Guidance

2026 to 2027 Compliance Audit checklist for schemes not delivered through Strategic Partnerships contracts

Updated 15 May 2026

Applies to England

Purpose of this checklist

This checklist is for independent auditors undertaking compliance audits under Affordable Homes Programme (AHP) and Shared Ownership and Affordable Homes Programme contracts.

It only applies to schemes not delivered through Strategic Partnership contracts.

Relevant programmes

Affordable Homes Programme (AHP) 2015 to 2018

Shared Ownership and Affordable Homes Programme (SOAHP) 2016 to 2021

Affordable Homes Programme (AHP) 2021 to 2026

Social and Affordable Homes Programme (SAHP) 2026 to 2036

Care and Support Specialised Housing Fund (CASSH)

Move On Fund

Next Steps and Rough Sleeping Accommodation Programme 2021 to 2024

Single Homelessness Accommodation Programme (SHAP)

This checklist is to ensure that requirements and funding conditions for AHP contracts have been met in accordance with the Capital Funding Guide (CFG).

All audits are undertaken online through the Compliance Audit system.

This document is for information only and is not intended to be used to record or submit information regarding any audit.

All questions in the Compliance Audit system require one of the following answers:

• yes
• no
• not applicable

You should include explanatory text to provide full details.

The numbers given in this guidance will not correspond with the numbers of the questions presented in the Compliance Audit system for individual schemes selected for audit.

General

1.

Has a comprehensive scheme file (or equivalent) been provided containing all relevant documents as set out in the CFG?

If no, provide details of what documents are missing.

Auditor notes

Check for documentation omissions. For example, dated valuation, consultants’ appointment and so on.

Attachments are required only to support specific audit findings or to evidence any mitigating circumstances. There is no requirement to upload complete scheme file as a matter of course. 

For more information, read CFG — Programme Management — Reporting and audit requirements.

2.

Was planning permission free from conditions that would make development ineligible for grant funding?

If no, provide reason and explanation.

Auditor notes

For more information, read CFG — Procurement and Scheme Issues — Planning Permission and Building Regulations.

3.

Does the purchase price of the land / property, match the data certified in the system?

If no, provide reason and explanation.

Auditor notes

Check for documentation omissions. For example, dated valuation, consultant appointment, and so on. There is no requirement to upload complete scheme file as a matter of course.

For more information, read CFG — Programme Management — Reporting and audit requirements.

4.

Where required, were other specified consents obtained for the relevant works?

If no, provide reason and explanation, or select ‘No other specified consents applied.’

Auditor notes

Check if other consents apply and if they were obtained.

For example:

• party wall award
• listed building consent
• permission to demolish
• Environment Agency remediation plan

For more information, read CFG — Programme Management — Audit Scheme File.

5.

Where there is documented evidence of factors that may adversely affect mortgageability, have relevant expert reports been obtained and, where applicable, has necessary warranty been documented?

If there is no documented evidence of factors, select ‘There is no documented evidence of factors that may adversely affect mortgageability’.

If there is documented evidence and relevant expert reports have been obtained or warranty has been documented, select ‘Yes’ and provide an explanation of what these factors were and how the risks associated with them were mitigated.

For example:   

• NHBC Buildmark certification or equivalent 
• valuation 
• structural report
• site investigation
• solicitor’s report
• indemnity insurance
• insurability of innovative house building systems

If there is documented evidence and relevant expert reports have not been obtained or warranty has not been documented, select ‘No’ and provide an explanation of what these factors were, and risks associated with them.

Auditor notes

Check filed documentation, noting which documents have been seen and their date.

House builder warranties / CML cover notes must be available on completion.

This question applies equally to both look-back and in-year schemes.

Attachments are required only to support specific audit findings or to evidence any mitigating circumstances.

For more information, read CFG — Procurement and Scheme Issues — Procurement.

6.

Where there are variations to agreed submitted standards, have these been authorised by Homes England?

If no, provide reason and explanation, or select “No variation to submitted standards”.

