being overly static.

Moreover, with the inclusion of causal theories, the Gauteng City Region Strategy on Adult Street Homelessness masterfully debunks common misconceptions associated with homelessness, which often perpetuate negativity, blaming and ill-treatment. By outlining that “…these people need neither blame, nor special treatment. What they urgently need is not mercy, but respect to their right to housing and social protection”, it underscores the need to reframe current policy responses, not to offer special treatment but to simply provide inclusionary, protective and accessible services to people experiencing homelessness. For the purposes of the current discussion and alignment of the policy content, the conceptualization of the following key terms will be approached: home, homelessness (including street homeless person, street people and rough sleepers) and vulnerable people.

In a critical appraisal of the previous version of the City of Tshwane Policy created in 2013, Mashau (2017) highlights the need to include the definition of a ‘home’ in homeless policies, and five of the six policies have made provision for its inclusion. It is further argued that the definition should extend beyond the idea of physical shelter or the fulfilment of basic human rights (Mashau 2017). Towards the development of a more suitable definition for homelessness, it is useful to highlight what the individual is essentially lacking, with reference to the concept of having a ‘home’ and what it means to the individuals. The City of Johannesburg Policy on Homelessness, for example, defines a home as “… a place where one lives permanently, especially as a member of a family or household and embodies the ideas of comfort, belonging, identity and security”. In addition to this, the Stellenbosch Municipality Draft Street People Policy contends that “…we cannot understand homelessness by only focusing on the concept of home or shelter. It is important that we also consider the psycho-socio economic drivers and outcomes of homelessness…”.

Based on these statements, it is evident that the static definitions employed in the policy documents are mostly inadequate, due to the central focus on the concept of lacking a home or shelter. The formulation of a universal definition is a persistent and recurrent issue in research, policy formulation and the intervention space. The analyzed policies reflect the contextualization gap discussed previously, as the static and restrictive definitions perpetuate the homogeneous stereotype commonly misattributed to people experiencing homelessness, which has significant implications for the intervention space and deciding who is eligible for support (Obioha 2022; Pophaim and Peacock 2021). The main theme across the policy documents, with reference to the formulation of a definition, includes “…those that live on the street”, with a list of alternative areas, “…such as pavements, under bridges or any area that cannot be regarded as a home”. The basic definitions include “…people who fall outside of the viable network of assistance and therefore cannot provide themselves with shelter at a given time or place”.

By emphasizing street homelessness and rough sleeping, the policies perpetuate a conceptual ‘othering’ and exclusion based on how the definitions will be interpreted to determine the scope of the policy and its interventions. While acknowledging the link between street homelessness and informal housing, the policies do not aim to address all categories of at-risk and absolute homelessness, thereby rendering the preventative stance obsolete. Three of the documents define homelessness as the “state of being”, while also referring to a street homeless person or a rough sleeper, which intersects with the definition of homelessness already provided. Generally, the distinction would serve as clarification in terms of the scope of the policy and its intended beneficiaries. However, the similar yet problematic nature of the definitions could become confusing for stakeholders in the enforcement of the policy directives and the development of departmental mandates. The extant definitions would have to be integrated and holistically formulated to include all relevant aspects in relation to the scope of the policy, which will also remove any unnecessary confusion.

The Street Homelessness Policy for the City of Tshwane includes the categorization of homelessness, referring specifically to a large group of near-homeless individuals, living on the verge of homelessness, but remains selective with who will be covered by the policy and its intended interventions, as it explicitly excludes the inadequately housed. Given the nature and complexity of homelessness, a more inclusive policy lens is required—one that recognizes the fluidity between housing insecurity and actual homelessness. If interventions only target those who are visibly homeless, the escalating vulnerabilities of near-homeless populations may go unaddressed, increasing the likelihood of street-based homelessness. The identified inconsistencies can be attributed to the inadequate contextualization of homelessness compounded by the broader systemic inadequacies. In the categorization of homelessness, the Street Homelessness Policy for the City of Tshwane makes mention of factors, such as the legacy of the past, unemployment rates, political displacement, housing backlogs and the destruction of family units, that contribute to the changing face of homelessness and lead to marginalization. The statement directly influences the definition of homelessness and the scope of the intended policy. It is concerning that these aspects do not appear in the other policies, as this implies that the directives will not consider factors that are bound to increase systemic barriers reinforced by the invisibility, marginalization and social exclusion of people experiencing homelessness. While a principled line must be drawn to distinguish homelessness from broader housing issues, the boundary should be informed by a nuanced and inclusive contextualization—one that anticipates and adequately addresses housing insecurity as a pertinent pathway to absolute homelessness.

The City of Johannesburg Policy on Homelessness refers to homelessness as “… the state of being displaced and includes displaced persons who lack housing, a fixed, regular and adequate night-time residence” and then proceeds to define a street homeless person as “…a displaced person, and is an individual who lacks housing, a fixed, regular and adequate night-time residence. These are people who live on the streets or pavements or open spaces, under bridges, in carports, plastic containers, bushes or next to rivers or spruits, who fall outside the viable social network of assistance and are unable to provide themselves with shelter at any given time or place”.

The conceptual convergence is problematic; through its interpretation, according to the policy, homelessness will only be based on the absence of a fixed, regular and adequate night-time residence and street homelessness will only be linked to one of the alternative spaces included in the definition. Similar to the City of Cape Town’s Street People Policy, the Stellenbosch Municipality Draft Street People Policy (refers to street people as “…people who for any reason use the outdoors as a place of abode for a lengthy period of time”. Referring to the use of the outdoors as a place of abode, would, as a standard interpretation, exclude the use of auxiliary structures such as tents, bridges, carports and plastic containers, which essentially provide cover as cited in the Gauteng City Region Strategy on Adult Street Homelessness and the City of Johannesburg Policy on Homelessness. These inconsistencies highlight the necessity of constructing less static, more dynamic definitions for the purpose of policy formulation.

