Housing & Communities Overview & Scrutiny Panel - 21 January 2026
Social Housing Regulation Act (2023) Progress Report Number 5 (Safety & Quality Standard)
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Purpose |
To Review |
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Classification |
Public |
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Executive Summary |
This report provides the Housing and Communities Overview & Scrutiny Panel with an update on the Council’s progress in meeting the Safety and Quality Standard under the Social Housing Regulation Act 2023 (SHRA). The Act and its associated consumer standards came into force for all stock-owning registered landlords including councils in April 2024. This report focuses on the Council’s progress against the Safety & Quality Standard and identified gaps in provision. It is the first of five consumer standards landlords must now deliver to meet the regulatory requirements set by the Regulator of Social Housing (RSH) The Safety & Quality Standard as stated by the RSH: “Outcomes landlords must deliver about the safety and quality of tenants’ homes.” Our approach and preparation for improving outcomes for our tenants and preparing for future Inspection by the RSH against this standard is presented in this report. This report focuses on the Council’s progress against the Safety & Quality Standard and identified gaps in provision. It is the first of five consumer standards landlords must now deliver to meet the regulatory requirements set by the Regulator of Social Housing (RSH) The Safety & Quality Standard as stated by the RSH: “Outcomes landlords must deliver about the safety and quality of tenants’ homes.” Our approach and preparation for improving outcomes for our tenants and preparing for future Inspection by the RSH against this standard is presented in this report. This is the fifth progress report and focuses on the Safety and Quality Standard, which covers stock quality, decency, health and safety, repairs and maintenance, and adaptations.
A self-assessment and gap analysis indicate good overall compliance, but 11 active gaps remain, primarily in stock condition data, integration of repairs systems, and tenant engagement. High-priority actions include completing 100% of all outstanding stock condition surveys by April 2026 (noting that ongoing non-access issues may reduce this to 98%) Improving data use for compliance and investment planning and implementing a new Maintenance and Repairs system to enhance service delivery and tenant experience.
Recent steps include providing additional staff and contractor resources to the stock condition team, updated policies, and strengthened governance through the Consumer Standards Board and implementing recommendations from our recent Mock Inspection.
Compliance is critical to ensure the provision of a good landlord service, maintain tenant satisfaction and avoid regulatory penalties.
The report seeks the Panel’s consideration of current compliance and recommendations to support preparedness for future regulatory inspection and improved tenant outcomes.
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Recommendation(s) |
1. That the Housing & Communities Overview & Scrutiny Panel consider the Housing Landlord’s compliance against meeting the Safety and Quality Standard and make any further recommendations to the Portfolio Holder for Housing and Homelessness.
2. That the Housing & Communities Overview & Scrutiny Panel note the high-level of performance against this standard to ensure the health and safety of our tenants and achieve positive tenant outcomes.
3. That the Housing & Communities Overview & Scrutiny Panel receive a further report on the Competence and Conduct Standard for Social Standard at its next meeting. |
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Reasons for recommendation(s) |
This report supports the Council’s Corporate Plan 2024–28, particularly in delivering on priorities related to resident wellbeing, housing needs, and community safety. It also outlines the financial, legal, and operational implications of achieving full compliance with the Safety and Quality Standard. |
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Ward(s) |
All |
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Portfolio Holder(s) |
Councillor Steve Davies, Housing and Homelessness |
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Strategic Director(s) |
Peter Matthew – Housing and Communities |
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Officer Contact |
Paul Thomas |
1. A comprehensive background to the implementation of the Social Housing Regulation Act (SHRA 2023) was given in the January 2025 report to this Panel. It was agreed that each of the four consumer standards would then be looked at in turn against our gap analysis at subsequent meetings, in the order where we considered there was the most work to be done.
2. Progress against the Transparency, Influence and Accountability (TIA) standard was considered in March, the Tenancy Standard in June and the Neighbourhood and Community Standard in September 2025. This is the fifth report in the series, and focus this time is on the fundamental Safety and Quality Standard.
3. The fifth Consumer Standard – The Competence and Conduct Standard for social housing, has recently been enacted by the RSH, so it will be part of the regulatory regime and future landlord inspections. It is worth noting that NFDC did not wait for the standard to be enacted and has a programme of professional development and qualification in place for all management levels of staff in partnership with the Chartered Institute of Housing (CIH) and this standard has been included in our gap analysis and action planning work from inception.