Auditor notes

Check files against submitted and agreed standards in IMS to ensure that any variations have been agreed by Homes England.

Note:

• documentation seen
• authoriser
• date of authorisation
• details of agreement (including reasons for variation)

For more information, read AHG Grant Agreement and CFG — Programme Management — Changes to Agreed Allocations.

7.

Has the provider obtained an independent valuation report for the site/property acquired?

If yes, provide details of evidence on file:

• valuation method
• date of valuation
• property or land acquisition date
• property or land value

If no, provide reason and explanation.

Auditor notes

For multiple valuations add the latest in the specified fields, and specific details of all others in the reason and explanation box.

A valuation does not necessarily need to be undertaken by an individual or organisation external to the grant recipient organisation, provided that the valuer is a MRICS Registered Valuer and adheres to the standards within the CFG (for exceptions to this read CFG — Procurement and Scheme Issues — Valuations — Sales Valuations).

In particular, when appointing an individual or organisation that is not fully independent of the grant recipient organisation, due consideration should be given to ensure there is no actual, or potential for, conflict of interest in the assessment of the valuation and that the grant recipient organisation is fully satisfied that any valuation provided will be impartial.

For more information read, CFG — Programme Management — Reporting and audit requirements — Audit requirements — Audit scheme file, and Procurement and Scheme Issues — Valuations.

Development

8.

Was secure legal interest held in the land / property:

• at the date of the first grant claim (having obtained this interest on, or before, the claim date)
• in one of the forms stated
• with an appropriate lease length or condition (where applicable)
• in the name of the grant recipient or relevant consortium member
• as defined in the grant agreement and CFG

If no, provide reason and explanation.

Auditor notes

Refer to the title document and verify against relevant CFG requirement and grant agreement.

If constitutional change has occurred, provide details, including company names involved and the date the change occurred. This may, for example, include, but is not limited to:

• a change in the organisation’s ownership
• a change in the company structure
• amalgamations
• transfer of engagements
• mergers
• de-mergers

9.

Does the land / property have either of the following:

• ‘Good Title’ as defined in the CFG
• defective title indemnity insurance in favour of the grant recipient, with a limit of indemnity equal to at least firm scheme grant for the site

If no, provide reason and explanation.

Auditor notes

Checks to include freehold, leasehold and any empty homes.

Check solicitor’s report on title or lease if one has been prepared, and a copy of the Land Registry extract. 

Where an acquisition grant claim is being made, the provider must have either the freehold or long leasehold interest prior to drawing down grant. A conditional interest / indemnity insurance would be insufficient. 

For more information, read CFG — Procurement and Scheme Issues — Acquisition — Property title.

10.

Have all of the following been achieved prior to Start on Site claim:

• the main building contract has been signed and dated (works order is acceptable where only minor works were undertaken) 

• contractual possession of the site has passed to the contractor

• Start on Site works have commenced

If any requirements have not been met, provide reason and explanation.

Auditor notes

Check site possession date recorded in signed and dated building contract. If contract dates do not reconcile, record detail and reason. 

Homes England requires assurance that the contractor has entered a legally binding contract covering the whole of the works required for the development. Therefore, a letter of intent, even where it creates a legal obligation to carry out part of the works or works up to a particular value, is not acceptable. 

Where the building contract is signed by a legal entity other than the grant recipient, for example a development company, this may be acceptable where the entity is a wholly controlled subsidiary. The independent auditor should establish whether the grant recipient has sufficient oversight of the entity’s board and control over its business decisions. 

Where the first grant claim is an acquisition tranche (consider whether this applies for profit), the grant recipient will need to have the freehold or long leasehold interest, not merely a conditional interest, prior to drawing down grant. 

For more information, read CFG — Finance — Grant Claims and Payments.

11.

Is or was adequate insurance in place during development to cover the scheme for the full cost of the works during development?

Provide full details of the insurance arrangements and clarify the adequacy of the arrangements for grant recipient / build contractor. 