The City of Cape Town Draft Strategy to address Rough Sleeping argues that homelessness is often defined broadly “…by including people who lack access to adequate housing conditions as being homeless” and by using a narrower approach “…referring to people who live on the street and engage in rough sleeping, only”. While acknowledging the varied approaches, the strategy aims to “…define homelessness in a way that is meaningful across the world, resonating in both the Global South and the Global North”. The strategy further considers that the United Nations defines homelessness as “…a material form of deprivation; homelessness refers to an inability of people to enjoy permanent accommodation”. It is further highlighted that homelessness often means that individuals lack access to other human rights such as work, healthcare, social security, privacy and education. Based on these discussions, the city defines homelessness as “… a concept referring to people without a regular, safe, secure and adequately sheltered place to live in”. Cognizant of the housing challenges and extent of informality in Cape Town, the strategy narrowly focuses on addressing ‘rough sleepers’, referring to “…Individuals regarded as people without accommodation, often nomadic, more specifically people sleeping on the streets or open spaces, buildings not intended for habitation, people sleeping in vehicles or the like and pavement dwellers in makeshift structures. Further included in this definition are people living in temporary accommodation such as sleeping in night shelters, safe spaces or similar temporary accommodation”.

Following public comment, the term rough sleeper was identified as being dehumanizing and a negative label that perpetuates stigmatization. It was further criticized for reflecting an uncaring disposition to the vulnerable by the city. The term was later changed to ‘sleeping rough’ (Booysen 2024). The City of Cape Town Draft Strategy to address Rough Sleeping further explores the classification of rough sleepers and uses it to support the notion that rough sleepers are not homogeneous and that a one-size-fits-all approach is unlikely to have any real impact. Individuals tend to experience rough sleeping differently and are in this position for varied reasons. While the city acknowledges that they do not have accurate data on how many people fall within the various categories of rough sleeping, these contextually specific classifications are an essential step in developing more accurate policy responses, as they portray a deeper understanding of why people are on the street and how best to assist them. While considerable progress has been made, there are still additional elements that can be considered towards the development of a more holistic working definition for homelessness. Historically, perceptions of homelessness have been shaped by socio-cultural and political trends. The process of social construction, which is the creation of meaning, has contributed to definitions in policy that are based less on empirical knowledge and more on public perceptions of homelessness (Cronley 2010). As a result, the definitions formulated thus far embody a more top-down approach and do not reflect the narratives of people experiencing homelessness, thereby inadequately capturing the full extent of their lived experiences and immediate needs. These static definitions often draw more attention to the state of homelessness, which is the lack of shelter, while neglecting the conditions or circumstances that characterize and often prolong the experience and would be conceptualized, contextualized and prioritized alongside the provision of a stable and adequate shelter.

The definition of vulnerable persons is currently used to “…refer to segments of society that are at higher risk of harm, discrimination or marginalization due to various factors such as age, gender, persons with disabilities, homeless and service users recovering from substance abuse. These individuals often face barriers in accessing resources, services, and opportunities that can further exacerbate their vulnerability”. Highlighting vulnerability in the context of homelessness is extremely important, and it should be included in all of the policy documents as it reflects the required progress towards inclusivity (De Beer and Vally 2021b). In the context of the policy documents, the term vulnerability is also often used to refer to the segments of the population that can be categorized as at risk of or near homelessness. To avoid confusion, it is suggested that the concept refers to the degree of vulnerability within the context of homelessness but clearly distinguishes between the associated risk of becoming homeless and the vulnerability of experiencing victimization, stigmatization, harassment, discrimination, exploitation and social exclusion.

4.2.3. Regulatory Contextualization

Homelessness exists within a vast policy and legislative environment; while there are not many international or local frameworks that directly mention or respond to homelessness, most of them do possess the ability to address related issues such as psychosocial services, poverty and the lack of shelter. However, concerns have been raised regarding the constrained application and implementation of the existing frameworks (Naidoo 2010; Pophaim and Peacock 2021). All of the documents under review have dedicated sections in which the regulatory considerations are mapped out in relation to the purpose and plans for implementation. Notably, the Constitution of the Republic of South Africa (1996) features in all of the policies; while others allude to the consideration of human rights principles, only the City of Johannesburg Policy on Homelessness explicitly cites the Universal Declaration on Human Rights. The absence of a national policy framework is evident, as there is no coherence regarding the regulatory considerations cited in the policy documents, which was well articulated in the City of Cape Town Draft Strategy to address Rough Sleeping: “…an overarching national framework to fully address homelessness, including rough sleeping and its effects, has never existed in South Africa. This constitutes a large policy deficit, which has led to incoherent homelessness policy and strategy at all government levels”.

“… Apart from this policy gap, National Government’s response to homelessness can also be characterized as being bureaucratically constrained and lacking in innovative and proactive measures as well as funding to address the issue. It is within this context that the city, has spent significant effort, as well as funding, to address rough sleeping”.

“…This policy deficit has also resulted in uncoordinated approaches of service providers, NGOs and government departments in dealing with homelessness.”.

