Consultation outcome

Annex 6: Consumer standards – Equality impact assessment

Updated 29 February 2024

Applies to England

Part 1: Introduction and scoping

1.1 Summary and scope

Overview 

The consumer standards set out the outcomes that registered providers must deliver. We set these in line with our revised objectives, which have been expanded by the Social Housing (Regulation) Act 2023 (the Act) to include safety, transparency, and energy efficiency.  

The Social Housing White Paper (the White Paper) set out the government’s intention to create a proactive consumer regulatory regime. The Act implements the regulatory measures in the White Paper. Following extensive engagement with tenants, landlords and other stakeholders, we intend to introduce a revised set of consumer standards. As part of our work to develop revised consumer standards, we have considered how our existing consumer standards could be revised and strengthened to deliver a set of standards that are robust, up to date and fit for purpose. In doing so we have sought to meet commitments set out in the White Paper, deliver on our expanded objectives, and address issues impacting the social housing sector that are within our remit. 

In developing the consumer standards, we have been guided by the three tests we have set ourselves for developing our approach to consumer regulation:  

• It must make a meaningful difference to tenants. 
• Landlords must be able to deliver its expectations. 
• We must be able to regulate against it.  

In developing the standards, we have been mindful of: 

• our statutory duty to exercise our functions in a way that minimises interference and (so far as is possible) is proportionate, consistent, transparent, and accountable (section 92K(5) of the Housing and Regeneration Act 2008)  
• the Government’s Regulators’ Code  
• our statutory duty, in setting consumer standards, to have regard to the desirability of registered providers being free to choose how to provide services and conduct business. 

We have also been mindful of our duty to comply with the Public Sector Equality Duty (PSED) as set out at section 149 of the Equality Act 2010. The broad aim of PSED (also known as the general equality duty) is to integrate considerations of equality and good relations into the day-to-day business of public authorities, so that when exercising their functions, they have due regard to the need to:  

• eliminate discrimination, harassment, victimisation, and any other conduct that is prohibited by or under the Equality Act 2010 (PSED aim 1); 
• advance equality of opportunity between people who share a relevant protected characteristic and those who do not (PSED aim 2);  
• foster good relations between people who share a relevant protected characteristic and those who do not (PSED aim 3). 

The general equality duty covers the following protected characteristics: age (including children and young people), disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. Marriage or civil partnership is also a protected characteristic under the Equality Act 2010, although this is only relevant to the first aim of the general equality duty (eliminating discrimination etc.) 

Scope of the equality impact assessment 

This equality impact assessment (EQIA) has continuously shaped our thinking as we have developed the requirements in our standards. We have considered the impacts (positive, negative, neutral and none) of the requirements on tenants and prospective tenants who share different protected characteristics.  

Following proper consideration of the impact of the requirements in our standards we have also considered whether any further steps or mitigation measures are appropriate but have not identified any.    

The Act has given the regulator the power to issue a code of practice on the consumer standards, to help tenants and landlords understand how compliance with the new standards might be achieved. We are publishing our Code of Practice alongside the revised consumer standards, and its contents have also been shaped by this assessment.  

The consumer standards include requirements that reflect where we are directed by government. The wording of the directions has been reflected in the standards. Where this is the case, we have generally not assessed the equality impacts of those requirements as they are fixed.  

We have assessed the equality impacts of post consultation changes to the revised standards. Where we have made changes to the revised standards post consultation, we have marked these in the columns to the left.  

This EQIA does not include an assessment of our revised approach to regulation.  

Our intention is that the diversity requirements in the revised consumer standards act as a driver for change, by influencing the sector to better understand their tenants, including in relation to the protected characteristics, which may provide a better baseline of evidence in the future.

1.2 Who are the main stakeholders that may be affected by these proposals?

• Tenants
• Communities
• Registered providers
• Sector organisations

1.3 Could the requirements(s) have a cumulative impact on people who share more than one protected characteristic?

The analysis of potential impacts in section 3 reflects areas where evidence shows cumulative impacts where protected characteristics intersect.

1.4 Do the requirements relate to RSH’s equality objectives?

Our equality objectives: 

1. We will use our role to help ensure that registered providers better understand the diverse needs of tenants. We will expect registered providers to take action to deliver equitable service outcomes for all.  

2. We will be respectful and inclusive in our engagement and communication. 

3. We will provide a supportive and inclusive working environment for all. 

Equality objective 1 relates to required outcome 1.2.1 and specific expectation 2.2.3 of the in the Transparency, Influence and Accountability Standard.

Part 2: Information gathering

Summarise below the data/ evidence you have used to undertake the assessment. Identify any gaps in evidence and how they might be filled.

2.1 Existing data/ evidence

A range of information taken from open-source research, data and evidence has been considered as part of this assessment, influencing the requirements so the consumer standards support us in considering our PSED, as well as helping to assess where any potential mitigation may be required. To avoid duplication, rather than set out the evidence in this section, we have referenced it in section 3 below.  

We have carried out a review of the recently-published English Housing Survey (EHS) Headline Report 22-23, and have included updated figures where relevant. 

With regard to some of the EHS data referenced in this document, please note that, in response to the COVID pandemic, internal inspections of properties for the EHS were suspended for a period of time. This may impact housing quality data from the 2020-2021 and 2021-2022 fieldwork periods. Further information on the impact of COVID on the EHS can be found here.

2.2 Data gaps

We did not find any statistical data about the following in relation to social housing tenants: 

• the number of social housing tenants who are married or in a civil partnership or their specific experiences of social housing. 
• the specific experiences of social housing tenants from different religious groups. We found data on anti-social behaviour (ASB) and hate crime victims broken down by religion which helped to inform this assessment. 
• the number of social housing tenants who are pregnant or who have recently had a baby or their specific experience of social housing. 

We have not attempted to fill these information gaps ourselves, due to the time and resources it would demand. Where new equality data becomes available that is relevant to the consumer standards, including in relation to the identified gaps, we will consider reviewing the EQIA. 

Data on Gypsy, Roma and Traveller (GRT) social renters 

Data on GRT households has been added under the ‘white’ ethnic group, to be consistent with the approach taken by the Office for National Statistics (ONS).  According to the 2021 census, approximately 13,480 household reference persons in England identified as a social renter and Gypsy or Irish Traveller (9794) or Roma (3686), indicating that approximately 44 per cent of Gypsy or Irish travellers live in social housing, and 10 per cent of those who identify as Roma live in social housing. This means that improved social housing is likely to have a significant impact on, particularly, Gypsy or Irish Traveller social housing tenants. 

It is difficult to draw robust conclusions about small populations, so we have not attempted to do so in this EQIA.

Part 3: Assessing the impact

This is our assessment of the potential equality impact of the consumer standards.  

We have rigorously considered equality considerations and relevant evidence throughout the development of the consumer standards. Where we have identified aspects of the current standards that might benefit from being strengthened or amended to address any potential negative equality impact, or where we have identified an opportunity to create a positive equality impact through our standards, we have taken the opportunity to do so. Because of this approach, we have not identified any potential negative equality impact at this point. 

The process of considering any potential equality impacts, has continued through our review of all the feedback on the draft consumer standards and Code of Practice on which we consulted between July and October 2023. We have carried out an assessment of any potential equality impacts of all the changes we have made in setting the final consumer standards and Code of Practice.  In the vast majority of cases, we have not identified any new potential equality impacts from the changes we are making. There have, however, been a small number where we have identified potential positive equality impacts from the changes being made.  Where this is the case, it is covered in the ‘our requirements’ section for each element of the standards, in the tables below.

Safety and Quality: Stock quality

Potential impact on different protected characteristics

• Age
• Disability
• Race

There is insufficient evidence of any impact on the other protected groups.

Final wording

Required outcome 

1.1.1 Registered providers must have an accurate, up to date and evidenced understanding of the condition of their homes that reliably informs their provision of good quality, well maintained and safe homes for tenants. 

Specific expectations 

2.1.1 Registered providers must have an accurate record at an individual property level of the condition of their homes, based on a physical assessment of all homes and keep this up to date.  

2.1.2 Registered providers must use data from across their records on condition to inform their provision of good quality, well maintained and safe homes for tenants including: 

a) Compliance with health and safety legal requirements 

b) Compliance with the Decent Homes Standard 

c) Delivery of repairs, maintenance, and planned improvements to homes stock 

d) Allocating homes with adaptations that are designed or adapted to meet specific needs appropriately.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us  

• Poor quality, hazardous accommodation can contribute to reduced mobility, social isolation, and depression for older people.^{[footnote 1]}
• Social renters in one person households or couples with no children were more likely to live in a non-decent home than lone parents with either independent children only or dependent children.^{[footnote 2]}
• EHS 2021-2022 data^{[footnote 3]} shows that 10 per cent of social rented homes in England are non-decent^{[footnote 4]}. Social rent households with a white housing reference person (HRP) (10.1 per cent) were more likely to live in a non-decent home than households with a minority ethnic HRP. Housing association (HA) renters with a white HRP (11 per cent) were more likely to be in a non-decent home than HRPs from an ethnic minority group (5 per cent). For local authority (LA) renters, non-decency figures were (9 per cent) for households with a white HRP and 8 per cent for those with an ethnic minority HRP. Within this data, however, there are differences for specific ethnic minority groups. In social housing 13.1 per cent of households with an Asian HRP lived in non-decent homes compared to 4 per cent of households with a black HRP and 5.5 per cent for those households with a HRP from an ‘other’ minority ethnic group.   
• Asset management databases were not always kept up to date. 26 per cent of HA survey respondents said that adapted properties were not clearly identified within asset management databases.^{[footnote 5]} 
• Levelling Up, Housing and Communities Committee’s inquiry into the regulation of social housing heard evidence about the quality of social housing, which included examples of poor quality homes, disrepair and damp and mould.^{[footnote 6]}  
• There was no significant difference in the likelihood of social renters living in a non-decent home according to whether the household had someone with a long-term illness or disability (10 per cent) or not (9 per cent)^{[footnote 7]}
• However, analysis of EHS data by the Social Market Foundation forecasts a 25 per cent increase in social housing tenants over 65 years and with a long-term illness or disability living in non-decent homes between 2021 and 2031.^{[footnote 8]}
• 5 per cent of social rented homes had a problem with damp. This is a higher proportion than owner occupied homes (2 per cent), but lower than private rented homes (9 per cent).^{[footnote 9]}  
• The proportion of 10 per cent of dwellings in the social rented sector failing to meet the Decent Homes Standard is lower than the proportion of private rented (23 per cent) and all owner occupied (13 per cent) homes (970,000 and 2.1 million homes respectively).^{[footnote 10]}  

Our requirements 

We consider that PSED aim 2, advancing equality of opportunity, is relevant to this requirement.  

Registered providers having a better understanding of their homes may help to improve the condition of social housing, which may have a positive impact on older and disabled tenants, who are more likely to be impacted by poor quality housing. 

We have taken the opportunity to make it clear in the Code of Practice that providers should take into account the potential risk to tenants when using information about the condition of the homes alongside information about the needs of individual tenants living in those homes to ensure they act in an appropriate and timely manner on investment and repair requirements. This may benefit tenants who share a number of protected characteristics, particularly disability. 

We consider that the change we are making, to reflect feedback we received in the consultation, to the wording of 2.1.2 d), is likely to have a positive equality impact.  This is because it is likely to encourage providers to improve data not only on adapted homes, but also on those designed to particular standards of accessibility. This additional element could have a positive impact on those sharing the protected characteristic of disability. It may result in improved access to suitable housing for tenants and prospective tenants with disabilities, creating better understanding and classification of properties to facilitate most appropriate future allocations. We consider that the changes we are making to the wording in 2.1.1.and in 2.1.2c) are likely to have no equality impact. 

Overall assessment 

Overall, for the reasons stated above, we believe our requirements relating to stock quality may have a positive impact on tenants who share the protected characteristics age, race,  and disability.

Safety and Quality: Decency

Potential impact on different protected characteristics

There is insufficient evidence of any impact on protected groups.

Final wording

We have only assessed changes that would exclude requirements that currently exist in 1.1 (b) and (c) of the Home Standard from the new Safety and Quality Standard.

Required outcome

1.2.1 Registered providers must ensure that tenants’ homes meet the standard set out in section five of the Government’s Decent Homes Guidance and continue to maintain their homes to at least this standard unless exempted by the regulator.