4. All these reports aim to give an accurate picture of the current state of compliance with the standard and the improvement plans in place. The aim is to ensure Members receive transparent assurance that the service understands any compliance gaps and has a clear plans to prioritise and implement required improvements in reasonable timescales taking account of higher risk areas.
5. We are awaiting to receive confirmation as to when the Regulator plans to inspect NFDC. However, at our first annual engagement meeting with the RSH in December 2025, it became apparent that their regional team did not have any immediate regulatory concerns about NFDC. Their view has probably been formed by our published high scoring Tenant Satisfaction Measures and our recent Mock Inspection level of preparedness.
6. The Regulator is now taking account of the potential impacts of LGR in Hampshire and their current inspection timetable, the outcome being it is unlikely NFDC will be inspected in the first two quarters of 2026. Nevertheless, the Regulator does continue to expect co-regulation between the council, its elected members, and their regulatory teams including self-referrals if significant gaps or failings are identified by the landlord service against the Consumer Standards and particularly the Safety and Quality standard for obvious reasons.
7. Members can be assured that the service will continue to prepare to ensure the health and safety of all our tenants and that we can demonstrate evidence of compliance against all the four main consumer standards, whilst continuing to deliver high quality services to our tenants as reflected in the other consumer standards.
Safety and Quality Standard
9. Each Consumer Standard is broken down into specific expectations. The following five are within the Safety and Quality Standard.
· Stock quality
· Decency
· Health and Safety
· Repairs, maintenance, and planned improvements
· Adaptions
10. This report has been broken down in these specific expectations and performance measured against the outcomes of the self-assessment and gap analysis process.
11. The self-assessment process had further areas, which are not part of the consumer standards and relate to the professional knowledge and best practice suggestions of the Housing Quality Networks (HQN).
12. These further areas have the following headings and where appropriate have been included in this report.
· General
· Tenant engagement
· Customer service
· Damp, mould and condensation
· Taking the Lead
Preparedness for Regulatory Compliance
13. The first stage of the preparedness process was the completion of a self-assessment against the consumer standards. This resulted in action plans and a gap analysis tracker.
14. A full explanation of the methodology of the self-assessment process was provided in the March 2025 report to Panel. It is worth noting that the self-assessment includes the specific expectations of the consumer standards as well as areas from the Code of Practice and the Housing Quality Networks professional knowledge.
15. Since the last report to Panel the Council has undergone a ‘mock inspection.’ This has provided a further opportunity to test our own preparation, give an external view of the evidence provided, both in written form and in face-to-face interviews, and has provided improvement actions to aid our preparedness.
16. The process of implementing these actions will be led by the Strategic Director Housing and Communities, through an internal Consumer Standard Board, and progress monitored by the Portfolio Holder at the monthly briefings. Progress reports will also be provided to the Housing and Communities Overview and Scrutiny Panel.
17. Chart 1 below displays the current active gaps within the 4 consumer standards.
Chart 1: Current Gaps across all standards
18. Chart 2 below demonstrates the priority rating for the 11 identified active gaps within the Safety and Quality standard. These are explained in further detail in this report.
Chart 2: Priority Ratings.
Stock Quality
19. ‘Registered providers must have an accurate, up to date and evidenced understanding of the condition of their homes that reliably informs their provision of good quality, well maintained and safe homes for tenants.’
20. Of the 11 current active gaps, 7 come under the Stock Quality specific expectation, 2 are rated as high Priority, meaning that any tasks or actions have been identified and are underway but are not yet business as usual. The rest are rated as medium priority, meaning the items have formed part of business as usual but may have a strong interdependency with other projects that are not yet complete.
21. The identified gaps and subsequent actions will be outlined below.
22. ‘Have you an accurate record at an individual property level of the condition of your stock, based on a physical assessment of all homes and do you keep this up to date?’
The repairs policy states that stock condition surveys will be completed every 5 years. Due to staffing issues the rate of surveying fell below the expected level. However, the stock condition action plan sets out the plan to have 98% of surveys completed by April 2026 and is back on track. This has been down to the employment of a further Stock condition surveyor and procuring an external provider to complete surveys. The progress of surveying is monitored through monthly compliance monitoring by the Portfolio Holder and a quarterly statutory compliance meeting, chaired by the Strategic Director. Other actions to ensure compliance include, addressing the properties that did not allow access and establishing which homes do not allow access on a general basis to understand the condition of the property and identify any other risks that may be present.
