Consultation outcome

A new deal for social housing and call for evidence on social housing regulation: summary of responses

Updated 17 November 2020

This document outlines the summary of responses to the social housing green paper consultation, and a call for evidence which sought views on how the current regulatory framework is operating.

1. A new deal for social housing: summary of responses

The social housing green paper, A new deal for social housing, was published in August 2018. It set out our proposals to ensure that homes are safe and decent, that residents are treated with dignity and respect, and that we have the social housing we need for the future.

The green paper set out our five principles to underpin a new, fairer deal for social housing residents:

• a safe and decent home which is fundamental to a sense of security and our ability to get on in life
• improving and speeding up how complaints are resolved
• empowering residents and ensuring their voices are heard so that landlords are held to account
• tackling stigma and celebrating thriving communities, challenging the stereotypes that exist about residents and their communities
• building the social homes that we need and ensuring that those homes can act as a springboard to home ownership

We heard the views of around 1,000 people and organisations in addition to the 8,000 contributions and submissions that shaped the green paper from the outset, including the bereaved and survivors of Grenfell Tower and the wider community. We also met more than 500 social housing residents across England, from Newcastle to Hastings, to hear their views.

Who responded?

As a private individual	432
On behalf of an organisation	496
Total responses	928

Breakdown of organisations which responded

Cooperative	4
Housing association	149
Local authority	144
Other	121
Tenant Management Organisation	15
Tenant Representation Group	39
Trade association	16
Did not specify	8
Total	496

Note on methodology and presentation of data

Members of the public and organisations were invited to submit responses to the consultation either online via a survey or by filling in a consultation response template, both of which were accessible through the GOV.UK website. Hard copies of the consultation template were also made available to those not responding online. All paper and digital template responses were manually entered into the online survey tool by officials for consistent analysis.

Only responses which engaged directly with consultation questions are represented in our quantitative analysis. A number of responses were received which either in part or in full did not conform to the consultation template provided. Submissions which in part responded to the consultation questions were manually entered into the online survey tool by officials. Those which did not directly respond to the questions posed in the consultation were not entered into the online survey tool but have been considered along with wider stakeholder engagement. All responses received have informed our wider understanding of the response to the social housing green paper.

We also held eight engagement events seeking views from more than 500 social housing residents around the country between September and November 2018, in Manchester, Norwich, London, Newcastle, Hastings, Birmingham and Bristol, as well as an event for the bereaved and survivors of Grenfell Tower and the wider community. The key points raised at these events are included in the summaries of wider engagement for each of the green paper chapters. As the points were raised during table discussions at each of the events, it is not possible to quantify the number of people who raised each point. The seven roundtable events which we held with social landlords alongside the events with residents are also reflected in the summaries of stakeholder engagement, as are other meetings and submissions received during the period of the consultation.

Due to rounding, numbers may not add up to 100% on certain questions. Not all organisations provided information on which sector they are in, meaning that the subtotals of organisations responding by sector may not sum to the total organisational responses.

In answering open questions respondents sometimes raised more than one issue. All of these issues have been included in our analysis of consultation responses, meaning that the numbers presented for each question may exceed 100%. The percentages presented indicate what proportion of respondents raised each issue.

Chapter 1 – Ensuring homes are safe and decent

The social housing green paper set out to ensure that social housing should be safe and decent. It sought views on:

• residents working with landlords to ensure homes are safe
• applying recently introduced safety measures in the private rented sector to social housing
• changes to the decent homes standard
• additional measures to ensure homes are safe and decent

Question 1 – How can residents best be supported in this important role of working with landlords to ensure homes are safe?

669 respondents answered this question. 283 responses were received from private individuals and 378 were on behalf of organisations. Of the organisational responses there were 138 from housing associations, 124 from local authorities, 7 from tenant management organisations, 33 from tenant representation groups, 11 from trade associations, 2 from cooperatives, and 63 from other sectors. 8 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question 581 (87%) respondents highlighted that more effective landlord-resident engagement would help to support residents, 398 (59%) respondents suggested improving fire safety awareness and 173 (26%) respondents were in favour of having a clearer route of escalation for safety issues and accountability. The fourth and fifth most common themes were each raised by over 10% of respondents. 127 respondents suggested strengthening consumer regulation, and 83 were in favour of government action, for instance through providing advice, funding and training.

Question 2 – Should new safety measures in the private rented sector also apply to social housing?

There were 742 responses to the closed section of this question. 355 of these responses were received from private individuals and 378 were on behalf of organisations. Of the organisational responses there were 138 from housing associations, 129 from local authorities, 8 from tenant management organisations, 29 from tenant representation groups, 7 from trade associations, 1 from a cooperative, and 65 from other sectors. 9 responses did not specify whether they were responding as an individual or on behalf of an organisation.

678 (91%) respondents agreed that new safety measures in the private rented sector should also apply to social housing, 52 (7%) respondents were not sure and 12 (2%) disagreed. 92% of individuals and 91% of organisations that responded agreed with the question.

289 respondents provided additional comments to this question. 64 of these additional responses were received from private individuals and 223 were on behalf of organisations. Of the organisational responses there were 87 from housing associations, 83 from local authorities, 4 from tenant management organisations, 10 from tenant representation groups, 7 from trade associations, and 32 from other sectors. 2 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question 56 (19%) respondents recommended that the Decent Homes Standard should be applied to the private rented sector so that safety standards are uniform across tenures, 51 (18%) respondents advised that they already met the standards, and 51 (18%) respondents raised concerns around costs relating to the introduction of additional standards. 13 (4%) of respondents suggested a need for phased implementation of any new requirements.

Question 3 – Are there any changes to what constitutes a Decent Home that we should consider?

There were 721 responses to the closed section of this question. 344 of these responses were received from private individuals and 370 were on behalf of organisations. Of the organisational responses there were 135 from housing associations, 125 from local authorities, 7 from tenant management organisations, 29 from tenant representation groups, 7 from trade associations, 1 from a cooperative, and 65 from other sectors. 8 responses did not specify whether they were responding as an individual or on behalf of an organisation.

519 (72%) respondents agreed that changes to what constitutes a decent home should be considered, 113 (16%) respondents were not sure and 89 (12%) did not think changes should be considered. 61% of individuals and 82% of organisations that responded agreed that there should be changes.

573 respondents provided additional comments. 207 of these responses were received from private individuals and 360 were on behalf of organisations. Of the organisational responses there were 124 from housing associations, 128 from local authorities, 5 from tenant management organisations, 28 from tenant representation groups, 9 from trade associations, 1 from a cooperative, and 66 from other sectors. 6 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 284 (50%) respondents highlighted building safety, particularly fire and electrical safety, as areas where changes should be made, 234 (41%) respondents highlighted energy efficiency changes, and 117 (20%) responses suggested changes related to standards for neighbourhood and place.

Two further themes were each raised by more than 5% of respondents: 39 respondents suggested changes relating to accessibility and 28 mentioned digital connectivity.

Question 4 – Do we need additional measures to make sure social homes are safe and decent?

There were 718 responses to the closed section of this question. 347 of these responses were received from private individuals and 363 were on behalf of organisations. Of the organisational responses there were 134 from housing associations, 120 from local authorities, 7 from tenant management organisations, 28 from tenant representation groups, 7 from trade associations, 1 from a cooperative, and 65 from other sectors. 8 responses did not specify whether they were responding as an individual or on behalf of an organisation.

525 (73%) respondents said that additional measures are needed, 114 (16%) respondents were not sure and 79 (11%) said that they were not. 72% of individuals and 74% of organisations that responded said there should be additional measures.

543 respondents provided additional comments. 214 of these responses were received from private individuals and 323 were on behalf of organisations. Of the organisational responses there were 111 from housing associations, 110 from local authorities, 4 from tenant management organisations, 24 from tenant representation groups, 7 from trade associations, 2 from cooperatives, and 65 from other sectors. 6 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 291 (54%) respondents highlighted the need for changes to create a safe and secure environment, 132 (24%) respondents mentioned implementation of the standard, for instance through stronger regulation, inspections, key performance indicators and transparency, and 75 (14%) respondents raised financing as an issue.

The remaining themes were each raised by between 7 and 10% of respondents. 52 respondents suggested improving resident engagement, 37 mentioned the importance of landlords having information about their properties (stock conditions, surveys, data) and 37 raised the issue of property access for landlords.

Chapter 2 – Effective resolution of complaints

The social housing green paper sought to ensure that social housing residents are able to access good complaints processes, as well as swift and effective redress where appropriate. It sought views on:

• strengthening the mediation opportunities
• reducing the waiting period for, or removing, the ‘democratic filter’ and ensuring that the “designated persons” are better able to promote local resolutions
• ensuring that residents understand how best to escalate a complaint and seek redress and can access the right advice and support when making a complaint
• ensuring that landlords’ processes for dealing with complaints are fast and effective
• ensuring that safety concerns are handled swiftly and effectively within the existing redress framework

Question 5 – Are there ways of strengthening the mediation opportunities available for landlords and residents to resolve disputes locally?

There were 594 responses to the closed section of this question. 277 of these responses were received from private individuals and 312 were on behalf of organisations. Of the organisational responses there were 117 from housing associations, 114 from local authorities, 6 from tenant management organisations, 26 from tenant representation groups, 6 from trade associations, 1 from a cooperative, and 41 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

415 (70%) respondents stated that there are ways of strengthening mediation opportunities, 133 (20%) respondents were not sure and 46 (8%) disagreed. 65% of individuals and 74% of organisations that responded thought there were ways to strengthen mediation opportunities.

494 respondents provided additional comments to this question. Of these, 177 responses were received from private individuals and 312 were on behalf of organisations. Of the organisational responses there were 115 from housing associations, 111 from local authorities, 6 from tenant management organisations, 27 from tenant representation groups, 8 from trade associations, 2 from cooperatives, and 43 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 135 (27%) respondents highlighted that mediation could be strengthened by promoting separate or independent mediation services, 124 (25%) respondents mentioned the benefits of tenants and/or tenant organisations playing a greater role in mediation and 107 (22%) responses stated that the speed of mediation and feedback should be improved.

In addition, the fourth to sixth highest themes each represented over 15% of comments received: 95 respondents suggested simplifying the complaints and mediation processes or issuing guidance, 91 mentioned promoting good practice or training on mediation and 85 stated that there should be greater investment in mediation services. A further two themes were each suggested by more than 5% of respondents: 29 respondents suggested making greater use of Members of Parliament and local councillors in mediating housing issues, and 27 respondents suggested more engagement and involvement from the Housing Ombudsman.

