Foreword: Rules That Protect Tenants
Housing
associations manage resources raised through rents, public grants, borrowing
and other sources to maintain homes and provide services. Decisions about how
that money is used affect repairs, safety work, investment and the ability to
service debt, so clear financial controls matter. Governance codes set
expectations for board oversight, while financial regulations and internal
policies put them into practice by defining who may approve spending, how
suppliers are selected, how conflicts are managed and what records must be kept
for scrutiny.
Procurement is
where those rules meet the outside world. Clear approvals and competitive
processes help ensure repairs, maintenance, and building-safety work are
properly specified, fairly priced, and delivered by capable contractors.
Contract monitoring can expose problems early, before a failing supplier leaves
damp unrepaired or a fire door unfitted. Without that discipline, avoidable
cost, delay and unreliable work become far more likely, and tenants are usually
the first to notice.
Good
governance also gives directors dependable information about risk, spending and
service quality, allowing them to test whether problems are being fixed and
whether resources will stretch to meet long-term commitments. The central
question is what happens when these safeguards are ignored, weakened or quietly
bypassed. The answer, drawn from regulatory judgements, parliamentary inquiries
and published payment data across the United Kingdom (UK), is rarely one
dramatic failure but an accumulation of smaller ones.
These
observations draw on the author’s more than ten years’ experience in social
housing and on governance and procurement behaviours encountered during that
work. They are professional observations, not findings from a representative
survey or claims about all providers. The housing association discussed remains
unnamed to protect its identity. The report describes its decisions as fairly
as possible, separating observation from interpretation. The named regulatory
cases concern other providers.
Why Governance and Financial Regulations Exist
Financial
regulations translate a board’s legal and regulatory duties into everyday
controls: delegated authority limits, approval routes, purchasing thresholds,
conflict declarations and record-keeping requirements. For a housing
association, these controls protect rental income and housing assets, direct
scarce money towards repairs and safety, and show tenants, lenders and
regulators that decisions were authorised and defensible. Their value is
greatest precisely when operational pressure tempts managers to take shortcuts
in the name of speed.
In England,
the Regulator of Social Housing (RSH) sets the standards that registered
providers must meet. Its Governance and Financial Viability (GFV) Standard
requires private registered providers to adhere to relevant law, comply with
their governing documents, protect social housing assets and maintain an
effective risk management and internal controls assurance framework.1
Providers must adopt an appropriate code of governance, explain any departures
from it and assess their governance effectiveness at least once a year.
The standard
is equally demanding on money. Providers must maintain a robust and prudent
business planning, risk and control framework that secures access to sufficient
liquidity at all times, rests on reasonable forecasting assumptions, accurately
reports delivery of plans and monitors compliance with funders’ covenants. The
board must approve the financial framework, and its effectiveness must be
reviewed at least annually. Providers must also communicate promptly with the
regulator about material or potential non-compliance.1
The sums at
stake are substantial. The RSH’s 2025 Global Accounts, covering 200 large
private registered providers, show that repairs and maintenance spending rose
13% to a record £10 billion in 2024/25, of which £3.9 billion was capitalised.
Providers also spent £14.2 billion on development and delivered 54,000 new
homes, while investment in existing stock is forecast to average £10.9 billion
a year over the following five years.2
Rules also
make decisions reviewable. A clear record of authority, competition,
evaluation, conflicts and contract approval lets directors test whether value
was achieved and whether exceptions were justified. Without it, a board may
receive reassuring summaries while inconsistent practice continues beneath
them. One procurement breach does not, by itself, establish financial
non-compliance, but repeated weaknesses can create unplanned commitments, erode
budgets and gradually undermine the resilience on which lenders and tenants
rely.
How the Regulator Grades Governance and Viability
The RSH
publishes governance grades from G1 to G4 for private registered providers
owning 1,000 or more social homes. G1 means the provider meets governance
requirements, while G2 means it meets them but must improve some arrangements.
G3 means requirements are not being met and serious regulatory concerns exist,
and G4 adds regulatory intervention or enforcement action. These are judgements
about a whole organisation, not scores calculated from a checklist of
individual transactions.
Viability
grades follow the same pattern. V1 indicates capacity to deal with a wide range
of adverse scenarios, while V2 signals capacity for a reasonable range,
provided material risks are managed. V3 and V4 mean viability requirements are
not met, with V4 associated with intervention or enforcement. Importantly, the
GFV Standard does not apply to local authorities, so councils receive consumer
grades from C1 to C4 but no governance or viability grades.3
Worthing Homes
shows how procurement weaknesses can move a grade. Following an inspection
completed in April 2026, the RSH downgraded the South East landlord, which owns
around 4,250 homes and reported turnover of £31.6 million, from G1 to G2. It
cited weaknesses in oversight of data quality, procurement and contract
management, with reviews of the repairs service revealing ineffective oversight
of performance and cost control, evidenced by recent repairs overspends.3
Regulatory
downgrades are not isolated. In the June 2025 publication that confirmed
Anchor’s governance downgrade, discussed later, the RSH also moved First Garden
Cities Homes and Southway Housing Trust from G1 to G2 and regraded each from V1
to V2 following inspections.⁴ None of these judgements resulted automatically
from an isolated error; each reflected the regulator’s assessment of the
evidence, organisational context and accumulated concerns.
The Cost of Treating Rules as Optional
Bypassing
approval limits or competition narrows the supplier field, weakens price
comparison, and leaves an association unable to explain why it chose a
particular contractor. Unmanaged conflicts can damage confidence in a decision,
even when no one benefited improperly. Incomplete contract records make it
harder to verify scope, price, performance or change control. The predictable
results are poor value, disputes, adverse audit findings and expenditure that
nobody with proper authority ever approved.
Weak
procurement also damages services. A contractor appointed without adequate
checks may lack the capacity, insurance, skills or safety systems that housing
work demands. Missed repairs or statutory checks then affect residents
directly, while emergency replacement arrangements can cost more than planned
purchasing. None of these outcomes is automatic, which is why boards need
reporting that links supplier performance to repairs, building safety, and
resident experience, rather than treating procurement as a back-office
function.
