Call for evidence outcome

Government response to the call for evidence for leasehold properties in social housing blocks

Updated 25 June 2025

1. Call for evidence: Mandatory checks on electrical installations for leasehold properties within social housing blocks

Q11. Would you support the introduction of a mandatory requirement for electrical installation checks in owner-occupier properties within social housing blocks?
Yes/No. Please provide supporting details.	Totals
Yes	101 (90%)
No	11 (10%)
Total	112

1. The call for evidence proposed mandating electrical installation checks (including fixed electrical equipment located on the consumer’s side of the electricity supply meter)^{[footnote 1]} in owner-occupied leasehold properties in social housing blocks. These checks would include the testing and inspection of these installations to make sure they are safe and comply with the technical requirements set out in BS7671 Requirements for Electrical Installations (also known as the IET Wiring Regulations). Following these checks, an Electrical Installation Condition Report (EICR) would be issued and provided to the party enforcing the checks.

2. The government notes that the majority of respondents (101 of 112) to the call for evidence supported the introduction of these mandated checks. Of these 101 respondents, 67 represented either a housing association or local authority, suggesting that these parties recognised the benefit that these proposals may have in respect of building safety. Other respondents in support of this proposal included electrical engineering companies, membership bodies representing the housing and electrical engineering sectors, and a Residents Management Company. Seven respondents did not provide a ‘yes’ or ‘no’ response, however four of these provided comments that indicated potential agreement if the regime is implemented correctly.

3. Reasons cited for extending this requirement to owner-occupied leasehold properties in social housing blocks mostly centred around better improving building safety as more checks being carried out would help to further reduce the risk of an electrical fire (see paragraph 17 for consideration of other tenures).

4. Some call for evidence responses (24 of 112) argued that this new regime would be difficult to implement and enforce due to potential issues around access rights and permissions (see paragraph 26), and may have a negative impact on the leaseholder-landlord relationship, with leaseholders potentially viewing the requirement as burdensome – either because the social landlord would need access to the property or because the leaseholder would be obligated to arrange the checks.

5. Those who highlighted difficulties with implementation or enforcement mostly represented housing associations or local authorities (18 of 24), though of these 18 responses, 13 were still in support of introducing these checks.

Q12. If yes, do you agree this requirement should apply every five years?
Yes/No. Please provide supporting details.	Totals
Yes	98 (92%)
No	9 (8%)
Total	107

6. 98 of 107 respondents agreed that requirements should mirror the regime in the private rented sector (PRS) and proposed scheme in the social rented sector (SRS) in respect of timings. Those who disagreed (nine of 107) with the obligation to provide an EICR every five years largely did so either because they opposed the proposals altogether, or because they felt that these checks should be more frequent, for example, between one and three years. Those who felt these checks should be carried out more often did not represent an organisation (two of nine), whereas those who disagreed from housing associations and local authorities (five of nine) were more likely to oppose the five-year period because they felt there were issues with implementing the new requirement.

Q13. What are your views on whether this requirement should be placed on owner-occupier leaseholders or their landlords?
Please provide supporting details.	Totals
Owner-occupier leaseholder	59 (61%)
The landlord	19 (20%)
Landlord and/or owner-occupier leaseholder	8 (8%)
Other	10 (10%)
Total[footnote 2]	96

7. The call for evidence set out two options regarding liability for arranging checks and repairs. These were:

• Option 1: The duty to arrange checks and associated repairs could be placed on social landlords. This may result in an additional administrative burden, the cost of which will likely be passed onto leaseholders.
• Option 2: A statutory requirement could be introduced to make leaseholders accountable for arranging checks. This would mean leaseholders would not be subject to administration or commission charges unless inspections lead to repair works in communal areas.

8. The majority of respondents (59 out of 96) felt that Option 2 should be introduced whereby there is a new statutory requirement for the leaseholder to arrange the checks. Concerns were raised over the additional administrative burden for social landlords if they were responsible for organising checks, whether the social landlord would be able to access the owner-occupier leaseholder’s property, and if this would damage the landlord-leaseholder relationship. Of these 59 respondents, 44 were from a local authority or housing association.

9. A minority of respondents (19 out of 96) favoured Option 1, with the social landlord having responsibility for electrical installation checks, noting that if the requirement lay with owner-occupier leaseholder, this may create patchwork compliance with the scheme. Other reasons for giving the social landlord responsibility included concerns over affordability for owner-occupier leaseholders in social housing blocks, aligning with existing safety requirements – such as those set out in the Building Safety Act 2022, as well as increased risk for the social landlord’s property if the scheme is not properly enforced. 14 of these respondents represented local authorities or housing associations.