Therefore, it would be useful to establish a level of uniformity regarding regulatory considerations to ensure that all associated aspects of homelessness are considered and addressed comprehensively. A crucial consideration would be to establish a balance between frameworks that address the criminogenic elements of homelessness and those that cater to the victimogenic and protective needs of the population. The policy documents refer to the municipal by-laws relevant to their respective geographies, which are read against the Criminal Procedure Act (51 of 1977) and give effect to penalties for ‘any offences’ that are in violation of the law, which perpetuates the use of the dominant punitive measures to address homelessness (Killander 2019; Owadally and Grundy 2023). With the improved contextualization of the experiences of victimization, policies need to be reframed and aligned to cater to the victimogenic needs of this vulnerable population. The City of Johannesburg Policy on Homelessness and the Gauteng City Region Strategy on Adult Street Homelessness are the only policies that refer to the indigent status of homelessness, while the City of Johannesburg Policy on Homelessness is the only one that refers to the Promotion of the Equality and Prevention of Unfair Discrimination Act (4 of 2000), while references to the Service Charter for Victims of Crime or the Prevention and Combatting of Hate Crimes and Hate Speech Act (16 of 2023) remain absent. This is a concerning issue, considering the purpose of the policies and how it reflects a rather oppressive orientation, instead of one that is centered around the well-being and upliftment of this vulnerable population.

4.2.4. Outlining the Strategic Intent, Stated Purposes and Problematic Phrasing

This section refers to the purpose and strategic framework of the policies, which serve as the foundation element of a policy document, since they establish focus and guidance, thus ensuring that the policy is aligned with its intended aims. The purpose of Street Homelessness Policy for the City of Tshwane is to “…ensure the effective implementation of integrated mechanisms to address street homelessness”. The Gauteng City Region Strategy on Adult Street Homelessness, under its vision and mission, commits to creating a “…Gauteng City Region free of street homeless and everyone has a safe place to call home and is self-reliant”, with its mission being “…to prevent and eliminate street homelessness through [the] provision of integrated services to affected persons and families”.

The Stellenbosch Municipality Draft Street People Policy outlines that its purpose and focus are to “…manage street people as part of an integrated and holistic approach to community development” and to define how the municipality can play a meaningful, enabling, collaborative and facilitating role in managing the social and economic challenges that currently confront people experiencing homelessness. The City of Cape Town Draft Strategy to address Rough Sleeping provides an executive summary that highlights the purpose of the policy as primarily being to reduce “…Rough sleeping and to ensure the constitutionally enshrined right of human dignity and facilitate an all-of-society approach through partnerships and collaboration”.

Although the more recent policies appear more detailed, an inherent flaw identified in the critical appraisal of the previous version of the City of Tshwane Policy by Mashau (2017) remains apparent in all of the analyzed documents. The overall purpose of the policies advocates for the enhancement of the lives of the homeless through achieving the positive elements outlined in the policy directives. However, the phrasing used in the documents represents a critical gap and may be indicative of the negative perceptions towards people experiencing homelessness. Much of what is presented in the purpose statements, which is meant to guide the action of the policies, can be perceived as oppressive, criminalizing and often counterproductive (Mashau 2017). The Street Homelessness Policy for the City of Tshwane contains an ambiguous purpose statement as it does not specifically delineate what the integrated mechanisms are and what actions would constitute effective implementation. Furthermore, the restricted focus of the policy on street homelessness only implies that the policy scope and reach will be limited to those already experiencing homelessness and perhaps only include individuals who reside on the street.

Realistically, a policy on homelessness should be holistic and broad enough to address the entire spectrum of homelessness in all of its forms, stages and categories—extending to those living in egregious conditions and on the verge of homelessness. Similarly, the City of Johannesburg Policy on Homelessness presents an ambiguous and slightly repetitive list as it outlines the policy purpose:

• Serve as an overarching policy framework for homelessness within the City of Johannesburg.
• Promote respect for the homeless and their inherent dignity.
• Provide a broad outline of the responsibilities and accountabilities for various stakeholders including practitioners,
• Provide homeless people with reasonable solutions including accommodation for effective governance,
• Promote, protect, and ensure the equal enjoyment of human rights and fundamental freedoms for homeless people in the City.
• Allow for data collection mechanisms to enhance future policy interventions.

The first statement lacks clarity regarding the characteristics that make it an overarching policy; the policy goals and objectives that follow are detailed but do not represent an exhaustive list of all challenges associated with homelessness. Therefore, it cannot be considered an overarching policy. The second and fifth points are redundant, the fifth point is more detailed, and one would assume that “…the promotion of respect and inherent dignity” should be included as part of the “enjoyment of human rights and fundamental freedoms”. Cognizant of the current treatment of the homeless, the document, as part of its purpose, should detail how punitive and criminalizing strategies, which are in direct contravention to the current nature of the purpose statement, will be avoided, as most of the strategies for reducing the visibility of homelessness (punitive and criminalizing measures) can and should be regarded as a gross violation and disregard of the human rights of people experiencing homelessness.

In general, the policies superficially build their purpose on the known shortcomings around capacity and resources in the country. The point regarding the provision of reasonable solutions, including accommodation for effective governance, is problematic, considering the housing shortage nationwide (Marutlulle 2021). The purpose statement further aims to provide an outline of the responsibilities for various role players and stakeholders. Based on several contextual flaws and amidst uncertainty within government regarding who the custodians of homelessness are (Waters 2020), it is unclear how the policy aims to avoid the misalignment of roles, overlooked and excluded sectors, wasted resources and ineffective actors, all of which will hamper the effective implementation of the policy. Lastly, the City of Johannesburg Policy on Homelessness allows for data collection mechanisms to enhance future policy interventions, which is already inherently flawed due to the constrained policy approval and implementation process. Using the City of Johannesburg Policy on Homelessness as an example, the draft-to-approval process took approximately two years (2022–2024), with minimal to no changes to the contextual information. The implication of the delay is that the approved policy is based on outdated information, and given the dynamic nature of homelessness, the proposed interventions will most likely be obsolete, within an already altered landscape, as they would not have been designed to address any new developments. However, as the critique relates more to the policymaking process, it is further expanded on and concluded under the process dimension.