Question 6 – Should we reduce the eight week waiting period to four weeks, or should we remove the requirement for the “democratic filter” stage altogether?

621 respondents answered this question, of whom 279 were private individuals, 337 on behalf of organisations, and 5 did not specify. 279 of these responses were received from private individuals and 337 were on behalf of organisations. Of the organisational responses there were 126 from housing associations, 117 from local authorities, 6 from tenant management organisations, 30 from tenant representation groups, 8 from trade associations, 1 from a cooperative, and 48 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

33 respondents (5%) supported no change (3% of individuals and 7% of organisations). 236 (38%) supported the option to reduce the waiting time to four weeks (52% of individuals and 26% of organisations), and 290 (47%) respondents supported the option to remove the democratic filter stage altogether (34% of individuals and 58% of organisations). 62 respondents (10%) said that they were not sure, which represented 11% of individuals and 9% of organisations.

Question 7 – What can we do to ensure that the “designated persons” are better able to promote local resolutions?

506 respondents answered this question. 195 responses were received from private individuals and 306 were on behalf of organisations. Of the organisational responses there were 110 from housing associations, 111 from local authorities, 5 from tenant management organisations, 28 from tenant representation groups, 7 from trade associations, 1 from a cooperative, and 44 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 207 (41%) respondents suggested training of designated persons, 115 (23%) respondents mentioned increasing awareness of who designated persons are and how to contact them, and 51 (10%) respondents stated that there should be regular engagement between designated persons and landlords, tenants and the Ombudsman.

Question 8 – How can we ensure that residents understand how best to escalate a complaint and seek redress?

573 respondents answered this question. 221 responses were received from private individuals and 347 were on behalf of organisations. Of the organisational responses there were 125 from housing associations, 119 from local authorities, 6 from tenant management organisations, 33 from tenant representation groups, 10 from trade associations, 1 from a cooperative, and 53 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 335 (58%) of respondents suggested generally improving awareness of the existence of complaints and redress procedures, 117 (31%) respondents said that it was important that landlords clearly signpost their complaints processes, and 96 (17%) respondents stated that the processes must be simple, clear and timely.

In addition, the following themes each represented over 5% of comments received: 57 respondents suggested creating resident focal points for help, advice and support, particularly for more vulnerable residents, 53 mentioned the accessibility of the complaints procedures, 39 said that the processes should be standardised across the sector, and 38 stated that the provision of information should be mandatory or supported through the social housing regulatory framework.

Question 9 – How can we ensure that residents can access the right advice and support when making a complaint?

507 respondents answered this question. 195 responses were received from private individuals and 306 were on behalf of organisations. Of the organisational responses there were 110 from housing associations, 106 from local authorities, 6 from tenant management organisations, 27 from tenant representation groups, 8 from trade associations, 1 from a cooperative, and 48 from other sectors. 6 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 242 (48%) respondents raised increasing signposting and awareness of the complaints processes, 89 (18%) respondents mentioned providing independent advice and advocacy for residents and 68 (13%) respondents suggested funding or promoting third sector organisations.

In addition, the fourth and fifth highest themes each represented over 10% of comments received: 57 respondents suggested ensuring that support and guidance is available, for instance in the form of resident champions, and 54 stated that the ease of use of information should be improved, for instance making it more accessible and improving clarity.

A further two themes were each suggested by more than 5% of respondents. 31 respondents advocated ensuring that the processes which exist are clear, simple and timely and 28 respondents suggested there should be a regulatory or national standard, or a code of practice.

Question 10 – How can we best ensure that landlords’ processes for dealing with complaints are fast and effective?

572 respondents answered this question. 227 responses were received from private individuals and 339 were on behalf of organisations. Of the organisational responses there were 126 from housing associations, 118 from local authorities, 6 from tenant management organisations, 29 from tenant representation groups, 8 from trade associations, 2 from cooperatives, and 50 from other sectors. 6 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 152 (27%) respondents mentioned standardising the complaints process, 134 (23%) respondents mentioned the importance of timely and effective communication and 92 (16%) respondents stated that complaints processes should be time-bound.

In addition, the fourth to sixth highest themes each represented over 10% of comments received. 73 respondents suggested that there should be penalties or incentives for landlords’ performance in complaints handling, 67 stated that there should be a focus on effectiveness, and 66 suggested that landlords should publish key performance indicators.

A further four themes were each supported by more than 5% of respondents: 50 respondents suggested introducing external oversight of complaints processes, 49 suggested a strategy for sharing best practice, 41 suggested a resident accredited complaints process with continuous improvement, and 36 recommended upskilling staff who deal with complaint handling.

Question 11 – How can we best ensure safety concerns are handled swiftly and effectively within the existing redress framework?

512 respondents answered this question. 194 responses were received from private individuals and 312 were on behalf of organisations. Of the organisational responses there were 108 from housing associations, 112 from local authorities, 6 from tenant management organisations, 29 from tenant representation groups, 9 from trade associations, 1 from a cooperative, and 47 from other sectors. 6 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question 230 (45%) respondents highlighted that safety concerns should be prioritised and that response times should be reduced, and 70 (14%) respondents mentioned that there should be greater transparency over complaints and subsequent action taken.

In addition, the third to seventh highest themes each represented over 10% of comments received. 67 respondents recommended better guidance and training to raise the awareness of staff and residents, 67 suggested a specific point of contact or named senior staff member dealing with the complaint, 64 stated that key performance indicators should be set and published, 63 mentioned better communication with regard to escalating complaints, and 55 said that residents should be more involved.

A further two themes were each suggested by more than 5% of respondents: 51 suggested penalties or sanctions for non-compliance and 29 recommended updating the redress process for quicker resolution.

Chapter 3 – Empowering tenants and strengthening the regulator

The social housing green paper set out to ensure that social housing should be safe and decent. It sought views on:

• the way key performance indicators for social housing landlords could work
• the link between the affordable homes programme and landlord performance
• the effectiveness of resident engagement and scrutiny measures
• the potential for resident representation at a national level
• the potential to promote the transfer of local authority housing, promoting options for greater resident-leadership and giving social housing residents greater choice and control including over services
• whether Tenant Management Organisations are delivering positive outcomes for residents and landlords and the framework for local authorities to hold such organisations to account
• help for leaseholders of a social housing landlord
• regulation objectives on consumer regulation, and powers to provide clarity or produce other documents
• whether “serious detriment” is the appropriate threshold for intervention by the Regulator of Social Housing (the “regulator”) for a breach of consumer standards and the potential for a more proactive approach to regulation of consumer standards including enforcement and scrutiny of local authority landlords
• the accountability of the regulator to parliament

Question 12 – Do the proposed key performance indicators cover the right areas? Are there any other areas that should be covered?

Response to ‘Do the proposed key performance indicators cover the right areas?’

584 respondents answered this question, of which 249 were private individuals, 330 were organisations and 5 did not specify. Of the organisational responses there were 117 from housing associations, 110 from local authorities, 8 from tenant management organisations, 30 from tenant representation groups, 6 from trade associations, 2 from cooperatives, and 54 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

392 (67%) respondents said that the proposed key performance indicators do cover the right areas (74% of individuals and 62% of organisations). 94 (16%) said that they do not (13% of individuals and 18% of organisations), while 98 (17%) were unsure (13% of individuals and 19% of organisations).

Response to ‘Are there any other areas that should be covered?’

There were 564 responses to the closed section of this question. 242 of these responses were received from private individuals and 319 were on behalf of organisations. Of the organisational responses there were 116 from housing associations, 104 from local authorities, 7 from tenant management organisations, 30 from tenant representation groups, 6 from trade associations, 2 from cooperatives, and 52 from other sectors. 3 responses did not specify whether they were responding as an individual or on behalf of an organisation.

328 (58%) respondents said that there are other areas that should be covered, 143 (25%) respondents were not sure and 93 (16%) said that there were not. 51% of individuals and 63% of organisations that responded said there were other areas that should be covered.

456 respondents provided additional comments to this question. 140 responses were received from private individuals and 313 were on behalf of organisations. Of the organisational responses there were 117 from housing associations, 96 from local authorities, 4 from tenant management organisations, 23 from tenant representation groups, 10 from trade associations, 2 from cooperatives, and 61 from other sectors. 3 responses did not specify whether they were responding as an individual or on behalf of an organisation.

Findings from consultation analysis

When considering the additional comments made in response to this question, 118 (26%) respondents said that there should be a new indicator. 115 (25%) commented on the make-up of the indicators, including that they should be measurable, meaningful and objective, while 95 (21%) suggest indicators based on data which is already collected, for instance on number of voids. 84 (18%) respondents requested a financial indicator. 67 (15%) said that key performance indicators must drive performance rather than creating perverse incentives.

In addition, the fifth to ninth most common themes each represented more than 10% of responses. 63 respondents mentioned that contextual information is needed to support key performance indicators, for instance in respect of local circumstances and size and type of landlord. 55 respondents stated that it was important to ensure a consistent methodological approach, and 54 mentioned the importance of working with partners and residents. 51 respondents expressed major concerns about the key performance indicators, including the ability to compare like with like, while 49 suggested setting indicators locally.

A small minority of respondents also raised other issues, for instance suggesting that the process of developing key performance indicators should build on what information is already collected and commenting that key performance indicators on neighbourhood management and anti-social behaviour present challenges. It was also suggested that it is important to consider the resourcing implications of preparing, collecting and publishing key performance indicators. A small number of respondents were specifically opposed to league tables, while some suggested key performance indicators on customer satisfaction, equality and accessibility, and engagement with residents.

Question 13 – Should landlords report performance against these key performance indicators every year?

594 respondents answered this question, of which 249 were private individuals, 340 were organisations and 5 did not specify. 249 of these responses were received from private individuals and 340 were on behalf of organisations. Of the organisational responses there were 122 from housing associations, 113 from local authorities, 8 from tenant management organisations, 30 from tenant representation groups, 8 from trade associations, 2 from cooperatives, and 54 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

509 (86%) respondents agreed that landlords should report performance against these key performance indicators every year (86% of individuals and 86% of organisations). 28 (5%) said that they should not (5% of individuals and 4% of organisations), while 57 (10%) were unsure (9% of individuals and 10% of organisations).