Specific expectations

None

What the evidence tells us

In 2021/22, 10 per cent of dwellings in the social rented sector failed to meet the Decent Homes Standard, down from 11 per cent in the previous year’s survey. This equates to around 400,000 homes. The proportion of non-decent homes in the social rented sector is lower than in the private rented sector (23 per cent), and amongst owner occupied dwellings (13 per cent).

Predictive modelled data indicated that:

• 4 per cent of dwellings in the social rented sector had a category 1 hazard under the Housing Health and Safety Rating System (HHSRS), compared to 14 per cent in the private rented sector and 10 per cent amongst owner occupied dwellings
• 4 per cent of dwellings in the social rented sector had a significant degree of damp, compared to 11 per cent in the private rented sector and 2 per cent amongst owner occupied dwellings.

The 2021/22 EHS SAP^{[footnote 11]} data showed that dwellings in the social rented sector had the highest mean SAP rating of the tenures with HAs and LAs both at 70, which means that social rented properties were more energy efficient than owner occupied properties (averaged a lower rating of 66) and private rented properties (rating of 65).^{[footnote 12]}

EHS data^{[footnote 13]} shows that 10 per cent of social rented homes in England are non-decent^{[footnote 14]}. Social rent households with a white HRP (10 per cent) were more likely to live in a non-decent home than households with a minority ethnic HRP. HA renters with a white HRP (11 per cent) were more likely to be in a non-decent home than HRPs from an ethnic minority group (5 per cent). For LA renters, non-decency figures were (9 per cent) for households with a white HRP and 8 per cent for those with an ethnic minority HRP. Within this data, however, there are differences for specific ethnic minority groups. In social housing 13.1 per cent of households with an Asian HRP lived in non-decent homes compared to 4 per cent of households with a black HRP and 5.5 per cent for those households with a HRP from an ‘other’ minority ethnic group.  

Ethnicity Facts and Figures from 2017/19 (nothing more recently available) showed differential rates amongst households living with damp, as follows:

• Damp in at least one room of the home appears to be more prevalent amongst certain ethnic minority groups – 3 per cent of households in England in total.
• White British households 3 per cent, mixed white and black Caribbean 13 per cent, Bangladeshi 10 per cent, black African 9 per cent, and Pakistani 8 per cent.
• Although households from Mixed white and black African (11 per cent) and black other (10 per cent) backgrounds were also more likely than white British households to have damp, findings for these groups are based on a small number of households and may not be reliable.

(From People without decent homes - GOV.UK Ethnicity facts and figures)

There was no significant difference in the likelihood of social renters living in a non-decent home according to whether the household had someone with a long-term illness or disability (10 per cent) or not (9 per cent).^{[footnote 15]}

The Institute of Health Equity’s 2011 Marmot Review^{[footnote 16]} found that the established link between housing and health has implications for children. Significant negative effects of cold housing are evident in terms of infants’ weight gain, hospital admission rates, developmental status, and the severity and frequency of asthmatic symptoms and impacts on the mental health of adolescents.

Our requirements

We consider that PSED aims 2 (to advance equality of opportunity) and 3 (to foster good relations) are relevant to these requirements.

We have simplified some remaining elements in our current Home Standard to avoid repetition with requirements in the Decent Homes guidance and in line with our approach to regulation. We have removed the requirement 1.1.b to meet the standards of design and quality that applied when the home was built and were required as a condition of publicly funded financial assistance if these standards are higher than the Decent Homes Standard. We have also removed the requirement 1.1.c that in agreeing a local offer, providers should ensure that it is set at a level not less than Decent Homes Standard. The former will already be covered under contractual requirements, and we feel that the latter requirement is unnecessary as the requirement is that all homes must be maintained to Decent Homes Standard, and we have removed reference in the standards to local offers.

We considered whether removing the stipulation to meet design standards at the time the housing was built could lead to a reduction in accessible housing, where homes designed for disabled and older tenants are not maintained to appropriate standards, resulting in a negative equality impact for disabled and older tenants. However, where standards have been agreed over and above the Decent Homes Standard as part of funding agreements, including in relation to accessibility, registered providers in receipt of that funding will be contractually obliged to continue to meet those standards for a set period or in perpetuity in line with those contracts. Therefore, we think that removal of this requirement is highly unlikely to result in a reduction of accessible housing.

Overall assessment

Taking the above into account, we consider that this requirement is likely to have a neutral equality impact on tenants who share different protected characteristics.

Safety and Quality: Health and safety

Potential impact on different protected characteristics

• Age
• Disability
• Race

There is insufficient evidence of any impact on the other protected groups.

Final wording

Required outcome

1.3.1 When acting as landlords, registered providers must take all reasonable steps to ensure the health and safety of tenants in their homes and associated communal areas.

Specific expectations

2.2.1 Registered providers must identify and meet all legal requirements that relate to the health and safety of tenants in their homes and communal areas.

2.2.2 Registered providers must ensure that all required actions arising from legally required health and safety assessments are carried out within appropriate timescales.

2.2.3 Registered providers must ensure that the safety of tenants is considered in the design and delivery of landlord services and take reasonable steps to mitigate any identified risks to tenants.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

• There are differences amongst social renters^{[footnote 17]} from different ethnic groups in levels of homes failing the Decent Homes Standard, with 13.1 per cent of households with an Asian HRP living in homes failing the Decent Homes Standard, compared to 10.1 per cent for those with a white HRP, 5.5 per cent for those with an ‘other’ HRP, and 4 per cent for those with a black HRP.
• There was no significant difference in the likelihood of social renters living in a non-decent home according to whether the household had someone with a long-term illness or disability (10 per cent) or not (9 per cent)^{[footnote 18]}
• 4 per cent of social rented homes had at least one category 1 hazard, a lower proportion than both owner occupied (10 per cent) and private rented homes (14 per cent).
• Within the social rented sector, dwellings rented from local authorities were more likely to have a Category 1 hazard (6 per cent) than dwellings rented from HAs (4 per cent).^{[footnote 19]}
• Poor quality, hazardous accommodation can contribute to reduced mobility, social isolation, and depression for older people.^{[footnote 20]}
• Renters were more likely to feel unsafe at home (8 per cent for both private and social renters) than owner occupiers (4 per cent). Those from an ethnic minority background were more concerned than those from a white background (13 per cent compared to 5 per cent)^{[footnote 21]}.
• In both 2020 and 2010 local authority owned homes were more likely to have category 1 hazards than those owned by HAs (6 per cent and 4 per cent respectively in 2020)^{[footnote 22]} Housing data quality and condition report 2020
• The main types of older people’s accommodation contain some form of communal area^{[footnote 23]}.

Our requirements

Based on the evidence, tenants within the sector who may be positively impacted by requirements relating to health and safety are those who share the protected characteristics of age, disability, and race. We consider that PSED aim 2, to advance equality of opportunity, is relevant to these requirements.

The new requirements set a more explicit expectation for registered providers to meet their legal health and safety requirements in respect of communal areas, which have expanded with recent legislation e.g., the Fire Safety Act 2021 and Building Safety Act 2022, which may lead to a greater focus by providers on tenant safety.

Requiring providers to consider the safety of communal areas may result in safer communal areas, which may have a positive impact on tenants who share the protected characteristic(s) age and disability. This is because individuals who share those protected characteristics are likely to have different (possibly additional) needs regarding the safety of communal areas compared to those who do not share these protected characteristics.

Ensuring that registered providers carry out the actions from health and safety assessments in a timely manner may have a positive impact on tenants who are more at risk of a safety failure as a result of non- compliance because of their protected characteristic, namely age (older people and children) and disabled people.

2.2.3 requires registered providers to ensure the safety of tenants in the design and delivery of landlord services. We have taken the opportunity in the Code of Practice to exemplify actions that providers may take to ensure the wider safety of tenants; responding promptly and effectively to reports of ASB, including where the victim is vulnerable, and taking into account, where appropriate, individual tenants’ safety, security, and health when prioritising repairs.

Overall assessment

For the reasons stated, we believe that our requirements relating to health and safety may have a positive impact on tenants who share the protected characteristics age, disability, and race

Safety and Quality: Repairs, maintenance and planned improvements

Potential impact on different protected characteristics

• Age
• Disability
• Race
• Sex

There is insufficient evidence of any impact on the other protected groups.

Final wording

Required outcome

1.4.1 Registered providers must provide an effective, efficient, and timely repairs, maintenance and planned improvements service for the homes and communal areas for which they are responsible. 

Specific expectations

2.3.1 Registered providers must enable repairs and maintenance issues to be reported easily.

2.3.2 Registered providers must set timescales for the completion of repairs, maintenance, and planned improvements, clearly communicate them to tenants and take appropriate steps to deliver to them.

2.3.3 Registered providers must keep tenants informed about repairs, maintenance, and planned improvements to their homes with clear and timely communication.

2.3.4 Registered providers must understand and fulfil their maintenance responsibilities in respect of communal areas.

2.3.5 Registered providers must ensure that the delivery of repairs, maintenance and planned improvements to homes and communal areas is informed by the needs of tenants and provides value for money, in addition to the requirement at 2.1.2.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

See evidence above under Decency relating to households from some minority ethnic groups being more likely to live in non-decent accommodation. There is a clear link between housing which is not compliant with the Decent Homes Standard, and the quality of the landlord’s service on repairs, maintenance and planned improvements.

• The EHS 2021/22 shows that 57 per cent of the households in social rented housing that had dependent children were lone parent households (compared to 39 per cent in the private rented sector, and 12 per cent in owner-occupation). With 90 per cent of lone parent households led by women, how flexible and timely repairs services are, can be of significant impact to women^{[footnote 24]}.
• Evidence to the Levelling Up Housing and Communities Committee inquiry on the regulation of social housing from the Merton Centre for Independent Living and Action Disability Training and Consulting showed that having no control over when contractors are coming can create difficulties for disabled tenants who need to manage their routines and energy carefully.^{[footnote 25]}
• The main types of older peoples’ accommodation contain some form of communal area^{[footnote 26]}.
• Research highlighted by the Foundations Independent Living Trust and others in 2022^{[footnote 27]} found that unannounced visits as part of neighbourhood campaigns where staff introduce themselves can be problematic as some disabled people struggle to get to the door, others worry about the state of their homes, and those with mental health issues and anxiety may not want to let anyone in. A proper appointment system could work better. This is particularly important for repairs as tenants may need to make arrangements e.g to be accompanied, help move furniture, reduce anxiety, help with short term memory etc.
• Responses to the regulator’s TSM consultation flagged the need for training and awareness of autism for managing interactions e.g. a resident may be perceived as being aggressive but may be becoming overwhelmed.

Satisfaction with repairs and maintenance is lower among social renters (62 per cent) than private renters (75 per cent). The most common reasons for dissatisfaction with repairs and maintenance among social renters are the landlord not bothering to do the repairs (30 per cent), the landlord is slow to get things done (30 per cent), and the work being of poor quality (11 per cent)^{[footnote 28]}.

Our requirements

Based on the evidence above, tenants who may be impacted by these requirements are those who share the protected characteristics of race, age, disability, and sex. We consider that PSED aim 2 is relevant to these requirements.  

We consider that the following help to make our requirements more tenant and outcomes focused, which may have a positive impact on tenants who share the protected characteristics of race, disability, and age:

• Requiring providers to ensure repairs and maintenance issues can be reported easily may have a positive impact on tenants who experience communication barriers due to a disability or whose first language is not English.
• Requiring providers to keep tenants informed about repairs, maintenance and planned improvements may have a positive impact on tenants who experience communication barriers due to a disability or whose first language is not English. From our engagement with tenants, we have heard that good communication with them about the progress of repairs is a priority.
• Replacing the ‘right first time’ repairs objective with requirements to set and meet timescales and clearly communicate them to tenants. We understand from our stakeholder engagement that ‘right first time’ is measured and defined in different ways by registered providers and so does not provide a consistent performance target for services to tenants. Instead, we are proposing that landlords set timescales for repairs, which should provide registered providers with flexibility to meet tenants’ different needs. This flexibility may have a positive impact on older tenants, those with young children and disabled tenants, with greater transparency on timescales so that tenants can hold landlords to account on delivery.
• Requiring providers to understand and fulfil their maintenance responsibilities in respect of communal areas may have a positive impact on older and disabled tenants, as most designed or adapted accommodation for people who share these protected characteristics has communal areas. This may help to ensure communal areas are accessible and safe to use both in terms of accessing and leaving the home as well as making use of communal areas. This may help to minimise the disadvantage disrepair or poor quality of communal areas could otherwise cause, particularly to tenants with reduced mobility.

