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	January 2025
Governance	G1 Our judgement is that the landlord meets our governance requirements.	Assessed and unchanged	January 2025
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.	Assessed and unchanged	January 2025

Reason for publication

We are publishing a regulatory judgement for Sanctuary Housing Association (Sanctuary) following an inspection completed in January 2025.

This regulatory judgement confirms a consumer grading of C2, a governance grading of G1 and a financial viability grading of V2.

Prior to this regulatory judgement, the governance and financial viability grades for Sanctuary were last updated in October 2022 following a stability check which confirmed 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 it is our judgement that there are some weaknesses in Sanctuary’s delivery of the outcomes of the consumer standards and improvement is needed, specifically in relation to outcomes in our Safety and Quality Standard. Based on this assessment, we have concluded a C2 grade for Sanctuary.    

Our judgement is that Sanctuary meets our governance requirements. Sanctuary has provided evidence to demonstrate the effectiveness of its governance arrangements and that it continues to effectively manage the risks of its activities, allowing it to deliver its strategic and charitable objectives. Based on this assessment, we have concluded a G1 grade for Sanctuary.  

Our judgement is that Sanctuary meets our financial viability requirements and has the financial capacity to manage a reasonable range of adverse scenarios. Sanctuary has a number of financial risks that need to be managed including increased investment in its existing homes and developing homes for outright sale. Sanctuary has provided appropriate assurance it has access to sufficient liquidity and adequate funding in place. Based on this assessment, we have concluded a V2 grade for Sanctuary.

How we reached our judgement

We carried out an inspection of Sanctuary to assess how well it is delivering the outcomes of the consumer standards and meeting our governance and financial viability standards, as part of our regulatory inspection programme. During our 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 our inspection we observed a board meeting and Sanctuary’s tenant scrutiny and advisory panels, spoke to tenants, held meetings with Sanctuary, including non-executive directors, and reviewed a wide range of documents provided by Sanctuary. Our regulatory judgement is based on a review of all the relevant information we obtained during the inspection as well as analysis of data received through its regulatory returns and other regulatory engagement activity.

Summary of findings 

Consumer – C2 – January 2025 

During the inspection, Sanctuary provided evidence-based assurance that it has appropriate systems for ensuring the health and safety of its tenants in their homes and communal areas. Sanctuary also demonstrated that it understands the condition of its homes and that this informs its provision of good quality, well maintained and safe homes for tenants. This includes ensuring its homes meet the Decent Homes Standard.

However, weaknesses were identified in the provision of an effective, efficient and timely repairs and maintenance service, and improvements are needed to deliver the outcomes of the Safety and Quality Standard. This was seen through tenant satisfaction levels, performance information and complaints. In particular, there is more work to do so that Sanctuary can meet its own repairs timescales for non-urgent works while responding effectively to tenant vulnerabilities. While Sanctuary has already initiated improvements, including a new IT system and operating model, it is too early to see the required outcomes being delivered for tenants. We will continue to engage with Sanctuary while it is working to improve its repairs service.

Sanctuary provided assurance that it is delivering the outcomes of the Neighbourhood and Community Standard, including through its partnership working with other organisations to deter and tackle anti-social behaviour and hate incidents and promote wellbeing. We also saw evidence that it is allocating and letting its homes in a fair and transparent way and supporting its tenants to maintain their tenancy.

In relation to the Transparency, Influence and Accountability Standard, we gained assurance that Sanctuary was delivering the required outcomes. The tenant voice was evident through its strategies, policies, and decision making, with meaningful opportunities for tenants to influence and scrutinise services. This was demonstrated through both central and regional engagement structures in line with Sanctuary’s size and geographical spread.

We saw evidence that Sanctuary uses the information and data it holds, about the diverse needs of its tenants, to assess whether housing and landlord services deliver equitable outcomes, that is underpinned by its outcomes-focussed reporting framework. Sanctuary also provides tenants with accessible information about its performance and services.

Recent work by Sanctuary to improve its complaint handling service has resulted in improved performance with an increase in complaints being handled within the required timescales. Alongside an ongoing focus on quality, we saw evidence that Sanctuary addresses complaints fairly, effectively, and promptly.

