Different countries have taken very different routes to reducing homelessness, but the ones showing measurable results tend to combine three things: rapid access to permanent housing, legal accountability on the agencies responsible, and a real supply of affordable homes. Looking at how other countries deal with homelessness — Finland, Japan, Canada, Denmark, the UK, France, Austria, South Korea, Australia, and constitutional-rights countries — shows both what works and where even good policy hits a wall.
The Shared Idea: Housing First
The most influential concept in modern homelessness policy is Housing First, developed in North America during the 1990s. The principle is straightforward: give someone a stable home immediately, without requiring sobriety or treatment compliance first, then offer voluntary support once they’re housed. That inverts the older “treatment first” model, which expected people to resolve addiction or mental health issues while still living on the street or moving through shelters.
The evidence on the housing outcomes is strong. A U.S. Department of Veterans Affairs research brief found that Housing First produces quicker exits from homelessness and greater housing stability than traditional approaches.1U.S. Department of Veterans Affairs. The Evidence Behind the Housing First Model The evidence is weaker on whether the model alone improves mental health or substance use outcomes, which matters because long-term housing stability often depends on those issues being addressed too. That tension runs through nearly every country that has adopted the approach.
Finland: The Pioneer and Its Recent Reversal
Finland is the country most identified with Housing First. Since making it national policy in 2008, the number of people in hostels or boarding houses dropped 76% over the following decade.2Housing First Europe. Housing First Europe – Finland Finland invested €250 million in new homes and residential support workers, and converted former shelters into permanent housing units with on-site help for benefits, banking, and health care.3thisisFINLAND. How Finland’s Housing First Model Makes Real Progress Against Homelessness The work is a collaboration between national and municipal governments and nonprofits.
For years Finland was the only EU country where homelessness kept falling. Then in 2025 the country reported 4,579 single homeless people, a 20% rise in a single year and the largest recorded spike in its history.4Y-Säätiö. Record Rise in Homelessness in Finland in 2025 The reversal makes the point advocates in every country repeat: Housing First works, but it cannot outrun a housing supply crisis.
Japan: Fast Public Assistance and Outreach
Japan’s approach draws less international attention, but the numbers are striking. In January 2025 the government counted 2,591 people living outdoors nationally, down from a peak of 25,296 in 2003. The backbone is the Livelihood Protection system, a public assistance program built on three principles: anyone below a certain income threshold can receive it, approval must come within 14 days by law (the statutory ceiling is 30 days), and enrollment automatically includes housing assistance and access to national health care.
Between 2004 and 2009 Tokyo ran one of the most ambitious Housing First experiments in Asia, the Moving to Community Living Project. Social workers set up mobile offices in parks, built relationships with unhoused residents over time, and helped nearly 2,000 people move directly into subsidized apartments at roughly $30 per month in rent. Residents got health screenings, enrollment in national health insurance, and job search help during the first six months. Japan’s results also reflect structural factors other countries can’t easily copy: no large-scale opioid crisis, a relatively friendly rental market, and higher rates of institutional care for people with severe mental illness.
Canada: Federal Money, Local Plans
Canada’s national strategy, Reaching Home, launched in 2019 as a $5 billion federal investment over nine years running through 2028.5Housing, Infrastructure and Communities Canada. Reaching Home – Canada’s Homelessness Strategy Its defining feature is that decisions are made at the community level. Local organizations develop their own plans, and the federal government funds projects through designated community entities rather than dictating a single approach.6Housing, Infrastructure and Communities Canada. Reaching Home Program Information Housing First is explicitly supported under the program for chronic homelessness.
What further distinguishes Reaching Home is its treatment of Indigenous homelessness as a separate policy challenge. A dedicated Indigenous Homelessness stream funds 30 communities and seven regions, with priority for Indigenous-led organizations delivering culturally appropriate services off-reserve. A Distinctions-based Approaches stream goes further, co-developing funding and service delivery directly with First Nations, Inuit, and Métis governments.7Housing, Infrastructure and Communities Canada. Reaching Home Funding Streams In Quebec the program operates through a bilateral agreement respecting both federal and provincial jurisdiction.
Denmark: Housing First Written Into Law
Denmark adopted Housing First as its guiding national principle in 2009, but the model ran for years through pilots and discretionary funding. That changed in October 2023, when key elements were written directly into Danish law. The legislation created financial incentives for municipalities to move people from temporary shelters into permanent housing, and it guaranteed partial refunds to municipalities that provide evidence-based support like Critical Time Intervention, Intensive Case Management, or Assertive Community Treatment for people making the transition.8Housing First Europe. Housing First Europe – Denmark
Denmark also committed one billion DKK (roughly €134 million) to making more affordable homes available. The shift from pilot to statute reflects a wider pattern: countries that begin with experimental programs eventually need legislation to lock the approach in against changes of government.
United Kingdom: Legal Duties on Councils
The UK takes two distinct approaches depending on the nation. Scotland arguably has the strongest legal protections for homeless people in the Western world. Under the Housing (Scotland) Act 2001, local councils must provide temporary accommodation, advice, and assistance to anyone homeless or threatened with homelessness. Successive reforms have moved Scotland toward a system where nearly everyone found unintentionally homeless has a right to settled accommodation.