The inappropriate phrasing in the purpose of the Stellenbosch Municipality Draft Street People Policy problematically states that it aims to “…manage street people”, which could inadvertently be interpreted as meaning that the homeless are to be viewed as a problematic group who lack agency and have to be managed to alleviate the burden on the rest of society in order to achieve community development. The interpretation of the statement could lead to stakeholders and service providers disregarding the fact that people experiencing homelessness are human beings, with rights, needs and the potential to do and become more. Finally, while addressing the omission of a policy purpose in the 2013 version, the City of Cape Town Draft Strategy to address Rough Sleeping, based on the purpose, is primarily geared towards reducing “…rough sleeping”, which can be regarded as another conceptual limitation within the homelessness policy space.

The City of Cape Town Draft Strategy to address Rough Sleeping acknowledges the complexity of rough sleeping and how it extends to other categories of homelessness. By virtue of inappropriate phrasing, the policy and its subsequent interventions are bound to exclude other categories of homelessness, for example, those who are at risk or marginally street-based, who may eventually end up in the “rough sleepers” category if not provided equal support, which the strategy claims to be cognizant of. Furthermore, none of the policies overtly mentions considerations for protection, safety and security against victimization as part of its purpose, thereby inadvertently perpetuating the silence around the vulnerability to victimization of the homeless and reducing any formal acknowledgment and action for redress. Although a purpose statement does not have to be overly prescriptive, it should be holistic, realistic, mindful and adequately structured so that it captures all the problem areas associated with the intended beneficiaries. Any policy document that fails to do so will likely, along with its subsequent interventions, remain constrained and largely ineffective. Based on this appraisal, one can clearly see that most of the policies resort to default and generic purpose statements, which are reflective of the flawed conceptual and contextual influences identified in the current appraisal.

The impact of the constrained contextual influences is further evidenced by the inclusion of narrowly defined scope and parameters, which effectively restrict the reach and dilute the broader strategic intent of most of the policies. While many policies cite proactive and preventative solutions as their primary aim, the scope statements often limit the application to individuals already experiencing (street-based) homelessness. This inadvertently excludes those at risk of homelessness, thereby undermining the preventative objectives set out in the respective policies. For example, the Street Homelessness Policy for the City of Tshwane states that its vision is to “…complete integration of street homeless people into the city of Tshwane’s mainstream society through activities and interventions aimed at the prevention and management of street homelessness and the facilitation of sustainable pathways out of street homelessness”. To address this, broader scope and parameter sections are required in policies. However, the Street Homelessness Policy for the City of Tshwane simultaneously clarifies that “…this policy is focusing on street homelessness and not on people living in informal settlements or sub-standard housing, although there are close links between these living conditions”. The narrowing of scope reveals a tension—not necessarily a contradiction, but perhaps a misalignment—between the preventative aspirations and the operational parameters of the policy.

Similar issues appear in the City of Cape Town’s Street People Policy and the Stellenbosch Municipality Draft Street People Policy, both of which refer to the prevention of at-risk segments but set parameters to only include street people and exclude street children (who could potentially end up becoming street adults if no interventions are made). In contrast, the City of Cape Town Draft Strategy to address Rough Sleeping offers a more integrated approach, acknowledging the need to support those at risk and currently in need: “…this strategy, in trying to address the existent problem of homelessness is applicable to those who currently engage in rough sleeping, as well as communities who at risk of migrating to the street, in order to prevent the expansion of rough sleeping”. While the revised City of Cape Town Draft Strategy to address Rough Sleeping is not without limitations, it does appear to better align its contextualization, conceptual framing, strategic focus and plans of action. This is a characteristic that should feature in all policies developed in the future.

4.3. Actors

The actor dimension delineates the influential figures who have contributed to the formulation of the policies and are expected to actively participate in their implementation (O’Brien et al. 2020; Walt and Gilson 1994). An analysis of the six policies revealed that The Gauteng City Region Strategy on Adult Street Homelessness was developed by the Gauteng DSD, and the City of Johannesburg Policy on Homelessness was prepared by the Social Development Integrated Policy, Planning and Research (IPPR) Unit. In both cases, no additional contributors were listed. The Street Homelessness Policy for the City of Tshwane was developed through a collaborative effort between the city, the University of Pretoria (UP), the University of South Africa (UNISA) and the Tshwane Homelessness Forum. In the Western Cape, the City of Cape Town’s Street People Policy was authored by an official from the Social Development and Early Childhood Development Department. The Stellenbosch Municipality Draft Street People Policy does not specifically identify the responsible author but does include the contact details for the manager of community development, planning and economic development at the municipality of Stellenbosch. The DSD initiated a review of the City of Cape Town’s Street People Policy, and the revised City of Cape Town Draft Strategy to address Rough Sleeping was developed by the Community Services and Health directorate (GroundUp and Hirsch 2024). Furthermore, as part of the development process, in the background and purpose section, the Street Homelessness Policy for the City of Tshwane reports that through a rigorous research process, there were “… focus group discussions with officials, politicians, NGO leaders, private sector, police and street homeless people”. The City of Johannesburg Policy on Homelessness highlights public participation as an integral part of the policy development process, which included “…beneficiaries, community members, and representatives of community and appropriate support organizations in the CoJ regions were among the invited stakeholders, who eventually constituted a specific reference group for consultation”.

The Western Cape policies and strategy do not provide information regarding consultation with the public or the intended beneficiaries. A major critique is that the policy documents do not clearly demonstrate how these consultations, especially with people experiencing homelessness, have been integrated into the policy and its subsequent interventions. As mentioned in the context section, information of this nature is lacking, and it is opined that the quality of the policies will greatly benefit from the better integration of this information. The importance of the homeless as stakeholders and actors in the development of policy responses is reflected in the argument that states that the stark increase in homeless numbers can be attributed to the fact that “…the voice of homeless people has not been used in policy formulation and development” (Jadezweni 2021). The observation that the policy documents are rigidly informed through secondary information is in line with the sentiments that homelessness and its dynamics appear to be documented based on the perspectives of government officials, academics and politicians and do not reflect the lived experiences of people experiencing homelessness. Consequently, this means that potentially important information is often overlooked by policymakers (Jadezweni 2021), which explains why policies tend to adopt a broad, systemic lens instead of a flexible and nuanced approach.