23. The following three identified gaps originate from one question but have been broken down into three separate action and progress update logs.
24. Do you use data from your records on stock condition to inform your provision of good quality, well-maintained and safe homes for tenants that meets the requirements of this standard? You must ensure:
a) Compliance with health and safety legal requirements.
There is a plan to increase the use of data to inform budgets for the next financial year 2026/27. It has also been identified that improvements are required in the evidencing of this happening. As previously stated, (para. 14) further work is required to address the homes that do not allow access. A new Resident Liaison Compliance Officer post was advertised in December. This post will take the lead in resolving access challenges for hard-to-reach properties, building relationships with residents, working toward ensuring essential compliance checks, such as gas servicing, electrical testing and water hygiene are completed within statutory timelines.
b) Compliance with the Decent Homes Standard
As stated above (para. 14) the stock condition action plan states the intention to have 98% surveys completed by April 2026. This also outlines how we get to the Decent Homes Standard and the requirement for tenants who wish to refuse works to their homes to sign an ‘Expression of Wish’ disclaimer. The recording and calculating of decent homes are likely to be impacted by the implementation of the new Maintenance and Repairs system.
c) Delivery of repairs, maintenance, and planned improvements to stock
This aspect of the question continues to be assessed as a high priority. While there is nothing wrong with either the repairs or planned improvements service, there continues to be a divide in that the two current systems do not talk to each other. This is something that will improve with the implementation of the new Maintenance and Repairs System.
25. Do you survey your homes frequently enough and in sufficient depth to remain assured about the quality and safety of your stock?
As previously stated, the action plan and survey target are working to ensure this happens. Training has also gone in to ensure operatives are able to spot other defects. For example, engineers have been trained in looking for damp and mould.
26. Do you ensure your approach to assessing and recording the condition of your homes is robust and kept up to date by using information from a range of relevant sources such as repairs, complaints, health and safety assessments and energy performance certificate (EPC) data to maintain a rounded view of property condition?
This is currently an ongoing medium priority action. While we do ensure our approach is robust, we recognise that the implementation of the new Maintenance and Repairs system will ensure the recording of this process will be more efficient.
27. In developing your understanding of the condition of your homes do you consider the needs of the individual tenants living in them? Do you consider the potential risk to tenants when identifying investment and repair requirements for their homes? Is this activity undertaken in an appropriate and timely manner?
This continues to be a high priority action. While at an individual level tenant’s needs are taken into consideration, for example when they have phoned through the hub. More work needs to be completed on using the data we hold about the tenants living in our properties to better understand and prevent potential risks from maintenance and repairs.
Decency
28. ‘Registered providers must ensure that tenants’ homes meet the standard set out in section five of the Government’s Decent Homes Guidance and continue to maintain their homes to at least this standard unless exempted by the regulator.’
29. When the self-assessment was initially conducted this action was highlighted as a gap. This was due to the process of identifying non-decent homes, offering the tenants of those properties works to be completed and working through any refusals or planning works, being new. However, this is now embedded into procedure as business as usual, it has therefore been completed.
Health and Safety
30. ‘When acting as landlords, registered providers must take all reasonable steps to ensure the health and safety of tenants in their homes and associated communal areas.’
31. As with the expectation above, any gaps initially identified under Health and Safety have now been completed. These include items such as identifying and meeting all legal requirements relating to the health and safety of tenants in their homes and communal areas. For example, communal areas checked weekly by one of the dedicated building safety officers who raise any repairs.
32. The safety of tenants has been and is considered in the design and delivery of landlord services, for example, through the review of all relevant policies, including the Damp and Mould policy.
33. An item raised under the extra ‘general health and safety’ section of the self-assessment that was raised as a gap and has now been assessed as being complete is around knowing whether messages on safety are getting through to tenants. Regular articles are published in the HomeTalk magazine, which is delivered to every council property, the building safety officers visit blocks and engage with tenants. The Tenant Satisfaction Measure data also shows good satisfaction around tenants feeling safe in their homes.
Repairs, Maintenance, and planned improvements
34. ‘Registered providers must provide an effective, efficient and timely repairs, maintenance and planned improvements service for the homes and communal areas for which they are responsible.’