Question 14 – Should landlords report performance against these key performance indicators to the regulator?

587 respondents answered this question, of whom 249 were private individuals, 333 were organisations and 5 did not specify. 249 of these responses were received from private individuals and 333 were on behalf of organisations. Of the organisational responses there were 115 from housing associations, 115 from local authorities, 8 from tenant management organisations, 28 from tenant representation groups, 8 from trade associations, 2 from cooperatives, and 55 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

458 (78%) respondents agreed that landlords should report performance against the key performance indicators to the regulator (86% of individuals and 72% of organisations). 51 (9%) said that they should not (4% of individuals and 12% of organisations), while 78 (13%) were unsure (9% of individuals and 16% of organisations).

Question 15 – What more can be done to encourage landlords to be more transparent with their residents?

497 respondents answered this question. 172 responses were received from private individuals and 320 were on behalf of organisations. Of the organisational responses there were 116 from housing associations, 105 from local authorities, 6 from tenant management organisations, 28 from tenant representation groups, 10 from trade associations, 3 from cooperatives and 52 from other sectors. 5 respondents did not indicate whether they were responding as private individuals or on behalf of an organisation.

In response to this question, 257 (52%) said that landlords should publish data, 65 (13%) mentioned league tables, and 45 (9%) suggested penalties.

Question 16 – Do you think that there should be a better way of reporting the outcomes of landlords’ complaint handling? How can this be made as clear and accessible as possible for residents?

There were 550 responses to the closed section of this question. 240 of these responses were received from private individuals and 306 were on behalf of organisations. Of the organisational responses there were 112 from housing associations, 102 from local authorities, 8 from tenant management organisations, 26 from tenant representation groups, 7 from trade associations, 2 from cooperatives, and 48 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

396 (72%) respondents agreed there should be better ways to handle the outcomes of landlords’ complaints handling, 116 (21%) respondents were not sure and 38 (7%) disagreed. 67% of individuals and 76% of organisations that responded said yes to the question.

380 respondents provided additional comments to this question. 111 responses were received from private individuals and 264 were on behalf of organisations. Of the organisational responses there were 97 from housing associations, 93 from local authorities, 4 from tenant management organisations, 21 from tenant representation groups, 9 from trade associations, and 40 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

When considering the comments in response to this question, 171 (45%) respondents recommended transparent, accessible, easy to understand reports, while 162 (43%) respondents commented on either the detail and/or frequency of publication of the reports.

The third and fourth most popular themes were each raised by more than 10% of respondents. 56 respondents suggested that the Housing Ombudsman needs to be better resourced, and 54 recommended the dissemination of lessons learned by landlords as the result of complaints upheld by the Ombudsman.

A further three themes were each raised by over 5% of respondents. 38 respondents raised the importance of ensuring focus remains on resolution of issues, rather than process or reporting at the expense of solving problems. 32 respondents mentioned consistency when comparing performance, and 26 suggested the best way to achieve good outcomes is through collaboration between landlords and tenants.

Question 17 – Is the regulator best placed to prepare key performance indicators in consultation with residents and landlords?

There were 556 responses to the closed section of this question. 243 of these responses were received from private individuals and 309 were on behalf of organisations. Of the organisational responses there were 114 from housing associations, 104 from local authorities, 8 from tenant management organisations, 28 from tenant representation groups, 7 from trade associations, 2 from cooperatives, and 44 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

298 (54%) respondents agreed that the regulator is best placed to prepare key performance indicators, 164 (29%) respondents were not sure and 94 (17%) disagreed. 54% of individuals and 53% of organisations that responded agreed with the question.

313 respondents provided additional comments to this question. 61 responses were received from private individuals and 248 were on behalf of organisations. Of the organisational responses there were 101 from housing associations, 80 from local authorities, 3 from tenant management organisations, 22 from tenant representation groups, 8 from trade associations, 2 from cooperatives, and 32 from other sectors. 4 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 117 (37%) of respondents recommended that key performance indicator development should be done in conjunction with tenants or be tenant-led and 106 (34%) respondents recommended key performance indicator development should be done in conjunction with landlords, or be sector-led. Some landlords praised how the sector scorecard was produced in collaboration with the sector. 68 (22%) respondents highlighted that local nuances needed to be taken into account, as there were concerns that a ‘one size fits all’ approach would not be appropriate for all localities, leading to concerns that this would hamper fair comparisons across providers.

The fourth to sixth most common themes were raised by at least 10% of respondents. 56 respondents raised the issue of consistency and a standardised approach, 32 mentioned concerns about the regulator’s skills and resources, and 32 advocated including existing performance benchmarking organisations in the process.

Two further themes were each raised by over 5% of respondents: 20 respondents suggested using existing information to prepare key performance indicators, and 17 respondents recommended the involvement of academics or other experts in designing new key performance indicators.

Question 18 – What would be the best approach to publishing key performance indicators that would allow residents to make the most effective comparison of performance?

453 respondents answered this question. 146 responses were received from private individuals and 303 were on behalf of organisations. Of the organisational responses there were 114 from housing associations, 108 from local authorities, 5 from tenant management organisations, 23 from tenant representation groups, 8 from trade associations, 2 from cooperatives and 43 from other sectors. 4 respondents did not indicate whether they were responding as private individuals or on behalf of an organisation.

In response to this question, 163 (36%) respondents suggested online publication, 144 (32%) said that it was important to compare like for like and contextualise performance, and 109 (24%) expressed opposition to league tables. 80 (18%) mentioned the importance of a simple and accessible format, and 66 (15%) suggested paper publication.

A further three themes were each raised by over 5% of respondents. 43 respondents were in favour of league tables, 35 respondents were opposed to key performance indicators, and 34 respondents recommended using standardisation to assist audit including standardised formats and methodology.

Question 19 – Should we introduce a new criterion to the Affordable Homes Programme that reflects residents’ experience of their landlord? What other ways could we incentivise best practice and deter the worst, including for those providers that do not use government funding to build?

Response to ‘Should we introduce a new criterion to the Affordable Homes Programme that reflects residents’ experience of their landlord?’

There were 558 responses to the closed section of this question. 239 of these responses were received from private individuals and 315 were on behalf of organisations. Of the organisational responses there were 114 from housing associations, 111 from local authorities, 8 from tenant management organisations, 28 from tenant representation groups, 7 from trade associations, 2 from cooperatives, and 44 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

271 (49%) respondents agreed that a new criterion should be introduced to the Affordable Homes Programme that reflects residents’ experience of their landlord, 124 (22%) respondents were not sure and 163 (29%) disagreed. 70% of individuals and 32% of organisations that responded agreed that such a new criterion should be introduced.

365 respondents provided additional comments in response to this question. 88 responses were received from private individuals and 273 were on behalf of organisations. Of the organisational responses there were 100 from housing associations, 101 from local authorities, 3 from tenant management organisations, 20 from tenant representation groups, 8 from trade associations, and 41 from other sectors. 4 respondents did not indicate whether they were responding as private individuals or on behalf of an organisation.

In making additional comments in response to this question, 124 (34%) agreed that a new criterion should be introduced, 88 (24%) said that more housing was needed regardless of new criteria, and 64 (18%) stated that data can be misleading about performance.

A further three themes were raised by over 5% of respondents. 47 respondents expressed the view that such a new criterion could have a negative effect on tenants, 37 respondents suggested that alternative measures should be considered, and 19 respondents raised the concern that an additional criterion would not cover all landlords.

Response to ‘What other ways could we incentivise best practice and deter the worst, including for those providers that do not use government funding to build?’

342 respondents answered this question. 124 responses were received from private individuals and 215 were on behalf of organisations. Of the organisational responses there were 77 from housing associations, 77 from local authorities, 5 from tenant management organisations, 20 from tenant representation groups, 5 from trade associations, 1 from a cooperative and 30 from other sectors. 3 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 67 (20%) suggested penalties, and 62 (18%) said that good practice should be incentivised. 52 (15%) felt that the regulator should use or further strengthen its powers, while 37 (11%) suggested creating a minimum standard.

A further three themes were raised by over 5% of respondents. 21 respondents expressed concerns about a negative impact on residents. 21 respondents suggested empowering residents by, for example, giving them the option to change landlord. 18 respondents questioned whether the current regulatory framework was setting the right expectations.

Question 20 – Are current resident engagement and scrutiny measures effective? What more can be done to make residents aware of existing ways to engage with landlords and influence how services are delivered?

Response to ‘Are current resident engagement and scrutiny measures effective?’

535 respondents answered this question, of whom 237 were private individuals and 293 were organisations. Of the organisational responses there were 110 from housing associations, 100 from local authorities, 8 from tenant management organisations, 29 from tenant representation groups, 6 from trade associations, 2 from cooperatives, and 37 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

120 (22%) respondents agreed that current resident engagement and scrutiny measures are effective (11% of individuals and 32% of organisations). 240 (45%) said that current measures are not effective (61% of individuals and 31% of organisations). 175 (33%) were not sure (28% of individuals and 36% of organisations).

Response to ‘What more can be done to make residents aware of existing ways to engage with landlords and influence how services are delivered?’

471 respondents answered this question. 166 responses were received from private individuals and 301 were on behalf of organisations. Of the organisational responses there were 113 from housing associations, 105 from local authorities, 6 from tenant management organisations, 28 from tenant representation groups, 7 from trade associations, 3 from cooperatives and 39 from other sectors. 4 respondents did not specify whether they were responding as an individual or on behalf of an organisation.

When considering the responses to this question, 183 (39%) respondents mentioned clearer information from, and clearer communication with, landlords. 162 (34%) suggested a greater choice and range of methods of communication, for instance taking into account physical barriers, location and time constraints. 85 (18%) respondents suggested strengthening resident scrutiny and Tenant and Resident Associations.

A further three themes were raised by over 5% of respondents. 65 respondents suggested strengthening consumer regulation, for instance through either strengthening the regulator better promoting the Tenant Involvement and Empowerment Standard. 64 respondents mentioned digital platforms. 28 respondents suggested the formation of a national tenant organisation.

Question 21 – Is there a need for a stronger representation for residents at a national level? If so, how should this best be achieved?

