emergency accommodation. All three elements of constructive accountability – monitoring, independent review against standards, and remedial action – are lacking. Constructive accountability requires independent review and remedial action As outlined in our first Inquiry report, accountability is about ensuring standards are respected and promises are kept. It does not need to be about blame and punishment. We acknowledge the complexity of the entire housing system in Aotearoa New Zealand, and the difficulty of developing strategy and policy that adequately addresses the entire continuum of housing need. We also acknowledge the difficulties that may emerge in responding meaningfully to homelessness, given the ongoing fragmentation of the emergency housing response across at least three agencies (MSD, HUD, and KO). However, HUD was established in large part as a response to this complexity. It is explicitly tasked with end-to-end system leadership across the whole of the housing system, including homelessness response. Despite HUD’s leadership in this area, we have observed inadequate accountability in the emergency housing system (i.e. emergency accommodation and transitional housing), and a lack of attention to the experiences of individuals and whānau. This has been exacerbated by the separated responsibility for, and administration of, emergency accommodation and transitional housing. In November 2021, the Implementation Unit in the Department of Prime Minister and Cabinet delivered a report on emergency accommodation and transitional housing. The purpose of this report was “to assess the current working arrangements between agencies responsible for delivering emergency and transitional housing.”74 56 Human Rights Commission This internal review found that transitional housing, led by HUD, has effective working arrangements, with end-to-end programme management, delivery plans and clear roles and responsibilities across agencies.75 It also found that HUD is broadly on track to deliver planned increases in transitional housing, agencies provide clear monthly reports including dashboards and milestones for transitional housing places, and agencies are well focused on increasing supply.76 The report found that despite “challenges at the system level and in communities”, and demand on the system not anticipated or envisaged when it was originally established, “agencies are fulfilling their roles and responsibilities as intended … [and] performing well in particular elements of programme delivery.”77 The report also found that HUD and MSD are working effectively together at the policy level to develop and provide joint advice to Housing and Social Development Ministers.78 However, the report also identifies gaps that persist in different emergency housing initiatives, and “neither HUD nor MSD have visibility over the whole emergency housing system, nor of the outcomes for people who move between [emergency housing grant]-funded accommodation into transitional housing, and other social housing providers.”79 The report raises particular concerns about the gaps and “black boxes” (significant voids) in knowledge about client outcomes, as HUD and MSD are unable to track clients through the whole emergency housing system. This internal report’s finding of gaps in the emergency housing system reflects what we have heard from providers who observe a continuing lack of information sharing and communication between different agencies, even when they all have an operational role in supporting individuals through the system. We highlight the importance of refining policy processes and interactions