Removing the specific reference in the current Home Standard to offering choices to tenants is likely to have a neutral equality impact. This is because we are requiring providers to ensure that the delivery of repairs, maintenance and planned improvements to homes and communal areas is informed by the needs of tenants, which may have a positive impact on all tenants. In the Transparency, Influence and Accountability Standard, we require providers, working with tenants, to regularly consider ways to improve and tailor their approach to delivering landlord services.

Elsewhere in the standards, we are strengthening requirements for registered providers to ensure that their services provide equitable outcomes for all tenants; and to meet the diverse needs of tenants in all their activities. This overall strengthening may provide an incentive for registered providers to address discrepancies in experiences and outcomes from repairs, maintenance and planned improvements services for tenants who share certain protected characteristics.

We have removed reference to adaptations in relation to repairs, maintenance and planned improvements but we have set a separate requirement on adaptations under the Safety and Quality Standard. This may have a positive equality impact, as it makes adaptations more of a focus of our requirements.

We have taken the opportunity in the Code of Practice to emphasise that providers’ policies, procedures, and processes on this area should take into account tenant views and diverse needs, which may include, for example, increasing the priority of repairs for some older and disabled tenants, and installing extra locks and security lights for tenants experiencing domestic abuse, in order to safeguard them.

Overall assessment

Taking the above into account, we consider that the requirements may have a positive impact on tenants who share the protected characteristics race, disability, sex, and age

Safety and Quality: Adaptations

Potential impact on different protected characteristics

• Age
• Disability
• Race

There is insufficient evidence on the impact of the requirement on the other protected groups

Final wording

Required outcome

1.5.1 Registered providers must assist tenants seeking housing adaptations to access appropriate services.

Specific expectations

2.4.1 Registered providers must clearly communicate to tenants and relevant organisations how they will assist tenants seeking housing adaptations services.

2.4.2 Registered providers must co-operate with tenants, appropriate local authority departments and other relevant organisations so that a housing adaptations service is available to tenants where appropriate

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

• 40 per cent of social housing tenants are disabled, significantly higher than the national average (22 per cent).^{[footnote 29]}
• 56 per cent housing association tenants who have a long-standing physical or mental health condition lack the adaptations they need.
• 25 per cent of LA tenants and 21 per cent of HA tenants that required adaptations said their home was unsuitable for their needs.
• The most common group in the social rented sector were households with a HRP aged 65 or over (26 per cent)^{[footnote 30]}.
• Disabled people can experience serious deterioration in their mental wellbeing due to living in unsuitable accommodation, but adaptations help to restore dignity and greater independence and help to reduce depressive symptoms.
• The national strategy for autistic children, young people and adults 2021-2026^{[footnote 31]} recognises that better use of adaptations is needed to support autistic people and this requires improving awareness of the types of adaptations that could be of benefit (e.g. soundproofing of walls to reduce distress from noise transmission) amongst LAs and autistic people.
• Working age disabled people with an unmet need for accessible housing are four times more likely to be either unemployed or not seeking work compared to those with no unmet need.
• Home adaptations can make a significant difference to the pressures facing households with disabled children where their circumstances are exacerbated by low incomes, isolation, and lack of support lead to high levels of family breakdown.
• Ethnic minority households appear to have fewer adaptations than white households and are twice as likely to have no adaptations at all, even with evidence of higher levels of limiting long-term illness in ethnic minority households^{[footnote 32]}.
• Accessing appropriate and timely adaptations can reduce the risk of emergency admission to hospital, speed up hospital discharge, improve independence and reduce the need for physical assistance for older people.^{[footnote 33]}
• Strong engagement and communication between LAs and private registered providers are important for successful coordination and delivery of adaptations to ensure the best outcome for tenants.^{[footnote 34]}
• While residents reported finding it easier to have adaptations installed in social housing than other tenures “the process … was described as lengthy, and participants often struggled to get the changes they needed”.^{[footnote 35]}

Government’s ambition is to give more people the choice to live independently and healthily in their own homes for longer.^{[footnote 36]}

Our requirements

Based on the evidence, tenants within the sector who may be impacted by housing adaptation services are those who share the protected characteristics of age, disability, and race. We consider that PSED aims 1 (to eliminate unlawful conduct) and 2 (to advance equality of opportunity) are relevant to this requirement.

We are increasing our expectations of registered providers in relation to housing adaptations, by requiring registered providers to assist tenants seeking housing adaptations to access appropriate services. Our requirements may improve access to adaptations services, particularly for older tenants and those who are physically disabled, which in turn may improve the accessibility of homes and areas around the home for tenants who need adaptations, allowing them to remain in their homes independently for longer.

Improving accessibility to and from the home may help to improve access to opportunities for disabled and older people to participate in public life, where the lack of adaptations may have created a barrier to such participation and the enjoyment of their home.

Requiring registered providers to be clear about the type of assistance they can provide to tenants seeking housing adaptations may help to raise tenants’ awareness and reduce barriers to the adaptations process for tenants who need a housing adaptation, particularly for older and disabled people and tenants from ethnic minority groups (who may currently experience difficulties accessing such services) when compared to individuals who do not share those protected characteristics. While this requirement does not guarantee that a tenant will be supplied with the adaptation they need, it seeks to lessen the barriers to accessing help and assistance that some tenants may experience.

Requiring registered providers to co-operate with LAs so that adaptations can be provided to those in need of them may help to reduce barriers for tenants when accessing adaptations and having the works completed via the LA. We make it clear in the Code of Practice that providers should not unreasonably withhold permission for agencies to install adaptations in their homes, nor should they unreasonably refuse to install an adaptation in their home where they provide that service directly.

The changes we are making to 2.4.2 are intended to make our requirements on registered providers clearer, and do not change the intention in the standards.  We therefore consider that the changes are likely to have no equality impact.

Overall assessment

For the reasons given, we believe that our requirements relating to housing adaptations may have a positive impact on tenants who share the protected characteristics age, race, and disability.

Transparency, influence and accountability  – Fairness and respect

Potential impact on different protected characteristics

• Age
• Disability
• Gender rassignment
• Race
• Sex
• Sexual orientation

There is insufficient evidence of any impact on the other protected groups. However, it can be reasonably assumed that the requirement is relevant to all protected characteristics as the stigma that social housing tenants can face can intersect with other protected characteristics.

Final wording

Required outcome

1. Registered providers must treat all tenants and prospective tenants with fairness and respect.

Specific expectations

None

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

Research on ethnicity and social housing in 2018 found that:

• 16 per cent of households with an ethnic minority HRP felt they were treated worse than other races by their landlord. This is compared to 9.5 per cent of households with a white HRP. The percentage of people who felt they were treated better than other races is broadly similar, at 4 per cent for both white and ethnic minority HRPs.
• 64 per cent of white social tenants agree their social landlords treat them fairly (and only 17 per cent indicate a perception of unfairness), against 53 per cent of ethnic minority social tenants agreeing with this statement, and 24 per cent believing they are treated unfairly. Perceptions of fairness vary between individual ethnic minority groups^{[footnote 37]}.
• Results are consistently lower in households with a minority ethnic HRP than a white HRP, across a range of questions including whether the landlord’s staff were friendly and helpful (65 per cent against 73 per cent); whether they trusted their landlord (55 per cent against 63 per cent); and whether the landlord’s services were good overall (42 per cent against 58 per cent).^{[footnote 38]}

Research on the experience of LGBT+ social housing residents^{[footnote 39]} has found:

• 37 per cent of survey respondents agreed that housing provider staff were always responsive to their concerns.
• 29 per cent agreed that staff were sensitive to the needs of LGBT+.
• 56 per cent felt that their housing provider was approachable.

The researchers reported repeated examples given by participants of poor staff understanding of LGBT+ lives and, in some cases, outright discrimination.

A 2021 survey^{[footnote 40]} of 161 LGBT+ people aged 16-25 who had experienced homelessness found that:

• Over half of LGBT+ young people have faced some form of discrimination or harassment while accessing housing and homelessness services.
• Only half (56 per cent) of LGBT+ young people who accessed housing support services while homeless were satisfied with their experience.
• Over a third (39 per cent) of LGBT+ young people have faced discrimination from services due to an illness, disability, or mental health condition.

Peer research carried out for Shelter in 2021 with 34 women living in a range of different housing situations found that two-thirds of participants (23) in this small study reported poor treatment by their landlord (private or social) or accommodation provider. Participants described being spoken to rudely, being made to feel like a burden or that their problems weren’t severe enough, or being shown a lack of empathy or understanding^{[footnote 41]}.

Evidence^{[footnote 42]} to the inquiry on regulation of social housing by the Levelling up Housing and Communities Committee from the authors of the Stigma and Social Housing in England report quoted from their research findings. They found that the stigma related to social housing is complex and intersects with other societal stigmas such as poverty, unemployment, mental health and disabilities and race and immigration. Their research uncovered a paternalistic attitude amongst housing association staff. The research also included several examples of social housing professionals and contractors stigmatising tenants through their lack of respect when engaging with them, ignoring repair requests, ignoring ASB complaints, and using derogatory rhetoric^{[footnote 43]}.

Our requirements

Based on the evidence above, being treated with fairness and respect by their landlords may have a positive impact on tenants who share the protected characteristics race, age, disability, sexual orientation, gender reassignment, and sex. We make it clear in the Code of Practice that providers should consider how they can adapt their services and communications to meet individual tenants’ needs. We consider that all three PSED aims (to eliminate unlawful conduct, to advance equality of opportunity and to foster good relations) are relevant to these requirements.

By making this a standalone required outcome, we hope that providers make this a priority across all interactions with tenants.

We consider that the change we are making as a result of feedback from the consultation to the wording of the required outcome, is likely to have a positive equality impact.  This is because it becomes a requirement on providers to treat prospective tenants, in addition to current tenants, with fairness and respect.  This may have a positive impact on those who share the protected characteristic of race, because ethnic groups are differently represented amongst applicants for social housing and those assessed as owed a housing duty under homelessness legislation (see Tenancy Standard section below).

Overall assessment

We consider that this required outcome may have a positive impact on tenants who share the protected characteristics race, age, disability, sexual orientation, gender reassignment, and sex.

Transparency and accountability to tenants – Diverse needs

Potential impact on different protected characteristics

• Age
• Disability
• Gender rassignment
• Race
• Sex
• Sexual orientation

There is insufficient evidence of any impact on the other protected groups.

Final wording

Required outcome

1.2.1 In relation to the housing and landlord services they provide, registered providers must take action to deliver fair and equitable outcomes and housing for  all tenants and, where relevant, prospective tenants. 

Specific expectations

2.1.1 Registered providers must use relevant information and data to:

a) understand the diverse needs of tenants, including those arising from protected characteristics, language barriers, and additional support needs; and

b) assess whether their housing and landlord services deliver fair and equitable outcomes for tenants.

2.1.2 Registered providers must ensure that communication with and information for tenants is clear, accessible, relevant, timely and appropriate to the diverse needs of tenants.

2.1.3 Registered providers must ensure that landlord services are accessible, and that the accessibility is publicised to tenants. This includes supporting tenants and prospective tenants to use online landlord services if required.