There were 576 responses to the closed section of this question. 246 of these responses were received from private individuals and 324 were on behalf of organisations. Of the organisational responses there were 113 from housing associations, 104 from local authorities, 8 from tenant management organisations, 33 from tenant representation groups, 7 from trade associations, 2 from cooperatives, and 54 from other sectors. 6 responses did not specify whether they were responding as an individual or on behalf of an organisation.

411 (71%) respondents said that there is a need for a stronger representation for residents at a national level, 114 (20%) respondents were not sure and 51 (9%) disagreed. 80% of individuals and 65% of organisations that responded supported stronger national representation.

433 respondents provided additional comments in response to this question. 128 responses were received from private individuals and 302 were on behalf of organisations. Of the organisational responses there were 114 from housing associations, 94 from local authorities, 4 from tenant management organisations, 30 from tenant representation groups, 9 from trade associations, 2 from cooperatives, and 49 from other sectors. 3 respondents did not indicate whether they were responding as private individuals or on behalf of an organisation.

In making additional comments in response to this question, 111 (26%) said that it was difficult but necessary to ensure that any body would be representative, 63 (15%) said that the government should either use or involve existing national bodies, 50 (12%) suggested a national forum made up of elected resident representatives, and 48 (11%) felt that local representation is equally or more important.

Two further themes were raised by over 5% of respondents. 26 respondents felt that it was important that any representative body or organisation should have real power to influence and not just be a tick-box exercise, and 25 suggested that there was a need for training or financial resources.

Question 22 – Would there be interest in a programme to promote the transfer of local authority housing, particularly to community-based housing associations? What would it need to make it work?

There were 526 responses to the closed section of this question. 239 of these responses were received from private individuals and 282 were on behalf of organisations. Of the organisational responses there were 95 from housing associations, 105 from local authorities, 10 from tenant management organisations, 30 from tenant representation groups, 5 from trade associations, 2 from cooperatives, and 33 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

140 (27%) respondents said there is interest in a programme to promote the transfer of local authority housing, particularly to community-based housing associations, 198 (38%) respondents were not sure and 188 (36%) did not think there would be interest. 30% of individuals and 23% of organisations that responded said there would be interest.

289 respondents provided additional comments in response to this question. 94 responses were received from private individuals and 193 were on behalf of organisations. Of the organisational responses there were 53 from housing associations, 75 from local authorities, 9 from tenant management organisations, 22 from tenant representation groups, 8 from trade associations, and 26 from other sectors. 2 respondents did not indicate whether they were responding as private individuals or on behalf of an organisation.

In making additional comments in response to this question, 95 (33%) respondents said that they did not support transfer of stock from local authorities. 61 (21%) were supportive of the suggestion, while 32 (11%) supported the suggestion with the caveat that financing or a long-term rent settlement was necessary. 32 (11%) said that tenants should have greater influence and empowerment locally, including with mergers and takeovers.

A further seven themes were each raised by more than 5% of respondents to this question. 27 respondents expressed support for the suggestion provided the right governance, structures and skills for delivery were available. 26 respondents suggested a need for residents and landlords to work together regardless of tenure. 23 respondents raised concerns about the suitability of the housing association sector, citing issues around governance and accountability. 22 respondents suggested that stock transfers from housing associations to local authorities should also be possible. 19 respondents expressed concerns regarding the increasing number of mergers creating very large housing associations and decreasing local connection. 18 respondents suggested the issue should be decided locally, and 15 respondents advocated that the process should be community led, through the likes of a ballot or consultation.

Question 23 – Could a programme of trailblazers help to develop and promote options for greater resident-leadership within the sector?

520 respondents answered this question. 232 of these responses were received from private individuals and 283 were on behalf of organisations. Of the organisational responses there were 102 from housing associations, 102 from local authorities, 10 from tenant management organisations, 26 from tenant representation groups, 7 from trade associations, 2 from cooperatives, and 33 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

267 (51%) respondents agreed that a programme of trailblazers could help to develop and promote options for greater resident-leadership within the sector (48% of individuals and 54% of organisations). 65 (13%) respondents did not support a programme of trailblazers (11% of individuals and 14% of organisations), while 188 (36%) respondents were unsure (41% of individuals and 32% of organisations).

Question 24 – Are Tenant Management Organisations delivering positive outcomes for residents and landlords? Are current processes for setting up and disbanding Tenant Management Organisations suitable? Do they achieve the right balance between residents’ control and local accountability?

Response to ‘Are Tenant Management Organisations delivering positive outcomes for residents and landlords?’

There were 496 responses to the closed section of this question. 234 of these responses were received from private individuals and 257 were on behalf of organisations. Of the organisational responses there were 89 from housing associations, 95 from local authorities, 11 from tenant management organisations, 23 from tenant representation groups, 5 from trade associations, 2 from cooperatives, and 30 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

66 (13%) respondents stated that Tenant Management Organisations are delivering positive outcomes for residents and landlords, (12% of individuals and 14% of organisations), 341 (69%) respondents were not sure and 89 (18%) disagreed.

221 respondents provided additional comments in response to this question. 78 responses were received from private individuals and 139 were on behalf of organisations. Of the organisational responses there were 43 from housing associations, 49 from local authorities, 9 from tenant management organisations, 11 from tenant representation groups, 3 from trade associations, 2 from cooperatives, and 22 from other sectors. 4 respondents did not indicate whether they were responding as private individuals or on behalf of an organisation.

In making additional comments in response to this question 57 (26%) respondents stated that Tenant Management Organisations are delivering positive outcomes, for instance meeting or exceeding key performance indicators and providing good delivery of services. 51 (23%) made reference to Grenfell Tower or the Kensington and Chelsea Tenant Management Organisation, feeling that this has damaged the image of Tenant Management Organisations^{[footnote 1]}. 43 (19%) said that Tenant Management Organisations assist local decision making and resident choice, and 42 (19%) said that some Tenant Management Organisations are providing positive outcomes but others are not.

In addition, the third and fourth most common themes both represented more than 10% of responses. 34 respondents mentioned high satisfaction rates, and 30 said that Tenant Management Organisations provide social value and/or community engagement.

Other comments, each raised by at least 5% of respondents, included greater scrutiny of Tenant Management Organisations, expressions of concern regarding sustainability and succession, and the professionalism and skills of Tenant Management Organisation staff. Some respondents also mentioned the democratic nature of Tenant Management Organisations, as well as the fact that they need resourcing to set up. A small number of respondents also stated that all landlords should be accountable, regardless of structure.

Response to ‘Are current processes for setting up and disbanding Tenant Management Organisations suitable? Do they achieve the right balance between residents’ control and local accountability?’

There were 469 responses to the closed section of this question. 232 of these responses were received from private individuals and 234 were on behalf of organisations. Of the organisational responses there were 84 from housing associations, 84 from local authorities, 10 from tenant management organisations, 21 from tenant representation groups, 4 from trade associations, 2 from cooperatives, and 26 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

85 (18%) respondents said that the current processes are not suitable and do not achieve the right balance. 19 (4%) said that the current processes are suitable and achieve the right balance, and 33 (7%) said that the current processes are suitable but do not achieve the right balance. 332 (71%) were unsure.

163 respondents provided additional comments on this question. 84 responses were received from private individuals and 78 were on behalf of organisations. Of the organisational responses there were 16 from housing associations, 32 from local authorities, 9 from tenant management organisations, 8 from tenant representation groups, 1 from a trade association, 1 from a cooperative, and 11 from other sectors. 1 response did not specify whether they were responding as an individual or on behalf of an organisation.

When considering the additional comments on this question, 85 (52%) suggested that the current processes are not suitable and do not achieve the right balance. 33 (20%) said that the processes are suitable but do not achieve the right balance. 21 (13%) mentioned that funding was needed to set up or build capacity. 19 (12%) said that the current processes are suitable and achieve the right balance, and 17 (10%) said that guidelines should be reviewed to address governance issues.

A further three themes were each raised by over 5% of respondents. 11 respondents commented that Tenant Management Organisations are too hard to disband, 9 respondents suggested tenant members need training, and 8 mentioned a lack of interest from residents.

Question 25 – Are there any other innovative ways of giving social housing residents greater choice and control over the services they receive from landlords?

343 respondents answered this question, of which 97 responses were from private individuals and 243 were on behalf of organisations. Of the organisational responses there were 85 from housing associations, 81 from local authorities, 9 from tenant management organisations, 27 from tenant representation groups, 6 from trade associations, 3 from cooperatives, and 32 from other sectors. 3 respondents did not indicate whether they were responding as private individuals or on behalf of an organisation.

In making additional comments in response to this question, 116 (34%) respondents mentioned resident involvement, for instance in service design, procurement and governance. 91 (27%) mentioned various types of Tenant Management Organisations and other alternative management models. 43 (13%) said that tenants should have a say and/or determine priority services and identify gaps in provision, and 36 (10%) suggested that decisions should be made locally.

Other comments, each made by at least 5% of respondents, included a suggestion that a range of channels should be available for residents to provide feedback, and that residents should be supported with empowerment and that funding should be provided to build capacity for skills and competency. Some respondents felt that there was little appetite from residents for innovation in this area, while others mentioned the extension of statutory rights and the use of regulation and the serious detriment test, as well as the simplification of information to make it more accessible.

Question 26 – Do you think that there are benefits to models that support residents to take on some of their own services? If so, what is needed to make this work?

There were 512 responses to the closed section of this question. 227 of these responses were received from private individuals and 280 were on behalf of organisations. Of the organisational responses there were 105 from housing associations, 96 from local authorities, 12 from tenant management organisations, 25 from tenant representation groups, 5 from trade associations, 2 from cooperatives, and 33 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

228 (45%) respondents agreed that there are benefits to models that support residents to take on some of their own services, 172 (45%) respondents were not sure and 112 (22%) disagreed. 45% of individuals and 44% of organisations that responded agreed that there are benefits to models that support residents to take on some of their own services.

315 respondents provided additional comments in response to this question. 96 responses were received from private individuals and 217 were on behalf of organisations. Of the organisational responses there were 83 from housing associations, 76 from local authorities, 9 from tenant management organisations, 16 from tenant representation groups, 6 from trade associations, 1 from a cooperative, and 27 from other sectors. 2 respondents did not indicate whether they were responding as private individuals or on behalf of an organisation.

In making additional comments in response to this question, 90 (29%) respondents suggested that in order for these models to work training and/or funding are required. 64 (20%) mentioned problems with governance structure and oversight, and 60 (19%) raised concerns about risks including safety, value for money and resource in this approach.