10. A further eight respondents argued that the requirement should lie with the social landlord and/or the leaseholder.

Q14. If this requirement were to be placed on the owner-occupier, do you have any views on how it should be enforced?
Please provide supporting details.	Totals
By the landlord	16 (19%)
Through the courts / legal system	4 (5%)
Through the lease terms	10 (12%)
By the local authority	23 (27%)
Through fines	7 (8%)
As a condition of the buildings insurance	3 (4%)
Other	21 (25%)
Total[footnote 3];	84

11. When asked in the call for evidence, respondents held mixed views about how this scheme could be enforced. A few respondents (23 of 84, 20 of whom were from local authorities or housing associations) felt that local authorities would be a suitable enforcement body as they would have greater oversight over both the SRS and PRS, as well as owner-occupied leasehold properties in social housing blocks.

12. Others felt that the social landlord (including housing associations) should have the right to enforce the regime (16 of 84) – this cohort was more mixed and included housing associations, electrical engineers, and membership associations. A few felt that this could be done through the lease terms (10 of 84, eight of whom were from a local authority or a housing association) or by relying on the legal system (4 of 84 – three from a housing association and one from a membership body). A few respondents (7 of 84, 6 from a local authority or housing association) advocated for a fixed penalty regime, such as those found in Energy Performance Certificate schemes, as a suitable measure for encouraging the social landlord to carry out their duties in a timely manner.

Q15. Do you have any views on how best to minimise the cost burdens of extending these requirements to owner-occupying leaseholders in social housing blocks?
Please provide supporting details.	Totals
The landlord arranges the checks or uses existing contractor contacts to offer a reduced price	36 (42%)
Through the service charge	15 (18%)
Owner-occupier pays	8 (9%)
Market adopts competitive rates	4 (5%)
Grant funding or government-backed schemes	4 (5%)
Through use of new technologies	2 (2%)
Other	16 (19%)
Total[footnote 4]	85

13. When asked how to reduce costs for owner-occupier leaseholders, a few respondents argued that the social landlord could arrange the checks and pass down the cost through the service charge (15 of 85), or offer contracted rates (i.e. through their links with contractors) for the service on an optional basis (36 of 85) – of the two groups who suggested using the service charge or contracted rates, 36 respondents were from local authorities or housing associations. Other suggestions included introducing a government-backed scheme (four of 85) or allowing the market to adopt competitive rates (4 of 85). Eight of 85 respondents felt that the importance of the checks outweighed any need to reduce costs for leaseholders, and that they should find a way to fund the works without assistance. Seven of eight respondents in this group came from local authorities or housing associations.

2. Government response

Mandating electrical installation checks in owner-occupier leasehold properties in social housing blocks

14. As set out in the call for evidence, mandating electrical safety checks and obtaining an EICR at least every five years in owner-occupied leasehold properties in social housing blocks is estimated to have a total net cost to leaseholders of between £50.1 million and £102 million (with a central scenario cost of £76.5 million) over the initial ten-year appraisal period.

15. The anticipated average cost to leaseholders to carry out an electrical safety check is £170.67 where the landlord is a registered provider and £164.80 where the landlord is a local authority, although there is likely to be significant variation across the sector depending on bedroom size and geographical location. On average, if leaseholders were required to conduct an electrical safety check every five years, that would equate to a cost of between £32.96 and £34.13 per year per property.^{[footnote 5]} We find this cost to be acceptable when considered against the importance of building safety, particularly where these checks help to prevent lives from being lost or injury being caused by an electrical fire.

16. We agree that this policy should be implemented to ensure consistency of checks in social housing blocks, providing peace of mind and reassurance that residents are living in a safe environment. It is important that the structural integrity of electrical installations within the building are up to standard, and that where these checks are required, compliance is widespread. We intend to explore the option of legislative changes to bring forward these proposals.

17. The call for evidence only explored mandating these checks for owner-occupied leasehold dwellings in social housing blocks. In light of the themes raised by the responses to the call for evidence, we will keep under review the case for extending the requirements to other multi-occupancy developments (for example, commonhold, or leasehold in the private sector) in future.

Frequency of checks

18. We are of the view that electrical installation checks should be carried out at least every five years to ensure a consistent approach to electrical safety and enable a simpler application of the scheme. We note that some dwellings will have already been checked and an EICR issued. Under this scenario, the EICR will be valid for five years (unless stated otherwise in the report) and will not require another check until that period has elapsed. Further discussion of this is set out in paragraphs 20 to 23. New checks may be required if there are new electrical installations, which are not covered elsewhere by legislation.

