Introduction
Councils provide a vital role in the community to serving personnel, their families and veterans through their responsibilities for a range of areas including for housing, education, public health, social care. Many councils have developed effective collaboration through networks and partnerships, often engaging with military charities, local Armed Forces Champions, and service personnel to share best practices.
Furthermore, many councils have used events such as Armed Forces Day have been used to raise the profile of Armed Forces issues, generate public support, and showcase local initiatives. Many councils use these occasions to launch or re-launch programs, celebrate successes, and encourage wider community involvement.
The LGA supports the aims of the Covenant and have promoted resources to support the covenant duties and good practice across the sector. The LGA also hosts the Armed Forces Covenant network of council officers.
The LGA is committed to working with central government to ensure that any legislative changes or new duties are realistic, outcome-focused, aligned with existing legislation and are resourced appropriately.
Our response
Does the Bill extend the scope of the Armed Forces Covenant Legal duty in an appropriate way?
The extension will need to be supported by clear guidance on its use and a clear understanding of any costs to councils.
It is important that any changes in scope that may have a financial impact on councils are assessed. The LGA is requesting that a full Impact Assessment is undertaken to identify any new burdens, however the MOD has said that they do not need to undertake an Impact Assessment as costs will be minimal.
In June 2025 the Government responded to the Defence Committee, Fourth Report of Session 2024–25, The Armed Forces Covenant (HC 572), on 1 April 2025. The Government Response says (Clause 9, Page 6):
‘We acknowledge that the expansion of the Covenant Legal Duty will place an additional strain on Government Departments and Local Authorities. We will continue to conduct extensive engagement to ensure resourcing constraints are considered. To mitigate any additional burden on Local Authorities, the MOD is co-developing a new burdens assessment, alongside Ministry of Housing, Communities and Local Government (MHCLG) and the Local Government Associations. Again, the MOD will be providing training materials, webinar sessions and downloadable resources to support organisations in their delivery of the Covenant Duty. These will help these bodies comply with their legal obligations’.
We are concerned that a full impact assessment has not been undertaken. The LGA have not been asked to assist in developing an Impact Assessment.
It is important that there is good communication of the extension of the Covenant duty and availability of support for councils if needed.
Are there policy areas which should/should not have been included?
No. But how the duty needs to be implemented by councils and partners is key. It is essential that clear guidance from government is issued and that the guidance has been created in collaboration with local authorities, partners and service personnel.
Councils are dedicated to supporting Armed Forces communities through the Covenant and report that it works best when integrated into local networks and supported by strategic partnerships. Councils with dedicated Armed Forces Officers provide responsive, flexible support tailored to veterans' needs, ensuring they can access housing, health, and community services.
Councils frequently coordinate with local charities, GPs, and public agencies to maintain consistent engagement. They report that strong local partnerships enhance visibility and accessibility, enabling veterans to access support more easily. Some councils also use digital platforms and regional forums to bridge communication gaps and standardise messaging.
However, councils consistently face challenges with inconsistent statutory guidance and little to no top-down leadership and support from central government departments affected by the Covenant such as MHCLG, DfE etc. This leads to varied interpretations and inconsistent applications, creating geographical disparities. Councils request clearer national guidelines to standardise Covenant duties and reduce ambiguity.
To overcome inconsistencies, councils actively participate in regional forums and partnership boards where they share interpretations of statutory guidance and effective practices. This collaborative approach enhances consistency, ensuring more uniform application across regions. Councils emphasise that open communication and knowledge-sharing are crucial for effective Covenant delivery.
Councils that successfully translate the Covenant duty into policy do so by embedding it into Equality Impact Assessments and their strategic planning processes. This systematic integration ensures that Armed Forces community needs are consistently considered in policy development. Some councils also maintain long-term commitment by including Covenant priorities as standing items in strategic agendas.
Councils frequently report challenges with conflicting statutory regulations in housing and education, which complicate the application of Covenant duties. They find it difficult to prioritise veterans’ needs without conflicting with other legal obligations. To navigate this, councils collaborate in regional forums to interpret statutory guidance collectively, reducing ambiguity and aligning their approaches.
Councils also work directly with local military bases, charities, and Armed Forces families to co-design policies that reflect local needs, ensuring relevance and responsiveness. However, inconsistent political support and stakeholder buy-in create uneven application across districts. Councils are addressing this by educating local leaders on the community benefits of Covenant policies and advocating for strategic alignment.