The wider
economy shows why payment discipline matters. Research commissioned by the
Department for Business and Trade (DBT) with the Small Business Commissioner
(SBC), published in July 2025, estimated that late payment costs the UK economy
almost £11 billion a year. Around 1.5 million businesses, 28% of the total, are
affected annually, collectively owed about £26 billion at any time, averaging
£17,000 each, and roughly 14,000 close every year as a result.5
Late
payment weakens housing supply chains: smaller contractors may struggle to
retain workers, buy materials or sustain emergency call-outs, while affected businesses
spend 86 hours annually chasing overdue invoices. The Government describes the
reforms as the Small Business Protections Bill, formally before Parliament as
the Commercial Payments Bill [HL]. Following report stage on 15 September 2026,
third reading is scheduled for 20 October. Proposals include a 60-day cap,
interest and enhanced SBC powers. ⁵ ⁶
Carillion
remains the starkest warning. When the contractor entered compulsory
liquidation in January 2018, it had liabilities of nearly £7 billion and just
£29 million in cash. A joint parliamentary inquiry found that it owed around £2
billion to some 30,000 suppliers, subcontractors and other short-term
creditors, and enforced standard payment terms of 120 days despite signing the
Prompt Payment Code. The government committed £150 million to keeping essential
public services running.7
The
committees’ diagnosis matters as much as the numbers. They concluded that
non-executive directors failed to scrutinise or challenge executives, and that
accounts were manipulated to present optimistic revenue assessments in defiance
of internal controls.7 Public bodies are not immune. Thurrock
Council issued a section 114 notice in December 2022, after financial losses
from commercial investments and the need to repay investment debt left an
in-year funding gap of around £470 million.8
Procurement Decisions and the Board’s
Oversight
The board
should seek assurance that procurement controls operate effectively in
practice, rather than merely confirming that policies exist. Reporting should
cover expenditure by value and procurement route, approval compliance,
competition waivers, contract variations, declared conflicts, supplier
performance, overdue actions and unresolved audit recommendations. Rising
waiver use, repeated awards to one supplier without adequate justification, or
unexplained cost growth should prompt challenge, supporting evidence and a
documented management response within an agreed timescale.
Internal audit
can test controls from requisition to payment, including delegated authority,
tender records, evaluation, contract approval, invoice matching and change
control. Its role is to provide assurance, not substitute for management. When
weaknesses are identified, management should assign named owners and deadlines,
while the board or audit committee monitors evidence of closure. A report that
identifies a weakness without establishing whether it was corrected provides
only limited assurance about the organisation’s continuing exposure.
Published
payment data shows how transparency exposes both progress and cost. The
Department of Health and Social Care paid 97% of invoices within 30 days in
July to September 2025, yet recorded late-payment interest liability of
£25,284.49 for that quarter alone. Three years earlier, in July to September
2022, it paid only 83% within 30 days and carried a liability of £406,508.66.9
Strong headline percentages can still conceal exceptions worth investigating.
Thurrock
Council’s published figures tell a similar story. It paid 97.70% of invoices
within 30 days in 2024/25, paid £878.08 in interest and estimated its potential
liability at £110,565.11, noting that suppliers decide whether to claim. In
2019/20, performance stood at 90.09%, with an estimated liability of
£503,453.78.10 Publishing both performance and liability allows
scrutiny committees to ask what the figures mean and what action followed.
Category
Managers: Mentoring and Challenge
Category
managers—in this case, property surveyors responsible for maintenance across
defined areas—turn organisational priorities into specifications, supplier
decisions and contract outcomes. Executive directors and heads of function
should ensure they understand delegated approval limits, procurement
requirements, conflict declarations, evaluation records, and when to seek
specialist advice. Guidance should come before employees make significant
purchasing decisions, with managers available to answer questions and constructively
challenge decisions.
Following
leadership changes and the expiry of the previous Framework Agreement, a new
Property Surveyor had to procure a replacement kitchen and bathroom installer
to maintain the planned replacement programme. The surveyor was not given clear
guidance on the Association’s procurement policy, approval requirements or
timetable. When the Procurement Manager questioned the proposed route, the Head
of Property Services did not assist or intervene, and the Operations Director
did not resolve the disagreement or direct the surveyor.
The proposed
route was a call-off from a third-party framework. Under the Procurement Act
2023, a framework call-off may be used where the framework and proposed
contract meet the Act’s requirements. This includes confirming that the
Association is entitled to use the framework, that the works fall within its
scope and that the call-off follows its stated process. These statutory
requirements apply only where the Association is a contracting authority, and
the proposed contract is within the Act’s scope.
The Act’s
requirements do not replace the Association’s own procurement policy, approvals
or financial regulations. According to the account provided, the Association’s
rules set open tender as the default for above-threshold procurement. A
framework should not be selected simply because it appears convenient: the
proposed route must satisfy both applicable legislation and the Association’s
internal controls. Where the Act does not apply, the Association’s own rules
and any relevant framework conditions still govern the decision.
The
disagreement should have prompted clear direction, coaching and a recorded
decision. The Head of Property Services should have supported the Procurement
Manager, explained the requirements to the surveyor and helped identify a
compliant route. The Operations Director should have clarified accountability
and ensured that the procurement decision was properly authorised before the
process continued.
The
Association then appointed an interim external procurement adviser to run
tender exercises and support supplier appointment recommendations. That
appointment did not transfer the Association’s compliance responsibility. The
adviser needed clear instructions on the applicable procurement route,
delegated authorities, approvals, evaluation, conflicts, contract terms and
record-keeping, with management review at key stages.
According to
the account provided, the adviser was unfamiliar with the Association’s
requirements. Although the rules required an open tender, the Association
allowed a closed tender with invited suppliers, described as loosely based on a
third-party framework arrangement. This was a different route from the proposed
framework call-off. The Association should have required the open competition
specified in its rules and checked the specification, evaluation criteria,
approvals, conflict controls, and records before issuing tenders.
The Association
also issued the tender documents without a works agreement or contract setting
out the terms suppliers would be expected to accept. Bidders therefore could
not assess legal and commercial risks consistently. That uncertainty could have
increased prices, limited competition or deterred suppliers; it also weakened
the audit trail and could make performance obligations harder to enforce.
