Grainger Trust Limited (4743) - Regulatory Judgement: 30 July 2025
Published 30 July 2025
Applies to England
© Crown copyright 2025
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Our Judgement
This judgement concerns an organisation that is designated a for-profit registered provider.
The registered provider is not at the head of its group. It is a subsidiary organisation within a larger group of connected companies.
The registered provider is not intended to operate as a standalone entity in the group structure. It requires the ongoing support of related parties to fulfil its functions and / or meet its objectives. The nature of this support is described in this judgement.
This judgement concerns the registered provider only and does not represent an assessment of the non-registered entities within the group.
| Grade/Judgement | Change | Date of assessment | |
|---|---|---|---|
| Consumer | C2* Our judgement is that there are some weaknesses in the landlord delivering the outcomes of the consumer standards and improvement is needed. |
First grading | July 2025 |
| Governance | G2* Our judgement is that the landlord meets our governance requirements but needs to improve some aspects of its governance arrangements to support continued compliance. |
First grading | July 2025 |
| Viability | V1* Our judgement is that the landlord meets our viability requirements and has the financial capacity to deal with a wide range of adverse scenarios |
First grading | July 2025 |
Reason for publication
We are publishing a regulatory judgement for Grainger Trust Limited following an inspection completed in July 2025.
This regulatory judgement confirms a consumer grade of C2, a governance grade of G2 and a financial viability grade of V1*.
This is the first time we have issued a regulatory judgement in relation to this landlord.
Summary of the decision
Based on the evidence and assurance gained during the inspection it is our judgement that there are some weaknesses in Grainger Trust Limited delivering the outcomes of the consumer standards and improvement is needed, specifically in relation to outcomes in our Safety and Quality Standard and Transparency, Influence and Accountability Standard. Based on this assessment, we have concluded a C2* grade for Grainger Trust Limited.
Our judgement is that Grainger Trust Limited meets our governance requirements but needs to improve some aspects of its governance arrangements to support continued compliance, specifically to increase board assurance on risk management, to strengthen business planning arrangements, and to demonstrate evidence-based decision making. Based on this assessment we have concluded a G2* grade for Grainger Trust Limited.
Our judgement is that Grainger Trust Limited meets our financial viability requirements and has the financial capacity to deal with a wide range of adverse scenarios. It has a strong financial profile, and its stress testing demonstrates that financial capacity is built into its business plan. Grainger Trust Limited has provided appropriate assurance that it has access to sufficient liquidity and adequate funding in place. Based on this assessment, we have concluded a V1* grade for Grainger Trust Limited.
How we reached our judgement
We carried out an inspection of Grainger Trust Limited to assess how well it is delivering the outcomes of the consumer standards and meeting our governance and financial viability requirements, as part of our planned regulatory inspection programme. During the inspection, we considered all four of the consumer standards: Neighbourhood and Community Standard, Safety and Quality Standard, Tenancy Standard, and Transparency, Influence and Accountability Standard.
During the inspection we observed a board meeting, spoke with tenants, held meetings with Grainger Trust Limited including its non-executive directors, interviewed staff, and reviewed a wide range of documents provided by Grainger Trust Limited.
Our regulatory judgement is based on a review of all of the relevant information we obtained during the inspection as well as analysis of information supplied by Grainger Trust Limited in its regulatory returns and other regulatory engagement activity.
Summary of findings
Consumer – C2* – July 2025
During the inspection Grainger Trust Limited demonstrated that it provides an effective, timely and efficient repairs service to its tenants, and can demonstrate compliance with statutory health and safety requirements. Grainger Trust Limited evidenced that there is proactive and appropriate oversight of the provision of both the repairs service and landlord health and safety compliance.
Grainger Trust Limited has a reasonable understanding of the condition of its homes, based on build quality, thermal efficiency and the age of its stock which was all built in the last ten years. However, it currently has some incomplete data and needs to improve its sources of evidence. A stock condition survey of all its homes is planned for later in 2025.
In relation to the Transparency, Influence and Accountability Standard, Grainger Trust Limited is effective in engaging with tenants through informal involvement at a local level. It has demonstrated that it gains insight from complaints and numbers of complaints are relatively low. However, there is limited evidence of tenant scrutiny of service delivery, and of the use of tenant insight or information about the diverse needs of tenants to shape its services. Grainger Trust Limited is taking steps to improve the collection and use of data and insight including learning from complaints.
Service information is clear and accessible to tenants. Annually published performance information provides limited assurance that this facilitates meaningful understanding of, or influence over, performance by tenants. Grainger Trust Limited acknowledges that improvements are required to its strategic approach to tenant scrutiny and engagement as it continues to grow. Its current activities include plans to develop a comprehensive customer engagement strategy and action plan, but this work is at its early stages and not yet implemented.
In relation to the Tenancy Standard Grainger Trust Limited demonstrated that it is letting homes fairly and that there are a range of measures in place to support tenancy sustainment including helping tenants to access financial support.
In relation to the Neighbourhood and Community Standard, Grainger Trust Limited evidenced that there is appropriate oversight of the provision of services to tackle anti-social behaviour, with proactive partnership working in place.
Governance – G2* – July 2025
Based on the evidence gained from the inspection we have assurance that Grainger Trust Limited is meeting the requirements of the Governance and Financial Viability Standard.