Despite proactive measures, councils consistently request clearer national guidelines to standardise policy implementation and reduce regional disparities. They argue that clear, actionable frameworks would enhance consistency and accountability.
Councils also stress the importance of avoiding a one-size-fits-all approach. They recommend flexibility in how any new duties are implemented to reflect local circumstances and priorities. Councils believe this approach would allow them to deliver effective support while maintaining local autonomy.
There must be clear communication and training materials available for all key sectors. It would be helpful for the Ministry of Justice to have a lead advisory role on any issues that may arise.
What are the resource implications of expanding the Covenant?
The Covenant is expanding to several functions that are managed, commissioned or delivered by councils – including social care. Social care is a significant resource pressure for councils.
Councils in England face a funding gap of up to £8 billion by 2028/29 (Spending Review 2025 submission: Letter to the Chancellor). While they continue to innovate and transform services to deliver for communities and provide greater value for money, they desperately-need a significant and sustained increase in overall funding to remain financially sustainable.
These pressures are already resulting in increasing reliance on Exceptional Financial Support (EFS) to enable councils to set lawful budgets. The LGA anticipates a significant increase in applications for EFS to help councils set their general fund budgets from 2026/27 onwards. Based on an LGA survey of chief finance officers (Emergency government bailouts needed by third of councils over next three years) (to which 49 per cent of member authorities responded) prior to the final local government finance settlement, more than a third (34 per cent) of councils have already applied, or are very or fairly likely to apply, for EFS in at least one of the financial years between 2026/27 and 2028/29.
Almost six in ten councils told the LGA that it will be fairly or very difficult to set a balanced budget in 2026/27. While eight in ten councils believe they will be able to meet their minimum legal duties in 2026/27, this falls to just 43 per cent by 2028/29.
Expanding statutory duties under the Armed Forces Covenant in this financial context, without a comprehensive impact assessment and any identified new burdens funding, risks compounding instability across local government. It is essential that any extension of the Covenant legal duty is accompanied by properly assessed and fully funded new burdens support.
Councils commission a range of services from independent and voluntary sector providers. Councils support the Covenant aims but are concerned about expanding the Covenant without dedicated funding and clear implementation plans. They are already facing serious resource constraints, and further extensions without clear financial evidence, could overburden local services. This could potentially limit their ability to prioritise Covenant-related work. Without dedicated funding or staff, delivery of the Covenant objectives risk becoming secondary to other statutory responsibilities.
Recent government funding initiatives have aimed to address inequalities and support local priorities, but they often lack explicit references to the Armed Forces Community.
Targeted programs like the Free from Fear Programme 2024/25 and the Fulfilling Futures Programme 2024/25, administered by the Armed Forces Covenant Fund Trust, are designed to support veterans and their families. However, these initiatives are relatively limited in scope and funding.
There is a need for more comprehensive integration of Armed Forces Community considerations into mainstream funding programs to ensure equitable support across all sectors.
How far will the Bill improve implementation of the Armed Forces Covenant?
The Bill will improve implementation of the Covenant if it is supported by clear guidance, some targeted resources and a mechanism of support such as the Armed Forces Covenant Network.
It is important to provide support for councils on Covenant delivery, where appropriate this support should be co-designed with councils and specific to the area of the legal duty, such as social care. Focus is needed on enabling councils through practical resources rather than adding new legislative or reporting burdens.
We also recommend that cross-government coordination is strengthened. Ensure better collaboration across departments (e.g. MHCLG, DHSC, DfE, DWP, Home Office) to support consistent Covenant delivery. It is particularly important to involve departments with local government expertise in policy development to ensure practical implementation.
The first principle of the Covenant is that those who serve in the Armed Forces, whether Regular or Reserve, those who have served in the past, and their families, should face no disadvantage compared to other citizens in the provision of public and commercial services. The LGA supports a future aspiration of moving beyond ensuring no disadvantage and instead embedding an active advantage for veterans in functions delivered by the public bodies outlined in the Covenant. Any future change will need to be subject to a full impact assessment.
LGA comments on specific areas
Contact
Contact: Kevin Halden, Policy Adviser
Email: [email protected]