The 2009/10 edition of the UK Housing Review, published just before Christmas, included an analysis of post-devolution developments in housing policies in the four countries of the UK.

It highlighted some key differences in approach, especially between Scotland as compared to England and Wales. A more detailed account has also now been published by the Joseph Rowntree Foundation.

Of the devolved administrations, Scotland has made more of a difference - but then in both budgetary and constitutional terms it has had more opportunity to make a difference. Devolution in Northern Ireland has so far been a very on off affair, while Wales has been hampered (thus far) by its lack of primary legislative powers and a less generous budget settlement.

Even within that context, though, Scotland has devoted a higher priority to housing expenditure than either England or Wales, and has taken a distinctive legal approach, notably in respect of homelessness and reforms to the right to buy. The picture in terms of policy outcomes is more variable.

In part, the higher levels of housing expenditure in Scotland reflects its larger council and social housing sector, relative to the rest of the UK.

While investment in improving the retained housing stock has risen in Scotland over the devolution decade, on a per dwelling basis, investment has risen even more sharply in England. Increases in Northern Ireland and Wales have lagged behind.

Scotland has also made the largest and most sustained increase in investment in new social sector housing over the decade; but at the same time has seen the greatest proportionate decline in its social housing sector stock. This is because although Scotland has reformed the right to buy for new council tenants (from 2002), it has done nothing to rein in the discounts for existing tenants - which in Scotland have never been subject to a maximum cap.

By contrast, England, Northern Ireland and Wales have all made use of extant powers to reduce maximum discounts. This has moderated both average effective discounts and sales levels, even before the impact of the credit crunch. There are cross-border lessons to be learnt here. Right-to-buy in Scotland now sets discounts at levels that are proportionate for what are, in effect, sales to sitting tenants with security of tenure paying rents significantly below current market values. The other countries of the UK could take note. Conversely, Scotland might do well to reconsider reforming the unconstrained discount entitlements of pre-2002 tenants.

There are many other housing devolution stories with significance for the future - the different finance arrangements, housing quality standards and approaches to homelessness among them. See the UK Housing Review or the JRF report for more.

Steve Wilcox is professor of housing policy at the University of York

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