35. There were 7 identified gaps from the self-assessment under repairs, maintenance, and planned improvements (2 of which came under the further section ‘customer service’). 4 of which are now assessed as being complete. The 3 further active gaps fall under the further ‘customer service’ section of the self-assessment.
36. The first completed gap was around setting timescales and clearly communicating them with tenants. The new Maintenance and Repairs policy clearly sets out the expected timescales and these will be promoted to tenants via the HomeTalk magazine. The second completed gap was ensuring the delivery of repairs, maintenance and planned improvements is informed by the needs of tenants and provides value for money. While the self-assessment process identified we were largely compliant it was felt this area required further review to ensure it is embedded in business as usual. During the period of review two examples of an effective procurement review process highlighted that contractors not performing at the expected level are being dealt with. The tenant involvement group are also kept informed as well as scrutinising the yearly accounts. These minutes are then published on the website.
37. The two completed gaps that fell under the sub-section of ‘customer service’ relate to having clear and comprehensive service standards and learning from complaints. As explained above all relevant policies have been updated and are published on the website. The housing service learning from complaints process has now had time to embed into business as usual and learning outcomes have started to identify failings in performance which have led to service improvements.
38. The three active gaps all share an interdependency with the implementation of the new Maintenance and repairs system and the corporate customer relationship management system. The first asks whether high levels of service user satisfaction are achieved with stock investment programme and asset management practices more generally. Similarly, the second gap asks the question, do you know what tenants think of your service? How do you plan to improve your repairs service to meet tenants needs? Currently satisfaction is measured through the TSMs. However, this is an area that could benefit from further resident insight.
39. The third active gap in this section is around how easy it is for tenants to report repairs. Currently, monitoring of the Housing Hubs response rate to telephone calls, emails and online forms takes place, but the digital option for tenants is currently limited by existing systems. The new maintenance and repairs system is the main solution in this improvement for tenants to be able to self-serve, see their notes, job history, and inspection certificates without having to request them.
40. The further extra section on Damp, mould and condensation has been assessed as compliant. A standalone policy has been developed and is now published on the website. Specialist posts deal with the increasing demand and relevant staff have all received accredited training.
Adaptations
41. ‘Registered providers must assist tenants seeking housing adaptations to access appropriate services.’
42. This is one of the areas of the consumer standards where it is worth reminding that they are written for all social landlords, and as a local authority, we also have the responsibility for the aids and adaptions service. Therefore, when the standard refers to the relevant organisations who will assist tenants seeking housing adaptions, as a council landlord this refers to the council.
43. The self-assessment process highlighted broad compliance with adaptions. However, two medium priority gaps were identified. These are around clearly communicating with tenants how they can seek assistance with the housing adaptions service and co-operating with tenants and other relevant organisations so that a housing adaptions service is available to tenants.
44. There is already a close working relationship between NFDC tenancy team, the allocations team, and Hampshire County Council to ensure the best use of properties. There is information published on the NFDC web pages for all. However, there is not anything specific in the landlord services area of the website. Therefore, a link is required from landlord webpages to the Aids and Adaptions information that is held under Private housing.
Taking the Lead
45. As previously explained the final ‘taking the lead’ section is not a specific expectation of the consumer standard. They are recommendations made by Housing Quality Network as a means of helping landlords meet the Regulator’s relevant standards around effective governance.
46. The self-assessment process highlighted that the governing body are aware of their responsibilities providing safe and decent homes, an efficient, effective, and timely repairs service and an adaptions service for those tenants that need it. The governing body are made aware and kept up to date through regular reporting to the Portfolio Holder and the Housing and Communities Overview and Scrutiny Panel. Further monthly updates to the Leader and Chief Executive have commenced and planned to go forward.
Analysis of Inspection Judgements – Safety and Quality Standard.
47. It is worth noting straight away that failings of the Safety and Quality Standard are the number one reason for landlord’s non-compliance with the Consumer Standards. Four of the top five issues of non-compliance are, stock condition data; repairs and maintenance service; health and safety compliance; performance oversight, with the fifth being tenant engagement and influence in meeting these standards.
48. At the time of writing this report, all five of the C4 inspection judgements state serious failures under the Safety and Quality Standard as reasons for fundamental change required and regulatory intervention. To date, all five have been local authority landlords.
49. Of the 39 C3 inspection judgements, 38 state failures under the Safety and Quality Standard. Of these, 33 are local authority landlords.