2.1.4 Registered providers must allow tenants and prospective tenants to be supported by a representative or advocate in interactions about landlord services.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

• As set out in evidence above under the Safety and Quality Standard and the requirement to treat tenants and prospective tenants fairly and with respect, there are differences amongst ethnic groups as to proportions from that ethnicity living in non-decent housing. People from some minority ethnic backgrounds also feel they are treated worse than those from other races. Black African, mixed white/black African, and black Caribbean, households are most likely to rent social housing out of all ethnic groups, and black households are over-represented in new social housing lettings.^{[footnote 44] [footnote 45]}
• There is a much higher proportion of households with at least one disabled member in the social rented sector than other tenures (54 per cent compared with 37 per cent for outright owners (despite these two groups having a similar age profile) and 30 per cent for private renters)). ^{[footnote 46]}
• ONS data on 2019^{[footnote 47]} identifies that the proportion of disabled people of all ages (16 to 64 years) who rent social housing is higher than for non-disabled people. The same report set out that disabled people with mental illness or other nervous disorders, or those with epilepsy were most likely to rent social housing (34.9 per cent and 36.0 per cent respectively). More recently the EHS, Social Housing sector report 2020/21^{[footnote 48]} places mental health (43%, 950,000 households) as the third most common issue reported by HRPs with a disability, after mobility and stamina.
• The Equality and Human Rights Commission in the report ‘Housing and disabled people: Britain’s hidden crisis’ ^{[footnote 49]} found that data available to local authorities was inadequate to cover the very different housing requirements that people living with different disabilities or combinations of disabilities can have.
• 20 per cent of social renters are from an ethnic minority background compared to 15 per cent in 2011 and compared to the national average of 15 per cent^{[footnote 50]}.
• 57 per cent of social housing tenants are aged 50 and over. Older tenants may require reasonable adjustments to access landlord services, live in their home and to participate in public life.
• Nearly a third of households in social housing comprise either a female living alone or a female single parent.^{[footnote 51]}
• There is some research showing how women can experience barriers when accessing advice and support with their housing.^{[footnote 52]}
• In 2021-22, 93 per cent of households in England had internet access at home, but social renters were the least likely out of all tenures to have this access, at 83 per cent.^{[footnote 53]}
• Cross-tenure research by OFCOM in 2021 found that amongst those aged 65+, only 77 per cent used the internet at home^{[footnote 54]}.
• Only 35 per cent of LGBT+ young people who have accessed a service while homeless recall being asked by service providers to provide information about their gender identity and sexual orientation.^{[footnote 55]} Research in 2017 on the experience of LGBT+ social housing residents found that 59 per cent of survey respondents had never been asked for information about their gender identity or sexual orientation by their housing provider.^{[footnote 56]}
• 3 per cent of those living in social housing identify as LGBT+^{[footnote 57]}
• 0.8 per cent of social housing residents do not identify with the sex registered at birth^{[footnote 58]}.

Our requirements

We are proposing to strengthen our requirements in this area, setting clear expectations that landlords must act to deliver fair and equitable outcomes of housing and landlord services for tenants. The Tenant Involvement and Empowerment Standard currently expects landlords to demonstrate they understand the different needs of tenants. The proposed Transparency, Influence and Accountability Standard goes further, requiring landlords to use information and data to inform their understanding of how they meet the different needs of tenants. The requirement makes clear that this relates to needs arising from tenants’ protected characteristics, as defined in the Equality Act 2010, as well as more broadly (2.1.1 ). We consider that these requirements may lead to registered providers doing more to collect and maintain better data about tenants and their diverse support needs, which means that they are better able to tailor services to meet those needs.

We are also proposing expectations of landlords on how they communicate with tenants (2.1.2), ensure their services are accessible including where those services are accessed online (2.1.3), and allowing tenants to be supported by advocates or other representatives (2.1.4). The aim of all these changes is to influence the social housing sector to meet the wide and varying range of tenant needs by understanding those needs and reducing barriers for tenants in accessing their landlord and its services.

The requirements support our equality objective 1, which is to use our role to help ensure that registered providers better understand the diverse needs of tenants. We will expect registered providers to take action to deliver equitable service outcomes for all. We consider that PSED aim 2, which is to advance equality of opportunity is relevant to these requirements.

We have amended the diverse needs required outcome to explicitly reference prospective tenants. This change is intended to ensure that registered providers also consider the diverse needs of prospective tenants when delivering landlord services that prospective tenants may interact with, such as allocations and lettings. This may have a positive impact on those who share the protected characteristic of race, because ethnic groups are differently represented amongst applicants for social housing and those assessed as owed a housing duty under homelessness legislation (see Tenancy Standard section below).

We have also amended the wording of the required outcome (and made an associated amendment to the specific expectations) to focus it more clearly on the outcomes of registered providers’ landlord services and housing. Whilst the drafting has changed slightly, the intention of fair and equitable outcomes remains central to the delivery of all requirements across the standards.  To achieve this, services must be accessible to tenants and prospective tenants, taking into account their diverse needs, as reflected in the specific expectations. This change is not likely to have any equality impact. 

Overall assessment

By the regulator introducing these requirements, landlords will have to consider how they intend to meet them, which in turn may benefit tenants overall but particularly those tenants who share the protected characteristics of race, age, disability, sexual orientation, gender reassignment and sex, given the evidence demonstrates that there are some disparities for these groups. We take the opportunity in the Code of Practice to amplify our requirements relating to diverse needs.

We consider that PSED aim 1 (to eliminate unlawful conduct) and 2 (to advance equality of opportunity) are relevant to these requirements.

Taking the above into account, we consider that these measures may have a positive impact on tenants who share the protected characteristics of race, age, disability, sexual orientation, gender reassignment and sex.

Transparency and accountability to tenants – Engagement with tenants

Potential impact on different protected characteristics

• Age
• Disability
• Gender rassignment
• Race
• Sex
• Sexual orientation

There is insufficient evidence of any impact on the other protected groups.

Final wording

As some the requirements on engagement with tenants reflect directions from government, our assessment has focussed on the required outcome and specific expectations 2.2.5 and 2.2.6 only.

Required outcome

1.3 Registered providers must take tenants’ views into account in their decision-making about how landlord services are delivered and communicate how tenants’ views have been considered.

Specific expectations

2.2.5 Registered providers, working with tenants, must regularly consider ways to improve and tailor their approach to delivering landlord services including tenant engagement. They must implement changes as appropriate to ensure services deliver the intended aims.

2.2.6. Where a registered provider is considering a change in landlord for one or more tenants, or a significant change in management arrangements, it must consult affected tenants on its proposals at a formative stage and take those views into account in reaching a decision. The consultation must:

a) be fair and accessible b) provide tenants with adequate time, information and opportunities to consider and respond c) set out actual or potential advantages and disadvantages (including costs) to tenants in the immediate and longer term d) demonstrate to affected tenants how the consultation responses have been taken into account in reaching a decision.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

• In our review of the requirements on fairness and respect we have referred to research from the Human City Institute which indicated differential levels of trust and confidence in landlords based on ethnicity. Lack of trust and feeling that you are not treated with respect are likely to act as barriers to engaging with your landlord.
• In our review of the requirements on diverse needs we have referred to research from the EHS and OFCOM which sets out potential lower rates of those having internet access at home in social housing generally, but also across all tenures amongst older households.
• Research commissioned by the Local Government Association and developed with TPAS calls for providers to do more to engage with younger tenants (age is not specified). It talks about the importance of using a variety of engagement methods to promote accessibility and to ensure engagement is representative and asks providers to consider what steps they take to increase representation and target all areas of the community.^{[footnote 59]}
• As part of the EHS in 2021/22, social renters with a disability were asked which areas were affected by their disability. The most common issues reported by HRPs with a disability were mobility (54 per cent), stamina (45 per cent), mental health (40 per cent) and dexterity (34 per cent). All of these are likely to affect disabled tenants’ ability to engage with their landlord.^{[footnote 60]}
• Joint research based on the views of people with a label of mild/moderate learning disability called for better opportunities for the voices of people with learning disabilities to be heard and to influence housing policy and noted that family members are often left to provide support.^{[footnote 61]}
• Shelter’s report Fobbed Off, referred to above, discusses the importance of involving women with lived experience in the design and delivery of housing and homelessness services in order to overcome barriers women face, particularly in relation to women-specific services.
• The Chartered Institute of Housing’s 2011 briefing on delivering housing services to LGBT+ tenants found that due to historical discrimination many LGBT+ people have been reluctant to articulate their needs or have been marginalised in consultation processes.^{[footnote 62]}
• An akt 2022 report recommended that the housing and homelessness sector should involve young people in the design of services, and commission training programmes for housing staff to raise awareness of the needs of LGBT+ young people who are homeless or at risk of homelessness.^{[footnote 63]}

Our requirements

Our expectations on providers in this area have been increased, requiring regular and ongoing consideration of ways to improve and tailor their approach to tenant engagement, as well as all other landlord services. This may lead to tenants who are less likely to be engaged with their landlord increasingly taking part.

The requirements on resident engagement recognise that the methods used should vary to meet a range of needs and interests, as some tenants may want to engage proactively with their landlord’s policies, and others may prefer just to be kept informed.

Based on the evidence above, all tenants within the sector may be positively impacted by requirements relating to tailoring of services, tenant engagement and consultation. This impact may be more positive for those who share the protected characteristics of race, age, disability, sexual orientation, gender reassignment, and sex. We consider that PSED aim 2, to advance equality of opportunity, is relevant to these requirements.

We have also clarified our expectations on landlords when considering significant changes in management arrangements. This has been done to address some of the issues we have seen in our consumer regulation case work since 2017 when the requirement currently in the existing Tenant Involvement and Empowerment Standard was introduced. The expanded expectations should encourage more effective consultation practice that improves the ability of those who share one or more protected characteristics (where it has been shown that participation / engagement levels are low) to give their views.

We have taken the opportunity in the Code of Practice to be clear that providers should take reasonable steps to ensure that all tenants have an equitable opportunity to be involved in influencing and scrutinising strategies, policies, and services, taking into account the diverse needs of tenants. 

The additional wording in the required outcome requiring providers to also communicate how tenants’ views have been considered, may have a positive effect on the experience of all tenants by improving feedback from landlords on tenant engagement.  However, it is not likely to make a specific difference to outcomes for those who share one or more protected characteristics.  

Overall assessment

Taking all the above into account, we consider that these requirements may have a positive impact on tenants who share the protected characteristics of race, age, disability, sexual orientation, gender reassignment, and sex.

Transparency and accountability to tenants – Information about landlord services

Potential impact on different protected characteristics

• Age
• Disability
• Race
• Sex

There is insufficient evidence of any impact on the other protected groups. It is recognised that communications and the standard of service received by tenants can be influenced by stigmatisation.

Research suggests that social housing stigma is complex and intersects with other issues such as poverty and immigration^{[footnote 64]}.

Final wording

We have not assessed the equality impact of  specific expectation 2.3.2 as this reflects directions to us from government.

Required outcome

1.4.1 Registered providers must communicate with tenants and provide information so tenants can use landlord services, understand what to expect from their landlord, and hold their landlord to account.

Specific expectations

2.3.1. Registered providers must have a policy for how they recognise and effectively respond to cases of domestic abuse.

a) available landlord services, how to access those services, and the standards of service tenants can expect

b) standards of safety and quality tenants can expect homes and communal areas to meet

c) rents and service charges that are payable by tenants

d) responsibilities of the registered provider and the tenant for maintaining homes, communal areas, shared spaces^{[footnote 65]} and neighbourhoods.

2.3.3. Registered providers must communicate with affected tenants on progress, next steps and outcomes when delivering landlord services.

2.3.4. Registered providers’ housing and neighbourhood policies must be fair, reasonable, accessible, and transparent. Where relevant, policies should set out decision-making criteria and appeals processes.

2.3.5 Registered providers must make information available to tenants about the relevant roles and responsibilities of senior level employees or officers, including who has responsibility for compliance with the consumer standards.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

• There is a much higher proportion of households with at least one disabled member in the social rented sector than other tenures (54 per cent compared with 37 per cent for outright owners (despite these two groups having a similar age profile) and 30 per cent for private renters)).
• 57 per cent of social housing tenants are aged 50 and over.^{[footnote 66]}
• 2.7 per cent of social rented households have a HRP who has little/no proficiency in the English language^{[footnote 67]}.
• 36 per cent of social rented HRPs do not have any educational qualifications. Comparatively the national average is 20 per cent^{[footnote 68]}.
• Women can experience barriers when accessing advice and support with their housing^{[footnote 69]}.
• In 2021-22, 93 per cent of households in England had internet access at home, but at 83 per cent, social renters were the least likely out of all tenures to have this access^{[footnote 70]}.
• Cross-tenure research by OFCOM in 2021 found that amongst those aged 65+, only 77 per cent used the internet at home^{[footnote 71]}.
• Analysis by an IT supplier in 2023 found that significant numbers of website pages across housing associations would restrict full access for those with visual impairments, more than for LAs and healthcare providers^{[footnote 72]}.

Our requirements

We are expanding requirements on transparency, including so that providers must keep tenants informed of plans and progress during the delivery of services.

To aid transparency, tenants must be able to access policies that relate to landlord services and these policies must be fair and reasonable, setting out the criteria for making decisions, and processes tenants must follow should they choose to appeal a decision (2.3.4). We are proposing to add to these a further requirement for landlords to have a dedicated person responsible for complying with the consumer standards (2.3.5). 

We consider that PSED aim 2, to advance equality of opportunity, is relevant to these requirements. These requirements may lead to an improvement in how registered providers provide information to tenants and the scope of that information, particularly to those tenants who are more likely to experience barriers to communication and/or engagement.

