Cross Keys Homes Limited (LH4428) - Regulatory Judgement: 26 March 2025
Updated 26 March 2025
Applies to England
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Our Judgement
| Grade/Judgement | Change | Date of assessment | |
|---|---|---|---|
| Consumer | C1 Our judgement is that overall the landlord is delivering the outcomes of the consumer standards. The landlord has demonstrated that it identifies when issues occur and puts plans in place to remedy and minimise recurrence. |
First grading | March 2025 |
| Governance | G1 Our judgement is that the landlord meets our governance requirements. |
Assessed and unchanged | March 2025 |
| Viability | V1 Our judgement is that the landlord meets our viability requirements and has the financial capacity to deal with a wide range of adverse scenarios. |
Regrade | March 2025 |
Reason for publication
We are publishing a regulatory judgement for Cross Keys Homes Limited (Cross Keys) following an inspection completed in March 2025.
This regulatory judgement confirms a consumer grading of C1, a governance grading of G1 and financial viability regrade to V1.
Prior to this regulatory judgement, the governance and financial viability grades for Cross Keys were last updated in December 2023 following a stability check, to confirm grades of G1 and V2. This is the first time we have issued a consumer grade in relation to this landlord.
Summary of the decision
From the evidence and assurance gained during the inspection, we have concluded that overall Cross Keys is delivering the outcomes of the consumer standards. Based on this assessment, we have concluded a C1 grade for Cross Keys.
Our judgement is that Cross Keys meets our governance requirements. The board and leadership team have the skills and capacity to deliver Cross Keys’ strategic objectives, with effective risk management, and performance and reporting frameworks in place to support this. Based on this assessment, we have concluded a G1 grade for Cross Keys.
Our judgement is that Cross Keys meets our financial viability requirements and has the financial capacity to deal with a wide range of adverse scenarios. Cross Keys has a strong financial profile and its stress testing demonstrates that financial capacity is built into its business plan. Cross Keys has provided adequate assurance that it has access to sufficient liquidity and has adequate funding in place. Based on this assessment, we have concluded a V1 regrade for Cross Keys.
How we reached our judgement
We carried out an inspection of Cross Keys to assess how well it is delivering the outcomes of the consumer standards and meeting our governance and financial viability requirements, as part of our planned regulatory inspection programme. During the inspection, we considered all four of the consumer standards: Neighbourhood and Community Standard, Safety and Quality Standard, Tenancy Standard, and the Transparency, Influence and Accountability Standard.
During the inspection we observed a board meeting and tenant scrutiny panel, spoke to tenants, held meetings with Cross Keys and its non-executive directors, and reviewed a wide range of documents provided by Cross Keys.
Our regulatory judgement is based on all the relevant information we obtained during the inspection as well as analysis of information received from Cross Keys through its regulatory returns and other regulatory engagement activity.
Summary of findings
Consumer – C1 – March 2025
During the inspection, Cross Keys provided evidence-based assurance that it has appropriate systems in place for ensuring the health and safety of tenants in their homes and associated communal areas. Cross Keys provided appropriate assurance that it has a good understanding of its compliance with its landlord health and safety requirements. Cross Keys has sought adequate assurance over these processes and data as part of the board’s commitment to take all reasonable steps to ensure the health and safety of tenants.
We saw evidence that Cross Keys keeps an accurate and up to date record of the condition of its homes through physical surveys and has a process for keeping this information up to date. Cross Keys uses its understanding of the quality and safety of its tenants’ homes to make decisions on future investment to maintain and improve homes, such as improvements to its approach in resolving cases of damp and mould.
Cross Keys provides an effective, efficient and timely repairs, maintenance and planned improvements service to tenants and continues to implement actions to improve the service and outcomes to tenants. We saw evidence that customers are satisfied with the repairs service contracted by Cross Keys. We reviewed evidence that gave us assurance that Cross Keys’ approach to repairs is informed by the needs of its tenants, and that it makes use of tenants’ information that it holds to tailor its services appropriately.
Cross Keys’ board and tenants receive reporting on complaints handling performance and insight, and we saw evidence that this performance data is used by Cross Keys to improve its services.
In meeting the Neighbourhood and Community Standard, Cross Keys has demonstrated that it works in partnership with relevant organisations to deter and tackle ASB in the neighbourhoods where it provides social housing. We saw evidence that Cross Keys has learnt from resident feedback and previous outcomes to shape how anti-social behaviour services are delivered. We saw that Cross Keys has a range of community partnerships and initiatives that promote the social, environmental and economic wellbeing in the neighbourhoods and communities that it serves.
Overall, Cross Keys’ approach is delivering the outcomes of the consumer standards in relation to transparency, influence and accountability. Cross Keys provides a wide range of opportunities for tenants to influence and scrutinise its strategies, policies and services. Cross Keys has arrangements in place to seek the views of tenants, which have directly influenced how Cross Keys delivers services to improve outcomes for tenants.
Tenant engagement is well structured and supported. Cross Keys acknowledges the need to continue to focus on its communication with tenants and to capture the views from a range of tenants, with strategies developed to deliver in these areas.
