The population falling within the Union at the 1831 census had been 9,715 with parishes ranging in size from Rowell (population 38) to Winchcomb itself (2,514). The average annual poor-rate expenditure for the period 1833-5 had been £4,911 or 10s.1d. per head.

The new Winchcomb Union workhouse was built in 1836 on a site to the west of the town at the north side of Gloucester Street. The Poor Law Commissioners authorised an expenditure of £3,750 on construction of the building which was intended to accommodate 180 inmates. It was designed by the Sampson Kempthorne who designed many other workhouses including one for the Thornbury Union. His design for Winchcomb was based on his model "200 pauper" plan. An entrance and administrative block lay at the south, with accommodation ranges behind in a cruciform layout. However, there was no central supervisory hub to the building. The workhouse location and layout are shown on the 1921 map below.