Senior management should have ensured the contract terms were settled before issuing
tenders or making an award.
New
Employees and Supplier Selection
New employees
need a practical procurement induction before selecting suppliers or committing
organisational funds. Training should cover the Association’s policy, approval
limits, competition requirements, framework use, conflicts, evaluation and
contract terms. Staff should know where to obtain advice and how to escalate a
disagreement. Publishing a policy on the intranet does not replace instruction,
supervision or clear accountability.
The surveyor’s
experience shows why induction must match the employee’s role and experience.
Before issuing a tender, a procurement professional should review the proposed tender
process, tender specification, evaluation criteria, approvals, and draft
contract. Tender documents should set out the material terms suppliers must
accept, including relevant provisions on liability, insurance, payment,
variations, delay and dispute resolution.
Where an external
adviser is used, management should provide clear instructions and check the
work rather than assume the adviser knows or will apply local requirements.
Approval systems should prevent commitments beyond delegated limits and require
authorisation before issuing a purchase order. Records should identify the
requester and approver, procurement route, supplier, contract value, evaluation
outcome, terms and declared conflicts, so the decision can later be examined.
Four public
cases illustrate related risks. They do not establish that the same events
occurred in the case described, but they show why procurement activity,
external support and contract management need active oversight.
Fairfield
Housing Association: The Scottish Housing Regulator reported poor
procurement practice, including contracting arrangements that did not comply
with Scottish Government requirements and had inherent weaknesses. It also
identified long-running contracts with external professional advisers. The case
illustrates the risks of weak procurement controls and insufficient review of
adviser and contract arrangements. The Scottish regulatory and procurement
context differs from England’s.11
Allnutt
Mill Housing Co-operative: The Regulator of Social Housing found
that a managing agent carried out some procurement functions, but the
co-operative had not maintained appropriate oversight of spending against
budget. Material unbudgeted expenditure and inadequate committee scrutiny
contributed to serious financial pressure. The lesson is that delegating
procurement work does not delegate the governing body’s responsibility to
oversee spending and controls.12
Worthing
Homes: The regulator identified weaknesses in procurement and
contract management of its repairs service, alongside recent repairs
overspends. It said the association was addressing longstanding issues through
a new service model and improved oversight. This demonstrates the connection
between procurement decisions, contract management and the cost and quality of
repairs.13
Christian Action (Enfield) Housing
Association: The regulator identified weaknesses in risk management,
financial governance and board oversight, and reported that the association had
nearly breached its loan terms. The regulator’s 2026 review also identified
contract management as an area requiring further improvement. The case
illustrates why leaders need reliable information, clear accountability and
timely challenge when controls are not working.14
Induction and
supervision should be reinforced by systems that prevent commitments above an
employee’s delegated limit and require approval before a purchase order is
issued. The audit trail should record the requester, approver, procurement
route, supplier, contract value, evaluation outcome, contract terms and any
declared conflicts. These controls make it possible to see whether decisions
were authorised, whether advice was considered and whether corrective action
was taken.
When Procurement Warnings Are Not Acted On
A procurement
warning should create a traceable decision. The record should capture what the
procurement manager said, when it was raised, who received it, the rule or
evidence cited and the action taken. Where a purchase appears to exceed
delegated authority or bypass competition, the manager should identify the
relevant control and recommend a proportionate next step, such as pausing the
commitment or seeking properly authorised approval before proceeding.
The response
should be proportionate, but silence is not a control. The responsible
executive director or delegated senior officer should accept the advice,
commission further review or authorise a properly justified exception within
their authority, recording the reasons and any conditions. If the issue remains
unresolved or suggests possible misconduct, employees should know how to
escalate it through procurement leadership, finance, internal audit or the
relevant board committee, and should be protected when doing so.
Unheeded
warnings can quickly become regulatory problems. Private registered providers
must tell the RSH promptly about material non-compliance, and the regulator
expects every landlord, councils included, to surface failures before
inspectors find them.1 When it graded Harlow District Council C3 in
September 2024, the RSH explained that it had identified the problems by
scrutinising the council’s reported Tenant Satisfaction Measures (TSMs), and
reminded landlords that notifying it of material issues is their
responsibility.15
Public-sector
rules show why oversight must test practice rather than accept assurances.
Under Procurement Policy Note 021, central government departments must build
rights to spot-check supply-chain payments into contracts worth more than £5
million a year, confirming that subcontractors are paid within 30 days. The
policy covers contracts advertised from 1 October 2025, and other public bodies
may adopt it.16 Housing associations can borrow the principle,
whatever their legal status.
Property Services and the Supply Chain
A head of
property services must turn the housing strategy into a deliverable maintenance
plan covering required work, service standards, budgets, risk ownership,
contract coverage and contingency arrangements. Leadership means setting
priorities, allocating capable people, explaining procedures and checking that
managers understand both service requirements and the procurement controls
governing how suppliers are appointed, instructed and paid. Commercial literacy
is now as important to the role as technical building knowledge.
Supply-chain
planning should reflect the homes and residents served. It should map planned
and responsive repairs, building-safety work, specialist trades, geographic
coverage, seasonal demand, emergency capacity and reliance on subcontractors.
Managers should know where capacity is fragile, whether alternative suppliers
exist and how work would continue if a contractor failed. Carillion’s collapse
showed how suddenly a major supplier can disappear, leaving clients scrambling
to protect essential services.
The head of
property services also develops the team’s commercial capability. Staff need
clear instructions on preparing specifications, assessing supplier competence,
monitoring quality, escalating risks and recording decisions. Contract managers
should review missed appointments, repeat repairs, complaints, safety actions
and resident feedback alongside cost. A low price cannot represent value if
work is incomplete, defects recur, or residents must repeatedly chase their
landlord to get problems resolved.
Cost control
belongs to the same discipline. At Worthing Homes, the regulator linked repairs
overspends to ineffective contract management and noted that the landlord had
appointed a new repairs contractor, work it described as still at a relatively
early stage and requiring continued oversight.3 It also found that
the landlord’s financial profile had weakened since 2024 because of rising
management and repairs costs, limiting its capacity to absorb adverse events.