If no, provide reason and explanation.

Auditor notes

Arrangements such as a group insurance that covers a portfolio value rather than specific property may be sufficient, where they provide adequate insurance cover for the full replacement value. 

Where the provider is a developer and isn’t retaining ownership, the Deed of Adherence means that this question can be answered by the landlord. 

Homes England expects the insurance arrangements to cover all of the required circumstances set out in the CFG. 

For more information, read CFG — Procurement and Scheme Issues — Scheme types and requirements.

Post-development

12.

Was the Practical Completion certificate in place at the point of the final (Practical Completion) grant claim?

If no, explain the reasons.

Auditor notes

Check certificate date against final cost and Practical Completion final claim date and that it corresponds to the building contract.

Check that CFG definition of Partial Possession or Practical Completion was met prior to final grant claim.

For more information, read CFG — Programme Management — Milestones — Practical Completion, and CFG — Finance — Grant Claims and Payments — Final (Practical Completion) claim.

13.

Is adequate insurance in place to cover the completed scheme for its full replacement value?

If no, provide reason and explanation.

Auditor notes

Arrangements such as a group insurance that covers a portfolio value rather than specific property may be sufficient, where they provide adequate insurance cover for the Full Replacement Value.

Where the provider is a developer and isn’t retaining ownership, the Deed of Adherence means that this question can be answered by the landlord.

Homes England expects the insurance arrangements to cover all of the required circumstances set out in the CFG.

For more information, read CFG — Procurement and Scheme Issues — Scheme types and requirements.

14.

Were all necessary planning consents obtained by Practical Completion?

For example, were all reserved matters and conditions precedent signed off by the planners prior to the completion of the scheme?

If no, provide reason and explanation, or select ‘No planning consents were required or reserved matters and conditions precedent’ as appropriate.

Auditor notes

Check if all necessary consents have been obtained by Practical Completion stage of the site.

If not, seek evidence that

• steps have been taken to obtain them
• the delay is only due to late issue by the Local Planning Authority, and
• there is no known reason why consents won’t be given or issued

In the event of planning consent not being granted before audit, note the detail of planning condition discharge outstanding (if applicable) and attach planning approval notice for reference. 

For more information, read CFG — Procurement and Scheme Issues — Planning Permission and Building Regulations.

15.

Were all the final certifications required under building regulations obtained by the grant recipient prior to scheme practical completion grant claim?

If no, provide reason and explanation, or select ‘No final certifications under building regulations were required’.

Auditor notes

Check all certification dates are prior to scheme practical completion grant claim. 

If building regulations sign-off has not been achieved at time of audit, note the regulation to be discharged and reason for non-discharge. 

For more information, read CFG — Programme Management — Milestones and CFG — Finance — Grant Claims and Payments.

16.

Where the provider has entered into a management agreement with a managing agent, is it satisfied that:

• the agent is viable
• its aims are compatible with those of the provider
• appropriate capacity, experience and resources are available, in line with responsibilities

If no, provide reason and explanation, or select ‘No management agreement’ as appropriate.

Auditor notes

Check filed evidence and IMS submission to substantiate. 

For more information, read CFG — Programme Management — Management arrangements.

17.

Do the management agreement terms allow the provider to:

• retain overall responsibility for scheme financial control
• monitor property condition and occupancy
• let rented homes on a written tenancy agreement between the provider and the occupant
• issue the SO leases to purchasers

If no, provide reason and explanation, or select ‘No management agreement’ as appropriate.

Auditor notes

Check filed evidence and IMS submission to substantiate. 

For more information, read CFG — Programme Management — Management arrangements.

18.

Where applicable, has the contractual requirement to register a restriction on title with Land Registry, indicating a requirement to gain Homes England consent to dispose, been met?

If no, provide reason and explanation, or select ‘No contractual requirement to register a restriction on title’ as appropriate.

Auditor notes

The restriction would only apply where the URB is retaining ownership or where they have offered the land as security. 

Check relevant grant agreement for details. 