19. By introducing similar regime standards, there will be greater clarity over what these responsibilities entail, such as how often the checks are required, which will in turn lead to better compliance.

Responsibility for the checks

20. On balance, we felt that giving leaseholders autonomy over their property and control to decide the cost and appointment of their own contractor is a compelling factor for our decision. We believe that the leaseholder (including shared owners) should have the duty to arrange checks and obtain an EICR for their demised premises – i.e. checks of a demised premises’ fuse board to the plug sockets within the demised premises.

21. This will also enable simpler application of the scheme as some leaseholders in the block may have already obtained an EICR for other purposes. If the social landlord has responsibility for arranging the checks, the leaseholder who has an EICR is likely to remain liable for paying the costs through the service charge. By placing a new responsibility with the owner-occupier leaseholder and retaining the existing requirement for PRS landlords to obtain an EICR, this will prevent duplication of checks and avoid higher costs for leaseholders where they have already obtained an EICR for other purposes.

22. The call for evidence did not ask a specific question on who would be responsible for remediation works and how this would be implemented but this was understandably raised in some call for evidence responses. Where a problem is identified within a leaseholder’s property (known as the demised premises), the leaseholder will be responsible for organising and fronting the cost of any repair works in line with the terms of the lease.

23. We recognise that if owner-occupier leaseholders have the duty for arranging checks, this may reduce compliance with the scheme – such as where a leaseholder is absent – which could risk the safety of the block. For this reason, we will grant the social landlord powers to enforce these checks. If the leaseholder fails to repair any faults within their demised premises within the statutory timeframe, as per the existing EICR regulations^{[footnote 6]}, the social landlord will then be able to enforce for non-compliance, including for breaching the terms of the lease if appropriate. (See: paragraphs 24-26).

Enforcement

24. We are of the view that the social landlord should enforce the checks in the leaseholder’s demised premises (i.e. the leaseholder’s dwelling).

25. Where the leaseholder is responsible for supplying the social landlord with a valid EICR and fails to do so, this may be classed as a breach of the lease. We propose that the social landlord be granted legal powers to go to court for an access injunction so that they can enter the property and check the electrical installations. If the EICR notes a fault with the installation, the social landlord will then be able to arrange repair works and charge the costs of this back to the leaseholder, along with any costs associated with accessing the property and arranging the checks.

26. We recognise that there may be some concerns about a social landlord having access to owner-occupied leasehold properties and the potential interference this could have on the leaseholder-landlord relationship. It is our understanding that most leases will already contain a standard clause that the leaseholder should allow access for the landlord to check for disrepair, or alternatively covenants will mean leaseholders have to comply with statutory requirements. We intend to explore the option of legislative changes to give social landlords a right to go to court to get an access injunction to undertake electrical installation checks in case the leaseholder fails to carry out the check and the social landlord has to take enforcement action.

Minimising cost burdens

27. As the social landlord will already be arranging these checks for SRS tenants, it seems appropriate that this service be offered by the social landlord to the leaseholder at the same time. Having one party carry out the checks may promote cost effectiveness and create more flexibility and convenience for the leaseholder, as the registered electrician will have increased business and will not need to make multiple visits to the building.

28. We acknowledge the financial merits of the social landlord offering to arrange the checks for the leaseholder. It will not be compulsory for the leaseholder to accept this offer, and if agreed, the arrangement will constitute a separate contract between the leaseholder and the social landlord and will not constitute a service charge. Leaseholders can also choose to arrange privately for a registered electrician to carry out these checks and provide an EICR certificate to their social landlord.

29. Existing legislation already prevents leaseholders from paying for any checks or repair works undertaken by the social landlord in respect of its social rented units. This will not change.

30. A government-backed scheme will not be implemented at this time as we anticipate that the market will self-adjust to adopt competitive pricing for these checks.

Other considerations

31. In response to question 16, a range of issues were raised by respondents including the complementary role of Portable Appliance Testing (PAT testing) to prevent fire outbreaks, and the need to check certain electrical installations such as fire alarms, or installations owned by the power distribution company.

32. Respondents also questioned who holds the responsibility for the checks where the leaseholder is also a PRS landlord, and the timescale for rolling out these changes. Some respondents called for immediate implementation whilst others suggested having a lengthier transition period to allow social landlords to familiarise themselves with the new requirements.