We consider that the post consultation change we are making to the wording of 2.3.1, where we are adding the word “accessible”, is likely to have a positive equality impact.  This is because it will encourage providers to review the accessibility of information they provide. This could have a positive impact on those sharing the protected characteristics of race, sex, age, and disability. 

Overall assessment

Taking the above into account, we consider that these requirements may have a positive impact on tenants who share the protected characteristics age, race, disability, and sex.

Transparency and accountability to tenants – Performance information

EXCLUDES specific expectations 2.4.1 – 2.4.3 relating to tenant satisfaction measures as they are covered by a separate EQIA

Potential impact on different protected characteristics

There is insufficient evidence of any impact on protected groups.

Final wording

Required outcome

1.5.1 Registered providers must collect and provide information to support effective scrutiny by tenants of their landlord’s performance in delivering landlord services.

Specific expectations

2.4.4. Registered providers must provide tenants with information about:

a) how they are performing in delivering landlord services and what actions they will take to improve performance where required b) how they have taken tenants’ views into account to improve landlord services, information and communication c) how income is being spent d) their directors’ remuneration and management costs.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

We did not find any evidence which is directly relevant to the provision of information to tenants by providers. However, we acknowledge that our general requirement for registered providers to consider how they communicate and present information to tenants is likely to support this specific expectation.

Our requirements

While all tenants may be positively impacted by requirements relating to the provision of performance information, as they help tenants to better hold their landlord to account, there is no evidence of a specific positive or negative impact on tenants who share different protected characteristics.

Overall assessment

Taking the above into account, we consider that these requirements are likely to have a neutral impact on tenants who share different protected characteristics.

Transparency and accountability to tenants: Complaints

Potential impact on different protected characteristics

• Age
• Disability
• Race

There is insufficient evidence of any impact of the requirement on the other protected groups.

Final wording

Required outcome

1.6.1 Registered providers must ensure complaints are addressed fairly, effectively, and promptly.

Specific expectations

2.5.1. Registered providers must ensure their approach to handling complaints is simple, and accessible and publicised.

2.5.2. Registered providers must provide accessible information to tenants about:

a) how tenants can make a complaint about their registered provider;

b) the registered provider’s complaints policy and complaints handling process;

c) what tenants can do if they are dissatisfied with the outcome of a complaint or how a complaint was handled; and  

d) the type of complaints received and how they have learnt from complaints to continuously improve services.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

• In the 12 months prior to the EHS 2020-2021, 33 per cent of social renters had considered making a complaint. Compared to private renters (17 per cent), social renters were almost twice as likely to consider complaining. Older renters were less likely to consider complaining than younger renters (20 per cent of those aged 65 or over considered making a complaint compared to 34 per cent of those under 65).^{[footnote 73]}
• Social renters who had considered, but did not make, a complaint were asked their reasons why. Similar proportions of social renting households said they had not complained because it was too much hassle (32 per cent) or for an ‘other’ reason not listed (37 per cent),  A further 22 per cent of social renters said they did not complain because they did not think anything would be done to fix the problem, 11 per cent because they did not know how to complain, 7 per cent because they did not think the problem was important enough and 3 per cent because they did not want to cause a problem with their landlord. The proportion selecting each reason was similar for LA and HA renters.^{[footnote 74]}
• Social renters with an HRP from an ethnic minority background were more likely to consider complaining than those with a white HRP, 38 per cent as opposed to 30 per cent (this difference might be due to the younger age profile of ethnic minority households, as younger tenants were more likely to consider complaining than older renters over aged 65). The proportion of social renters who, after considering a complaint, went on to make one was the same for households with an ethnic minority HRP and those with a white HRP, 85 per cent in both groups.^{[footnote 75]}
• Evidence presented by Social Housing Action Campaign (SHAC) to the Levelling Up Housing and Communities Committee’s inquiry into the regulation of social housing indicated that for disabled people the complaints process could be draining and demoralising when met by landlords who (SHAC alleged) intentionally protract the process or completely ignore their complaints. The complaints process itself is not always accessible depending on the tenant’s disability, and landlords often refuse to make reasonable adjustments to facilitate this^{[footnote 76]}.

Our requirements

The requirements relating to complaints handling should result in registered providers making tenants aware of how to make a complaint to their landlord, which, given the evidence, may have a positive impact on tenants who share the protected characteristics of race, age, and disability. We consider that PSED aims 1 and 2 are relevant to these requirements.

The expanded requirements on providers regarding complaints should help to ensure that registered providers have an accessible and responsive complaints system which does not place barriers in the way of any tenants. Our standard operates alongside the work of the Housing Ombudsman Service, setting expectations about how registered providers are expected to handle complaints, and incorporating requirements around transparency to tenants.

We consider that the changes we are making to both 2.5.1 and 2.5.2, are likely to have a positive equality impact. This is because the amended wording will encourage providers to make tenants aware of their approach to complaints and to review the accessibility of the information they provide to tenants around complaints. This could have a positive impact on those sharing the protected characteristics of race, age, and disability.

Overall assessment

Taking the above into account, we consider that these requirements may have a positive impact on tenants who share the protected characteristics of race, age, and disability.

Transparency and accountability to tenants: Self-referral

Potential impact on different protected characteristics

There is insufficient evidence of any impact on protected groups

Final wording

Specific expectation

2.6.1 Registered providers must communicate in a timely manner with the regulator on all material issues that relate to non-compliance or potential non-compliance with the consumer standards.

What the evidence tells us

We did not find any equality evidence which is directly relevant to this requirement.

Our requirements

The Governance and Financial Viability Standard requires private registered providers to communicate to the regulator on material issues that relate to their non-compliance or potential non-compliance with the standards, and the Rent Standard requires this of both private registered providers and local authority registered providers where there are material issues related to non-compliance in respect of rents. This requirement makes clear that this is also a requirement in respect of our consumer standards.

While all tenants are likely to be positively impacted by requirements on providers to communicate with the regulator on material issues relating non-compliance with the consumer standards, there is no evidence of any specific impact on tenants who share one or more protected characteristics.

Overall assessment

Taking the above into account, we have not identified any equality impacts from this requirement.

Neighbourhood and Community: Safety of shared spaces

Potential impact on different protected characteristics

• Age
• Disability
• Race

There is insufficient evidence of any impact on the other protected groups

Final wording

Required outcome

1.1.1 Registered providers must work co-operatively with tenants, other landlords and relevant organisations to contribute to the upkeep and take all reasonable steps to ensure the safety of shared spaces.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

• Specialist older persons’ housing is likely to be flatted accommodation, where communal areas are important for accessibility and create spaces that help combat isolation. These need to be safe and well maintained. While there is a distinction between communal areas (which are covered under the Safety & Quality Standard) and shared spaces, older people’s housing may be also more likely to have shared spaces as well as communal. Government planning guidance indicates the importance of the quality and accessibility of shared spaces for the wellbeing of older residents.^{[footnote 77]}
• 45 per cent of social housing tenants live in a flat (compared to 22 per cent for all tenures) and 48 per cent of disabled social housing tenants live in a flat, maisonette or apartment^{[footnote 78]}.
• Accessibility and social cohesion are two of the most significant factors affecting how older people experience their neighbourhood.^{[footnote 79]}
• Research by Foundations in 2022 also emphasised the importance of shared spaces and their accessibility to the lives of disabled people.^{[footnote 80]}
• The Housing Ombudsman in his evidence to the Levelling Up Housing and Communities Committee’s inquiry on the regulation of social housing advocated that as part of a reviewed Decent Homes Standard, a minimum standard should apply to communal spaces including external areas such as gardens, including lighting, bin areas and bin chutes.^{[footnote 81]}
• The 2021 Census showed that overall, 10 per cent of social housing tenants were overcrowded, and within this there was substantial variation amongst different ethnic groups in social housing.  24 per cent of Asian households were overcrowded, as were 22 per cent of black households, 21 per cent ‘other’ ethnicity, and 14 per cent mixed or multiple ethnic groups, compared to 7 per cent of white households.^{[footnote 81]}
• The Government’s 2021 ‘Tackling violence against women and girls strategy’^{[footnote 82]} acknowledged that through targeted improvements to the environment it is possible to both prevent crime and improve feelings of safety for women and girls.

Our requirements

Responses to the Social Housing Green Paper highlighted tenants’ concerns about the quality and upkeep of the spaces around their homes. These requirements set expectations in relation to ‘shared spaces’, which the landlord does not have responsibility for but where, working with others, they can help ensure they are safe for tenants to use.

Based on the evidence, older people may be more likely to live in accommodation where shared spaces are a feature. Disabled people need shared spaces to be accessible and safe. People from some minority ethnic groups are more likely to live in overcrowded conditions and therefore have most to gain from quality shared spaces. The requirement to take all reasonable steps to ensure the safety of shared spaces may therefore have a positive impact on tenants who share the protected characteristics of age, disability, and race. We consider that PSED aim 2, to advance equality of opportunity, is relevant to these requirements. The changes we are making to this required outcome after consultation are not likely to have any impact on the outcomes for tenants who share one or more protected characteristics.   

Overall assessment

Taking the above into account, we consider that these requirements may have a positive impact on tenants who share the protected characteristics age, disability, and race.

Neighbourhood and Community: Local cooperation

Potential impact on different protected characteristics

• Age
• Disability
• Gender reassignment
• Race
• Sex
• Sexual orientation

There is insufficient evidence of any impact on the other protected groups.

Final wording

Required outcome

1.2.1 Registered providers must co-operate with relevant partners to promote social, environmental, and economic wellbeing in the areas where they provide social housing.

Specific expectations

2.1.1 Registered providers, having taken account of their strategic objectives, the views of tenants and their presence within the areas where they provide social housing, must:

a) identify and communicate to tenants the roles registered providers play in promoting social, environmental, and economic wellbeing and how those roles will be delivered.

b) co-operate with local partnership arrangements and the strategic housing function of local authorities where they are able to assist them local authorities in achieving their objectives.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

2020 Government data^{[footnote 84]} for the most deprived 10 per cent of neighbourhoods shows that:

• White British people were the least likely to live in the neighbourhoods most deprived in relation to living environment (9.2 per cent), crime (8.9 per cent) and barriers to housing and services (8.2 per cent).
• Out of the 18 individual ethnic groups used in this research, black African (32.3 per cent), black other (31.6 per cent), and black Caribbean (29.2 per cent) people were the most likely to live in the neighbourhoods most deprived in relation to housing and services.
• People from the Pakistani ethnic group were the most likely to live in the 10 per cent of neighbourhoods most deprived in relation to education, skills, and training (27.4 per cent), health and disability (16.0 per cent), crime (21.2 per cent) and the living environment (28.2 per cent).

A Bristol University report The Inequality of Poverty^{[footnote 85]} from 2021 indicates the following:

• People from Bangladeshi and Pakistani ethnic minorities have the highest rates of poverty (at 23-26 per cent), followed by Indian, black Caribbean and black African groups (9-11 per cent). The white majority has the lowest poverty rate at (6 per cent).
• Some protected characteristics are associated with an increased risk of poverty in the UK: race, sex (in the case of single mothers), and disability. In relation to age, while pensioner poverty has fallen over the last few decades, younger workers are much more likely to be in poverty than other age groups. We also found that intersectionality plays a large role; the more protected characteristics a person has, the more risk they bear of being in poverty.
• Poverty amongst minority ethnic groups arises largely from their position in the labour market. Overall, people from minority ethnic groups are more likely to work in low-paid occupations or earn below the living wage. There are also higher unemployment rates in some minority ethnic groups, and workers from black minority ethnic groups are more likely to have insecure work.

A Houseproud project report from the University of Surrey in 2018 found that:

• Nearly 50 per cent of LGBT+ survey respondents in social housing do not feel a sense of belonging in their local community.
• 25 per cent reported feeling lonely in the area they live and only 31 per cent of LGBT+ survey respondents felt their housing provider could deal effectively with issues of harassment.^{[footnote 86]}
• The poverty rate is consistently higher for disabled people (32 per cent in 2019/20 compared to 20 per cent not disabled).^{[footnote 87]}
• In the year ending March 2021, disabled people were more likely to report feelings of loneliness “often or always” (15.1 per cent) than non-disabled people (3.6 per cent).^{[footnote 88]}
• Government planning guidance highlights the value of the inclusive and age-friendly design of public spaces such as town centres in helping older and disabled people live more independently.^{[footnote 89]}
• Government Office for Science research has identified the importance for older people of wider neighbourhoods and the built environment.^{[footnote 90]}
• Similarly, the Government’s 2021 Tackling violence against women and girls strategy^{[footnote 91]} acknowledged that through targeted improvements to the environment it is possible to both prevent crime and improve feelings of safety for women and girls.
• Research by Foundations in 2022 drew similar conclusions regarding quality of life for disabled people.^{[footnote 92]}.

