Decision

First Garden Cities Homes Limited (5090) - Regulatory Judgement: 25 June 2025

Updated 25 June 2025

Applies to England

Our Judgement

	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	June 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.	Downgrade	June 2025
Viability	V2 Our judgement is that the landlord meets our viability requirements. It has the financial capacity to deal with a reasonable range of adverse scenarios but needs to manage material risks to ensure continued compliance.	Regrade	June 2025

Reason for publication

We are publishing a regulatory judgement for First Garden Cities Homes Limited (FGCH) following an inspection completed in April 2025 and responsive engagement completed in June 2025.

This regulatory judgement confirms a consumer grading of C2, a governance grading of G2 and a viability regrade to V2.

Prior to this regulatory judgement, the governance and financial viability gradings for FGCH were last updated in December 2023 following a stability check which confirmed grades of G1 and V1. This is the first time we have issued a consumer grade in relation to this landlord.

Summary of the decision

From the evidence and assurance gained during the inspection, it is our judgement that there are some weaknesses in FGCH’s delivery of the outcomes of the consumer standards and improvement is needed, specifically in relation to the outcomes in our Safety and Quality Standard, and our Transparency, Influence and Accountability Standard. Based on this assessment, we have concluded a C2 grade for FGCH.

Our judgement is that FGCH meets our governance requirements but needs to improve some aspects of its governance arrangements to support continued compliance. Specifically, FGCH needs to strengthen its risk and internal control assurance framework, particularly in relation to procurement risk. FGCH must also improve its oversight and training of interim staff. Based on this assessment, we have concluded a G2 grade for FGCH. 

Our judgement is that FGCH meets our financial viability requirements and has the financial capacity to manage a reasonable range of adverse scenarios. FGCH has provided appropriate assurance that it has access to sufficient liquidity. However, there is uncertainty around the level of decarbonisation investment needed for its homes. Based on this assessment, we have concluded a V2 grade for FGCH.

How we reached our judgement

As part of our planned regulatory inspections programme, we carried out an inspection of FGCH to assess how well it is delivering the outcomes of the consumer standards and meeting our governance and financial viability requirements. We considered all four of the consumer standards: Neighbourhood and Community Standard, Safety and Quality Standard, Tenancy Standard, and the Transparency, Influence and Accountability Standard.

During the inspection we observed a board meeting and a Resident Partnership Group meeting, spoke to tenants, held meetings with FGCH, including with its non-executive directors, and reviewed a wide range of documents provided by FGCH. This inspection concluded in April 2025.

We also undertook responsive engagement to understand governance-related issues following a self-referral by FGCH in April 2025 relating to financial controls around a recent procurement. This involved reviewing documents, including third-party documents, provided by FGCH and discussion with members of FGCH’s executive team. This work concluded in June 2025.

Our regulatory judgement is based on all the relevant information we obtained during the planned inspection and the responsive engagement that followed.

Summary of findings 

Consumer – C2 – June 2025 

FGCH provided evidence-based assurance that it has appropriate systems in place to ensure the health and safety of its tenants in their homes and associated communal areas. FGCH has a good understanding of its compliance with landlord health and safety requirements, and we saw evidence that it is delivering the actions arising from health and safety assessments.

However, we found weaknesses in reporting and data in some areas. Smoke and carbon monoxide detector compliance was not routinely reported to FGCH’s board, and in some instances, there was reliance on records that were not accurate. Damp and mould caseloads were also not accurately reported to FGCH’s board because follow-up checks were either not documented or had not taken place. We have assurance that FGCH is reviewing these cases, managing any risks arising and ensuring that its overall process for addressing damp and mould is working appropriately.

The Safety and Quality Standard requires landlords to have an accurate and up to date understanding of the condition of its homes at an individual property level based on a physical assessment of all homes, and to ensure that homes meet the requirements of the Decent Homes Standard. There is evidence that FGCH is improving the information it holds about the condition of its homes at an individual property level, and that it uses this information to inform its decisions on future investment and the provision of good quality, well maintained and safe homes for tenants. However, the proportion of homes that have had a recent physical survey remains low. FGCH has a programme in place to gain an accurate and up to date record of the condition of its homes and has completed the first year of the three-year programme.

We saw evidence that FGCH provides an effective, efficient and timely repairs service to tenants and takes action to improve the service and outcomes for tenants when issues occur.

We have assurance that FGCH is delivering the outcomes of the Neighbourhood and Community Standard, including through its partnership working with other organisations to deter and tackle anti-social behaviour (ASB) and hate incidents and promote wellbeing. We found some weaknesses in how ASB cases are reported, which FGCH expects to resolve through the introduction of a new IT system.

In relation to the Tenancy Standard, FGCH has evidenced that it is allocating and letting its homes in a fair and transparent way and is supporting its tenants to maintain their tenancy.