33. We will reflect on these comments as we further develop an implementation plan for the electrical installation inspections.

Mandating Portable Appliance Testing

34. Portable Appliance Testing (PAT testing) deals with individual appliances rather than the structural integrity of the electrical supply which is covered by the EICR. PAT testing was outside the scope of the call for evidence and as such there was no consultation on whether to mandate PAT testing for leasehold properties in social housing blocks. The average household has many individual appliances, and we note the importance of PAT testing in supporting building safety measures.

Buildings insurance

35. Several respondents raised buildings insurance throughout their answers to the call for evidence. Buildings insurance generally covers structural damage to a property, such as that caused by fire or flooding. In the context of leasehold tenures, it is usually the landlord’s responsibility to insure the building, and a proportionate contribution then paid by the leaseholders in the building through the service charge.

36. Some respondents queried whether buildings insurance would be invalid if these checks are not carried out in time, with others suggesting that this could be a mechanism for enforcing adherence with the scheme.

37. The duty holder for the insurance policy will need to ensure that they meet the requirements of their insurance company, which may or may not require an EICR, depending on the terms of the individual insurance policy. Buildings insurance, however, will not be a regulatory tool for the new electrical safety regime.

Glossary

Electrical Appliance: A portable electrical good, including electrical white goods (e.g. cookers, refrigerators and washing machines). Portable appliances generally have a cable and a plug.

Electrical Installation: Electrical installations cover all aspects of the supply, distribution and use of electrical power in the house from the consumer unit (where the electric supply connects to the wiring in the house) to the point of use at the switch or socket-outlet.

Electrical Installation Condition Report (EICR): A report carried out by a skilled person that confirms that the electrical installation is satisfactory for continued use and where identified details any remedial works required.

The Electrical Safety in Social Rented Homes Working Group: (Also known as the SRS Electrical Safety Working Group) The Electrical Safety in Social Rented Homes Working Group was a stakeholder working group formed by the Department for Levelling Up, Housing and Communities (DLUHC) (now Ministry for Housing, Communities and Local Government (MHCLG)) to inform the content of this call for evidence.

The Electrical Safety Standards in the Private Rented Sector (England) Regulations 2020: The regulations require that landlords have property electrics checked at least every five years by a properly qualified person. The electrics must meet standards and landlords must give their tenants proof of this.

Electrical Safety Standards: Standards specified in, or determined in accordance with, the regulations in relation to the installations in the premises for the supply of electricity, or electrical fixtures, fittings or appliances provided by the landlord.

Hazard: As set out in the Housing Health and Safety Rating System (HHSRS) Operating Guidance, a hazard is any risk of harm to the health or safety of an actual occupier of accommodation that arises from a deficiency in the dwelling. This includes hazards at both the category 1 and category 2 levels.  

Housing Association: Non-profit organisation set up to provide affordable homes for those in need.

Inspection: Examination of an electrical installation using all the senses as appropriate.

Leasehold: A form of ownership normally used for flats (but occasionally for houses) that is a long tenancy, providing the right to occupation and use of the property for a long period – the ‘term’ of the lease. A long lease is a lease originally granted for a term of more than 21 years. The building structure and any common parts are usually owned by the freeholder who is likely to be the landlord.

Leaseholder: A person who buys a leasehold property on a long lease.

Local Housing Authority: In England and Wales, local housing authorities are the unitary authorities, district councils, the Council of the Isles of Scilly, the London Borough councils and the Common Council of the City of London.

Owner-Occupier Leaseholders: An owner-occupier leaseholder is a person who owns the property in which they live on a leasehold basis.

Portable Appliance (PAT) Testing: PAT tests are the process of checking electrical appliances for safety and can include a series of visual inspections and electronic tests. The technical name for a PAT test is In-Service Inspection and Testing of Electrical Equipment (ISITEE).

Private Registered Provider: A registered provider of social housing in England that is registered with the Regulator of Social Housing and is not a local authority. Most are housing associations.

Private Rented Sector (PRS): The housing tenure consisting of properties owned by private landlords and rented to tenants.

Registered Provider (of social housing): A social landlord registered with the Regulator of Social Housing. They may be local authorities or private registered providers of social housing.

Repair Works: Action taken to address and eradicate hazards identified within a home.

Shared Ownership Lease: An arrangement under which a leaseholder purchases an equity stake in a house or flat (between 10% and 75%) and pays rent to the landlord on the remainder. The lease permits the leaseholder to acquire additional equity in the property over time (a process known as ‘staircasing’), usually up to 100% with some limited exceptions.