Our requirements

Based on the evidence, requiring providers to co-operate with partners to promote social, environmental and economic wellbeing may have a positive impact on tenants who share the protected characteristics age, race, disability, sex, gender reassignment, and sexual orientation. We consider that all PSED aims are relevant to these requirements.

Requiring registered providers to set out how they will deliver their role in the promotion of social, environmental, and economic wellbeing strengthens the current expectation as it is more transparent and active.

The changes we are making post-consultation are not likely to have an impact on the outcomes for those sharing one or more protected characteristics.

Overall assessment

Taking the above into account, we believe this requirement may have a positive impact on tenants who share the protected characteristics age, race, disability, sex, gender reassignment, and sexual orientation.

Neighbourhood and Community: Antisocial behaviour and hate incidents

Potential impact on different protected characteristics

• Age
• Disability
• Gender reassignment
• Race
• Religion or belief
• Sex
• Sexual orientation

There is insufficient evidence of any impact on the other protected groups.

Final wording

Required outcome

1.3.1 Registered providers must work in partnership with appropriate local authority departments, the police, and other relevant organisations to deter and tackle anti-social behaviour (ASB) and hate incidents in the neighbourhoods where they provide social housing.

Specific expectations

2.2.1 Registered providers must have a policy on how they work with relevant organisations to deter and tackle ASB in the neighbourhoods where they provide social housing.

2.2.2 Registered providers must clearly set out their approach for how they deter and tackle and deter hate incidents in neighbourhoods where they provide social housing.

2.2.3 Registered providers must enable ASB and hate incidents to be reported easily and keep tenants informed about the progress of their case.

2.2.4 Registered providers must provide prompt and appropriate action in response to ASB and hate incidents, having regard to the full range of tools and legal powers available to them.

2.2.5 Registered providers must support tenants who are affected by ASB and hate incidents, including by signposting them to agencies who can give them appropriate support and assistance.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

Government 2021/22 hate crime figures[#93]:

• 70 per cent (109,843) of hate crimes were racially motivated - racially motivated hate crimes increased by 19 per cent between year ending March 2021 and year ending March 2022.
• Religious hate crimes increased by 37 per cent between year ending March 2021 and year ending March 2022 (from 6,383 to 8,730). In year ending March 2022, where the perceived religion of the victim was recorded, two in five (42 per cent) of religious hate crime offences were targeted against Muslims (3,459 offences). The next most targeted group were Jewish people, who were targeted in just under one in four (23 per cent) of religious hate crimes (1,919 offences).
• Sexual orientation hate crimes rose by 41 per cent (to 26,152 offences). This was the largest percentage annual increase in these offences since the time series began in year ending March 2012.
• Disability hate crimes increased by 43 per cent (from 9,945 to 14,242) over the last year, the largest percentage annual increase seen since year ending March 2017 (53 per cent).

ONS crime figures 2020^{[footnote 94]}

• 40 per cent of white British households experienced ASB in the local area compared to 46 per cent mixed white and black African and 55 per cent other mixed ethnic background.
• 50 per cent of Jewish households experienced ASB in the local area.
• 52 per cent of gay/lesbian households and 49 per cent of bisexual households experienced ASB in the local area compared to 42 per cent of heterosexual households.

ONS perception of personal safety and experiences of harassment 2022^{[footnote 95]}

• People felt less safe walking alone in all settings after dark than during the day; with women feeling less safe than men in all settings after dark.
• Disabled people felt less safe in all settings than non-disabled people.
• More women (27 per cent) than men (16 per cent) reported they had experienced at least one form of harassment in the previous 12 months.

Research^{[footnote 96]} from the University of Surrey indicated that transgender respondents were particularly concerned about safety in their neighbourhood, due to transphobia and transphobic hate crime.

Disabled people aged 16 years and over (43.4 per cent) were significantly more likely to have experienced ASB than non-disabled people (39 per cent). This was most pronounced amongst those aged 35-44, where 57.7 per cent of disabled people experienced ASB compared with 43.3 per cent of non-disabled people.^{[footnote 97]} .

London Councils’ 2014 report^{[footnote 98]} on ASB and mental health found that people with learning disabilities and mental health problems can sometimes be perceived as perpetrators of ASB through displaying behaviours due to their impairment.

A Cambridge University research project^{[footnote 99]} found very differing ideas about what constitutes ASB between adults and people aged 11-15 within the same area.

Social housing tenants are more likely to experience ASB and be victims of crime than those in other tenures^{[footnote 100]}.

Feedback received through the TSM consultation suggests that tenants with certain mental health conditions may be less able to cope with anti-social behaviour such as noise and neighbour disputes, which can exacerbate stress and mental health issues.

Our requirements

Based on the evidence, tenants who share the protected characteristics age, race, religion or belief, disability, sex, gender reassignment, and sexual orientation may be more positively impacted by requirements relating to ASB and hate crime. We consider that all PSED aims (to eliminate unlawful conduct, to advance equality of opportunity and to foster good relations) are relevant to these requirements.  

The expectation that providers set out their approach to tackling and deterring hate incidents may have a positive impact on tenants who share the protected characteristics race, religion  or belief, gender reassignment, disability, sexual orientation, and age, as providers need to define their policy and approach, taking into account the needs of their tenants and current sector good practice in this area.  The post-consultation change of making overt references to hate incidents alongside ASB may have a further positive impact on those sharing these protected characteristics as it clarifies for providers the parallel importance of both things.  

Some perpetrators of ASB suffer with mental health problems. 2.3.5 requiring providers to support those affected by ASB rather than limiting support to victims of ASB may help to facilitate the right support and interventions being put in place for those perpetrators and achieve a positive outcome that reduces further offending and helps them to maintain their tenancy.

We have taken the opportunity in the Code of Practice to make it clear that providers should aim to eliminate any barriers to reporting ASB and hate incidents to their landlord, which may have a positive impact on those tenants who may be reluctant to report ASB and hate incidents, or who experience communications barriers.

Overall assessment

Taking the above into account, we consider that these requirements may have a positive impact on tenants who share the protected characteristics race, religion or belief, gender reassignment, disability, sex, sexual orientation, and age.

Neighbourhood and Community: Domestic abuse

Potential impact on different protected characteristics

• Age
• Disability
• Gender reassignment
• Pregnancy and maternity
• Race
• Sex
• Sexual orientation

There is insufficient evidence of any impact on the other protected groups.

Final wording

Required outcome

1.4.1 Registered providers must work co-operatively with other agencies tackling domestic abuse and enable tenants to access appropriate support and advice.

Specific expectations

2.3.1. Registered providers must have a policy for how they recognise and respond effectively to cases of domestic abuse.

2.3.2. Registered providers must co-operate with appropriate local authority departments to support the local authority in meeting its duty to develop a strategy and commission services for victims of domestic abuse and their children within safe accommodation.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

ONS data on domestic abuse victim characteristics 21/22^{[footnote 101]} :

• In 74 per cent of domestic abuse related crimes recorded by the police the victim was female.
• A significantly higher proportion of adults aged 20 to 24 years were victims of any domestic abuse compared with those in age categories of 55 years and over.
• 10 per cent of adults with a disability experienced domestic abuse compared to 4 per cent of adults without a disability.
• ONS statistics^{[footnote 102]} show that, of all victims of any type of domestic abuse, it was reported by 5.0 per cent of white people, 8.7 per cent of mixed ethnicity people, 3.9 per cent Asian people, and 5.9 per cent black people. Looking at female victims only, the figures were 7.0 per cent white, 3.2 per cent Asian, and 10.2 per cent black.  In addition to the difference in proportions reported, there is some evidence of DA being experienced differently by black and minority ethnic groups^{[footnote 103]}
• Domestic abuse can escalate during pregnancy^{[footnote 104]}.
• 1 in 15 survivors using domestic abuse services are pregnant women.^{[footnote 105]}
• The Safe at Home Report^{[footnote 106]} recommends creating a domestic abuse policy for staff and tenants in order to raise awareness of domestic abuse.
• The Home Office states^{[footnote 107]} that between an estimated quarter and a third of children have been exposed to domestic abuse at some point in their lives; and that women aged 16 to 19 years were significantly more likely to be victims of any domestic abuse in the last year than women aged 25 years and over. It also found that disabled adults were more likely to have experienced domestic abuse in the last year than non-disabled adults.
• There is further evidence to suggest that disabled people are at increased risk of experiencing domestic abuse in the Crime Survey for England and Wales year ending March 2020[^{[footnote 108]}. This found that around 1 in 7 (14 per cent) disabled adults aged 16 to 59 years experienced domestic abuse, compared with 1 in 20 (5 per cent) non-disabled adults, and that disabled women were more than twice as likely to have experienced domestic abuse (18 per cent) than non-disabled women (7 per cent).
• While there are no official statistics on the experiences of LGBT+ communities with domestic abuse, research ^{[footnote 109]} by GALOP suggests it is very prevalent.
• A Stonewall study^{[footnote 110]} found more than a quarter of British transgender people (28 per cent) in a relationship in the previous year had faced domestic abuse from a partner.

Our requirements

The White Paper commits the regulator to introducing a requirement for landlords to have a policy setting out how they should tackle issues surrounding domestic abuse, working with other agencies as appropriate, and the Act extends our powers to set standards to include policies and procedures in connection to domestic abuse. This is reflected in the standard. We consider that all PSED aims (to eliminate unlawful conduct, to advance equality of opportunity and to foster good relations) are relevant to these requirements.

Based on the evidence, requiring providers to work with others to tackle domestic abuse may have a positive impact on tenants who share the protected characteristics of pregnancy and maternity, gender, age, race, disability, gender reassignment, and sexual orientation. By working with other agencies, registered providers may be able to achieve more to tackle domestic abuse than they could by working alone, which may reduce disadvantages suffered by victims and survivors. The outcome of such partnership working should help to ensure that victims and survivors of domestic abuse can remain safe in their home or move to a place of safety.

Having a domestic abuse policy should raise awareness of and increase understanding of domestic abuse and the support available to victims and survivors of domestic abuse within the community and with a registered provider’s staff. Having a policy setting out how they respond to cases of domestic abuse may also help to ensure that providers respond appropriately and consistently to reports of domestic abuse. The Domestic Abuse Statutory Guidance Framework states that it is vital that housing providers are able to recognise and respond to the signs of domestic abuse. Its findings include the risk of housing providers misdiagnosing the effects of domestic abuse as ASB and the cost to providers of doing so.

Expecting registered providers to have a clear policy and commitment to this approach may also help to contribute to a societal challenge against domestic abuse towards victims and survivors, where there is significant correlation across protected characteristics, particularly for women.

The Code of Practice makes clear that providers’ approach to recognising and responding to cases of domestic abuse should include offering appropriate staff members to support tenants experiencing domestic abuse, and offering tenants affected by domestic abuse referrals to specialist domestic abuse agencies.

We consider that adding a requirement in 2.3.1 for providers to have a policy which includes how they recognise cases of domestic abuse, as well as how they respond to such cases could have an impact on the outcomes for those sharing one or more protected characteristics as more emphasis on registered providers recognising domestic abuse could encourage a more proactive approach to how providers tackle domestic abuse.

Overall assessment

Taking the above into account, we consider that these requirements may have a positive impact on tenants who share the protected characteristics pregnancy and maternity, sex, age, race, disability, gender reassignment, and sexual orientation.

Tenancy: Allocations and lettings

Potential impact on different protected characteristics

• Age
• Disability
• Race

There is insufficient evidence of any impact on the other protected groups.

Final wording

Required outcome

1.1.1 Registered providers must allocate and let their homes in a fair and transparent way that takes the needs of tenants and prospective tenants into account.

Specific expectations

2.1.1 Registered providers must co-operate with local authorities’ strategic housing functions and assist local authorities to fulfil their duties to meet identified local housing needs. This includes assistance with local authorities’ homelessness duties, and through meeting obligations in nominations agreements.