The fourth to sixth most popular themes were raised by over 5% of respondents. 37 respondents expressed concerns that there would be little resident interest. 35 respondents suggested that there were benefits of resident-led social enterprises and local contractors for non-core services. 26 respondents suggested that residents taking on more of their own services might lead to positive outcomes, including higher customer satisfaction, confidence, wellbeing and inclusion.

Question 27 – How can landlords ensure residents have more choice over contractor services, while retaining oversight of quality and value for money?

455 respondents answered this question. 166 responses were received from private individuals and 285 were on behalf of organisations. Of the organisational responses there were 110 from housing associations, 101 from local authorities, 6 from tenant management organisations, 26 from tenant representation groups, 5 from trade associations, 2 from cooperatives, and 35 from other sectors. 4 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 272 (60%) respondents suggested that residents should have a greater role in the process, including procurement, tendering, contractor selection and monitoring of the process. 35 (8%) respondents mentioned a need for good scrutiny of contractors’ work, for instance using scrutiny panels, focus groups, or tenant inspectors. 32 (7%) respondents raised concerns that resident choice will increase costs and/or prevent appropriate oversight. 25 (5%) respondents suggested the use of IT for real-time assessment of work, feedback and information distribution.

Question 28 – What more could we do to help leaseholders of a social landlord?

301 respondents answered this question. 85 responses were received from private individuals and 215 were on behalf of organisations. Of the organisational responses there were 80 from housing associations, 80 from local authorities, 3 from tenant management organisations, 15 from tenant representation groups, 5 from trade associations, 1 from a cooperative, and 31 from other sectors. 1 response did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 82 (27%) respondents suggested providing clearer information and transparency on service charges. 80 (27%) respondents mentioned increasing leaseholders’ and social landlords’ awareness of leaseholders’ rights and obligations, and 68 (23%) suggested more leaseholder involvement and engagement. The fourth to sixth most popular themes were raised by over 5% of respondents. 30 respondents suggested adopting and sharing best practice. 23 respondents suggested provision of alternative payment arrangements including introducing flexible payments or a cap for major works. 19 respondents suggested increasing leaseholders’ awareness of their rights and obligations under health and safety regulations.

Question 29 – Does the regulator have the right objective on consumer regulation? Should any of the consumer standards change to ensure that landlords provide a better service for residents in line with the new key performance indicators proposed, and if so how?

Response to ‘Does the regulator have the right objective on consumer regulation?’

There were 489 responses to the closed section of this question. 200 of these responses were received from private individuals and 284 were on behalf of organisations. Of the organisational responses there were 105 from housing associations, 100 from local authorities, 6 from tenant management organisations, 27 from tenant representation groups, 4 from trade associations, 2 from cooperatives, and 39 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

282 (58%) respondents stated that the regulator does have the right objective on consumer regulation, with 47% of individuals and 65% of organisations in agreement. 119 (24%) respondents were not sure and 88 (18%) disagreed.

245 respondents provided additional comments in response to this question. 63 responses were received from private individuals and 182 were on behalf of organisations. Of the organisational responses there were 71 from housing associations, 55 from local authorities, 2 from tenant management organisations, 13 from tenant representation groups, 7 from trade associations, 1 from a cooperative, and 33 from other sectors.

When considering the additional comments to this question, 61 (25%) respondents suggested a proactive approach to enforcement, 54 (22%) were unsure about the current objective, and 51 (21%) made specific comments about the appropriateness of the current consumer standard.

Other comments included the suggestion that the serious detriment test should be removed, and requested that any changes should be made collaboratively and that the quality and transparency of information should be improved. Other respondents suggested strengthening the Tenant Involvement and Empowerment Standard which is already widely used by the sector.

Response to ‘Should any of the consumer standards change to ensure that landlords provide a better service for residents in line with the new key performance indicators proposed, and if so how?’

There were 466 responses to the closed section of this question. 195 of these responses were received from private individuals and 266 were on behalf of organisations. Of the organisational responses there were 102 from housing associations, 91 from local authorities, 5 from tenant management organisations, 23 from tenant representation groups, 4 from trade associations, 2 from cooperatives, and 38 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

231 (50%) respondents said that some of the consumer standards should change to ensure that landlords provide a better service for residents in line with the new key performance indicators proposed, 143 (31%) respondents were not sure and 91 (20%) disagreed. 46% of individuals and 52% of organisations that responded were in favour of change.

234 respondents provided additional comments in response to this question. 56 responses were received from private individuals and 176 were on behalf of organisations. Of the organisational responses, there were 71 from housing associations, 55 from local authorities, 3 from tenant management organisations, 12 from tenant representation groups, 4 from trade associations, 2 from cooperatives, and 29 from other sectors. 2 responses did not indicate whether they were responding as a private individual or on behalf of an organisation.

In respect of additional comments to this question, 68 (29%) respondents suggested increased enforcement, 47 (20%) mentioned a need for more detailed guidance. 39 (17%) mentioned resident engagement, and 32 (14%) raised health and safety issues.

Other feedback included respondents who felt that more regulation and prescription were not needed, as well as more general complaints. Some responses also mentioned a need for more localisation.

Question 30 – Should the regulator be given powers to produce other documents, such as a Code of Practice, to provide further clarity about what is expected from the consumer standards?

498 respondents answered this question. 197 of these responses were received from private individuals and 297 were on behalf of organisations. Of the organisational responses there were 106 from housing associations, 104 from local authorities, 6 from tenant management organisations, 27 from tenant representation groups, 9 from trade associations, 2 from cooperatives, and 42 from other sectors. 4 responses did not specify whether they were responding as an individual or on behalf of an organisation.

408 (82%) respondents said that the regulator should be given powers to produce other documents, such as a Code of Practice, to provide further clarity about what is expected from the consumer standards (86% of individuals and 79% of organisations). 39 (8%) respondents disagreed (4% of individuals and 10% of organisations), while 51 (10%) respondents said that they were unsure (10% of individuals and 10% of organisations).

Question 31 – Is “serious detriment” the appropriate threshold for intervention by the regulator for a breach of consumer standards? If not, what would be an appropriate threshold for intervention?

There were 491 responses to the closed section of this question. 197 of these responses were received from private individuals and 289 were on behalf of organisations. Of the organisational responses there were 109 from housing associations, 99 from local authorities, 6 from tenant management organisations, 26 from tenant representation groups, 6 from trade associations, 2 from cooperatives, and 40 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

156 (32%) respondents said that “serious detriment” is the appropriate threshold for intervention by the regulator for a breach of consumer standards, 91 (19%) respondents were not sure and 244 (50%) disagreed. 30% of individuals and 33% of organisations that responded supported maintaining the current level of the threshold. 335 respondents provided additional comments in response to this question. 95 responses were received from private individuals and 236 were on behalf of organisations. Of the organisational responses there were 86 from housing associations, 82 from local authorities, 4 from tenant management organisations, 19 from tenant representation groups, 7 from trade associations, 1 from a cooperative, and 37 from other sectors. 4 responses did not indicate whether they were responding as a private individual or on behalf of an organisation.

In making additional comments in response to this question, 247 (74%) respondents said that the threshold should be lower than is currently the case. 91 (27%) respondents mentioned that there should be a risk-based approach to intervention with persistent low performance flagged early. 45 (13%) respondents said that the threshold should remain at “serious detriment”. 39 (12%) said that there should be greater clarity over the meaning of “serious detriment”.

The fourth to seventh most popular themes were each raised by over 5% of respondents. 24 respondents expressed concerns that lowering the threshold would lead to a resource burden on the regulator. 22 respondents suggested the threshold should be systemic failure where a group of residents are affected, while 16 respondents suggested the threshold should be a single breach of the standards.

Question 32 – Should the regulator adopt a more proactive approach to regulation on consumer standards? Should the regulator use key performance indicators and phased interventions as a means to identify and tackle poor performance against these consumer standards? How should this be targeted?

Response to ‘Should the regulator adopt a more proactive approach to regulation on consumer standards?’

There were 485 responses to the closed section of this question. 197 of these responses were received from private individuals and 284 were on behalf of organisations. Of the organisational responses there were 107 from housing associations, 97 from local authorities, 6 from tenant management organisations, 25 from tenant representation groups, 5 from trade associations, 2 from cooperatives, and 41 from other sectors. 4 responses did not specify whether they were responding as an individual or on behalf of an organisation.

383 (79%) respondents agreed that the regulator should adopt a more proactive approach to regulation on consumer standards (85% of individuals and 75% of organisations). 41 (8%) respondents disagreed (3% of individuals and 13% of organisations), while 61 (13%) respondents were unsure (13% of individuals and 12% of organisations).

Response to ‘Should the regulator use key performance indicators and phased interventions as a means to identify and tackle poor performance against these consumer standards? How should this be targeted?’

There were 470 responses to the closed section of this question. 197 of these responses were received from private individuals and 269 were on behalf of organisations. Of the organisational responses there were 101 from housing associations, 96 from local authorities, 6 from tenant management organisations, 21 from tenant representation groups, 4 from trade associations, 2 from cooperatives, and 38 from other sectors. 4 responses did not specify whether they were responding as an individual or on behalf of an organisation.

334 (71%) respondents agreed that the regulator should use key performance indicators and phased interventions as a means to identify and tackle poor performance against these consumer standards, 89 (19%) respondents were not sure and 47 (10%) disagreed. 75% of individuals and 68% of organisations that responded agreed with the question.

292 respondents provided additional comments in response to this question. 71 responses were received from private individuals and 221 were on behalf of organisations. Of the organisational responses there were 82 from housing associations, 82 from local authorities, 3 from tenant management organisations, 12 from tenant representation groups, 7 from trade associations, 1 from a cooperative, and 34 from other sectors.

In making additional comments in response to this question, 52 (18%) suggested that data from tenant groups or the Ombudsman should be used. 47 (16%) mentioned working with landlords before intervention, and 43 (15%) said that other information should be used, including In Depth Assessments and tenant views.

Other respondents stated that tackling poor performance should be proportionate based on context, and that a clear understanding of the trigger level for intervention was needed. A small number of respondents also suggested that the regulator should be more proactive and should prioritise enforcement. Some respondents also felt that key performance indicators are a flawed basis for intervention, and that landlords should self-assess performance against the consumer standards.

Question 33 – Should the regulator have greater ability to scrutinise the performance and arrangements of local authority landlords? If so, what measures would be appropriate?