Grainger Trust Limited’s board has a clearly articulated corporate plan with strategic objectives that reflect its planned growth, commitment to continuous improvement of services, and development of its approach to customer engagement and tenant scrutiny. It was able to provide evidence that its board considers alternative options to deliver value for money and make best use of resources. The skills and knowledge of board members align with Grainger Trust Limited’s strategic direction.
Grainger Trust Limited’s board has oversight of its risk and assurance framework. However, assurance around its internal control framework, operated on its behalf by its parent Grainger PLC, requires more effective oversight by Grainger Trust Limited’s board. Plans are in place to improve reporting and board oversight in this area, but these are not yet fully implemented.
We have reasonable assurance that Grainger Trust Limited’s operational relationship with its parent demonstrates an appropriate level of independence. However, we have identified that improvement is required in Grainger Trust Limited board’s decision making, specifically how the board demonstrates that it is making evidence-based decisions for the benefit of Grainger Trust Limited. Although we have evidence that the decisions we reviewed were made with the appropriate degree of diligence, skill and prudence, assurance around the clarity and transparency of reporting strategic decisions requires improvement.
The quality of strategic financial reporting, and board oversight of business planning also requires strengthening. We conclude that the development and documenting of Grainger Trust Limited’s business planning framework requires improvement for Grainger Trust Limited to provide sufficient evidence that it has a robust and prudent business planning framework in place.
Grainger Trust Limited’s board has acknowledged the need for improvement and in some areas, such as improved reporting on internal audit recommendations, action has already been taken. Strategies for improved financial reporting and overall transparency of decision making are in place but are not fully implemented
Viability – V1* – July 2025
Based on the evidence obtained in the inspection we have concluded that Grainger Trust Limited has provided appropriate assurance that it meets our financial viability requirements. It has a strong financial profile with a track record of meeting or exceeding business plan profitability targets. Grainger Trust Limited’s business planning model demonstrates that it has the financial capacity to deliver the corporate plan 2025 - 2030, continuing to contribute to the financing of growth, and future stock investment to meet its energy performance and de-carbonisation targets. Its stress testing confirms that it can withstand a wide range of adverse financial scenarios.
Grainger Trust Limited is financed by 100% equity funding from its parent; it has no external debt and there are no plans at group level to change this funding strategy in the foreseeable future. We have assurance that Grainger Trust Limited has access to sufficient liquidity with funding in place to meet all business plan requirements for the duration of its five-year corporate strategy.
Background to the judgement
About the landlord
Grainger Trust Limited is a wholly owned, ring fenced subsidiary of its non-registered parent, Grainger Plc (GPLC). GPLC is the UK’s largest listed residential landlord, which owns and manages around 11,000 private rental sector homes in most major cities in the United Kingdom.
Grainger Trust Limited currently manages 1,075 homes across London and the Southeast of England split between five main sites. Property management and central services are provided by GPLC connected companies via intra-group management services agreements. Services are provided by Grainger Residential Management Ltd (GRML) on behalf of GPLC.
Just over half of Grainger Trust Limited’s homes are affordable rented stock, with the remainder including low-cost home ownership and intermediate rent properties. It has two blocks over 18m in height, both of which have been assessed as having no life-critical defects that require immediate remediation.
Grainger Trust Limited is forecasting growth of 360 homes over the next five years comprising 249 affordable rent homes and 111 shared ownership homes.
Grainger Trust Limited’s Financial Statements for the year ended 30 September 2024 reported a turnover of £15.7m and four full-time equivalent employees.
Our role and regulatory approach
We regulate for a viable, efficient, and well governed social housing sector able to deliver quality homes and services for current and future tenants.
We regulate at the landlord level to drive improvement in how landlords operate. By landlord we mean a registered provider of social housing. These can either be local authorities, or private registered providers (other organisations registered with us such as non-profit housing associations, co-operatives, or profit-making organisations).
We set standards which state outcomes that landlords must deliver. The outcomes of our standards include both the required outcomes and specific expectations we set. Where we find there are significant failures in landlords which we consider to be material to the landlord’s delivery of those outcomes, we hold them to account. Ultimately this provides protection for tenants’ homes and services and achieves better outcomes for current and future tenants. It also contributes to a sustainable sector which can attract strong investment.
We have a different role for regulating local authorities than for other landlords. This is because we have a narrower role for local authorities and the Governance and Financial Viability Standard, and Value for Money Standard do not apply. Further detail on which standards apply to different landlords can be found on our standards page.
We assess the performance of landlords through inspections and by reviewing data that landlords are required to submit to us. In Depth Assessments (IDAs) were one of our previous assessment processes, which are now replaced by our Regulatory inspections programme from 1 April 2024. We also respond where there is an issue or a potential issue that may be material to a landlord’s delivery of the outcomes of our standards. We publish regulatory judgements that describe our view of landlords’ performance with our standards. We also publish grades for landlords with more than 1,000 social housing homes.
The Housing Ombudsman deals with individual complaints. When individual complaints are referred to us, we investigate if we consider that the issue may be material to a landlord’s delivery of the outcomes of our standards.
For more information about our approach to regulation, please see Regulating the Standards.