With reference to stakeholder roles and responsibilities, given the complex nature of homelessness, it is no surprise that the policies call for multi-sectoral collaboration between actors to assume joint responsibility for the implementation of the policies. However, the convergence of several interrelated factors stemming from the evident policy vacuum has resulted in the inability to mobilize the correct team of stakeholders as well as identify the leading agency, which has consistently exacerbated the lack of collaboration between various sectors. The pressing ambiguity has led to the lack of accountability and an easy cop-out for stakeholders who have not been explicitly mentioned (De Beer 2021; De Beer and Vally 2021a). Considering the social orientation of homelessness and the core mandate of the DSD, which emanates from section 27(1)(c), section 28(1) and schedule 4 of the Constitution,3 the DSD has been indirectly identified as the lead actor, as most of the interventions are currently being filtered through it. However, the current approaches are widely criticized for being uncritical, welfare-orientated services that further perpetuate the notion that homelessness should only be viewed and addressed as a social welfare issue, inadvertently disregarding the several other challenges that amount to gross human rights violations (De Beer 2021; Muleya and Mlilo 2023), thereby further constraining the mobilization of diversely skilled stakeholders and restricting the much needed collaboration across sectors.

Furthermore, the documents provide sufficient information regarding the expected roles and responsibilities of stakeholders during the implementation of the policy. The Gauteng City Region Strategy on Adult Street Homelessness provides extensive information regarding the roles each stakeholder is expected to fulfil in line with short-, medium- and long-term goals. The City of Johannesburg Policy on Homelessness clearly demarcates the roles and responsibilities of stakeholders in matters relating to homelessness. The Stellenbosch Municipality Draft Street People Policy provides detailed information for the ‘lead’ stakeholders, but simply lists the additional internal and external stakeholders, which can be improved on for more clarity. The City of Cape Town’s Street People Policy followed the same structure, but this was greatly improved in the revised City of Cape Town Draft Strategy to address Rough Sleeping as each strategic focus area in its implementation plan is clearly aligned with the responsible stakeholder(s). The last element, which was mentioned in most of the documents but should be emphasized, is the provision of training and capacity building for all actors. Service delivery to the homeless is already strained, and to compound the issue, it has been reported that general social workers are not equipped to deal with the complexities of homelessness, especially in cases where several social issues intersect and where interventions are required that extend beyond the scope and capacity of social workers (Muleya and Mlilo 2023). Therefore, to facilitate the promotion of inclusivity, sensitivity and awareness and the alignment of roles and services, more training is required.

4.4. Process

The final dimension includes how the policies were initiated, developed, communicated, implemented and evaluated (O’Brien et al. 2020; Walt and Gilson 1994). With reference to the implementation and action plans of the respective policies, most of the older documents have, for the most part, been ineffective. One can verify this claim using the latest recorded increase in the South African homeless population, which compares the estimate from the 1996 Census (13,135) to that of the 2022 Census (55,719) (Maluleke 2025). Furthermore, it would be unjust to criticize the recently approved City of Johannesburg Policy on Homelessness and the City of Cape Town Draft Strategy to address Rough Sleeping using the same baseline. However, based on the underlying thread established in the preceding discussions, it becomes evident that the historic generic, one-size-fits-all approach, which lacks the required contextual sensitivity, will reign supreme (Desmond et al. 2017; Groenewald et al. 2023). In other words, policymakers will persist in disregarding the individual complexities embedded in this heterogeneous population and continue to foster the production of uncritical, fragmented and overzealous policies that fail at the implementation stage.

Based on the findings of the policy analysis, it is important to note that the identification of challenges faced by people experiencing homelessness has only been included in the Gauteng City Region Strategy on Adult Street Homelessness, which means that the remaining policies are formulating and intend to implement plans without due consideration of the potentially debilitating impact these challenges can have on the policy outcomes, where in some cases it could render them obsolete. Failure to account for these challenges would further perpetuate the assumption that people experiencing homelessness do not want to make use of services or are showing resistance to support, while not acknowledging the packaging and delivery of these services and how the challenges they experience may act as systemic barriers, inadvertently blocking access to and usage of the several interrelated and often overlooked contextual, conceptual and structural factors.

The lack of accountability is another concerning factor; it has been outlined as an institutional challenge in the Street Homelessness Policy for the City of Tshwane: “…the absence of a regulatory body to keep service providers accountable”. Furthermore, the importance of this sentiment has been reinforced by its inclusion in the City of Cape Town Draft Strategy to address Rough Sleeping: “…additionally, service providers in the sector have not been held legally accountable to deliver on their mandates and to provide much needed services to their beneficiaries—rough sleepers”. Paving the way for ensuring accountability, the City of Johannesburg Policy on Homelessness is the only document that includes a section on the contravention of the policy to ensure accountability from all stakeholders involved. The main concern would be its implementation and enforcement and whether this will become standard practice across geographies and with the introduction of the impending national policy on homelessness.

In summary, the policies, for the most part, reflect the intention to improve the lives of people experiencing homelessness. However, the standardized and rigid structure is illustrated by a logical yet generic connection between the contextualization, directives and subsequent plans for intervention and implementation. Given the current nature and extent of the homeless population in South Africa, the policy documents will have to be reframed in such a way that reduction becomes a priority before progressing to the overly ambitious plans for presentation as presented in the respective documents. Based on the contextual and conceptual shortcomings identified under the content dimension, it is important to emphasize the refinement of policy content in such a way that its influence is regulated and correctly interpreted and implemented at the grassroots level. To illustrate this, one can consider the City of Johannesburg Policy on Homelessness approach to prioritizing vulnerable groups within the homeless population as an example.