There were 475 responses to the closed section of this question. 203 of these responses were received from private individuals and 267 were on behalf of organisations. Of the organisational responses there were 96 from housing associations, 98 from local authorities, 6 from tenant management organisations, 22 from tenant representation groups, 5 from trade associations, 2 from cooperatives, and 36 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

355 (75%) respondents agreed that the regulator should have greater ability to scrutinise the performance and arrangements of local authority landlords, 85 (18%) respondents were not sure and 35 (7%) disagreed. 82% of individuals and 69% of organisations that responded agreed with the question.

502 respondents provided additional comments in response to this question. 201 responses were received from private individuals and 295 were on behalf of organisations. Of the organisational responses there were 101 from housing associations, 106 from local authorities, 6 from tenant management organisations, 27 from tenant representation groups, 9 from trade associations, 2 from a cooperative, and 44 from other sectors. 6 respondents did not indicate whether they were responding as private individuals or on behalf of an organisation.

In making additional comments in response to this question, 369 (74%) respondents were in favour of the regulator having greater ability to scrutinise the performance and arrangements of local authority landlords.

36 (7%) respondents were against the regulator having greater oversight of local authority landlords. 30 (6%) respondents called for further consistency, such as to ensure those in the private rented sector had similar protections to those in the social sector.

Question 34 – Are the existing enforcement measures set out in Box 3 adequate? If not, what additional enforcement powers should be considered?^{[footnote 2]}

There were 476 responses to the closed section of this question. 197 of these responses were received from private individuals and 274 were on behalf of organisations. Of the organisational responses there were 103 from housing associations, 94 from local authorities, 6 from tenant management organisations, 25 from tenant representation groups, 5 from trade associations, 2 from cooperatives, and 38 from other sectors. 5 responses did not specify whether they were responding as an individual or on behalf of an organisation.

230 (48%) respondents felt that existing enforcement measures are adequate, 111 (23%) respondents were not sure and 135 (28%) disagreed. 30% of individuals and 69% of organisations that responded agreed with the question.

487 respondents provided additional comments in response to this question. 197 responses were received from private individuals and 285 were on behalf of organisations. Of the organisational responses there were 106 from housing associations, 99 from local authorities, 5 from tenant management organisations, 25 from tenant representation groups, 7 from trade associations, 2 from a cooperative, and 41 from other sectors. 5 respondents did not indicate whether they were responding as private individuals or on behalf of an organisation.

In making additional comments in response to this question, 231 (47%) respondents felt the existing enforcement measures are adequate, while 130 (27%) felt that the measures are not adequate.

A further two themes were raised by over 5% of respondents. 82 respondents suggested measures should be standardised across tenure, and 63 respondents commented that the existing measures are not enforced.

Question 35 – Is the current framework for local authorities to hold management organisations such as Tenant Management Organisations and Arms Length Management Organisations to account sufficiently robust? If not, what more is needed to provide effective oversight of these organisations?

There were 443 responses to the closed section of this question. 193 of these responses were received from private individuals and 246 were on behalf of organisations. Of the organisational responses there were 87 from housing associations, 90 from local authorities, 9 from tenant management organisations, 24 from tenant representation groups, 5 from trade associations, 2 from cooperatives, and 28 from other sectors. 4 responses did not specify whether they were responding as an individual or on behalf of an organisation.

66 (15%) respondents agreed that the existing framework for holding management organisations to account is sufficiently robust, 258 (58%) respondents were not sure and 119 (27%) disagreed. 15% of individuals and 15% of organisations that responded felt the existing framework was sufficient.

172 respondents provided additional comments in response to this question. 46 responses were received from private individuals and 125 were on behalf of organisations. Of the organisational responses there were 33 from housing associations, 44 from local authorities, 7 from tenant management organisations, 11 from tenant representation groups, 5 from trade associations, 2 from cooperatives, and 23 from other sectors. 1 respondent did not indicate whether they were responding as a private individual or on behalf of an organisation.

In making additional comments in response to this question, 57 (33%) respondents suggested local authorities should have more powers to inspect and enforce. 42 (24%) suggested the regulator should have more oversight. 34 (20%) said there should be consistency across the sector, with one set of standards for all providers. A further two themes were raised by over 5% of respondents. 24 respondents suggested Arms Length Management Organisations and Tenant Management Organisations should be accountable to residents and to the community, and 11 said that lessons from Grenfell Tower must be learned.

Question 36 – What further steps, if any, should government take to make the regulator more accountable to Parliament?

152 respondents provided comments in response to this question. 28 responses were received from private individuals and 124 were on behalf of organisations. Of the organisational responses there were 49 from housing associations, 35 from local authorities, 3 from tenant management organisations, 13 from tenant representation groups, 4 from trade associations, 1 from a cooperative, and 19 from other sectors.

In the additional comments on this question, 57 (38%) respondents stated that the current arrangements are satisfactory. 24 (16%) said the regulator should present an annual report to Parliament. Some of these suggested the regulator should report on key performance indicators. There were mixed views on whether the report should cover the regulator’s activities or the state of the sector. 21 (14%) respondents said that the relevant select committee should have oversight of the regulator. 15 (10%) respondents said that the regulator should be more accountable to tenants and the general public, rather than just Parliament.

Chapter 4 – Tackling stigma and celebrating thriving communities

The social housing green paper noted that stigma was the most consistent theme raised by residents at the engagement events before the green paper was published. It sought views on:

• potential for a best neighbourhood competition
• sharing positive stories of social housing
• professionalisation of housing management
• measuring whether landlords are providing good neighbourhood management
• the social value provided by landlords
• the way landlords are working to tackle anti-social behaviour
• supporting good design in the social sector

Question 37 – How could we support or deliver a best neighbourhood competition?

393 respondents answered this question. 112 responses were received from private individuals and 279 were on behalf of organisations. Of the organisational responses there were 105 from housing associations, 102 from local authorities, 3 from tenant management organisations, 23 from tenant representation groups, 8 from trade associations, 1 from a cooperative, and 37 from other sectors. 2 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question 203 (52%) of respondents were critical of the idea of a best neighbourhood competition. 100 (25%) respondents said that any such competition needed to be led locally by residents or by the community.

Several other themes were each raised by a small number of respondents. Some suggested that a best neighbourhood competition could increase stigma, while others provided specific case studies. Other respondents suggested that any best neighbourhood competition should be approached from a multi-tenure perspective, encourage sharing of best practice or including a financial incentive. It was also commented that positive publicity would be needed in advance of and after such events.

Question 38 – In addition to sharing positive stories of social housing residents and their neighbourhoods, what more could be done to tackle stigma?

429 respondents answered this question. 127 responses were received from private individuals and 300 were on behalf of organisations. Of the organisational responses there were 111 from housing associations, 106 from local authorities, 4 from tenant management organisations, 23 from tenant representation groups, 7 from trade associations, 2 from cooperatives, and 48 from other sectors. 2 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question 136 (32%) respondents suggested changing how the media reports on social housing and poverty. 134 (31%) respondents suggested stopping the emphasis of home ownership as the tenure of choice. 98 (23%) respondents said that it was important to invest in the quality and design of stock and neighbourhoods. 96 (22%) respondents suggested that the government needs to lead the change in language.

In addition, the fifth to eighth most common themes were each raised by over 10% of respondents. 84 respondents suggested increasing the supply of social homes, 74 mentioned better promotion of positive stories, 61 suggested promoting tenure-blind or mixed communities and 51 suggested myth busting or information campaigns. Other comments included mentions of government policy, particularly welfare reform and suggestions that local community initiatives should be supported and encouraged. Some respondents mentioned the importance of tackling anti-social behaviour, while others said that government should support resident engagement and national tenant forums.

Question 39 – What is needed to further encourage the professionalisation of housing management to ensure all staff deliver a good quality of service?

421 respondents answered this question. 123 responses were received from private individuals and 296 were on behalf of organisations. Of the organisational responses there were 106 from housing associations, 106 from local authorities, 4 from tenant management organisations, 20 from tenant representation groups, 7 from trade associations, 1 from a cooperative, and 52 from other sectors. 2 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 111 (26%) suggested more professional qualifications at all stages, for instance clear development for apprentices and graduates. 87 (21%) felt that the issue is not professionalisation but rather that good quality service is grounded in the culture and values of the sector. 73 (17%) said that the onus is on the housing provider to encourage and provide training.

A small number of respondents each raised several other points, including bespoke training for specific areas of housing management, the provision of resources and certainty from central government to landlords, and the possible introduction of league tables or key performance indicators. Some respondents also mentioned the wellbeing and pay of housing staff, more tenant engagement, penalties for poor performance and a suggestion that government should work with existing bodies. A small number of respondents expressed the opinion that there is not currently an issue with professionalisation.

Question 40 – What key performance indicator should be used to measure whether landlords are providing good neighbourhood management?

370 respondents answered this question. 95 responses were received from private individuals and 273 were on behalf of organisations. Of the organisational responses there were 98 from housing associations, 105 from local authorities, 4 from tenant management organisations, 19 from tenant representation groups, 6 from trade associations, 1 from a cooperative and 40 from other sectors. 2 responses did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 178 (48%) respondents mentioned satisfaction surveys to get resident opinions, including STAR (Survey of Tenants and Residents) surveys which are commonly used across the sector. 110 (30%) expressed concerns about measuring good neighbourhood management by landlords, for example that only having one key performance indicator is too limited, or that landlords would be expected to do more than is fair by taking on the role of other agencies.

In addition, the third and fourth most common themes each represented more than 10% of responses. 64 respondents said that this key performance indicator should be related to anti-social behaviour specifically, for instance the percentage of cases resolved within a certain time frame, and 47 mentioned maintenance of shared spaces.

A further three themes were raised by over 5% of respondents. 25 respondents suggested that landlords report on community events and services or on social value and social return on investment, 20 respondents suggested the use of peer review or mystery shoppers, and 20 respondents recommended quantitative key performance indicators including property turnover, length of tenancy and rent arrears.

Question 41 – What evidence is there of the impact of the important role that many landlords are playing beyond their key responsibilities? Should landlords report on the social value they deliver?

Response to ‘What evidence is there of the impact of the important role that many landlords are playing beyond their key responsibilities?’

