Decision

Moat Homes Limited (L0386) - Regulatory Judgement: 18 December 2024

Updated 18 December 2024

Applies to England

Our Judgement

	Grade/Judgement	Change	Date of assessment
Consumer	C2 Our judgement is that there are some weaknesses in the landlord delivering the outcomes of the consumer standards and improvement is needed.	First grading	December 2024
Governance	G2 Our judgement is that the landlord meets our governance requirements but needs to improve some aspects of its governance arrangements to support continued compliance.	Downgrade	December 2024
Viability	V2 Our judgement is that the landlord meets our viability requirements. It has the financial capacity to deal with a reasonable range of adverse scenarios but needs to manage material risks to ensure continued compliance.	Regrade	December 2024

Reason for publication

We are publishing a regulatory judgement for Moat Homes Limited (Moat) following an inspection completed in December 2024.

This regulatory judgement confirms a consumer grading of C2, a governance downgrade to G2 and a financial viability regrade to V2.

Prior to this regulatory judgement, the governance and financial viability grades for Moat were last updated in December 2023 following a stability check, to confirm grades of G1 and V1. 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 it is our judgement that there are some weaknesses in how Moat is delivering the outcomes of the consumer standards and improvement is needed. This is in relation to outcomes in the Safety and Quality Standard and the Transparency, Influence and Accountability Standard. Based on this assessment, we have concluded a C2 grade for Moat.

Our judgement is that Moat meets our governance requirements but needs to improve some aspects of governance arrangements to support continued compliance, specifically in relation to the effectiveness of risk management and the performance framework. Based on this assessment, we have concluded a G2 grade for Moat.

Our judgement is that Moat meets our financial viability requirements and has the financial capacity to deal with a reasonable range of adverse scenarios but needs to manage material risks to ensure continued compliance. Moat’s financial profile reflects the investment it is making in tenants’ homes alongside the development and sale of new homes. Moat has provided appropriate assurance that it has access to sufficient liquidity and has adequate funding in place. Based on this assessment, we have concluded a V2 grade for Moat.

How we reached our judgement

We carried out an inspection of Moat to assess how well Moat 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 a tenant scrutiny panel, spoke to tenants, held meetings with Moat including with its management and non-executive directors and reviewed a wide range of documents provided by Moat.

Our regulatory judgement is based on all the relevant information we obtained during the inspection as well as analysis of information supplied by Moat through its regulatory returns and other regulatory engagement activity.  

Summary of findings 

Consumer – C2 – December 2024 

During the inspection, Moat provided evidence-based assurance that it has appropriate systems in place to ensure the health and safety of its tenants in their homes and associated communal areas. Moat has provided appropriate assurance that it has a good understanding of its compliance with landlord health and safety requirements and that it is delivering the actions arising from legally required health and safety assessments. This includes using external assurance reviews of its processes to assess the accuracy of its data around its health and safety performance.

There is evidence that Moat keeps an accurate record of the condition of its homes at an individual property level through physical surveys of all homes and has a process for keeping this information up to date. Moat has demonstrated that it uses its understanding of the quality and safety of its tenants’ homes to make decisions on future investment to maintain and improve homes.   

We found evidence of some weaknesses in the provision of the repairs and maintenance service to Moat’s tenants, particularly for non-emergency repairs, including those related to remediation of damp, mould and condensation.

Performance information, in combination with feedback and complaints from tenants, demonstrated that improvement is needed for Moat to evidence an effective, efficient and timely repairs and maintenance service. Moat continues to take steps to manage its repairs performance with plans for new arrangements to make the improvements required. These plans are regularly shared with its tenants. Improvement will take time and through our ongoing engagement we will continue to seek assurance from Moat that progress is being made so that outcomes for tenants improve.

Moat has demonstrated that it has an established policy to work in partnership with appropriate partners to deter and tackle anti-social behaviour and hate incidents in the neighbourhoods where it provides homes. However, Moat recognises its approach to anti-social behaviour, whilst clearly set out in policy, continues to require improvement given the low levels of tenant satisfaction and limited evidence of the effectiveness of partnership working arrangements. Its approach to maintenance of shared spaces is comprehensive and meets the expectations of the standard.

In relation to the Tenancy Standard, our inspection found evidence that Moat’s approach to lettings and allocations is transparent, that measures are in place to ensure terms of tenancy are appropriate and meet the needs of tenants. There are a range of measures in place to support tenancy sustainment including successfully helping tenants to access financial support.

