Our regulation of social housing in Scotland, a blog from our Chair, George Walker

01 October 2018

We are gearing up to launch the consultation on our new Regulatory Framework in October. I wanted to give a brief update ahead of that. The consultation proposals have been shaped by the invaluable feedback we’ve had from stakeholders so far. Thank you again for your input, and I hope that you will continue to share your views and ideas with us through the consultation. To help you plan and to involve governing bodies and committees where necessary, here’s what’s happening next.

The consultation will run for just over nine weeks, from 9 October until 14 December. During that time we’ll be out and about speaking at meetings and events, including landlord roundtables organised by SFHA and GWSF’s annual conference. We are also working with TIS and TPAS to run ten events for tenants across the country. We’re keen to discuss our thinking and hear feedback from as many of you as possible.

The consultation package will be fairly sizeable, as we are consulting on our full Regulatory Framework and all of the statutory guidance that sits alongside it. We’ve aimed to break it up into bite-size pieces, and to keep all of the documents as short and easy to understand as possible. We’ll also publish a narrative report alongside the draft Framework and guidance, which we hope will help readers navigate the consultation package. The report will explain how our thinking has developed from the early ideas in the discussion paper, how we have responded to feedback, and highlight the main changes we are proposing.

Our proposals aim to support responsible landlords to do the right things. There are three main areas where we will be proposing to do something new, or most changed from our current approach. These are to:

  • support landlords’ self-assurance;
  • make it easy for landlords to see what they need to do; and
  • be clear about our regulatory view of RSLs.

We will be proposing the introduction of an Annual Assurance Statement for every landlord. We see this as a way to support RSL governing bodies and local authority committees to get the assurance they need that their organisations are well-run, so can deliver what tenants and other service users need and want at a price they can afford to pay. We’ve developed the detail in discussion with stakeholders, including a working group of volunteer RSLs who have really helped us to work through how we can make the Statement work in practice.

Linked to this, we want to make it easier for landlords to see what they need to do, so they can assure themselves that they are doing it. We have moved all of the regulatory requirements for landlords into one part of the draft Framework for consultation. That means that landlords will have a single go-to-place. The vast majority of these requirements are not new, but they are peppered throughout the current Framework.

We also propose to introduce Engagement Plans for each landlord, both for RSLs and local authorities. The Plans would set out clearly what each landlord needs to do and how we are engaging with them.

Many people we have talked with have stressed the importance of us being transparent in this way, and particularly about us stating clearly our view of each RSL. At the moment we state the engagement level we have with each RSL – high, medium or low – rather than our regulatory judgement about them.  So, having considered this, we believe it is right that we should make our regulatory view of each RSL readily available to tenants and others.  

We propose to focus this around our judgement on each RSL’s compliance with the Standards of Governance and Financial Management and other regulatory requirements.  We’ve been talking to the working group, and others, about this over the summer.  This has helped us to develop the approach that we’ll consult on.

The main thrust of our new Framework is about promoting and supporting a culture of assurance, openness and transparency. As Chair of SHR’s Board, I see open discussion and feedback from our stakeholders as a vital way for us to get assurance that we are regulating in the right way. I look forward to discussing the proposals with many of you over the coming months, and I welcome your feedback.

George Walker 

Chair 
 

Read our earlier blogs on our regulation of social housing in Scotland: