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Assessment of Initial Judgments in Consumer Regulation

Examining Initial Judgements in Consumer Regulation for Social Housing Providers by Campbell Tickell, aiming to uncover valuable understandings that can aid clients in presenting evidence demonstrating compliance with the new Consumer Standards. Six months into the active regulation of English...

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Insights into the Initial Decisions Made in Consumer Regulation
Insights into the Initial Decisions Made in Consumer Regulation

Assessment of Initial Judgments in Consumer Regulation

In the six months since the new English social housing regulatory regime was introduced, local authorities (LAs) and housing associations (HAs) have been assessed against consumer standards, with grades ranging from C1 (highest) to C4 (lowest).

The largest share of the grades published to-date is the middle C2 grade, with 38%, followed by C3 with 35%, indicating 'serious failings'. Surprisingly, no LA has received the top grade of C1, instead 69% have been assigned a C3. In contrast, half of HAs graded so far have received a C1.

The key themes and consumer standards driving the C1 to C4 grading system focus on tenant services, governance, tenant engagement, and housing quality.

Consumer Standards and Grading:

Landlords are assessed against consumer standards, with grades ranging from C1 (highest) to C4 (lowest). Achieving a higher C1 grade reflects landlords’ strong performance in service delivery, while C3 and C4 indicate significant challenges in meeting standards.

Key Themes Driving C1 to C4 Grades:

  1. Tenant Services Variation: There is wide disparity among landlords in delivering tenant services, with private registered providers generally achieving better consumer gradings than local authorities, which face greater pressures and are newer to the regulatory regime.
  2. Commitment and Progress: While many landlords show dedication to improve, some tenant engagement practices and decency standards evolve gradually and require more time to fully embed.
  3. Governance: Robust governance, including strong leadership and risk management oversight, is fundamental to delivering positive tenant outcomes and achieving higher grades within the consumer standards framework.

Consumer Standards Components:

  • Tenant Engagement: Effective communication and responsive services to tenant concerns are critical factors in grading.
  • Housing Quality: Ensuring homes meet decency and safety standards influences grading outcomes.
  • Transparency and Accountability: Landlords must demonstrate timely and transparent responses to service failures or issues.

The Regulator issues a C3 grade where it judges there to be 'serious failings' in the landlord delivering the outcomes of the consumer standards and significant improvement is needed. Weaknesses in meeting the Safety and Quality Standard are mentioned in 92% of the 13 C2s awarded to date. Weakness in meeting the Transparency, Influence and Accountability Standard are cited in 54%.

Common weaknesses identified in C3s include incomplete and out-of-date data on health and safety, failure to meet health and safety regulations or improve performance, outdated or incomplete stock condition data, poor data accuracy impeding effective prioritisation of stock investment, not meeting timeliness and quality standards for repairs service, significant and persistent numbers of outstanding repairs, poor or declining tenant engagement, inadequate complaint handling.

In awarding a C1 to nine HAs to date, the RSH has concluded that they are delivering the outcomes of the consumer standards and have demonstrated that they identify when issues occur and put plans in place to remedy and minimize recurrence. Of the nine C1s awarded to date, four mention areas where the organization has identified room for future improvements. The scale of the gaps are not considered large, that the RSH has confidence that progress is being made, and that the Board is driving a credible improvement plan.

The new regime has brought local authorities into the world of publicly available Regulatory Judgements (RJs) and C grades, as they were not regulated by the RSH on Governance and Viability before. As of now, 34 RJs have been published, with 12 triggered by regulatory engagement and 22 following from an Inspection. The Safety and Quality Standard is cited in all but two of the RJs where a C2 or C3 grade was awarded. The Transparency, Influence, and Accountability Standard follows in frequency, appearing in 52% of the below-C1 grades.

In comparing the narratives of the nine C1s and the thirteen C2s, it is beginning to be seen how the regulator allows for an organization that has some room for improvement to nevertheless gain a C1. For the most part, the language in a C1 RJ reflects that in the definitions of the Consumer Standards.

[1] Regulator of Social Housing. (n.d.). Consumer Standards and Grading. Retrieved from https://www.rsh.gov.uk/regulation/consumer-standards-and-grading/ [3] Regulator of Social Housing. (n.d.). Consumer Standards Components. Retrieved from https://www.rsh.gov.uk/regulation/consumer-standards-and-grading/consumer-standards-components/

  1. The housing quality in certain neighbourhoods might be influenced by the landlord's performance, as robust governance and housing quality are essential components of the consumer standards that determine a landlord's grade.
  2. Businesses in the education-and-self-development sector could potentially leverage the new social housing regulatory regime to improve their offerings, as some tenant engagement practices and decency standards evolve gradually and require more time to fully embed.
  3. The financial stability of local authorities and housing associations may be affected by their performance under the consumer standards, as significant failings in meeting the stated standards can lead to 'C3' grades, indicating serious challenges in service delivery.

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