Basildon
Borough Council illustrates what happens when contractor oversight and
information fail together. In April 2026, following a planned inspection, the
RSH gave the council a C4 consumer grade, the lowest available, finding
insufficient assurance of repairs performance, ineffective oversight of its
contractor, poor data assurance for legal health-and-safety requirements and
inaccurate information about home condition. Basildon became the seventh local
authority to receive that grade.17
The council’s
own statement acknowledged a backlog of around 4,600 fire-safety remedial
actions requiring better tracking.17 The regulator also found
problems with the council’s TSM reporting and no evidence that results had been
analysed or used to improve services. It required fundamental change and
intensive improvement, with enforcement still under review. For any landlord,
the lesson is that contract management failures rarely stay confined to a
single service.
One-to-One Meetings and Management Control
Regular
one-to-one meetings between executive directors, heads of function and managers
help align priorities, test progress and identify problems that dashboards may
miss. A useful meeting reviews current risks, pending decisions, supplier or
staffing pressures, effects on tenants and actions from the previous
discussion. It should produce a concise record of agreed actions, owners and
deadlines, preventing important issues from disappearing between teams,
committees and formal reporting cycles.
For a property
function, these conversations connect repairs demand, contractor capacity,
safety checks, planned investment, complaints and resident feedback.
Procurement managers can flag upcoming renewals, spend approvals, weak
competition or supplier concerns before they become urgent. Finance and
operational managers can reconcile forecasts with commitments and expected
work, reducing the temptation for a service team to make an unauthorised
purchase to solve an immediate problem under pressure.
When meetings
are repeatedly missed, the concern is not a declined calendar invitation but
the consequences: decisions left unmade, risks without owners, inconsistent
instructions and managers with no route to challenge a plan. Frequency should
reflect risk, with monthly discussions suiting routine planning and urgent
safety matters demanding faster escalation. Proportionate records also reveal
patterns such as repeated slippage, recurring contractor failure or actions
closed administratively without evidence of improvement.
What the TSMs Show
The TSMs are a
standard set of performance measures that registered providers in England must
calculate and publish annually. Since the RSH added an electrical safety
measure in June 2026, the framework has comprised 23 measures: 12 drawn from
tenant perception surveys and 11 generated from management information.18
They aim to give tenants greater transparency about landlord performance and to
inform the regulator about compliance with consumer standards.
The 12
perception measures cover overall satisfaction, repairs, repair time, whether
the home is well maintained and safe, whether the landlord listens and keeps
tenants informed, fair and respectful treatment, complaint handling, communal
areas, neighbourhood contribution and anti-social behaviour. Question wording
and response options are prescribed, and responses must be weighted where
necessary to represent the tenant population. They capture reported experience
but cannot, on their own, explain why a service performed well or poorly.
The 2024/25
results, published in November 2025, draw on nearly half a million tenant
surveys conducted by large landlords. Seven in ten tenants in low-cost rental
accommodation were satisfied with their landlord’s overall service, while 18%
were dissatisfied. The median landlord recorded 74% satisfaction with repairs,
78% satisfaction that homes were safe and 78% agreement that tenants were
treated fairly and respectfully, but only 36% satisfaction with complaint
handling.19
These figures
are benchmarks, not targets. Differences in landlord size, tenant profile and
collection method affect comparisons, and 71% of landlords used telephone
surveys as their main method in 2024/25.19 The regulator has noted
that small changes in collection methods can partly explain year-on-year
movements in average satisfaction. Boards should therefore interpret shifts in
their own results cautiously, seeking corroborating evidence before either celebrating
improvement or reacting to apparent decline.
Responsibility for accuracy rests with
governing bodies. The technical requirements state that boards of private
registered providers and governing bodies of local authority landlords are
ultimately responsible for ensuring reported measures are accurate and comply
with regulatory requirements.¹⁸ This responsibility cannot be delegated to a
survey contractor or performance team. Audit committees should therefore review
data assurance regularly and whenever material concerns arise, supported by
testing of source records, calculations and reporting controls.
Reading Repairs, Safety and Condition Data
The
management-information repair measure, RP02, reports the proportions of
emergency and non-emergency responsive repairs completed within the landlord’s
published target timescales. Completion must be measured end to end, from when
the problem is first reported until the repair is recorded as completed. The
measure covers work delivered by contractors or directly employed teams,
including communal-area repairs, but excludes planned and cyclical works. It
therefore reflects the responsive service tenants experience.18
Recent legal
changes have sharpened the measure. Following the Hazards in Social Housing
(Prescribed Requirements) (England) Regulations 2025, known as Awaab’s Law, the
technical requirements were updated in March 2026 so that defects representing
emergency hazards must be counted as emergency repairs, and significant hazards
generally as non-emergency repairs.18 Across large landlords, 79% of
the 11 million non-emergency responsive repairs completed in 2024/25 met target
timescales.19
RP01 reports
homes failing the Decent Homes Standard and is not interchangeable with
perception measure TP04, which asks whether tenants feel their home is well
maintained. A provider can therefore score quite differently on each.
Divergence should prompt analysis of property-level condition data, investment
programmes, and tenant experience, rather than assuming one figure disproves
the other. Both depend on accurate stock condition information, which several
recent regulatory judgements have found lacking.
Building-safety
measures cover gas, fire, asbestos, water, lift and now electrical checks,
reporting the proportion of relevant homes for which all required checks were
completed at year-end. Denominators matter. In the regulator’s worked example,
a landlord with 10,150 homes requiring gas checks, including 100 flats served
by one unchecked communal boiler and 1,000 unchecked houses, reports 89%
compliance, showing how a single communal failure affects every flat it serves.18
The electrical
safety measure, BS06, came into effect on 11 June 2026. Large landlords, those
with 1,000 or more homes, must publish it for the first time for the 2026/27
reporting year, with results reflecting the position at 31 March 2027, while
smaller landlords publish for reporting years ending on or after that date.20
The measure creates no new legal duty, because landlords should already have
been carrying out these checks.
A reported
percentage has limits. The building-safety measures deliberately exclude
completion of remedial actions identified by inspections, although the
technical requirements stress that those actions must still be carried out.18
A landlord could therefore report every fire risk assessment as complete while
hundreds of high-risk actions remain outstanding. Boards need separate
reporting on overdue remedial work, categorised by risk level and age, to
understand whether residents are genuinely safer.
Harlow
demonstrates the value of reading these measures critically. After reviewing
the council’s submission, the RSH found that fire risk assessments had been
completed for only around 20% of the buildings requiring them across its 9,100
social homes. More than 500 high-risk and around 1,500 medium-risk fire-safety
actions were overdue, most by over 12 months. The regulator also criticised
weak oversight, with key safety information submitted without sufficient
scrutiny.15
Engagement, Complaints and Neighbourhood Measures
Three
perception measures address engagement: whether the landlord listens and acts
on tenant views, keeps tenants informed and treats them fairly and with
respect. Results should be read alongside evidence of tenant involvement,
access to services and whether feedback has actually changed decisions. A
favourable score does not prove that every group is heard equally, and a low
score should prompt investigation into whose experience is being missed, and
why.
Complaints
appear in both survey and management data. TP09 records satisfaction with
complaint handling, CH01 reports stage one and stage two complaints per 1,000
homes, and CH02 reports responses within the Housing Ombudsman’s Complaint
Handling Code timescales. Under the 2024 Code, a stage one response is due
within 10 working days of acknowledgement and a stage two response within 20
working days, with limited extensions for complex cases.18
Sector
performance reveals a striking gap between process and perception. In 2024/25,
78% of more than 290,000 stage one complaints received responses within Code
timescales, yet median satisfaction with complaint handling was just 36%.19
Volume alone is ambiguous, since a rise may reflect worsening service, better
awareness or easier reporting. More useful questions concern fair
investigation, meaningful remedies, repeat issues and whether learning
genuinely changes future service delivery.
Neighbourhood
measures combine tenant views on communal cleanliness, neighbourhood
contribution and anti-social behaviour handling with NM01, which counts
anti-social behaviour cases, including those involving hate incidents, per
1,000 homes.18 These indicators can highlight estate services, case
handling and communication, but they do not capture every local outcome.
Landlords may need supporting information on case severity, response times,
repeat incidents and tenant safety before drawing reliable conclusions.
Financial
Viability in Practice
Financial
viability is not simply whether rent covers this month’s bills. The RSH expects
providers to maintain sufficient liquidity, base plans on reasonable
assumptions, stress-test adverse scenarios and monitor lender covenants. Boards
need reliable forecasts linking income, debt, repairs, investment and long-term
commitments so they can act before a cash-flow warning threatens homes,
services or continued operation.
South
Yorkshire Housing Association (SYHA), with 5,700 homes and £46.5 million group
turnover in 2021/22, illustrates how governance and viability failings can
emerge before insolvency. In June 2023, the RSH downgraded it from G2 to G3 and
V2 to V3 after finding it had miscalculated covenant compliance over several
years. A historic breach, forecast breach and cross-default clauses exposed it
to wider loan risks; inaccurate information reached funders, the board and
regulator.²¹
The RSH found
no immediate liquidity or solvency concerns, but said control failures exposed
social housing assets to undue risk and the business plan relied on uncertain
cash flows. Separately, SYHA offered an improvement plan and voluntary
undertaking, which the regulator accepted in March 2024 and later confirmed had
been honoured. The judgement was withdrawn on 28 January 2026, after SYHA
became a subsidiary of Places for People Group on 1 December 2025.²¹
My Space
Housing Solutions offers a V4 example. In 2022, it reported 1,817
supported-housing units and £27.3 million turnover. The RSH downgraded it from
G3/V3 in 2020 to G4/V4 in December 2022 and began enforcement action, saying it
could not assure the regulator it was solvent and appeared reliant on continued
third-party support to trade. It also cited weak liquidity planning and
concerns about connected-party property transactions.²²
My Space’s
2024 accounts record a later development: a Company Voluntary Arrangement (CVA)
was agreed on 7 March 2025 following lease and debt restructuring, restoring
solvency on both a balance-sheet and cash-flow basis. This outcome should be
read alongside, not as a revision of, the RSH’s 2022 V4 judgement. That
judgement describes the provider’s position at the time; the CVA records a
subsequent restructuring and recovery measure.²³
These
judgements show the difference between serious weakness and proven insolvency.
V3 means the provider does not meet viability requirements and is working with
the regulator; V4 means intervention or enforcement. Neither grade alone
declares a provider insolvent. Both show why boards need to monitor cash
forecasts, covenant headroom, lease exposure and downside scenarios, and
connect financial warnings to plans for repairs, safety work and service
continuity.
How Procurement Affects Tenant Outcomes
Procurement
decisions shape the capacity, skills and incentives of the suppliers delivering
repairs, maintenance and safety work. Specifications that omit response times,
quality standards, reporting duties or resident-care requirements make later
performance difficult to assess. A competitive process should test more than
price, examining relevant experience, workforce capacity, subcontracting,
safety arrangements, geographic coverage and how the supplier will evidence
completed work to the landlord’s satisfaction.
Contract
management turns those promises into daily service. Landlords should track
attendance, completion, repeat visits, outstanding remedial actions, complaints
and resident communication against agreed requirements. Where contractor data
feeds the landlord’s systems, the contract should define formats, validation,
correction and audit access. Anchor’s experience is instructive: it
self-reported to the regulator after discovering that contractors were failing
to complete electrical remediation work to specification and on time.24
Poor supplier
management may contribute to delayed repairs, repeat visits and unresolved
complaints, which in turn depress both perception and operational measures.
Correlation, however, does not prove causation. Investigation should trace
individual work orders, appointment records, supplier reports and tenant
feedback to establish where the process broke down. The practical test is
whether managers intervene early and can later show what they knew, when they
knew it and whether outcomes improved.
Performance Data: Accuracy, Assurance and Alleged
Manipulation
Every reported
figure needs a defined measure, a reliable source, a consistent period and an
accountable owner. For housing services, the underlying records include work
orders, appointment outcomes, safety certificates, inspection results,
complaint logs and survey responses. A data dictionary should set out each
measure’s scope, denominator, exclusions, target and calculation, allowing
managers and auditors to reproduce reported results directly from source
records without relying on explanation or memory.
Checks should
occur before figures reach dashboards, board papers or regulatory returns. They
can include exception reports, sample testing against source documents, tests
for duplicate or missing records, reconciliation between contractor and
landlord systems and review of late changes. The person preparing data should
not be the only person approving it, and material corrections should retain a
dated audit trail showing original and amended values, the reason and the
authorisation.
Anchor, the
largest provider in England of specialist housing and care for older people,
provides a salutary example. In February 2025, the RSH gave it a C3 consumer
grade for serious failings, and in June 2025 downgraded its governance from G1
to G3, finding insufficient assurance that its data was robust or that systems
ensured key information was accurately reported. Its viability grade remained
V1.4.
The language
matters. Anchor had itself identified errors in its health-and-safety
compliance reporting and begun reviewing its data; the regulator described
errors, and that finding should not be recast as deliberate manipulation
without separate evidence.4 Its interim chief executive apologised
and accepted the judgement in full.24 Boards should apply the same
discipline internally, distinguish error from misconduct, and investigate
allegations fairly before labelling anyone responsible.
The London
Borough of Newham shows how weak information conceals risk. When the RSH issued
its first-ever C4 grade in October 2024, it found more than 9,000 overdue
fire-safety remedial actions, over 4,000 of them high risk. Some 40% of the
council’s 16,000 homes had not received an electrical condition test for more
than 11 years, and 60% had no stock condition survey within five years.25
When figures
appear inconsistent, the first task is to establish the cause: a definition
change, system migration, incomplete contractor feeds, human error, weak
controls or deliberate alteration. Evidence may include source records, version
histories, system permissions, emails, approvals and explanations from data
owners. Findings should clearly state what is established, what remains
uncertain, and what correction or control improvement is required, without
treating suspicion alone as proof of misconduct.
Competence, Transparency and Tenant Access to Information
The new
Competence and Conduct Standard takes effect on 1 October 2026. Originally
proposed as part of the Transparency, Influence and Accountability Standard, it
was issued separately to increase its visibility for tenants and landlords. It
requires landlords to ensure that relevant staff have the skills, knowledge,
experience and behaviours needed to deliver a high standard of service, making
professional capability an explicit organisational responsibility.26
Qualification
requirements apply to in-scope senior housing managers and senior housing
executives, subject to defined exemptions. The government’s policy statement
specifies a relevant Level 4 qualification for senior housing managers and a
Level 5 qualification or foundation degree for senior housing executives.²⁸
Providers with 1,000 or more homes have a three-year transition; smaller
providers and their service providers have four years.²⁷ The requirement is
phased, not an immediate obligation on every individual from October 2026.
The revised
Transparency, Influence and Accountability Standard also introduces the Social
Tenant Access to Information Requirements (STAIRs) for private registered
providers. From 1 October 2026, they must proactively publish specified
information about how they manage social housing, and from April 2027 they must
respond to information requests from tenants or their designated
representatives.26 Providers need processes to identify the
information they hold, keep it current and make it accessible.
STAIRs give
tenants of private registered providers broadly similar access to information
to that enjoyed by council tenants under the Freedom of Information Act 2000.26
They should not, however, be described as bringing housing associations within
that Act. Providers must explain the reason if they refuse or delay a request,
and should have a published policy explaining when information may reasonably
be withheld. Tenants can challenge the handling or outcome through the
provider’s review process and, if dissatisfied, refer the matter to the Housing
Ombudsman; the regulator oversees providers’ compliance with the standard.
Together,
these standards make competence and transparency essential parts of service
accountability. A housing association should be able to identify who was
responsible for each material decision, what authority and guidance they had,
what training they received, what evidence they considered and how the outcome
was reviewed. It should also maintain sufficient records to enable tenants, the
board, auditors and regulators to scrutinise relevant decisions through the
appropriate channels.
Where services
fall below the required standard, the Association should investigate the cause
and assign responsibility according to the evidence. That evidence may show
failings by an employee, inadequate supervision, unclear instructions,
insufficient resources, defective systems or weaknesses in senior management
oversight. Relevant responsibilities, policies, training records,
correspondence, information requests, responses and recorded reasons should
therefore be examined. Accountability should follow established facts, ensuring
that failings are corrected rather than overlooked, assumed or passed between
teams.
Accountability and Corrective Action
Establishing
what happened requires a dated trail of evidence. Relevant material may include
financial regulations, delegated authority schedules, procurement plans, tender
and evaluation records, conflict declarations, induction records, warning
emails, meeting records, approval logs, contracts, supplier performance data
and the source records behind published returns. Evidence should be preserved
in its original form wherever possible, with separate records of later
corrections, decisions and the explanations offered for them.
An
investigation should test both the event and the control system around it: who
made or approved each decision, which rule applied, whether advice was received
and whether records support the reported account. It should distinguish honest
mistakes, unclear guidance, weak supervision, control failures and deliberate
conduct. Where a material issue may affect compliance or tenant safety, the
provider should consider its duty to notify the regulator and act promptly.
Corrective
action should match the cause and include evidence that the fix works. Options
include independent review, corrected data, tighter approval controls, targeted
training, revised supervision, supplier recovery plans and board-monitored
actions with named owners and deadlines. Torus62 shows that recovery is
achievable: graded C2 after a May 2025 inspection, it delivered an improvement
plan and was upgraded to C1 in April 2026 after strengthening safety oversight
and repairs assurance.29
A written
action plan alone does not prove improvement. Follow-up should test whether
decisions now comply with the rules, records reconcile to source data, and
residents experience better services. Boards should not close actions solely
because they have been marked complete administratively. They should require
evidence such as repeat audit testing, reconciled data and improved tenant
feedback. Sustained improvement, rather than visible activity, ultimately
restores the confidence of tenants, lenders and regulators.