Governance – G1 – January 2025

Sanctuary has provided assurance that its governance arrangements are effective in delivering its strategic objectives, social purpose and value for money. It has demonstrated that its actions are consistent with its code of governance and its legal and regulatory obligations, seeking external advice as appropriate. It has provided evidence that it has an effective business planning, risk management and control framework, with a good understanding of its risk profile and mitigations. We also saw evidence that Sanctuary is effectively managing the integration of the social housing providers that came into the group in 2023 and 2024.

Sanctuary’s stress testing meets the requirements of the Governance and Financial Viability Standard and demonstrates that it has the financial capacity to withstand a reasonable range of adverse scenarios. Mitigating actions are credible, developed and understood and the board is fully engaged in Sanctuary’s stress testing and mitigation planning.

Sanctuary has a skilled and independent group board, that actively seeks assurance in relation to group activities and financial viability, and effectively scrutinises its performance. It is supported by an appropriate committee structure, providing further oversight in relation to the delivery of outcomes for tenants under our consumer standards. We have assurance that Sanctuary’s governance arrangements are suitable to deliver the improvements required in line with its C2 grade in a transparent and accountable manner. The board annually reviews its own effectiveness and performance with regular external reviews of its governance arrangements, most recently in September 2022. In line with the organisation’s risks and activities, Sanctuary has addressed potential gaps in board member skills and experience through its succession planning.

Viability – V2 – January 2025

Based on the evidence gained from this inspection, we have concluded that there is appropriate assurance that Sanctuary’s financial plans are consistent with, and support its financial strategy. Sanctuary has access to sufficient liquidity, an adequately funded business plan and is forecasting to continue to meet its financial covenants. Performance against golden rules and covenants is closely monitored and regularly reported to board.

Sanctuary continues to meet our viability requirements. Sanctuary’s financial plan is based on the delivery of its strategy, which involves disposing of assets that are not central to its purpose. Transformation and integration programmes are in place to generate efficiency savings following the addition of social housing providers into the group in 2023 and 2024. Sanctuary is also increasing investment into its existing homes including fire remediation, this further reduces its financial capacity.

Sanctuary continues to develop new homes, including those for outright sale which exposes it to housing market risk. We have assurance that Sanctuary has reporting and oversight to manage its risks and that its stress testing shows that there is financial capacity in the business plan to mitigate a reasonable range of adverse scenarios.

Background to the judgement

About the landlord

Sanctuary is a charitable community benefit society. It is the asset-owning parent of a group with 47 subsidiaries and five joint ventures. The group’s main activities relate to the provision of housing for social and affordable rent, affordable home ownership and housing for older people. It provides a range of care services, including domiciliary and extra care, supported and retirement living.

There are three other registered providers in the group, Sanctuary Affordable Housing Limited (SAH) delivers the development and management of affordable homes in England. ‘Johnnie’ Johnson Housing Trust Limited (JJHT) and Swan Housing Association Limited. JJHT plans to transfer its engagements into Sanctuary Housing Association by 31st January 2025.

Sanctuary has 47 unregistered subsidiaries established to support the group’s objectives. A number of entities are progressing to dissolution/liquidation once all legal processes are complete. Its core remaining subsidiaries cover treasury, development, operational and care activities. The most significant of these include:

• Sanctuary Scotland Housing Association Limited a Registered Social Landlord operating in Scotland;

• Sanctuary Treasury Limited, Sanctuary Capital PLC and Swan Housing Capital PLC;

• Beech Grove Homes Limited a development vehicle for outright sale; and

• Sanctuary Care Limited and Sanctuary Care (North) Limited.

The group also has an interest in five jointly controlled entities through development partnerships.

Sanctuary operates nationally across England and Scotland. It owns and manages around 85,000 social housing homes in England across 237 local authorities.

The group employs the full-time equivalent of 11,090 staff. Its turnover for the year ended 31 March 2024 was £1,085m.

Sanctuary’s development programme is focussed on its strategic partnership agreements to deliver around 1000 new affordable homes over the next three years. It is also developing around 400 homes for outright sale.

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

Related documents

• Decent Homes Standard