2.1.2 Registered providers must seek to allocate homes that are designated, designed, or adapted to meet specific needs in a way that is compatible with the purpose of the housing.

2.1.3 Registered providers must develop and deliver services that seek to address under-occupation and overcrowding in their homes. These services should be focused on the needs of tenants.

2.1.4 Registered providers must take action to prevent and tackle tenancy fraud.

2.1.5 Registered providers must have a fair, reasonable, simple, and accessible appeals process for allocation decisions.

2.1.6 Registered providers must record all lettings and sales as required by the Continuous Recording of Lettings (CORE) system.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

Government figures on overcrowded households based on survey data collected between 2018 and 2021 found ^{[footnote 111]} :

• Households with the highest rates of overcrowding were in the Bangladeshi (24 per cent), Pakistani (18 per cent), black African (16 per cent), Arab (15 per cent) and mixed white and black African (14 per cent) ethnic groups. 2 per cent of white British households were overcrowded.
• In social housing 6 per cent of white British were overcrowded compared to 13 per cent of the tenant population other than white British.
• White British households were more likely to under-occupy their home than households from all other ethnic groups combined.

Census 2021 data

• The 2021 Census showed a similar picture - that overall, 10 per cent of social housing tenants were overcrowded, and within this there was substantial variation amongst different ethnic groups in social housing.  24 per cent of Asian households were overcrowded, as were 22 per cent of black households, 21 per cent ‘other’ ethnicity, and 14 per cent  mixed or multiple ethnic groups, compared to 7 per cent of white households.^{[footnote 112]}

Government data on renting social housing^{[footnote 113]}, ^{[footnote 114]}

• Households with a black lead applicant were the most disproportionately homeless at 9.7 per cent of those owed a duty but only 3.5 per cent of the population.
• For vulnerable Bangladeshi households, the most common reason they were given priority was the need to move out of unsanitary, unsatisfactory, or overcrowded conditions.
• Black British, black Welsh, Caribbean or African households were most likely to rent social housing out of all ethnic groups with 42 percent of this group being social renters, followed by mixed or multiple ethnic groups’ (27 per cent), other ethnic groups (23 per cent), white (16 per cent), Asian, Asian British or Asian Welsh (13 per cent).
• In London, white British households were less likely to rent social housing than households from all other ethnic groups combined. Outside London, white British households were as likely to rent social housing as households from all other ethnic groups combined.

2020 Government data^{[footnote 115]} for the most deprived 10 per cent of neighbourhoods shows that:

• White British people were the least likely to live in the neighbourhoods most deprived in relation to living environment (9.2 per cent), crime (8.9 per cent) and barriers to housing and services (8.2 per cent)
• Out of the 18 individual ethnic groups used in this research, black African (32.3 per cent), black Other (31.6 per cent), and black Caribbean (29.2 per cent) people were the most likely to live in the neighbourhoods most deprived in relation to housing and services.
• People from the Pakistani ethnic group were the most likely to live in the 10 per cent of neighbourhoods most deprived in relation to education, skills, and training (27.4 per cent), health and disability (16.0 per cent), crime (21.2 per cent) and the living environment (28.2 per cent).

Research[^116] by the National Institute for Health Research, School for Social Care Research highlights some of the difficulties those with mild and moderate learning disabilities have with accessing social housing: 

• Social housing was often viewed as the first or preferred option, but the sector was difficult to access.
• The process of applying for social housing, generally through choice-based lettings, is challenging, even where a person has advocates. The bidding process is difficult to understand and the competitive nature of it places significant pressure on people with learning disabilities.
• The choice-based letting system needs to be made much more accessible. Having a trusted and well-informed individual that supports someone through a move and maintaining their tenancy is essential.

Some of the evidence[117] provided to the Levelling Up, Housing and Communities Committee’s inquiries into the regulation of social housing, and into exempt accommodation, indicated that unsuitable allocations can have a detrimental effect. SHAC’s written evidence to the inquiry on the regulation of social housing suggests that support provided to disabled tenants experiencing ASB needs to be improved, with better use made of powers under the Anti-Social Behaviour, Crime and Policing Act 2014. West Midlands Police’s written evidence to the inquiry on exempt accommodation expressed concern about ‘concentrations of vulnerable persons, many with complex needs’ in ASB hotspot areas as it provides ‘opportunity for them to be exploited, to exploit others or for their vulnerabilities to be otherwise taken advantage of or exposed’.

A 2019 report^{[footnote 118]} from the All-Party Parliamentary Group (APPG) for housing and care for older people highlighted that older tenants in social housing are most likely to under-occupy and that this can create several problems with fuel poverty and maintenance cost.

Overcrowding is much more prevalent amongst those aged 16 to 34.^{[footnote 119]}

A 2021 publication^{[footnote 120]} from the House of Commons Library stated that older households who want to move may struggle to move to an accessible home due to a shortage of accessible and specialist housing for older people (for example, retirement housing, sheltered housing and housing with care) in both the private and social sectors.

Our requirements

Based on the evidence, tenants within the sector who may be positively impacted by these requirements share the protected characteristics age, race, and disability. We consider that PSED aim 2 is relevant to these requirements.

We are broadening the current requirement that providers take into account the housing needs and aspirations of tenants and potential tenants, to take into account the needs of tenants and prospective tenants. This may encourage registered providers to consider the wider needs of tenants and prospective tenants arising from their protected characteristics, or broader circumstances, in their allocations decisions, and therefore help to advance opportunities for some tenants who share one or more protected characteristics.

2.1.2 makes the need clear for providers to make best use of the limited stock of adapted and accessibly designed properties, which may improve opportunities for those who share protected characteristics of disability and age.

2.1.3 has been amended following the consultation, to require providers to develop and deliver services that seek to address under-occupation and overcrowding in their homes. We do not consider that this change is likely to have an impact on the outcomes for those sharing one or more protected characteristics.

2.1.5 requires that the appeals process must be fair, reasonable, simple, and accessible, and reiterates requirements that are elsewhere in the standards for landlord services to be accessible.

2.1.6 ensures the continued availability of data on social housing lettings which helps to increase information in the public domain about who is moving into social housing.  This is a fundamental element in ensuring equitable access and outcomes.

Overall assessment

Taking the above into account, we consider that these requirements may have a positive impact on tenants who share the protected characteristics age, race, and disability.

Tenancy: Tenure

Potential impact on different protected characteristics

There is insufficient evidence of any impact on protected groups.

Final wording

We not assessed required outcome 1.3.1 or any of the specific expectations as they reflect directions to us from government.

Required outcome

1.3.2 They shall meet all applicable statutory and legal requirements in relation to the form and use of tenancy agreements or terms of occupation.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

We did not find any evidence which is directly relevant to the requirement for registered providers to meet all applicable statutory and legal requirements in relation to the form and use of tenancy agreements or terms of occupation.

Our requirements

We considered whether this requirement may have a positive impact on tenants who share different protected characteristics. While all tenants may be positively impacted by this requirement, there is no evidence of any particular impact on tenants who share different protected characteristics.

Overall assessment

Taking the above into account, at this stage we have not identified any equality impacts relevant to this requirement.

Tenancy: Tenancy sustainment and evictions

Potential impact on different protected characteristics

• Age
• Disability
• Race
• Sex

There is insufficient evidence of any impact on the other protected groups.

Final wording

Required outcome

1.2.1 Registered providers must support tenants to maintain their tenancy or licence. Where a registered provider ends a tenancy or licence, they must offer affected tenants advice and assistance.

Specific expectations

2.2.1 Registered providers must provide services that support tenants to maintain their tenancy or licence and prevent unnecessary evictions.

2.2.2 Registered providers must provide tenants required to move with timely advice and assistance about housing options before the tenancy or licence ends.

Evidence of potential impact(s) and an assessment of our requirements and of the potential impact: positive, negative, or neutral

What the evidence tells us

Data from the English Housing Survey^{[footnote 121]} tells us that social renters tend to have lower incomes compared to the rest of the population. 47 per cent of social renters are in the lowest income quintile compared to 20 per cent of the entire population.

• The youngest and oldest social renters (those aged 16 to 24, and 75 and over) had the highest proportions in the lowest income quintile for their age (68 per cent and 62 per cent respectively).
• Those without dependent children are more likely than those with dependent children to be in the lowest income quintile (53 per cent and 35 per cent respectively).
• Social renters over 65 are less likely than other ages groups to be in rent arrears in the past 12 months. 16- to 24-year-olds were most likely to be in rent arrears in the last 12 months, followed by those aged 35-44.
• Lone parents in social housing with dependent children (32 per cent) were more likely to have been in rent arrears within the previous year than any other household type. This was followed by couples with dependent children (19 per cent).

The Inequality of Poverty report from the University of Bristol ^{[footnote 122]} also found significant differences in rates of poverty, which seem to align with certain protected characteristics:

• Some protected characteristics are associated with an increased risk of poverty in the UK: race, sex (in the case of single mothers), and disability. People from Bangladeshi and Pakistani ethnic minorities have the highest rates of poverty (at 23-26 per cent), followed by Indian, black Caribbean and black African groups (9-11 per cent), with the white majority having a rate of  6 per cent. Their findings indicate that younger workers are much more likely to be in poverty than other age groups. Intersectionality plays a large role; the more protected characteristics a person has, the more risk they bear. They also found a very strong relationship between poverty and disability.

The Race Equality Foundation’s work in its Housing Collaborative reported^{[footnote 123]} that:

• Across all tenures and groups, around 6 per cent of households responding to the Understanding Society survey^{[footnote 124]} were in arrears with their housing payments. Those born outside the UK were twice as likely to be in housing arrears. Single parents and other households with dependent children also twice as likely. Social housing tenants were two and a half times as likely to be in housing arrears. They identified inequality by ethnicity with a quarter of people with Bangladeshi ethnicity and a fifth of those with Pakistani or black African ethnicity being in housing arrears.
• This study also looked at those who had told the survey that they intended to move from their present accommodation. Of the total who said this, 4 per cent were moving because of the end of their tenancy or eviction. The report does not explain its results particularly clearly, but it does indicate that the numbers of lone parent with dependent children households who intended to move because of the end of their tenancy or eviction was disproportionately high, both in social housing and private rented housing. They also indicate that black Caribbean, Bangladeshi, white other and mixed ethnic groups were more likely to intend to move because of the end of tenancy or eviction.

Census 2021 data^{[footnote 125]}

• Social housing tenants have the second lowest employment rate behind owners who have bought their homes outright.

Our requirements

Our requirements on tenancy sustainment and evictions give greater emphasis on landlords supporting tenants to maintain their tenancy, as we are setting a required outcome on this issue. Being in arrears with rent is a means by which a tenant may face eviction and the evidence shows us that certain groups e.g. young people (age), people from certain ethnic minorities (race), lone parents (sex), and those with a disability are more likely to be in rent arrears within the social housing sector when compared to other groups who do not share those protected characteristics. By introducing these requirements, registered providers have to demonstrate how they support tenants in this area. Where tenants can access this additional support, this may reduce the disparities.

We are also being explicit that this requirement applies not only to tenancies, but to licences. These are commonly granted as the basis of occupation in a supported housing context, where licensees are more likely to share the protected characteristic of disability. Registered providers need to ensure that their approach to tenancy sustainment and evictions covers licensees as well as tenants.

The evidence indicates that tenants within the sector who may be positively impacted by this requirement are those who share protected characteristics of age, race, disability, and sex, as they are more likely to be in poverty and to fall into rent arrears, and so at higher risk of eviction. Other protected groups can also be vulnerable to eviction, such as families with support needs, young people leaving care, and single parents. Vulnerable individuals are also more likely to be housed in supported accommodation, including people fleeing abusive relationships, refugees and migrants, young care leavers and people experiencing mental health problems.

We consider that PSED aim 2, to advance equality of opportunity, is relevant to these requirements.

Overall assessment

Taking the above into account, we consider that these measures may have positive impacts on tenants who share the protected characteristics age, sex, race, and disability.

Tenancy: Mutual exchange

Potential impact on different protected characteristics

• Age
• Disability
• Race
• Sex

There is insufficient evidence of any impact on the other protected groups.

Final wording

Our assessment has been carried out on the required outcome and on specific expectation 2.2.4 as other specific expectations reflect where we have been directed by government.

Required outcome

1.4.1 Registered providers must support relevant tenants living in eligible housing to mutually exchange their homes.

Specific expectation

2.4.4. Registered providers must offer tenants seeking to mutually exchange  information about the implications for tenure, rent and service charges.