Since vulnerability is inaccurately contextualized and conceptualized, the policy outcomes of the prioritization of certain vulnerable characteristics could lead to the inadvertent exclusion of an already vulnerable population, with already restricted access to services, by a homelessness policy. Proposing the prioritization of vulnerable groups within an already vulnerable population demonstrates the poor contextualization of the local policy responses, as has been suggested, without considering the current landscape of the homelessness service sector. Given the limited availability of shelters, bed spaces and resources, it would not be feasible to expect certain members within a vulnerable population to be prioritized above others who are in a similar position but do not conform to the generally accepted vulnerable categories of the elderly, women, children, people with disabilities and members of the LGBTQI+ community. The misalignment presented demonstrates the importance of accurately conceptualizing key terms such as vulnerability and victimization and then appropriately contextualizing them for the more targeted operationalization in policy outcomes. Amidst some positive strides, the discussion demonstrates that the formulation of the policies appears to follow a rigid and structural top-down approach, leaving very little room for flexibility or the visible inclusion of the cited stakeholder and beneficiary consultation. Furthermore, the discussion highlights the importance of accurate conceptualization and contextualization to ensure that it is correctly interpreted and actions, to avoid these practical inconsistencies that could erupt into potentially volatile situations.

The final aspect concerning the process dimension is the constrained implementation, monitoring, review and updating of the respective policy documents. The drawn-out implementation of contextual and conceptually flawed responses is of particular concern, considering the human element associated with addressing homelessness and how the success or failure of the policies can impact the well-being of people experiencing homelessness. The lack of direct policy responses is further perpetuated by the observable procedural delays in the formulation, approval, implementation and funding of the policies. For example, the Stellenbosch Municipality Draft Street People Policy has retained its draft status since 2018 and has not been revised or updated in recent years. Similarly, the Street Homelessness Policy for the City of Tshwane, after the revision of the 2013 version, was only approved in 2019, alarmingly, without an allocated budget (De Beer 2021). The City of Johannesburg Policy on Homelessness was drafted in 2022 and approved in 2024, which might not seem like a long time, but because the conceptual and contextual factors had not been markedly updated, concerns are raised regarding the effectiveness of a potentially outdated policy in the context of an ever-changing homelessness landscape. The Cape Town Policy was only submitted for review in 2020, and its revised version was only released in 2024 for public commentary and subsequently approved later that same year.

Concerningly, the constrained implementation of the analyzed policies indicates that the documents have all lapsed in terms of their review and revision period. The Gauteng City Region Strategy on Adult Street Homelessness has a five-year implementation plan, with no clear details regarding its review or revision. Four of the policies indicate that reviews will be conducted within a specified timeframe, as the need arises or as per the instruction of the relevant authorities. Furthermore, another concern is the implementation of the national policy, which could suffer a similar lax roll-out as its provincial and municipal counterparts. The implication would be that the uncritical, uncoordinated and ineffective approaches will most likely continue for the foreseeable future, and the constrained outcomes will remain a reality even when policies are absent, outdated or lapsed. The current reality cannot be considered beneficial for the required reduction or even the seemingly far-fetched prevention and distant eradication of homelessness in South Africa.

5. Recommendations

Following the analysis of the six policy documents and the alignment with the dimensions of the HPT, it can be deduced that these documents were indeed developed to fill the void left by absent national structures and governance around homelessness. Amidst some strengths, several shortcomings were identified, and based on the nature of the analysis, valuable recommendations can be proposed by focusing on three distinct areas. The first set of recommendations includes general aspects that can be considered for the reframing of existing and future policy responses to homelessness. Secondly, based on the challenges that exist at a grassroots level, stakeholder-specific recommendations have been proposed for future consideration. Lastly, the third section will focus on the silence of the policies, around the experiences of victimization, towards the development of a victim-inclusive policy framework for people experiencing homelessness.

5.1. General Policy Recommendations

Data scarcity and the inability to accurately contextualize homelessness are among the most prominent challenges identified across the policies. To address these shortcomings, comprehensive research on homelessness in conjunction with the identification of the strengths, weaknesses, resources and capacity available within South African society is required. To better position policies and their intended interventions, more support for the development of a national research agenda, as proposed by the National Homeless Network, is required. The agenda can be aligned with government departments and academic institutions to encourage collaboration and emphasize the shared responsibility to address the dearth of local research. To promote the relevance and urgency of research, incentives and seed money for emerging research fields related to homelessness can be used to enhance interest and participation among scholars. Through fostering a collaborative approach, mobilizing the required expertise, innovation and versatile research methods, participating stakeholders and organizations can ensure the collection of comprehensive data to aid in the development of evidence-based policies.

With a consistent influx of reliable, contemporary local research, an opportunity presents itself to refine, contextualize and accurately conceptualize homelessness within the policy space. Once a thorough understanding is established, the next logical step would be to overcome the shortcomings that stem from a lack of a universal definition. Through the exploration of viable alternatives, it is important to consider the creation of a range of definitions (Kriel 2017; Tenai and Mbewu 2020) that reflect the individual’s orientation regarding how they are experiencing homelessness. The information, based on their lived experiences, can provide insight for stakeholders involved in service delivery and policymaking, who can use their knowledge and expertise to use the key aspects provided by the beneficiary to formulate policy and shape interventions more accurately. By promoting the use of a flexible definition, a primarily stigma-driven sector could experience a significant reduction in the harmful and exclusive implications of socially constructed definitions that have been formulated based on perceptions, instead of the lived experiences and empirical data (Cronley 2010). To guide this process, it is recommended that a more nuanced approach to defining homelessness be developed and tested before it can be adopted in practice.

