Authorities so far had dismissed more than 30 properties as unsuitable to house a convicted child sex offender who had been granted release from custody, the South Australian Supreme Court was told.
Mark Trevor Marshall, 43, has a history of child sex offences and was jailed indefinitely in 2009, after the court ruled he was incapable or unwilling to control his sexual urges.
In 2011, a Supreme Court judge allowed his release on licence if appropriate accommodation could be found.
Prosecutor Pauline Barnett told the latest hearing dozens of properties had been ruled out.
"The problem in terms of finding suitable accommodation has continued. We're now at house number 34. All of the houses have, for one reason or another, proven unsuitable," she said.
"The accommodation is a problem for two reasons: one, obviously the community protection, the house has to be away from schools and childcare centres.
"The other problem is Mr Marshall, his own personal security is at risk or could be at risk in relation to those people who do not want to see him released. It's very tricky."
She said police and Housing SA were trying to help.
"There is a steering group of eight people trying to work with Housing SA, trying to work with the police and the offender management program to secure this," she said.
Defence lawyer Zoe Lewis said Marshall was distressed by the lack of progress.
"Although there has been some progress, there has been no indication of an end date to this," she said.
Another hearing has been scheduled for April.