For more information, read CFG — Programme Management — Milestones — General.

19.

Was secure legal interest obtained for the land / property:

• by practical completion
• in one of the forms stated
• where applicable, with an appropriate lease length or condition in the name of the grant recipient or relevant consortium member

as defined in the grant agreement and CFG?

If no, provide reason and explanation.

Auditor notes

Refer to the title document and verify against relevant CFG requirement and the grant agreement.

If constitutional change has occurred, provide details, including the company names involved and the date change occurred.

This may, for example, include, but is not limited to:

• a change in the organisation’s ownership
• a change in the company structure
• amalgamations
• transfer of engagements
• mergers
• de-mergers

Sale

20.

For Shared Ownership — have all of the fundamental clauses set out in the Shared Ownership chapter of the CFG at Chapter 1, Shared Ownership section 5 (Leases) and section 11 (Model leases and Key Information Documents) been included in shared ownership leases?

If no, provide reason and explanation.

Auditor notes

Registered Providers developing grant-funded homes on Shared Ownership terms must ensure that their Shared Ownership leases are mortgageable and contain Homes England’s required fundamental clauses.

Check: 

• the correct model lease has been used
• the correct fundamental clauses for the relevant funding programme have been used
• the fundamental clauses have been used in an unaltered state including no changes to the defined terms (unless Homes England permission for a lease variation is held on file)
• for homes funded through the AHP 2021 to 2026, the Initial Repair Period is 10 years from the lease grant date

For more information, read CFG — Shared Ownership — Leases, and Model Leases, and Key Information Documents.

21.

For Shared Ownership — has the provider referred the applicants for a free affordability assessment, and retained evidence on file of the assessment, undertaken by an adviser for every purchaser, which assesses their overall affordability and share that they are able to purchase?

If no, provide reason and explanation.

Auditor notes

Check: 

• the detailed affordability assessment for each purchaser has been carried out by a qualified, regulated mortgage / financial adviser
• the share amount purchased has been assessed as affordable by a qualified, regulated adviser and the mortgage lender
• a copy of the completed sign-off form (signed by relevant parties — for example, the adviser, provider and applicant) is held on file

Changes to affordability guidance

The updated affordability guidance was initially published on 17 May 2024. There was then a transitional period before the guidance took effect on 1 August 2024.

For sales agreed before implementation of the updated guidance, or during the transitional period, where the previous iteration of the guidance was used, the audit checklist requirements for new build sales will apply.

For sales agreed post-implementation of the updated affordability guidance, or during the transitional period, where the previous iteration of the guidance was used, the updated CFG requirements must be followed.

For more information, read CFG — Shared Ownership — Affordability Guidance.

22.

For Shared Ownership — do purchasers meet the eligibility requirements in the CFG?

If no, provide reason and explanation.

Auditor notes

Providers are ultimately responsible for confirmation of an applicant’s eligibility for Shared Ownership. As such, providers should conduct a thorough assessment of an applicant’s eligibility to ensure that all the relevant criteria are met. Any exception to the eligibility criteria should have the written agreement of Homes England which should be documented on file. 

Check:

• evidence that each purchaser has met all the relevant eligibility criteria and that evidence of this is held on file
• where an exception has been agreed by Homes England to any of the eligibility criteria, their written agreement should be held on file alongside all supporting documentation relating to this

For more information, read CFG — Shared Ownership — Application Eligibility.

23.

For Shared Ownership — have the rents been calculated according to the formula set out in the CFG — specifically in section 4.1 of the Shared Ownership chapter?

If no, provide reason and explanation.

Auditor notes

Check filed evidence against the CFG Rents and Service Charges section. 

Check the rents have been calculated according to the percentage of unsold equity outlined in the original bids. For example, if the bid outlined that rents would be calculated on 2.75% of unsold equity, this should be reflected in the rents at initial sale. 

For new Shared Ownership homes funded via the AHP 2021 to 2026 the calculation of any annual sinking fund charge (included in the service charge and where relevant) should not include any external and structural repair work, expected or unexpected, within the first 10 years. 

