Decision

Together Housing Group Limited (L4464) - Regulatory Judgement: 26 March 2025

Updated 26 March 2025

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

Reason for publication

We are publishing a regulatory judgement for Together Housing Group Limited (THG) following an inspection completed in March 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 gradings for THG were last updated in November 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, our judgement is that there are some weaknesses in THG’s delivery of the outcomes of the consumer standards and improvement is needed specifically in relation to the outcomes in our Safety and Quality Standard. Based on this assessment, we have concluded a C2 grade for THG.

Our judgement is that THG meets our governance requirements. The board and leadership team have the skills and capacity to deliver THG’s charitable and strategic objectives. It manages the risks associated with its activities and has performance reporting frameworks in place. Based on this assessment, we have concluded a G1 grade for THG.

Our judgement is that THG meets our financial viability requirements, has access to sufficient liquidity, and continues to forecast covenant compliance with reasonable headroom. Additional investment in its private finance initiative (PFI) subsidiary has weakened THG’s financial performance. Forecast financial performance remains weak due to investment in its existing homes, which includes fire safety works and energy efficiency improvements, while continuing to develop new homes. THG has the financial capacity to deal with a reasonable range of adverse scenarios. Based on this assessment, we have concluded a V2 grade for THG.

How we reached our judgement

We carried out an inspection of THG to assess how well it is delivering the outcomes of the consumer standards and meeting our governance and viability standards, 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, held meetings with THG including with its non-executive directors, observed the Customer Voice Group and a scrutiny meeting, and spoke with THG’s tenants involved in scrutiny and wider engagement activities. We also reviewed a wide range of documents provided by THG.

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

Summary of findings 

Consumer – C2 – March 2025 

During the inspection, THG 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. THG demonstrated that it has a good understanding of its compliance position with landlord health and safety requirements. Its performance information demonstrated a good level of reported compliance with legal obligations.

THG seeks an accurate and up to date record of the condition of its homes through a range of physical stock condition surveys and has a process for keeping this information up to date. However, at the time of our inspection, there had not been sufficient progress in delivering its programme of surveys. THG uses the information it has to understand the quality and safety of tenants’ homes, and to make decisions on future investment to maintain and improve homes. We will continue to engage with THG while it delivers the actions required to complete the gaps in its understanding of the condition of its homes.

While THG has a good understanding of its compliance with landlord health and safety requirements, and reporting on health and safety compliance has not identified any areas of significant underperformance, we identified areas for improvement regarding the level of detail provided on reporting remedial actions. In our judgement this does not impact the effectiveness of the board’s oversight of risks.

THG has evidenced that it provides an effective and timely repairs service to tenants and continues to implement actions to improve the service and outcomes to tenants, including to address issues in relation to the damp, mould and condensation service.

In relation to the Neighbourhood and Community Standard, THG demonstrated that it is working in partnership with relevant organisations to deter and tackle anti-social behaviour and hate incidents in the neighbourhoods where it provides social housing.

We gained assurance that, in line with the Tenancy Standard, THG has arrangements in place to ensure properties are let in a fair and transparent way, working with appropriate third parties to allocate homes according to individual need. We saw evidence of THG ensuring tenants are supported in sustaining their homes, including successfully helping tenants to access financial support.

In relation to the Transparency, Influence and Accountability Standard, we saw evidence that THG’s complaint process is simple, accessible and publicised to tenants, and that complaints are addressed fairly, effectively, and in most cases promptly. THG’s board and all tenants receive reporting on complaints handling performance and insight, and there is evidence that this is used by THG to improve its services. We saw evidence that when tenant complaints are received, THG considers them and makes service improvements in response.

THG provides a wide range of opportunities for tenants to influence and scrutinise its strategies, policies and services. We saw evidence that THG has arrangements in place to seek the views of tenants and enables them to provide scrutiny. This has directly influenced how THG delivers services to improve outcomes for tenants.