Summary: Governance Must Be Evident in Practice
Financial
regulations and governance controls exist to protect tenants’ homes, rental
income and long-term viability. They set clear limits on spending, supplier
selection, approvals and record-keeping, but provide assurance only when people
understand and follow them. Evidence from Carillion, Thurrock, Worthing Homes
and Anchor is consistent: failure rarely begins with a single catastrophic
decision, but with tolerated exceptions, unchallenged executives and
information nobody properly tested.
Boards must
oversee how controls operate in practice, while executive directors and heads
of function should support and challenge category managers, induct new
employees and treat procurement warnings as matters requiring a recorded
decision and response. Property services leaders must plan supply chains
realistically and actively manage contractors. TSMs, payment data, and
regulatory grades provide useful signals, but each requires careful
interpretation, reliable source records, and investigation before reaching
conclusions about cause or blame.
Electrical
safety reporting, the Competence and Conduct Standard and STAIRs are raising
expectations of professionalism and transparency during 2026 and 2027. If
enacted, the Commercial Payments Bill [HL], which the Government describes as
the Small Business Protections Bill, would strengthen payment protections and
enforcement. Effective accountability depends on reliable evidence, candid
reporting and corrective action with clear owners. Claims of ignored warnings
or manipulated data must be substantiated and distinguished from honest error.
Additional
articles can be found at Procurement Made Easy. This site looks at procurement
issues to assist organisations and people in increasing the quality,
efficiency, and effectiveness of their product and service supply to the
customers' delight. ©️ Procurement Made Easy. All rights reserved.
Sources and Notes
1.
RSH, GFV
Standard (April 2015), GOV.UK: https://www.gov.uk/government/publications/governance-and-financial-viability-standard.
See also the Harlow judgment coverage below for the regulator’s expectation
that all landlords notify it of material issues.
2.
RSH, 2025
Global Accounts of private registered providers, published 15 January 2026: https://www.gov.uk/government/news/regulator-of-social-housing-2025-global-accounts-published
3.
RSH,
Worthing Homes Limited (LH4208), Regulatory Judgement, 15 April 2026 (including
the statement that the GFV Standard does not apply to local authorities): https://www.gov.uk/government/publications/worthing-homes-limited/worthing-homes-limited-lh4208-regulatory-judgement-15-april-2026
4.
RSH, press
release, “Anchor fails to meet RSH’s governance standards”, 25 June 2025,
including the table of judgements for First Garden Cities Homes and Southway
Housing Trust: https://www.gov.uk/government/news/anchor-fails-to-meet-rshs-governance-standards
5.
DBT and
SBC, Late Payments Research (London Economics), published 15 July 2025:
https://www.smallbusinesscommissioner.gov.uk/late-payments-research-2/
6.
LexisNexis,
“Small Business Protections Bill introduced to Parliament”, 19 May 2026: https://www.lexisnexis.com/en-gb/legal/news/small-business-protections-bill-introduced-to-parliament;
SBC, “UK sets global standard for small business payment rights”, 2 July 2026: https://www.smallbusinesscommissioner.gov.uk/uk-sets-global-standard-for-small-business-payment-rights/;
Institute of Chartered Accountants in England and Wales, Insights, “UK
government ploughs ahead with late payments Bill”, 21 May 2026: https://www.icaew.com/insights/viewpoints-on-the-news/2026/may-2026/uk-government-ploughs-ahead-with-late-payments-bill;
UK Parliament, Commercial Payments Bill [HL], Bill page (report stage completed
15 September 2026; third reading scheduled for 20 October 2026): https://bills.parliament.uk/bills/4128; Department for
Business and Trade et al., “Largest crackdown on late payments in over 25 years
as landmark Bill enters Parliament”, GOV.UK, 19 May 2026 (describing it as the
Small Business Protections Bill and stating that it is formally known as the Commercial
Payments Bill): https://www.gov.uk/government/news/largest-crackdown-on-late-payments-in-over-25-years-as-landmark-bill-enters-parliament.
7.
House of
Commons Business, Energy and Industrial Strategy and Work and Pensions
Committees, Carillion, Second Joint Report of Session 2017–19, May 2018: https://publications.parliament.uk/pa/cm201719/cmselect/cmworpen/769/76903.htm
8.
Local
Government Lawyer, “Financially troubled Thurrock Council issues section 114
notice”, 20 December 2022; Thurrock Council news release, 19 December 2022: https://www.thurrock.gov.uk/news/council-finances-and-accounts/thurrock-council-takes-major-step-to-financial-recovery
9.
Department
of Health and Social Care, prompt payment of suppliers quarterly data, updated
5 May 2026: https://www.gov.uk/government/publications/department-of-health-and-social-care-prompt-payment-of-suppliers
10.
Thurrock
Council, “Payment of invoices within 30 days”: https://www.thurrock.gov.uk/what-we-spend/payment-of-invoices-within-30-days
11.
Scottish
Housing Regulator, Statutory intervention at Fairfield Housing Association,
published 17 January 2023 (paragraph 28 records poor procurement practice
leading to contracting arrangements not compliant with Scottish Government
requirements, and rolling contracts with external auditors, accountants and
solicitors lasting 10 to 18 years): https://www.housingregulator.gov.scot/landlord-performance/national-reports/statutory-intervention/statutory-intervention-at-fairfield-housing-association/;
Scottish Housing Regulator, “Scottish Housing Regulator ends its statutory
intervention at Fairfield Housing Association” (transfer of homes to Kingdom
Housing Association on 1 December 2021): https://www.housingregulator.gov.scot/about-us/news/scottish-housing-regulator-ends-its-statutory-intervention-at-fairfield-housing-association/
12.
RSH,
Allnutt Mill Housing Co-operative Limited (C4108), Regulatory Judgement, 15
January 2025 (managing agent undertaking certain aspects of procurement;
material levels of unbudgeted expenditure; inadequate financial monitoring and
committee scrutiny): https://www.gov.uk/government/publications/allnutt-mill-housing-co-operative-limited/allnutt-mill-housing-co-operative-limited-c4108-regulatory-judgement-15-january-2025;
RSH, press release, “RSH removes two officers from Allnutt Mill Housing
Co-operative’s committee” (subsequent enforcement action): https://www.gov.uk/government/news/rsh-removes-two-officers-from-allnut-mill-housing-co-operatives-committee
13.