323 respondents answered this question. 71 responses were received from private individuals and 251 were on behalf of organisations. Of the organisational responses there were 96 from housing associations, 93 from local authorities, 2 from tenant management organisations, 16 from tenant representation groups, 8 from trade associations, and 36 from other sectors. 1 response did not specify whether they were responding as an individual or on behalf of an organisation.

In response to this question, 155 (48%) respondents said that there was positive evidence of the role that many landlords are playing beyond their key responsibilities, 82 (25%) respondents mentioned specifically the areas of employment, skills and education. 78 (24%) were negative about the suggestion that landlords play additional roles, suggesting that it could result in trade-offs needing to be made, represented an additional burden, or was difficult to quantify. 76 (24%) respondents mentioned social and community impact, while 62 (19%) responses raised issues of health and wellbeing.

In addition, the sixth and seventh most common themes each represented 13% of comments received, with 41 respondents mentioning financial inclusion and 41 raising housing related support for vulnerable or older people. A further five themes were raised by over 5% of respondents. 30 respondents mentioned tackling anti-social behaviour and crime. 23 respondents suggested there was little or no evidence of impact being made by landlords beyond their key responsibilities. 21 respondents mentioned business or resource benefits, 21 respondents mentioned resident involvement and empowerment, and 21 mentioned tackling isolation and loneliness.

Response to ‘Should landlords report on the social value they deliver?’

There were 441 responses to the closed section of this question. 165 of these responses were received from private individuals and 272 were on behalf of organisations. Of the organisational responses there were 103 from housing associations, 101 from local authorities, 4 from tenant management organisations, 21 from tenant representation groups, 5 from trade associations, 1 from a cooperative, and 35 from other sectors. 4 responses did not specify whether they were responding as an individual or on behalf of an organisation.

302 (68%) respondents said that landlords should report on the social value they deliver (70% of individuals and 68% of organisations), 91 (21%) respondents were not sure and 48 (11%) did not support landlords reporting on social value.

236 respondents provided additional comments to this question. 42 responses were received from private individuals and 193 were on behalf of organisations. Of the organisational responses there were 83 from housing associations, 69 from local authorities, 3 from tenant management organisations, 12 from tenant representation groups, 2 from trade associations, and 24 from other sectors. 1 response did not specify whether they were responding as an individual or on behalf of an organisation.

When offering additional responses to this question, 94 (40%) respondents said landlords should report on the social value that they deliver provided certain conditions are met, such as social value being clearly and consistently defined. 91 (39%) said yes without qualifications. 46 (19%) said that social value was difficult to quantify, and 40 (17%) felt that social value was important but that government should not prescribe what form this takes. 27 (11%) of respondents said that landlords should not report on social value.

A further two themes were raised by over 5% of respondents. 19 respondents recommended that reporting on social value would require more funding or resource. 15 respondents suggested that the reporting would help tackle stigma and change perceptions.

Question 42 – How are landlords working with local partners to tackle anti-social behaviour? What key performance indicator could be used to measure this work?

Response to ‘How are landlords working with local partners to tackle anti-social behaviour?’

215 respondents answered this question. 34 responses were received from private individuals and 181 were on behalf of organisations. Of the organisational responses there were 79 from housing associations, 64 from local authorities, 3 from tenant management organisations, 11 from tenant representation groups, 2 from trade associations, and 22 from other sectors.

In response to this question, 158 (73%) respondents stated that there were regular multi-agency meetings, 35 (16%) mentioned information sharing and awareness raising, 34 (16%) mentioned resident and community involvement and events, and 34 (16%) raised challenges faced by landlords such as court decisions, communication barriers and funding. 24 (11%) respondents mentioned safeguarding and supporting vulnerable people and those with mental health issues.

A further five themes were each raised by over 5% of respondents. 20 respondents mentioned the use of existing powers, there were 18 negative reactions to the suggestion of a key performance indicator in this area, and 16 suggested that current methods are not working. 14 respondents mentioned the use of mediation, and 11 mentioned the use of charters and/or performance indicators.

Response to ‘What key performance indicator could be used to measure this work?’

305 respondents answered this question. 83 responses were received from private individuals and 220 were on behalf of organisations. Of the organisational responses there were 86 from housing associations, 86 from local authorities, 4 from tenant management organisations, 15 from tenant representation groups, 4 from trade associations, and 25 from other sectors. 2 respondents did not indicate whether they were responding as private individuals or on behalf of organisations.

In response to this question, 88 (29%) respondents suggested that the key performance indicator should be the percentage of anti-social behaviour cases dealt with satisfactorily, 80 (26%) respondents said that it should be based on resident perception, including STAR (Survey of Tenants and Residents) results, and 77 (25%) stated that it was a complex matter and that multiple partnerships were needed.

31 of respondents stated that the key performance indicator should be based on qualitative data and 20 would not support the use of key performance indicators.

Question 43 – What other ways can planning guidance support good design in the social sector?

317 respondents answered this question. 73 responses were received from private individuals and 243 were on behalf of organisations. Of the organisational responses there were 75 from housing associations, 99 from local authorities, 4 from tenant management organisations, 15 from tenant representation groups, 8 from trade associations, and 42 from other sectors. 1 respondent did not indicate whether they were responding as a private individual or on behalf of an organisation.

In response to this question, 140 (44%) respondents raised adopting nationally defined space standards and minimum social housing standards, including health and safety, thermal and energy efficiency and lifetime homes. 89 (28%) respondents advocated adopting a tenure neutral approach to design, 56 (18%) suggested community engagement in the design process and/or the promotion of self-build and community build schemes.

In addition, the fourth to seventh most common themes each represented more than 10% of responses. 53 respondents said that adequate community facilities should be provided, 45 mentioned the use of tools and processes to evaluate and assess quality, 42 advocated integration into surrounding streets and areas and 36 stated that it was important to ensure that viability does not compromise design quality.

A further four themes were raised by over 5% of respondents. 30 respondents suggested ensuring safety and ease of access and movement, 19 raised the issue of maintenance, 19 suggested the use of surveys, customer insight or feedback, including post-occupation.

Question 44 – How can we encourage social housing residents to be involved in the planning and design of new developments?

379 respondents answered this question. 111 responses were received from private individuals and 265 were on behalf of organisations. Of the organisational responses there were 93 from housing associations, 96 from local authorities, 3 from tenant management organisations, 21 from tenant representation groups, 5 from trade associations, 1 from a cooperative and 46 from other sectors. 3 respondents did not indicate whether they were responding as private individuals or on behalf of an organisation.

In response to this question, 161 (42%) respondents mentioned meaningful engagement with pre-planning events or resident involvement in masterplans, 137 (36%) suggested inclusive methods of communication, including training. 92 (24%) respondents said that resident surveys should be conducted, including post-occupancy. In addition, the fourth to sixth most common themes each represented more than 10% of responses. 68 respondents mentioned setting up resident steering groups or community-led structures, 53 suggested good practice guidance and projects, and 40 said that there should be a statutory commitment for developers to involve residents in design.

A further three themes were raised by over 5% of respondents. 34 respondents suggested involving the community in mapping and analysing the area, 30 respondents suggested understanding the wider area context, and 20 recommended engaging with those from minority groups.

Chapter 5 – Expanding supply and supporting home ownership

The social housing green paper recognised the need for long term need for social housing and sought views on:

• the right balance between providing grant funding for housing associations and Housing Revenue Account borrowing for local authorities
• boosting community-led housing
• the level of additional affordable housing that could be delivered by social housing providers if they were given longer term certainty over funding
• the development of new shared ownership product

Question 45 – Recognising the need for fiscal responsibility, this green paper seeks views on whether the government’s current arrangements strike the right balance between providing grant funding for housing associations and Housing Revenue Account borrowing.

There were 434 responses to the closed section of this question. 165 of these responses were received from private individuals and 267 were on behalf of organisations. Of the organisational responses there were 93 from housing associations, 108 from local authorities, 4 from tenant management organisations, 20 from tenant representation groups, 3 from trade associations, 0 from cooperatives, and 37 from other sectors. 3 responses did not specify whether they were responding as an individual or on behalf of an organisation.

62 (14%) respondents said that the government’s current arrangements strike the right balance, 175 (40%) respondents were not sure and 197 (45%) disagreed. 7% of individuals and 18% of organisations that responded agreed with the current balance.

322 respondents provided additional comments on this question. 54 responses were received from private individuals and 266 were on behalf of organisations. Of the organisational responses there were 78 from housing associations, 110 from local authorities, 1 from a tenant management organisation, 21 from tenant representation groups, 8 from trade associations, 1 from a cooperative and 47 from other sectors. 2 respondents did not indicate whether they were responding as private individuals or on behalf of an organisation.

In response to this question, 90 (28%) respondents said that grants should be increased, 82 (25%) wanted to increase local authority borrowing and 61 (19%) suggested both.

Question 46 – How we can boost community-led housing and overcome the barriers communities experience to developing new community owned homes?

356 respondents answered this question. 101 responses were received from private individuals and 254 were on behalf of organisations. Of the organisational responses there were 85 from housing associations, 100 from local authorities, 3 from tenant management organisations, 15 from tenant representation groups, 7 from trade associations, and 44 from other sectors. 1 respondent did not indicate whether they were responding as a private individual or on behalf of an organisation.

When responding to this question, 117 (33%) were in favour of extending the life of the Community Housing Fund or increasing central government funding in general. 104 (29%) suggested measures to overcome the barriers faced by communities, including technical advice, support, training and awareness raising.

In addition, the third and fourth most common themes were in support of Local Authorities providing support or assistance to community groups, and promotion and publicity of successful schemes and best practice. These each represented 10% of the total responses.

Question 47 – What level of additional affordable housing, over existing investment plans, could be delivered by social housing providers if they were given longer term certainty over funding?

322 respondents provided additional comments on this question. 68 responses were received from private individuals and 253 were on behalf of organisations. Of the organisational responses there were 95 from housing associations, 95 from local authorities, 1 from a tenant management organisation, 12 from tenant representation groups, 8 from trade associations, 1 from a cooperative, and 41 from other sectors. 1 respondent did not indicate whether they were responding as a private individual or on behalf of an organisation.

In response to this question, 123 (38%) respondents said that overall supply should be increased with grants, 28 (9%) said supply should be increased with rent, and 42 (13%) said both. Respondents suggested estimated increased outputs of up to 25% with longer term certainty, and funding through strategic partnerships which have been welcomed by the sector.