Social Landlord: A local authority landlord or private registered provider of social housing (such as a housing association). Social landlords typically own the freehold of a building in which there are leasehold properties but they may hold a long lease themselves of all or part of the building.

Social Rented Sector (SRS): Homes for rent that are owned and managed by local authorities and private registered providers. This includes general needs, affordable rent and self-contained supported housing. This does not include shared ownership homes, rent to buy, or similar schemes. It also does not include other types of housing which have their own safety standards such as Houses in Multiple Occupation (HMOs), care homes, student halls of residence, hostels, hospices and other accommodation relating to healthcare provision.

Social Resident: In this consultation response, social resident or ‘resident’ refers to someone who rents their home from a social landlord.

Tenancy: Agreement between a tenant and a landlord.

Tenant: Someone who rents their home from a social or private landlord, including those who own a percentage of the home and rent the remaining share from a social landlord (i.e. shared owners).

The Regulator of Social Housing (RSH): An independent regulator which regulates providers of social housing (including local authority and private registered providers) in England. Its principal role is to promote a viable, efficient and well-governed social housing sector able to deliver and maintain homes of appropriate quality that meet a range of needs.

Annex A: Breakdown of respondents and lists of organisations that responded

Details of respondents	Totals
Individuals	27 (23%)
On behalf of an organisation	90 (74%)
Not provided	2 (3%)
Total	119

List of Organisations who responded

• Abri
• Anchor
• Ashfield District Council
• BEAMA
• believe housing
• Blackpool Borough Council
• Blackpool Coastal Housing
• My Blackpool Home
• Blenheim Gardens Resident Management Organisation
• Brent Housing Management, Brent Council
• Bristol City Council
• Broadland Housing Association
• CBM Group Ltd
• Certsure (NICEIC)
• Chartered Institute of Housing
• Chartered Institution of Building Services Engineers
• CHP
• Citizen
• Clarion Housing Group
• Connected Innovations
• Connexus Housing Association Ltd
• Crawley Borough Council
• Curo
• Dudley Metropolitan Borough Council
• Electrical Contractors Association
• Electrical Safety First
• Electrical Safety Roundtable
• emh
• Epping Forest District Council
• Flagship Group
• ForHousing
• Futures Housing Group
• G15
• Grand Union Housing Group
• Greatwell Homes
• Halton Housing
• Housemark
• Institution of Engineering and Technology
• L&Q
• Langstane Housing Association ltd
• Leeds City Council
• LiveWest Homes Limited
• London Borough of Hammersmith and Fulham Council
• London Borough of Lambeth
• Lumen
• Magna Housing Ltd
• Manchester City Council
• Mendip District Council
• Mid-Bucks Electrical Training Ltd
• Midland Heart
• Moat Homes
• NAPIT
• National Federation of ALMOs
• National Housing Federation
• National Housing Maintenance Forum
• North Kesteven District Council
• North Tyneside Council
• Norwich City Council
• Notting Hill Genesis
• Nottingham City Homes
• Paradigm Housing Group
• Penge Churches Housing Association
• Places for People
• Planet Gas and Electrical Solutions
• Platform Housing Group
• Progress Housing Group
• Redkite Community Housing
• Rochdale Boroughwide Housing
• Safety-Logic (Health, Safety and Compliance) Ltd
• Saffron Housing Trust
• Silva Homes
• South Gloucestershire Council, Private Sector Housing
• South Kesteven District Council
• Sovereign Housing
• Sovini Group (Incorporating One Vision Housing and Pine Court Housing Association)
• St Leger Homes Doncaster
• Stockport Homes Group
• Thanet District Council
• The Pioneer Housing & Community Group Ltd
• Thirteen
• Thrive Homes
• Thurrock Council
• Together Housing Association
• Unitas Stoke on Trent Limited
• VIVID
• Walsall Housing Group Limited
• Wandsworth Council
• Watford Community Housing

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1.  Regulation 2(1) of the Building Regulations 2010.  ↩

2.  23 respondents did not directly respond to the question or provided no response, as they did not have strong views or could not agree which party should have responsibility for the checks. ↩

3.  35 respondents did not answer this question, likely because they felt unable to provide a detailed response. ↩

4.  34 respondents did not answer this question, likely because they felt unable to provide a detailed response. ↩

5.  Paragraphs 126 to 131, Consultation and Call for Evidence on electrical safety in the social rented sector, June 2022. ↩

6.  Guide for landlords: electrical safety standards in the private rented sector, October 2021. ↩