In relation to the Transparency, Influence and Accountability Standard, we gained assurance that FGCH takes tenants’ views into account in its strategies, policies and decision making, with meaningful opportunities for tenants to influence and scrutinise services. FGCH has engaged with tenants to improve how it delivers services while treating tenants with fairness and respect. FGCH holds some information on the diverse needs of its tenants, and we saw evidence of this being used to deliver fair and equitable outcomes for tenants, however, FGCH needs to ensure it has an agreed plan for building on this.

FGCH has taken steps to address weaknesses in the provision of a complaints handling service that addresses tenants’ concerns fairly, effectively and promptly. Some weaknesses remain in how FGCH evidences the resolution of complaints within agreed timescales, and in its reporting to the Board on complaints handling to improve how it learns from complaints and drive service improvements.

Governance – G2 – June 2025

Based on the evidence gained from the inspection and responsive engagement, there is assurance that FGCH’s governance arrangements are meeting the requirements of the Governance and Financial Viability Standard. However, FGCH needs to take action to improve some aspects of its governance arrangements.

We saw evidence that FGCH has, for the most part, an appropriate risk management and control framework that aligns with its strategic risks. However, there are weaknesses in its approach to managing procurement risk, the design and effectiveness of related controls, and corporate oversight over delegated authority limits in relation to contract spend and management. We will continue to work with FGCH to seek assurance that it makes sustainable improvements in these areas.

During the inspection, we observed that the board considers its risk appetite in strategic decision making and has reflected in its plan the challenges associated with investing in FGCH’s homes. Development risk is managed effectively, and we are assured that FGCH identifies and makes progress on changes that are needed. FGCH’s board seeks an appropriate level of assurance across a range of areas and looks to continually improve its approach to scrutinising its risks. This includes improvements in how the board ensures there is oversight of progress against internal audit recommendations. We will continue to monitor the implementation of these improvements as part of our follow-up work to this inspection.

We saw evidence that FGCH’s actions are consistent with its code of governance and its legal and regulatory obligations, seeking external advice as appropriate. Continuing improvement in governance is evidenced through effectiveness reviews, and we saw evidence of the recommendations being implemented. FGCH conducts focused internal reviews in the periods between external reviews.

Board ownership of stress testing and mitigation strategies is evidenced and is used to inform decisions, supplementing the wider control framework. FGCH’s board has asked for improvements in demonstrating the effectiveness of planned mitigations. While progress on this has been slow, it is now near resolution. We will continue to monitor the improvements being made in this area.

FGCH has provided evidence that it has appropriate plans in place for board succession and recruitment, with a proactive approach taken to addressing future skills gaps. FGCH regularly reviews its governance arrangements to ensure they remain fit for purpose. It is supported by an appropriate committee structure, providing further oversight in relation to the delivery of outcomes for tenants under our consumer standards. FGCH needs to improve its oversight and training of interim staff.

We have assurance that FGCH’s governance arrangements are suitable to deliver the improvements required in line with its C2 grade in a transparent and accountable manner. 

Viability – V2 – June 2025                                                                  

Based on evidence gained from this inspection, we have concluded a regrade from V1 to V2. We have assurance that FGCH’s financial plans are consistent with, and support, its financial strategy. FGCH has provided evidence-based assurance that it has an adequately funded business plan, sufficient security in place to support its plans, and is forecast to continue to meet its financial covenants. FGCH has also provided appropriate assurance that it is closely monitoring performance against its loan covenants, and that this is reported to the board regularly.

FGCH is increasing its investment in existing homes while continuing to develop new homes. The Board is currently considering the available options for the decarbonisation investment needed in several of its homes located in a conservation area. The costs associated with this investment are not yet included in the business plan. This creates uncertainty around financial capacity within the plan in the short and medium term. Once a costed plan is included, the financial performance of the organisation may be reduced on an ongoing basis.

FGCH also has material risks to manage associated with its development programme and a reliance on shared ownership sales receipts. This means that FGCH has the capacity to respond to a reasonable range of adverse scenarios, but it will need to manage these material risks.

Background to the judgement

About the landlord

FGCH is a charitable community benefit society with 2,365 homes. It was formed in March 2020 from the merger of Howard Cottage HA and Welwyn Garden City HA, and operates predominantly in North Hertfordshire, Central Bedfordshire and Welwyn Hatfield.

FGCH has one trading subsidiary; the St Saviour’s Almshouses Trust. Garden City Homes is a dormant unregistered subsidiary.

Based on unaudited accounts for the year ended 31 March 2025, FGCH reported group turnover of £20.7m for the year and employs 59 full-time equivalent staff. The group’s development strategy is to deliver 245 new homes by 2027.

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 new 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.

Further information

• Regulating the standards

• Regulatory standards for landlords