The proposed conceptual framework for the formulation of an experiential definition of homelessness will be person-centered, guided by an integrative checklist that comprises the most prominent pathways into homelessness. From a practical perspective, the checklist will include the most simplistic expression of homelessness, which is the absence of a home or adequate shelter (Obioha 2022; United Nations 2025). Furthermore, the checklist will include emotive responses related to feelings of safety and belonging, which are commonly associated with the notion of having a home, while also considering the elements a person experiencing homelessness usually lacks within the physical, social and legal domains (Mashau 2017). Considering the elements associated with a home, the traditional European Typology of Homelessness and Housing Exclusion (ETHOS) can be used to outline the physical elements of homelessness (FEANTSA 2005). While primarily developed in the European context, such frameworks provide a useful reference point and could be extrapolated, with caution, to the South African context. Moving towards a more individualized, humanistic approach that is based on the person’s lived experiences, the conceptual framework will include the recognition of homelessness as an outright violation of human and constitutional rights, while extending to feelings and practices associated with navigating life as a person experiencing homelessness (De Beer 2021). There will also be consideration around how their homelessness experience is shaped by systemic discrimination and social exclusion and stigmatization (United Nations 2025). The primary motivation for the formation of an experiential definition would be to challenge societal perceptions of homelessness and initiate the process of destigmatization in both policy and service delivery. Finally, by demonstrating the practical value of this process, the word homeless will be used as a noun, referring to the experience, instead of as an adjective that ascribes it as a state of being, ultimately defining the person based on their circumstances (Iwata 2021). Framing homelessness as an experience emphasizes that with adequate support, individuals can escape it, which could ultimately change the way homelessness is perceived and addressed.

Once the contextual and conceptual issues have been addressed, the next aspect within the homelessness policy space would be to outline and remove the use of negatively phrased and potentially harmful language used in the current policy documents. Considering the vulnerability and position of the intended beneficiaries, formal responses should adopt the use of sensitive diction. This will allow stakeholders to remain cognizant of the power dynamics, avoid inadvertent stigmatization and ultimately promote inclusivity in the delivery of services. Furthermore, there should be advocacy for the removal of punitive and criminalizing measures from the policies that are intended to assist and improve the lives of homeless individuals. The presence of hyper-criminogenic information and by-law considerations has the tendency to overpower the positive intent of the responses. The criminal elements can be dealt with separately and should not interfere with or distract from the goal of helping individuals to find viable and sustainable pathways out of homelessness. Inasmuch as punitive measures are counterproductive, awareness should be created around the disadvantages of compassionate responses. Furthermore, for this area of intervention, there should be a greater emphasis on the development and support for the creation of developmental and sustainable solutions (Hopkins et al. 2024). Once the inaccuracies have been addressed with regard to policy writing and planning, the focus needs to be shifted to the regulation of the implementation phase. Although the establishment of regulatory and oversight boards is a recurring suggestion, this will have to be reinforced and should be introduced on a national, provincial and municipal level. This will ensure that there is transparency and that stakeholders remain compliant and are held accountable to perform their intended functions within the policy space. Stakeholders should receive continuous, targeted, homelessness-specific training, with rigorous alignment in terms of their core functions and the circumscribed policy directives. Furthermore, regulatory boards should be used to encourage constant communication and collaboration, which will eliminate the detrimental silo effect between stakeholders (Powell et al. 2021) at various levels within the homelessness sector.

With the impending introduction of a national homelessness policy framework in South Africa, there exists a need to facilitate policy coherence to ensure that existing responses are not undermined and rendered obsolete. The coherent and complementary nature should remain a priority to ensure that homelessness is addressed cohesively and concurrently. The lax policy development, review and adoption processes will have to be addressed and streamlined, within the South African context. This was another major shortcoming identified through the analysis of the existing responses. Remaining relevant, active and present within the fight against homelessness is of utmost importance.

5.2. Stakeholder-Specific Recommendations

Albeit limited, existing research does identify problematic areas within the provision of essential services to people experiencing homelessness (Muleya and Mlilo 2023; Weng and Clark 2018; Wentzel and Voce 2012). Accordingly, as part of the appraisal process, several operational considerations and recommendations have been formulated to aid in the improvement of stakeholder engagement and conduct within the homeless sector. In terms of the Department of Correctional Services (DCS), the City of Cape Town Draft Strategy to address Rough Sleeping and the Gauteng City Region Strategy on Adult Street Homelessness are the only documents that refer to the DCS as a stakeholder that is required to assist with de-institutionalized individuals, training families of ex-offenders and tracking offenders who lack support systems prior to release. Additional considerations include the following:

• Investigating the number of homeless individuals who have been incarcerated for minor offences, such as those related to the violation of by-laws or the inability to pay a fine.
• Investigating the number of homeless individuals who are unable to serve non-custodial sentences due to the lack of community resources (no residential address) and the implications thereof.

The Department of Community Safety is primarily tasked with ensuring safety in shelters. Additional considerations include the following:

• Increasing safe zones on the street, for those who are unable to access or afford shelter spaces and in areas where there are no shelters or constrained capacity.
• Mobilizing SAPS, neighborhood watch or security companies to increase street patrols, to ensure the safety of those on the street or to provide direction to safe spaces and zones.

The Department of Health should assist in streamlining mental health care services, given its emphasized and often synonymous relationship with homelessness (Pophaim and Peacock 2021). The services, roles and responsibilities need to be carefully articulated, and the referral pathways and procedures should be clearly established. Specificity in this regard will help avoid releasing someone impacted by mental health challenges back to the street or to other inappropriate spaces where their needs cannot be met and where they are at an increased risk for victimization. Moreover, an additional consideration for the Department of Employment and Labor would be to establish a realistic, attainable and sustainable job market for people experiencing homelessness.