We gained assurance that Moat treats its tenants with fairness and respect. Moat is working to improve the information it holds about the diverse needs of its tenants to better adapt and tailor its services to their individual needs, to ensure its housing and landlord services deliver equitable outcomes for tenants.

Moat has evidenced that it listens to tenants views and provides meaningful opportunities for tenants to scrutinise landlord services, through its customer advocate structure. It is seeking to improve the effectiveness of its approach through implementing a tenant led scrutiny group with direct links to the governance structure. The service and performance information made available to tenants is accessible and we saw evidence of tenants using this information to scrutinise services through its tenant repair scrutiny group.

Moat has recognised it needs to make improvements to its complaints service to evidence that complaints are handled fairly, effectively and promptly and that it uses this information to help drive service improvement and outcomes for tenants. There are high volumes of complaints, in part due to the issues with its repairs service and Moat is taking steps to improve the quality and timeliness of responses to its tenants.  

Governance – G2 – December 2024

Based on the evidence gained from the inspection, there is assurance that Moat’s governance arrangements are meeting the requirements of the Governance and Financial Viability Standard. However, we have concluded that it needs to improve aspects of its governance arrangements to support continued compliance with the standard.

Moat has demonstrated that there is an appropriate risk management and control framework that aligns to its strategic risks. However, it needs to improve the effectiveness of this framework in practice, to deliver improvements in outcomes to tenants. Whilst Moat’s board actively seeks and gains an appropriate level of assurance across a range of areas, there are weaknesses in its use of this information to drive improvement. It does not consistently apply lessons learnt across the organisation or identify where there are trends in the weaknesses of internal controls. Moat is currently in the process of making improvements to its assets and liabilities register to increase the effectiveness of its use in the board’s decision making. Alongside this Moat has undergone significant change within its leadership team in recent years, which has impacted the pace of improvements.

Moat’s board demonstrated that it considers its risk appetite in strategic decision making. However, there are weaknesses in the effectiveness of the performance framework. This has impacted on the board’s ability to provide effective challenge on performance against the organisation’s strategic targets.

Moat’s board has demonstrated that there is regular and appropriate consideration of alternative options to deliver value for money and make best use of resources. During the inspection Moat has demonstrated that it reconsiders its corporate structure according to changes in its strategy, including how it contributes to delivery of its purpose and objectives. This is reflected in successful outcomes such as development performance.

Moat was able to provide evidence that it has established clear roles, responsibilities and accountabilities within its leadership and governance structure. The relationship between its board and committees is working in line with its delegations to strengthen assurance in key areas of risk and compliance. 

Continuing governance improvement is evidenced through annual effectiveness reviews and in depth periodic external governance reviews. The most recent external review took place in July 2023, and we saw evidence that its recommendations had been implemented. There is a structured approach to developing and appraising skills, experience and knowledge of board members to support succession planning. At the time of the inspection, it had been identified that work was needed to understand what gaps might arise from planned departures and the board was updating its succession plan.

Board ownership of stress testing and mitigation strategies is evidenced and is used to inform decisions, supplementing the wider control framework. Reporting to board provides sufficient detail for the board to ensure effective oversight.

Viability – V2 – December 2024

Based on the evidence gained through the inspection we have concluded that there is appropriate assurance that Moat’s financial plans are consistent with and support its financial strategy. Moat has appropriately evidenced that it has an adequately funded business plan and sufficient security in place to support its financial plans.

Moat is investing in its existing homes to improve their quality and energy efficiency, alongside investing in improvements to its repairs service. In addition to this, Moat continues to develop new homes funded largely by new debt, which exposes it to sales and interest rate risk. This will mean that Moat has the capacity to respond to a reasonable range of adverse scenarios, but it will need to manage these material risks. We have assurance that Moat has reporting and oversight in place to manage these risks.

Background to the judgement

About the landlord

Moat is an exempt charity registered under the Co-operative and Community Benefit Societies Act 2014. Moat is the parent to Moat Homes Finance plc the treasury vehicle for the group, Moat Housing Group Limited is a registered provider operating as a non-charitable community benefit society, and the dormant Moat Construction Services Limited. Moat Development Limited and Mariner Facilities Management Limited are dormant subsidiaries of Moat Housing Group Limited.

Moat operates across the South East and East of England, including London and owns 19,199 homes.

Moat generated a turnover of £154m in the year ended 31 March 2024 and employed 456 full-time equivalent staff.

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.

Further information

• Regulating the standards

• Regulatory standards for landlords