Check: 

• rents and service charges have been set in accordance with the requirements in the CFG for initial sale, rent increases and resale

• the requirement concerning ground rents where contracts have not been exchanged before 23 May 2022 for AHP 2021 to 2026 and SOAHP 2016 to 2021 has been met (this includes Older Persons Shared Ownership (OPSO))

• for new Shared Ownership homes funded via the AHP 2021 to 2026, the requirement concerning the calculation of any annual sinking fund charge has been met

For more information, read CFG — Shared Ownership — Rents and service charges.

24.

For Shared Ownership — for the sale of homes, have the Key Information Documents (KIDs) been provided to the buyer no later than reservation stage, and provided to the buyer’s solicitor along with the memorandum of sale?

Has confirmation been received from the buyer’s solicitor that the KIDs have been provided to the buyer, or where there was a possibility that this could delay the purchase, that confirmation has been achieved through one of the other acceptable means?

If there has been no prospective purchaser, then select “No prospective purchaser” from the dropdown menu. 

If no, provide reason and explanation.

Auditor notes

For the sale of Shared Ownership homes funded through either the SOAHP 2016 to 2021 or AHP 2021 to 2026, providers are required to make available a suite of KIDs at the appropriate time to enable customers to make an informed decision on their purchase, or to enable them to compare different homes. Homes England has made available a suite of KIDs for each programme and for each Shared Ownership product type. 

Check: 

• the correct KIDs have been prepared for the relevant programme and Shared Ownership product type

• the KIDs have been passed to the buyer no later than the reservation stage

• confirmation has been received from the buyer’s solicitor that the KIDs have been provided to the buyer or, if there is a possibility that this requirement could cause a delay to the purchase, that one of the other acceptable means of confirmation is held on file

For more information, read CFG — Shared Ownership — Model Leases and Key Information Documents — Key Information Documents for shared owners.

Rent

25.

For Affordable Rent, Social Rent, Rent to Buy and Specialist Rent properties — do expected rents or rents being charged meet the requirements outlined in the CFG and associated documents or regulations?

If no, provide reason and explanation.

Auditor notes

Review:

• methodology and formula used
• lease and tenancy length
• service charges
• client group
• eligibility criteria

26.

For Affordable Rent, Social Rent, Rent to Buy and Specialist Rent properties — do the tenures and rents recorded in the system at the point of final grant claim match the tenancy agreements?

If not yet let, does the data recorded in the system match the prospective tenures and rents?

If no, provide reason and explanation.

Auditor notes

Review the tenancy documents held in the scheme file and compare these to the data in the system. If there are any discrepancies, note the differences.

27.

For Affordable Rent, Rent to Buy and Specialist Affordable Rent properties — has the provider obtained a valuation confirming the gross market value / market rent, when setting affordable and intermediate rents, to support the information recorded in the system at the time of bid submission / site activation?

If no, provide reason and explanation.

Auditor notes

Refer to the provider’s valuation evidence in the scheme file and compare the values with the values submitted in the system at the point of bid submission and site activation.

28.

For Social Rent and Specialist Social Rent properties — has the provider obtained a valuation confirming the relative property value in January 1999, when setting social rent, to support the information recorded in the system at the time of bid submission / site activation?

If no, provide reason and explanation.

Auditor notes

Rather than carrying out individual valuations for each property, registered providers may decide to rely on more generic valuations for particular types and sizes of properties in different locations.

Refer to the provider’s valuation evidence in the scheme file and compare the values with the values submitted in the system at point of bid submission and site activation.

If there are any discrepancies, note the differences.

Empty Homes

29.

For Empty Homes — is there evidence to confirm that the property is not an existing social home owned by the provider or another provider (for example, local authority or housing association)?

If no, provide reason and explanation.

Auditor notes

Ensure supporting filed evidence. 

For more information, read CFG — Procurement and Scheme Issues — Other Scheme Types.