The Department of Justice and Constitutional Development (DoJ&CD) is only mentioned in the City of Cape Town Draft Strategy to address Rough Sleeping, where its listed purpose is as follows: “…review application of parole conditions and addressing gaps”. With regard to vulnerability, as mentioned previously, the department can work towards including the homeless as part of the promotion of the rights of vulnerable groups and facilitate their inclusion in victims’ rights and protective frameworks. Given the criminal component associated with homelessness, incurring a criminal record could be detrimental to policy outcomes, whether it is due to “survival crimes” or more serious offences. The department could intervene and provide much-needed assistance for expungement applications, which may lead to some relief, especially with housing and employment opportunities.

Lastly, in terms of practical considerations, effective mechanisms will have to be put in place and monitored to ensure effective collaboration and communication between the various stakeholders. This should entail rigorous and regular reporting structures to maintain effective and accountable actors. Considering the nomadic and transient nature of the homeless, main service providers could consider the creation of mobile departments to promote the accessibility of services. Additionally, the costs involved in the provision of services by the respective actors should be considered. In the Gauteng City Region Strategy on Adult Street Homelessness, the Department of Home Affairs is the only stakeholder that provides information related to the cost of making an identity document (ID). These costs should be reevaluated and weighed against the implications of not having the financial means, which may be the case for many people experiencing homelessness.

5.3. Considerations for Future Research and Recommendations for the Development of a Victim-Inclusive Policy Framework

Based on the analysis of current policy responses to homelessness, the general silence around victimization among people experiencing homelessness in South Africa is evident in both academic discourse and policy. To support the scant and limited local research, contemporary and holistic research is needed to offer critical insights, which highlight the urgency of the issue and encourage the pursuit of social change. To address the many injustices faced by the homeless, the formulation of more inclusive policies and interventions is necessary. To facilitate the development of a victim-inclusive policy framework, research exploring the experiences of victimization, service needs, service use patterns and challenges related to access is a central requirement. In addition to this, engagement with relevant stakeholders, currently working in the homeless sector, will assist in advocating for the need for victim-inclusive policy responses and guide the formulation of the proposed framework. Through the processes outlined above, it will be possible to develop a contribution that facilitates the creation of more inclusive policies, services and general practice regarding people experiencing homelessness. Additionally, while the HPT provides a valuable framework for examining the interplay between the context, content, actors and process dimensions, it does not account for the broader structural and rights-based elements of homelessness. Therefore, it is important to acknowledge the value of complementary frameworks such as the Social Determinants of Health (SDH), which highlight how poverty, housing, education and health inequalities create pathways into homelessness, and Human Rights-Based Approaches (HRBA), which highlight the constitutional and international rights obligations of several countries. Although these frameworks were not applied systematically in this analysis, future longitudinal studies on policy development and implementation would benefit from the integration of these frameworks and the analysis through the HPT lens to help underscore the need for contextually grounded, inclusive and protective responses to homelessness.

6. Limitations

The analysis is primarily descriptive and provides a roadmap for an in-depth comparative and theoretical application that extends beyond the lens of the HPT. While implicit comparisons are made, explicit comparisons and implications are drawn following empirically formulated engagements with people experiencing homelessness and stakeholders involved in service delivery and policymaking. The study is, however, subject to several limitations that should be acknowledged. First, the analysis relies exclusively on secondary sources and document analysis, which constrains the ability to capture the lived experiences and perspectives of individuals directly affected by homelessness. While this approach allows for a comprehensive examination of policies, legislative frameworks and institutional responses, it limits the depth of insight into the everyday realities and coping mechanisms of homeless populations. Second, the focus on South Africa provides an important contextual understanding but restricts the generalizability of findings to other countries or regions, particularly where policy environments and socio-economic conditions differ substantially, especially in highly developed settings. Third, the study emphasizes policy discourse and institutional responses, which, although central, do not fully address the intersections of homelessness with other structural determinants such as health, gender and urban planning. These limitations highlight the need for future research that integrates stakeholder perspectives, cross-country comparisons, and a broader range of intersecting social factors. Critiques and comparisons are provided where possible; however, given the arguably subjective nature of document interpretation and analysis, the findings are based on what is presented at face value without an overcritical approach based only on the analysis of documents, without engaging with stakeholders and the intended beneficiaries. To address these limitations directly, the current study serves as the first phase and preliminary inquiry into the current responses to guide further investigations, which are subdivided into two further distinct phases. The second phase involves the determination of the service needs and experiences of victimization of people experiencing homelessness. The third phase includes engagement with stakeholders who are involved in the service delivery and policymaking domains in the homelessness sector. Finally, the findings from the three phases are collated to facilitate the development of an evidence-based victim-inclusive policy framework for people experiencing homelessness. Lastly, the recommendations presented are not intended to be directly actionable in their current form, but rather serve to facilitate further inquiry and reflection, building on the issues investigated in preceding themes.

7. Conclusions

While considering the positive strides, the state’s response to homelessness requires a considerable amount of reflection and subsequent reframing. Based on the analysis, it is evident that there is a need for a shift towards victim-inclusive and protective policy reform that not only addresses the pathways into homelessness, but also prioritizes alleviating the negative experiences associated with the condition. Effective policies should be outlined by accurately contextualized and conceptualized directives, which encourage integrated and collaborative stakeholder contributions. By redefining the currently reactive policy space, one can envision moving towards successfully reducing, preventing and ultimately eradicating homelessness in a more systematic way. To reiterate, tackling homelessness is not about the reduction in visibility and provision of shelter or advocating for special treatment. Addressing homelessness holistically is about acknowledgment, respect, dignity, protection and implementing the constitutional guarantees of a democratic country.