50. There have been 71 C2 judgements. Of these 62 state some weakness in the delivery of the Safety and Quality standard.
Corporate plan priorities
51. Priority 2: Empowering our residents to live healthy, connected and fulfilling lives.
52. Priority 3: Meeting Housing Needs – particularly in relation to the number of council homes achieving Energy Performance Certification Band C and percentage scores for the five safety and compliance management Tenant Satisfaction Measures (TSMs).
Consultation undertaken.
53. We understand that tenant consultation should be factored into any service investment and over 500 hundred tenants participated in the independent TSM data collection exercise about their perceptions regarding the safety and quality of their homes.
54. Consultation with tenants, Members, senior management as well with colleagues across the housing sector has been a strong focus of the preparation process including the learning from the Independent Mock Inspection recently undertaken and other external audits undertaken by Hampshire County Council in relation to Health and Safety social landlord requirements.
Financial and resource implications
56. Failure to raise standards, meet the regulatory requirements of the consumer standards and respond appropriately to complaints could lead to fines and compensation levied by the Housing Ombudsman or the Local Government and Social Care Ombudsman.
57. There are significant BAU demands on HR, Finance, and Procurement demands in running this critical part of the housing service due to our operating model of having an in-house Direct Labour Organisation with around 100 employees mostly trades. This labour is supplemented by several large contracts for planned works including kitchens and bathrooms plus energy efficiency works which are procured on regular timetable of works. These resources are recharged and paid for by the HRA along with several connected shared corporate posts in performance and transformation etc.
Legal implications
Risk assessment
59. This report gives assurance that NFDC currently provides a good overall service to its tenants as evidenced by the TSMs and the risk profile is professionally managed. It is nonetheless considered prudent to add any significant gaps in consumer standards to the corporate risk register due to the unknown timescales for inspection to maintain corporate oversight on this business-critical issue, but also what this means for the satisfaction services deliver to our tenants.
Environmental / Climate and nature implications
60. Whilst the report has no direct implications, the work of NFDC will include improving the energy efficiency of our local housing stock, providing better services on our estates, including open spaces, and the positive contribution to neighbourhoods. This may present further opportunities to contribute to the Council’s neighbourhood and climate objectives in the longer term.
Equalities implications
61. The Consumer Standards are likely to have a positive impact on NFDC tenants as there is a requirement under the Transparency, Influence and Accountability standard for landlords to ‘understand the diverse needs’ of tenants, including those arising from protected characteristics, language barriers, and additional support needs and assess whether all tenants have fair access to, and equitable outcomes of, housing and landlord services.
Crime and disorder implications
62. It is anticipated there will be potential indirect and direct positive impacts on the Council’s tenants and neighbourhoods. The interventions proposed through our improvement to tackling Anti-Social Behaviour as part of the consumer standards is likely to lead to an initial increase in the number of cases prosecuted in the courts, or by the Police, whilst long term interventions proposed should lead to a long-term reduction in crime and disorder.
Data protection / Information governance / ICT implications
63. The collection, retention and deletion of tenant data is governed by GDPR and associated guidance. All data will be collected and maintained in line with the required legislation. The Policies are required in the shorter-term at a service level to improve service delivery and outcomes. Once the service plan is fully adopted the policies will be updated in line with any changes required and will be continuously reviewed.
New Forest National Park / Cranborne Chase National Landscape implications
64. The approach of ensuring the Housing Service is fully compliant with the consumer standards including for housing neighbourhoods as well as home may involve increased and better partnership working with the National Park Authority where the Council’s housing stock is also located and managed by the housing landlord.
Conclusion
65. The Council has made considerable progress toward meeting the Safety and Quality Standard under the Social Housing Regulation Act 2023, demonstrating good overall compliance and embedding many improvements into business-as-usual processes. However, eleven active gaps remain, primarily relating to stock condition data, system integration, and tenant engagement. High-priority actions, including completing stock condition surveys, improving data use, and implementing the new Maintenance and Repairs system, are underway and monitored through robust governance arrangements.
66. While the current risk profile is managed well, the continued focus on improving our services for tenants and the unknown timing of regulatory inspection requires continued focus and oversight. By maintaining momentum on these actions and strengthening tenant engagement, NFDC will be well-positioned to achieve full compliance, deliver positive outcomes for residents, and uphold its corporate priorities.
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Appendices:
None.
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Background Papers:
Regulator of Social Housing Consumer Standards
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