Certainty over long term funding was a repeated request from the responses, as this would better align with the 30 year business models used within the sector.

Some respondents noted that a lack of certainty around rental income had impacted on delivery of new homes, and although government’s rents policy allowing landlords to raise rents by up to Consumer Price Index plus 1% each year was largely welcomed, there were calls for rents certainty beyond 2025.

Certainty over welfare payments was also requested as respondents said it would create confidence in building larger developments and reduce risk for providers.

Question 48 – How can we best support providers to develop new shared ownership products that enable people to build up more equity in their homes?

332 respondents answered this question. 73 responses were received from private individuals and 255 were on behalf of organisations. Of the organisational responses there were 86 from housing associations, 100 from local authorities, 1 from a tenant management organisation, 20 from tenant representation groups, 5 from trade associations, and 43 from other sectors. 4 respondents did not indicate whether they were responding as private individuals or on behalf of an organisation.

When responding to this question, 158 (48%) respondents were in favour of smaller or fixed price staircasing. 84 (25%) suggested other or new affordable homes products. 83 (25%) respondents said that shared ownership should be rebranded, for instance to provide greater clarity on responsibilities and processes. 73 (22%) stated that the priority should be funding for low cost rent.

In addition, the fourth to seventh most common themes each represented more than 10% of responses. 58 respondents were either opposed to expansion of shared ownership or to the model itself. 56 suggested increasing subsidies and reducing rents and service charges. 49 said that financial institutions should be encouraged to adopt new products or adapt their existing products to suit shared ownership models, or offer better mortgage rates, and 49 said that general housing market issues needed to be addressed.

2. Call for evidence: summary of responses

Alongside the social housing green paper consultation, the call for evidence set the government’s intention to conduct an in-depth review of the regulation of social housing to ensure it remains fit for purpose, reflects changes in the social housing sector and drives a focus on delivering a good service for residents. The call for evidence complemented questions on consumer regulation in the social housing green paper, and asked how the regulatory regime is meeting its current objectives. The responses to those questions are summarised in the social housing white paper.

There were 106 responses to the call for evidence in total. Not all respondents answered every question. All responses have been read and analysed and have been taking into consideration when developing the proposed package of reform. We are grateful to everyone who took the time to respond.

The table and graph below provide a breakdown of the type of respondents to the call for evidence.

Who responded?

As a private individual	23
On behalf of an organisation	83
Total responses	106

Breakdown of organisations which responded

Housing association	37
Local authority	18
Arms Length Management Organisation (ALMO)	4
Financial sector	3
Resident association or tenant panel	4
Trade association or interest group	8
Other	9
Total	83

Overall the responses showed widespread support for the current economic regulatory system, including from the financial sector. There was a recognition that the regulatory regime may need to adapt to new types of provider, such as for-profit organisations.

There was also a recognition that there needs to be greater consumer regulation. However, many respondents expressed concerns about the proposals for key performance indicators (KPIs) and/or league tables. This was expressed in responses to a broad range of questions.

Principles of regulation

Question 1. We would welcome information on whether the current statutory objectives, and monitoring and enforcement powers are right, whether they need amending, and if so, how. 

There were 85 responses to this question, of which 12 were from individuals and 73 from organisations.

34% of respondents to this question (29 responses) feel that the current system works well and that there should be no change.

40% of respondents (34 responses) consider that the government sets the right objectives for the regulator but that there needs to be greater monitoring and/or enforcement of the consumer standards.

14% (12 responses) expressly stated that the review should address the existing imbalance between consumer and economic standards.

18% (15 responses) called for change to the ‘serious detriment’ test.

A small number of respondents called for a change to a consumer standard.

Question 2. We would welcome information on whether the ‘regulated self-assurance’ approach to regulation of social housing is the right approach. If not, how should it be changed?

There were 84 responses to this question, of which 13 were from individuals and 71 from organisations.

Just over 70% (62 responses) consider that regulation self-assurance remains the right approach to regulation. Of these 35 were housing associations and 16 were Local Authorities or Arms Length Management Organisations. Only 4 came from individuals.

Of those 62 responses, 20 expressly mentioned that there needed to be greater enforcement and/or monitoring of compliance against the standards. Some of the remaining 42 mentioned that the co-regulation was not a barrier to greater enforcement.

21% (18 responses) felt that regulated self-assurance did not work and that there should be either direct regulation or some rebalancing of regulatory accountability.

Other proposals included 19% (16 responses) that felt that the regulator should provide greater clarity on the standards, including through a Code of Practice. 12% (10 responses) felt that landlords should be more accountable to tenants.

Economic regulation

Question 3. We would welcome information on the effectiveness of the current approach to economic regulation.

There were 69 responses to this question, of which 8 were from individuals and 61 were from organisations.

80% (55 responses) said that the current approach to economic regulation was working well. This included organisations who said that the current economic regulation is robust and gives lenders the confidence needed to invest.

13% of respondents (9) that said economic regulation should be more proactive, with greater monitoring and enforcement. This includes 7 organisational responses and 2 individual responses.

Other issues raised by some respondents were that economic regulation is not working well enough for very large registered providers, tenants should have access to financial information from their landlord, and that economic regulation should be extended to other bodies including local authorities. These were only raised by between 3-4 respondents each.

Question 4. We would welcome information on any areas of the economic regulatory framework which might not work effectively or provide sufficient oversight when meeting the challenges of the evolving sector.

There were 54 responses to this question, of which 9 were from individuals and 45 were from organisations.

50% of respondents to this question (27 responses) said that the economic regulatory framework needs to be adaptable to cover a very diverse sector, for example for-profit providers, lease-based models, and local authorities. But only 11% of respondents (6 responses) suggested that the regulator should discourage or clamp down on certain types of providers such as for-profits.

31% of respondents (17 responses) reiterated that they are content with the current system.

One housing association noted that the current regulatory regime was designed with non-profit housing associations in mind, so the regulator may have to adapt it to cater for commercial profit-driven organisations. Another housing association noted that there should be more recognition of the smaller margins for supported housing providers.

13% of respondents (7 responses, including an Arms Length Management Organisation and 6 individuals) thought that there should be more transparency to tenants about a provider’s finances and service charges, or they should be independently audited.

11% of respondents (6, including a professional consultancy) called for greater ring-fencing or oversight of the relationship between social housing and non-social housing activities.

The regulatory system as a whole

Question 5. We would welcome information on any specific issues that we should be aware of as the review progresses, to ensure that we retain a coherent regulatory framework.

There were 66 responses to this question, of which 10 were from individuals and 56 were from organisations.

21% of respondents (14 responses) explicitly recognised that there was likely to be, or desirable to be, an increase in consumer regulation. However, there was an implicit acceptance of this in many other answers – only 11% (7 respondents) said the current approach was fine and no change was needed. The potential for Codes of Practice to help deliver better consumer regulation was mentioned by four respondents (three housing associations and an Arms Length Management Organisation).

There were a variety of responses to this question. 6 responses stated that KPIs (in varying forms) might be beneficial. Responses were also was often caveated with a desire to ensure that economic regulation was not undermined (and the regulator properly resourced) and/or that ultimately responsibility for delivering should continue to rest with providers and their Boards. Other responses said that the focus should be reviewing the serious detriment test, while others highlighted a likely desire to increase consumer regulation overall.

Other issues that emerged (from at least three respondents) were: if consumer regulation were to be a greater focus, ‘serious detriment’ would need to be reviewed; the need to consider how future regulation might work with the changes to oversight of Supported Housing providers; the need to make clearer to tenants the relationship between the regulator and the Ombudsman; and, that local authorities and housing associations should be regulated in the same way.

Question 6. We would welcome information on any risks arising from improving the approach to consumer regulation enforcement.

There were 71 responses to this question, of which 7 were from individuals and 64 were from organisations.

14% (10) of those that replied said that there were no risks associated with giving the regulator a greater regulatory focus on ensuring a good service for tenants.

20% (14 respondents) identified the risk that the regulator would not be adequately resourced and/or the potential impact on economic regulation and lender confidence.

18% (13 respondents) said that changes could result in an overly prescriptive regulatory approach that was not sufficiently flexible.

10% (7 respondents) had similar concerns about how an increased consumer focus might be resource-intensive and impact on the delivery of providers’ core objectives, while 6% (4 respondents) were concerned that we might move to a regulatory approach that failed to recognise the diversity of the sector and how local needs varied. One respondent highlighted the potential risk of reclassification for the sector if there was a more ‘hands-on’ approach to regulation.

Some respondents made more general comments about regulation, including about KPIs, league tables and the serious detriment test.

Relationship with the Hackitt Review

Question 7. What are your views on risks and opportunities presented by the regulatory regime suggested by Dame Judith Hackitt and how that should work with social housing regulation?

There were 73 responses to this question, of which 6 were from individuals and 67 were from organisations.

The biggest risk identified is a potential lack of consistency between regulators leading to a fragmented or duplicatory regime which may be confusing to navigate – this includes bodies like the Health and Safety Executive, Care Quality Commission, as well as between the Joint Competent Authority and Regulator of Social Housing. 32% of all respondents raised this risk (23 responses).

The biggest opportunity identified is to improve health and safety regulation. 48% of responses (35) identified this opportunity.

Further major opportunities identified are to improve tenant empowerment and ensure tenants are at the heart of the regulatory regime, and to apply consistency across the social and private sectors (both raised by 27%, or 20 responses).

Any other suggestions for improvement

Question 8. We would welcome any further information that might inform the review of the regulatory framework.

There were 64 responses to this question, of which 16 were from individuals and 48 were from organisations.

The importance of careful design of the KPIs was highlighted in responses to the call for evidence about the regulatory regime for social housing. Many respondents, 61% of respondents (39 responses) expressed concern about the comparability of different social housing providers and the regulator will need to carefully consider this in its work.

38% of respondents (24 responses) said that the regulator needs to work more collaboratively with others, such as the Housing Ombudsman Service, local authorities and tenant representative groups.

20% of respondents (13 responses) thought that the regulator’s duty to minimise interference and the current definition of ‘serious detriment’ should be re-examined.

45% of respondents (29 responses) explicitly said they support greater consumer regulation.

Other issues raised were the importance of health and safety and the needs of vulnerable tenants in supported housing.

1. Kensington and Chelsea Tenant Management Organisation became an Arms Length Management Organisation in 2002. ↩

2. See ‘A new deal for social housing’, p. 42. ↩