RSH,
Regulatory Casework Review 2026, published 28 July 2026, Lesson 2, Worthing
Homes case summary (weaknesses in procurement and contract management of the
repairs service, highlighted by recent repairs overspends; longstanding repairs
procurement issues being addressed through a new service model and improved
oversight): https://www.gov.uk/guidance/regulatory-casework-review-2026.
See also note 3 for the underlying Regulatory Judgement of 15 April 2026.
14.
RSH,
Christian Action (Enfield) Housing Association Limited, Regulatory Judgements
of 14 December 2022 (governance downgrade to G3) and 25 February 2026 (upgrade
to G2/V2, with further improvement needed in performance management and
contract management): https://www.gov.uk/government/publications/christian-action-enfield-housing-association-limited;
RSH, Regulatory Casework Review 2026, Lesson 2, Christian Action (Enfield)
Housing Association case summary (weaknesses in financial monitoring, board
reporting and oversight; near breach of loan terms): https://www.gov.uk/guidance/regulatory-casework-review-2026
15.
RSH
judgement on Harlow District Council, September 2024, as reported by Local
Government Lawyer (25 September 2024) and Local Government Chronicle: https://www.localgovernmentlawyer.co.uk/housing-law/397-housing-news/58611-regulator-of-social-housing-accuses-district-council-of-serious-failings-amid-fire-assessment-concerns
16.
Cabinet
Office, Procurement Policy Note 021: Payment spot checks in public
sub-contracts, April 2025, in force 1 October 2025: https://assets.publishing.service.gov.uk/media/680117a3ea3dd40f93681fe7/2025-04-16_PPN_021_Payment_spot_checks_in_public_sub-contracts.pdf
17.
RSH,
Basildon Borough Council (22UB), Regulatory Judgement, 15 April 2026: https://www.gov.uk/government/publications/basildon-borough-council/basildon-borough-council-22ub-regulatory-judgement-15-april-2026;
Inside Housing Management (seventh local authority C4); council statement
reported by Essex Live, 15 April 2026 (fire-safety backlog).
18.
RSH, TSM
technical requirements, updated 11 June 2026 (includes BS06, the Awaab’s Law
clarification of March 2026, worked examples and board responsibility for
accuracy): https://www.gov.uk/government/publications/tenant-satisfaction-measures-technical-requirements
19.
RSH, TSM
2024/25 headline report and press release, 4 November 2025: https://www.gov.uk/government/news/analysis-of-tenant-satisfaction-in-the-social-housing-sector-published-by-rsh
20.
RSH, “RSH
finalises requirements for electrical safety checks TSM”, 11 June 2026: https://www.gov.uk/government/news/rsh-finalises-requirements-for-electrical-safety-checks-tsm
21.
Regulator
of Social Housing, South Yorkshire Housing Association Limited, Regulatory
Judgement, 8 June 2023 (withdrawn 28 January 2026 following its becoming a
subsidiary of Places for People Group): https://www.gov.uk/government/publications/regulatory-judgement-south-yorkshire-housing-association-limited/current-regulatory-judgement-south-yorkshire-housing-association-limited-8-june-2023;
Regulator of Social Housing, “South Yorkshire Housing Association Limited”
(page withdrawn and updated 28 January 2026; recording that the voluntary
undertaking was accepted in March 2024 and honoured): https://www.gov.uk/government/publications/regulatory-judgement-south-yorkshire-housing-association-limited
22.
Regulator
of Social Housing, My Space Housing Solutions, previous Regulatory Judgement,
17 December 2020: https://www.gov.uk/government/publications/regulatory-judgement-my-space-housing-solutions/current-regulatory-judgement-my-space-housing-solutions-17-december-2020;
current Regulatory Judgement, 19 December 2022, updated 16 January 2023: https://www.gov.uk/government/publications/regulatory-judgement-my-space-housing-solutions/current-regulatory-judgement-my-space-housing-solutions-19-december-2022
23.
Charity
Commission for England and Wales, My Space Housing Solutions: accounts and
trustees’ annual report for the year ended 31 October 2024 (filed 24 June
2025), recording that a Company Voluntary Arrangement was agreed on 7 March
2025 and restored the charity’s solvency on a balance-sheet and cash-flow
basis: Charity Commission accounts and annual returns
24.
Local
Government Lawyer, report on the RSH governance judgement for Anchor, 25 June
2025 (self-referral and contractor remediation failures; chief executive
statement): https://www.localgovernmentlawyer.co.uk/housing-law/397-housing-news/61398-later-life-social-housing-provider-hit-with-c3-governance-grading-by-regulator
25.
Local
Government Lawyer, report on the first C4 consumer grade, issued to the London
Borough of Newham, October 2024: https://localgovernmentlawyer.co.uk/housing-law/397-housing-news/58806-london-borough-first-to-receive-lowest-grade-from-regulator-of-social-housing
26.
RSH, press
release, “RSH publishes revised consumer standards and requirements”, 9 July
2026: https://www.gov.uk/government/news/rsh-publishes-revised-consumer-standards-and-requirements
27.
Ministry
of Housing, Communities and Local Government, Competence and Conduct Standard
for social housing: government response, updated 30 September 2025: https://www.gov.uk/government/consultations/competence-and-conduct-standard-for-social-housing-consultation/outcome/competence-and-conduct-standard-for-social-housing-government-response
28.
Department
for Levelling Up, Housing and Communities, Policy Statement on Qualifications
Requirements for Social Housing, sections 3.1–3.2 (qualification level and
course-content requirements for senior housing managers and executives): https://assets.publishing.service.gov.uk/media/65ba1006ee7d4900139849f8/Policy_Statement_on_Qualifications_Requirements_for_Social_Housing.pdf
29.
Regulator
of Social Housing, Torus62 Limited (5065): Regulatory Judgement, 15 April 2026
(records the upgrade from C2 to C1 following the May 2025 inspection and the
provider’s improvement plan): https://www.gov.uk/government/publications/torus62-limited/torus62-limited-5065-regulatory-judgement-14-may-2025