England’s approach is more focused on prevention. The Homelessness Reduction Act 2017 imposed new duties on local housing authorities to intervene before people lose their homes. The law expanded the definition of “threatened with homelessness” and requires councils to assess every eligible applicant, agree on a personalized plan, and take reasonable steps to prevent homelessness or help secure accommodation.9Legislation.gov.uk. Homelessness Reduction Act 2017 It also created a duty for other public bodies, including hospitals and prisons, to refer people they believe are at risk to the local housing authority.
France: An Enforceable Right to Housing
France took the unusual step of making housing a legally enforceable right through the DALO law (Droit au Logement Opposable). Anyone who is homeless, living in unsafe or unsanitary conditions, or has been waiting an unreasonably long time for social housing can appeal to a departmental mediation commission. If the commission recognizes the applicant as a priority, it directs the local prefect to offer adapted housing within three to six months, depending on the department. If that doesn’t happen, the case can go to an administrative court.10Service-Public.fr. DALO – Enforceable Right to Housing
The system reads powerfully on paper and has given many families leverage they wouldn’t otherwise have. It doesn’t guarantee quick results. Availability depends on actual social housing supply, and in high-demand cities like Paris the gap between legal right and physical reality stretches for years. Enshrining a right in law creates accountability, but it doesn’t build apartments.
Vienna: Preventing Homelessness Through Social Housing
Vienna’s approach doesn’t begin with homelessness policy. It begins with housing policy. The city owns roughly 220,000 apartments, making it the largest municipal landlord in Europe, and about a quarter of Vienna residents are social tenants. Add in cooperative housing built with municipal subsidies and more than half the city’s population lives in some form of publicly supported housing.
The system works because Vienna never sold off its public housing stock the way most European cities did during the privatization waves of the 1980s and 1990s. The city maintains a land procurement fund reserving parcels for social housing, and a 2019 zoning rule requires two-thirds of floor space in any large residential development to be subsidized. Income caps apply at move-in, but there’s no ongoing means testing. A student who enters a municipal apartment can stay after their career takes off, which prevents the economic segregation that plagues public housing elsewhere. Vienna doesn’t eliminate homelessness, but it removes much of the market pressure that produces it.
South Korea: A Statutory Framework for Support
South Korea passed the Act on Support for Welfare and Self-Reliance of the Homeless, which places explicit responsibility on national and local governments to prevent rough sleeping, protect the rights of homeless people, and assist rehabilitation and self-support.11Korea Legislation Research Institute. Act on Support for Welfare and Self-Reliance of the Homeless The Minister of Health and Welfare must create and implement a comprehensive five-year plan covering prevention, gender-specific services, housing, and welfare infrastructure.
Housing assistance under the law includes admission to shelters or social welfare facilities, provision of rental housing, and subsidies for temporary housing costs. The government also operates dedicated medical facilities for homeless people and provides employment support including job placement, career development, and public-sector jobs.11Korea Legislation Research Institute. Act on Support for Welfare and Self-Reliance of the Homeless One notable provision requires programs to account for gender-specific needs, including health and sanitary supplies for homeless women.
Australia: Federal Funding, State Delivery
Australia’s structure resembles Canada’s: the federal government funds while states and territories deliver services. The National Housing and Homelessness Agreement channels roughly $1.6 billion annually from the Commonwealth to the states, and total government spending on housing and homelessness reaches about $16 billion per year when state contributions are counted.12Australian Government Department of Social Services. National Housing and Homelessness Plan – Issues Paper – Summary
Australia also defines homelessness more broadly than most countries. The definition takes in not just people sleeping rough but those in severely overcrowded housing, couch-surfing, or living in temporary lodgings without security of tenure.12Australian Government Department of Social Services. National Housing and Homelessness Plan – Issues Paper – Summary Specialist Homelessness Services provide early intervention, crisis support, and emergency accommodation, alongside practical help like meals, laundry, and financial advice. The government is developing a broader National Housing and Homelessness Plan to set national goals and improve coordination with the states and the private sector.
Constitutional Rights to Housing
More than 20 countries, including South Africa, Spain, Ecuador, Mexico, and Russia, have written an explicit right to housing into their constitutions. The government bears a legal obligation to protect and ensure access, though enforcement is typically subject to progressive realization and available resources. South Africa’s Constitutional Court applied this principle in the landmark Grootboom case, ordering the government to develop a housing program with provision for people living in intolerable conditions.
A larger group of countries, including Finland, India, the Netherlands, and the Philippines, treats housing as a constitutional directive principle rather than a directly enforceable right. Courts in some of them have found workarounds. India’s Supreme Court has ruled that the right to housing is an integral part of the justiciable right to life, giving it legal teeth without explicit enforceability in the constitutional text. Whether these provisions actually reduce homelessness depends less on the wording and more on whether governments invest in implementation.
What Actually Moves the Numbers
The countries with the most measurable progress share a few patterns. They invest in dedicated housing supply rather than relying on the private market alone. They adopt Housing First or similar models that remove barriers to getting people indoors quickly. They build legal accountability into the system, whether through enforceable rights, municipal obligations, or statutory timelines for processing applications. And they tailor programs to specific populations rather than treating homelessness as a single problem with a single solution.
Finland’s 2025 spike and France’s long DALO waiting lists point to the same hard truth: no policy framework outperforms a housing shortage. The countries with the lowest rates of homelessness tend to be the ones that never stopped building affordable housing. Vienna didn’t need a Housing First program because it never created the conditions that make one necessary. That’s the most uncomfortable lesson in the international data, and the one that gets the least political traction almost everywhere.