What the evidence tells us

• Shelter’s ‘Fobbed off’ report^{[footnote 126]} identifies that women face barriers when accessing advice and support with their housing including lack of knowledge of how the system works and poor treatment by professionals.
• Data from the EHS and OFCOM (see previous sections of this impact assessment) shows rates of home internet use reducing with age and being lowest generally amongst social housing tenants compared to other tenures.
• 2.7 per cent of social rented households have a HRP who has little/no proficiency in the English language^{[footnote 127]}.

Our requirements

We consider that PSED aims 1 and 2 (to eliminate unlawful conduct and to advance equality of opportunity) are relevant to these requirements.

The required outcome should help to ensure that all tenants are equally supported to mutually exchange their home by their landlord. Similarly, 2.4.4 should help to ensure that those who wish to exchange and are eligible can understand the full implications of it, allowing them to make an informed choice about what is best for them. Both changes may have a positive impact on female tenants, tenants who have communication difficulties, and those whose first language is not English.

Overall assessment

Taking the above into account, we consider that these requirements may have a positive impact on tenants who share the protected characteristics sex, age, disability, and race.

Part 4: Monitoring and review

We asked respondents to the consumer standards consultation whether they agreed with the conclusions in the draft EQIA.  89% of respondents agreed with our draft conclusions.

We have taken the opportunity to update this version with data published since the draft was put out to consultation, and have revised its content in the light of responses to the consultation and consequent changes we have made to the final versions of the consumer standards and Code of Practice.

We acknowledge that the general equality duty creates a continuing duty on us. We will therefore review the implementation of the revised consumer standards and their impacts on equality periodically.

---

1. Communities and Local Government Committee [5 February 2018]. Housing for older people. [Online] ↩

2. Department for Levelling Up, Housing & Communities. English Housing Survey, Social rented sector, 2021-22.  ↩

3. English Housing Survey 2021-2022, social rented sector, dwelling condition safety and energy. [online]. The English Housing Survey Headline Report 22-23 also shows that 10% of social rented homes in England are non-decent. ↩

4. Decent Homes Standard data from the period 2021-2022 was not gathered through physical inspection due to the Covid -19 pandemic – instead a predictive model was used to estimate Decent Homes Standard levels. ↩

5. Foundations. [March 2022] Housing associations and home adaptions: Finding ways to say yes. [Online] ↩

6. Levelling Up, Housing and Communities Committee. [13 July 2022] The Regulation of Social Housing. [Online] ↩

7. Department for Levelling Up, Housing & Communities. English Housing Survey, Social rented sector, dwelling condition safety and energy, 2021-22. ↩

8. APPG Housing and care for older people. [July 2019]. Rental housing for an ageing population. [Online] ↩

9. English Housing Survey (EHS) Headline Report 22-23 [Chapter 4: Dwelling condition] ↩

10. Department for Levelling Up, Housing & Communities. [15 December 2022]. English Housing Survey 2021 to 2022: headline report. [Online] The English Housing Survey Headline Report 22-23 also shows that 10% of social rented homes in England are non-decent. ↩

11. The Government’s Standard Assessment Procedure (SAP) is used to monitor the energy efficiency of homes. It is an index based on calculating annual space and water heating costs for a standard heating regime and is expressed on a scale of 1 (highly inefficient) to 100 (highly efficient, with 100 representing zero energy costs). ↩

12. Department for Levelling Up, Housing & Communities. [15 December 2022]. English Housing Survey 2021 to 2022: headline report. [Online] ↩

13. English Housing Survey 2012-2022, social rented sector, #dwelling condition safety and energy. [online] ↩

14. Decent Homes Standard data from this period was not gathered through physical inspection due to the Covid -19 pandemic – instead a predictive model was used to estimate Decent Homes Standard levels. ↩

15. English Housing Survey 2012-2022, social rented sector, #dwelling condition safety and energy [online] ↩

16. Marmot 2011 review of health impacts of cold homes and fuel poverty ↩

17. This category includes households renting from Local Authorities (including Arms’ Length Management Organisations (ALMOs) and Housing Action Trusts) and Housing Associations, Local Housing Companies, co-operatives, and charitable trusts. ↩

18. English Housing Survey 2012-2022, social rented sector, #dwelling condition safety and energy [online] ↩

19. English Housing Survey 2021-2022    ↩

20. Housing for Older People 2017-2019 CLG Inquiry ↩

21. English Housing Survey, 2020 to 2021: feeling safe from fire - GOV.UK (www.gov.uk) ↩

22. English Housing Survey: Housing quality and condition, 2020 (publishing.service.gov.uk) ↩

23. Government guidance on Housing for older and disabled people, 2019 ↩

24. English Housing Survey 2021-2022, social rented sector ↩

25. The Regulation of Social Housing – Written evidence – Committees – UK Parliament ↩

26. Government guidance on Housing for older and disabled people, 2019 ↩

27. Housing-Associations-and-Home-Adaptations-Finding-ways-to-say-yes.pdf (housinglin.org.uk) ↩

28. English Housing Survey 2021-2022, satisfaction and complaints ↩

29. https://www.ons.gov.uk/census ↩

30. EHS, Home Adaptations, 2019/20 ↩

31. National strategy for autistic children, young people and adults: 2021 to 2026 - GOV.UK (www.gov.uk) ↩

32. [Foundations (2022)]https://www.housinglin.org.uk/_assets/Resources/Housing/OtherOrganisation/Housing-Associations-and-Home-Adaptations-Finding-ways-to-say-yes.pdf) ↩

33. Care and Repair report 2021) ↩

34. Guidance for LAs on DFG delivery from DLUHC and DHSC (2022) ↩

35. Equality & Human Rights Commission ↩

36. DFG Guidance for LA, DLUHC/DHSC, 2022 ↩

37. Human City Institute Surveys (2013-17) of Weighted Data from 6,493 interviews with social tenants in England ↩

38. Human City Institute ↩

39. No Place Like Home ↩

40. akt lgbtq+ youth homelessness report ↩

41. Fobbed Off, Shelter, 2021 ↩

42. https://committees.parliament.uk/writtenevidence/41984/pdf/ ↩

43. The Regulation of Social Housing LUHC Committee inquiry report ↩

44. New social housing lettings - GOV.UK Ethnicity facts and figures (ethnicity-facts-figures.service.gov.uk) ↩

45. English Housing Survey: Social rented sector, 2020-21 (publishing.service.gov.uk) ↩

46. EHS Headline report 2021/22 ↩

47. Disability and housing, UK - Office for National Statistics (ons.gov.uk) ↩

48. English Housing Survey: Social rented sector, 2020-21 (publishing.service.gov.uk) ↩

49. Housing and disabled people: Britain’s hidden crisis EHRC ↩

50. https://www.ons.gov.uk/census ↩

51. EHS Headline report 2021/22 ↩

52. Fobbed Off, Shelter, 2021 ↩

53. EHS Headline report 2021/22 ↩

54. Adults’ Media Use and Attitudes report 2020/21 (ofcom.org.uk) ↩

55. akt LGBT+ Youth Homelessness Report ↩

56. No Place Like Home ↩

57. https://www.ons.gov.uk/census ↩

58. https://www.ons.gov.uk/census ↩

59. Engaging and empowering tenants in council-owned housing ↩

60.  English Housing Survey 2021 to 2022: social rented sector - GOV.UK (www.gov.uk) ↩

61. Supporting people with learning disabilities to rent their own place - Resource Library - Resources - Housing LIN ↩

62. CIH Practice Brief: Delivering housing services to lesbian, gay, bisexual and transgender customers ↩

63. Building inclusive housing support for lgbtq+ communities ↩

64. Inside Housing - Home - Paternalistic attitudes from social landlords can add to the stigmatisation of residents ↩

65. Throughout the consumer standards ‘shared spaces’ are those spaces used by tenants that are not the responsibility of the landlord, as opposed to communal areas where landlords have direct responsibilities for ensuring their safety and maintenance. ↩

66. https://www.ons.gov.uk/census ↩

67. https://www.ons.gov.uk/census ↩

68. https://www.ons.gov.uk/census ↩

69. Fobbed Off, Shelter, 2021 ↩

70. EHS Headline report 2021/22 ↩

71. Adult’s Media Use and Attitudes report 2020/21 (ofcom.org.uk) ↩

72. Public Sector Web Accessibility and the Impact on Users - NEC Software Solutions (necsws.com) ↩

73. EHS: Social rented sector, 2020-21 ↩

74. English Housing Survey 2021 to 2022: satisfaction and complaints - GOV.UK (www.gov.uk) ↩

75. EHS: Social rented sector, 2020-21 ↩

76. https://committees.parliament.uk/writtenevidence/41978/pdf/ ↩

77. Housing for older and disabled people - GOV.UK (www.gov.uk) ↩

78. https://www.ons.gov.uk/census ↩

79. Future of an aging population, Government Office for Science, ↩

80. Housing-Associations-and-Home-Adaptations ↩

81. https://committees.parliament.uk/writtenevidence/41938/pdf/ ↩ ↩²

82. Ethnic group, occupancy rating for bedrooms and tenure of household - Office for National Statistics (ons.gov.uk) ↩

83. People living in deprived neighbourhoods - GOV.UK Ethnicity facts and figures (ethnicity-facts-figures.service.gov.uk) ↩

84. The-Inequality-of-Poverty-Full-Report.pdf (fairbydesign.com) ↩

85. No Place Like Home ↩

86. 2022 UK Poverty report ↩

87. Outcomes for disabled people in the UK - Office for National Statistics (ons.gov.uk) ↩

88. Housing for older and disabled people - GOV.UK (www.gov.uk) ↩

89. Future of an aging population, Government Office for Science, ↩

90. Tackling violence against women and girls strategy - GOV.UK (www.gov.uk) ↩

91. Housing-Associations-and-Home-Adaptations ↩

92. Crime in England and Wales, 2020 ↩

93. Perceptions of personal safety and experiences of harassment, Mar 22 Great Britain - ONS ↩

94. SAFE Housing University of Surrey, 2017 ↩

95. Outcomes for disabled people in the UK - ONS ↩

96. Mental-Health-and-Anti-Social-Behaviour-London-Councils-2014.pdf (hampshiresab.org.uk) ↩

97. Generation blame: how age affects our views of anti-social behaviour University of Cambridge ↩

98. The charter for social housing residents: social housing white paper - GOV.UK (www.gov.uk) ↩

99. Domestic abuse victim characteristics, England and Wales - Office for National Statistics (ons.gov.uk) ↩

100. Domestic abuse prevalence and victim characteristics - Office for National Statistics (ons.gov.uk) ↩

101. Domestic Abuse in Black, Asian and Minority Ethnic Groups Interventions Alliance ↩

102. Safe Lives: Cry for health, 2016 ↩

103. The Domestic Abuse Report, 2022 ↩

104. Safe at Home Report.pdf (safelives.org.uk) ↩

105. Policy Equality Statement: demonstrating compliance with the Public Sector Equality Duty (PSED) (publishing.service.gov.uk) ↩

106. Disability and crime - Office for National Statistics (ons.gov.uk) ↩

107. Galop_domestic abuse.indd ↩

108. stonewall_and_nfp synergy_report ↩

109. Overcrowded households – GOV.UK Ethnicity facts and figures ↩

110. Ethnic group, occupancy rating for bedrooms and tenure of household - Office for National Statistics (ons.gov.uk) ↩

111. Renting social housing – GOV.UK Ethnicity facts and figures ↩

112. Ethnic group and tenure of household - Office for National Statistics (ons.gov.uk) ↩

113. People living in deprived neighbourhoods - GOV.UK Ethnicity facts and figures (ethnicity-facts-figures.service.gov.uk) ↩

114. HAPPI-5-Rental-Housing.pdf (housinglin.org.uk) ↩

115. English Housing Survey: Housing across the life course 2018-19 (publishing.service.gov.uk) ↩

116. Housing an ageing population: a reading list (parliament.uk) ↩

117. English Housing Survey 2021 to 2022: social rented sector - GOV.UK (www.gov.uk) ↩

118. The-Inequality-of-Poverty-Full-Report.pdf (fairbydesign.com) ↩

119. Layout 1 (raceequalityfoundation.org.uk) ↩

120. COVID-19 Understanding Society ↩

121. https://www.ons.gov.uk/census ↩

122. Fobbed Off, Shelter, 2021 ↩

123. https://www.ons.gov.uk/census ↩