There are clear arrangements in place through which THG hears from its tenants and there is evidence of a wide range of meaningful engagement activities available to tenants. There are opportunities for tenants to be involved in short and long-term projects, and more structured arrangements including opportunities to influence as part of THG’s governance structure. We also saw evidence that tenant scrutiny and feedback has directly and positively impacted service delivery.

THG has provided appropriate evidence that it is making effective use of its performance and insight information. It provides a range of information to tenants through a range of channels and the information is used to support effective scrutiny, using neighbourhood and property level data.

Governance – G1 – March 2025

Based on the evidence gained from the inspection there is assurance that THG’s governance arrangements enable it to effectively manage risk and adequately control the organisation, allowing it to deliver its objectives.

THG’s board has a clearly articulated corporate plan, business plan and associated strategies. These are subject to regular review internally and by tenants, and where appropriate THG draws on third-party expertise. Arrangements are in place for reporting on its strategic delivery, oversight of its financial risks, and building safety, and we have evidence that the board applies relevant scrutiny and oversight. An appropriate risk management and control framework aligned with the activities of the organisation is in place. THG’s board actively seeks and gains appropriate levels of assurance across a range of areas. We saw evidence of board challenge on performance against their strategic objectives and consideration of risks in its decision making.

Board ownership of stress testing, mitigation strategies and wider governance of risks through review of golden rules is evident. Stress testing demonstrates that THG can manage a reasonable range of risks should they arise. Reporting to board on stress testing and mitigation strategies provides sufficient detail for board to ensure oversight.

We identified some areas of improvement relating to board reporting, but we do not consider these to impact on the grading decision, as we saw evidence that existing reporting provides effective board oversight of key risks.

THG provided appropriate assurance that it has established and maintains clear roles, responsibilities and accountabilities within its leadership and governance structure, including well established roles for tenants. There is evidence that the relationship between the board and committees is working in line with its delegations to strengthen assurance in key areas of risk and compliance, with some areas to focus on as part of its programme of continuous improvement. The most recent external review of THG’s governance took place in June 2024.

Board members’ skills, experience and knowledge are aligned with the activities of the organisation and there is a structured approach to effectiveness reviews and the development and appraisal of skills, which also feed into succession planning. We have seen evidence of this through board observation, meetings with non-executive directors, and executive team members, as well as reviewing relevant documents including meeting minutes.

An area of improvement identified during the inspection was data integrity. We sought assurance on THG’s approach to this at all stages of the inspection process, which demonstrated that THG was aware of, and taking action to address the matters identified.

Viability – V2 – March 2025

Based on the evidence gained through the inspection there is appropriate assurance that THG’s financial plans are consistent with, and support, its financial strategy. THG has appropriately evidenced that it has an adequately funded business plan and has access to sufficient liquidity and security in place to support its financial plans. THG is forecast to continue to meet its financial covenants under a reasonable range of financial scenarios. We saw evidence that THG has appropriate controls and monitors performance against its covenants, which are forecast with reasonable headroom, and the board has effective oversight of covenant compliance.

THG continues to meet our viability requirements and has financial capacity to deal with a range of adverse scenarios. Its recent financial performance indicates a sustainable financial position in a period of economic uncertainty. However, in the short term this has been weakened by the levels of investment in its private finance initiative (PFI) scheme which have impacted on THG’s on-lending. THG is also continuing to invest in its existing homes, which includes fire safety works and energy efficiency improvements, while continuing to develop new homes. This will need to be managed and is something we will continue to engage with THG on as it delivers its financial plans. We have assurance that THG has reporting and oversight in place to manage the risks associated with this.

Background to the judgement

About the landlord

THG is a charitable community benefit society and non-stockholding parent of the group.

THG is the registered parent of the group, which includes RSH registered Together Housing Association Limited and non-registered entities including Together Commercial Limited, Newground Together and Together Housing Finance PLC. The group is eleven years into a thirty-year refurbishment led PFI agreement with Salford City Council.

THG operates across 33 local authority areas across the north of England, mainly in Lancashire and West Yorkshire, and owns around 38,000 homes.

At 31 March 2024, the group employed over 1,400 full-time equivalent staff. Group turnover for the year ended 31 March 2024 was £242m.

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