Governance – G1 – March 2025
Based on the evidence gained from the inspection, there is assurance that Cross Keys’ governance arrangements enable it to effectively manage its risks and adequately control the organisation, allowing it to deliver its objectives. We saw evidence of board challenge on performance regarding Cross Keys’ strategic objectives, and robust consideration of risks in its decision making.
Cross Keys provided evidence that there is a regular robust review of its approach to making best use of resources to deliver against the organisation’s purpose. This includes Cross Keys’ board regularly undertaking an appraisal of alternative options to ensure strategic value for money.
Cross Keys provided appropriate assurance that it has established and maintains clear roles, responsibilities and accountabilities within its leadership and governance structure. There is evidence that the relationship between its board and committees is working in line with its delegations to strengthen assurance in key areas of risk and compliance, and its risk management and control framework is aligned to its strategic risks.
Continuing governance improvement is evidenced through annual effectiveness reviews and in-depth periodic external governance reviews. The most recent
external governance review took place in October 2021 and Cross Keys has implemented its recommendations. The next external review is due to commence at the start of the 2025/26 financial year.
Board members’ skills, experience and knowledge are aligned with the activities of the organisation and there is a structured approach to developing and appraising skills that feed into succession planning. We saw evidence of this through board observation, meetings with non-executive directors and executive team members as well as reviewing relevant documents including meeting minutes.
We saw evidence that Cross Keys carries out detailed and robust stress testing against identified risks and combinations of risks, across a range of scenarios with appropriate mitigation strategies in place as a result.
Viability – V1 – March 2025
In November 2022 following a stability check and responsive engagement, we published a regulatory judgement that regraded Cross Keys’ viability grade to V2. At that time Cross Keys was investing in its existing homes and had a committed programme of development and a reliance on sales income exposing it to market risk. Coupled with economic uncertainty in relation to inflation and interest rates, this reduced the capacity within Cross Keys’ business plan and reduced capacity to respond to adverse events.
Based on the evidence gained through the inspection, we have concluded that there is appropriate assurance that Cross Keys’ financial plans are consistent with, and support, its financial strategy. Cross Keys has evidenced that it has an adequately funded business plan, sufficient security in place to support its financial plans, and forecasts that it will continue to meet its financial covenants under a wide range of adverse scenarios.
We have assurance that Cross Keys’ board has a good oversight of covenant compliance and there is evidence of strong levels of forecast headroom with no reliance on sales income. Cross Keys forecasts strong interest cover while continuing to deliver its development programme and invest in existing stock to meet both stock quality and de-carbonisation objectives.
Background to the judgement
About the landlord
Cross Keys is an exempt, charitable community benefit society, owning and managing 12,486 homes across 12 local authority areas.
Cross Keys is the only RSH registered entity in its group, and directly owns almost all the housing stock and other assets. It is a non-profit registered provider of social housing and has four unregistered subsidiaries in the group:
- CKH Developments Limited;
- Cambridgeshire Housing Capital Plc;
- Cross Keys Property Limited; and
- Cambridgeshire Homes LLP.
At 31 March 2024, Cross Keys employed 313 full-time equivalent staff. Cross Keys’ turnover for the year ended 31 March 2024 was £90.5m. Cross Keys developed 244 new homes during the 2023/24 financial year and plans to develop around 1,000 homes between 2024/27, with around 660 being general needs homes and 340 low-cost home ownership.
Our role and regulatory approach
We regulate for a viable, efficient, and well governed social housing sector able to deliver quality homes and services for current and future tenants.
We regulate at the landlord level to drive improvement in how landlords operate. By landlord we mean a registered provider of social housing. These can either be local authorities, or private registered providers (other organisations registered with us such as non-profit housing associations, co-operatives, or profit-making organisations).
We set standards which state outcomes that landlords must deliver. The outcomes of our standards include both the required outcomes and specific expectations we set. Where we find there are significant failures in landlords which we consider to be material to the landlord’s delivery of those outcomes, we hold them to account. Ultimately this provides protection for tenants’ homes and services and achieves better outcomes for current and future tenants. It also contributes to a sustainable sector which can attract strong investment.
We have a different role for regulating local authorities than for other landlords. This is because we have a narrower role for local authorities and the Governance and Financial Viability Standard, and Value for Money Standard do not apply. Further detail on which standards apply to different landlords can be found on our standards page.
We assess the performance of landlords through inspections and by reviewing data that landlords are required to submit to us. In Depth Assessments (IDAs) were one of our previous assessment processes, which are now replaced by our new inspections programme from 1 April 2024. We also respond where there is an issue or a potential issue that may be material to a landlord’s delivery of the outcomes of our standards. We publish regulatory judgements that describe our view of landlords’ performance with our standards. We also publish grades for landlords with more than 1,000 social housing homes.
The Housing Ombudsman deals with individual complaints. When individual complaints are referred to us, we investigate if we consider that the issue may be material to a landlord’s delivery of the outcomes of our standards.
For more information about our approach to regulation, please see Regulating the standards.