Guidance

Tenant Satisfaction Measures - FAQs

Frequently asked questions about the Tenant Satisfaction Measures.

From:
Regulator of Social Housing
Published
23 March 2023

Applies to England

Documents

Tenant satisfaction measures - frequently asked questions (PDF)

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Details

Please note

The frequently asked questions do not form part of the requirements that landlords need to meet to deliver the TSM related outcomes of the Transparency, Influence and Accountability Standard.

Contents

General queries on technical requirements

Complaints

Neighbourhood management – Anti-social behaviour

Repairs and stock condition

Tenant perception surveys

Building safety

Overview

The Transparency, Influence and Accountability Standard came into effect from April 2024 (^1). This requires all registered providers to meet the regulator’s requirements in relation to the tenant satisfaction measures (TSMs) set by the regulator as set out in two documents:

  • TSM Technical Requirements (‘technical requirements’)
  • TSM Tenant Survey Requirements (‘survey requirements’)

The final version of these TSM requirements was published in September 2022. They contain significant information as to how TSMs must be defined, calculated, and reported. The regulator has also published a range of information on the consultation exercise on the TSMs. This includes a Decision Statement which summarises feedback and the regulator’s decision on the final set of TSM requirements.

The regulator has received a large volume of queries on the TSM requirements since September, as providers review requirements and prepare to collect their first set of TSMs for 2023/24. This note sets out examples of specific queries received to date, focusing on frequently asked questions and those relating to key fundamental issues. It is intended to inform those already familiar with the published TSM requirements, and covers some technical issues. To be clear, this note does not form part of the requirements providers must meet to deliver the outcomes of the ​Transparency, Influence and Accountability Standard.

The note summarises specific queries and responses as follows, with some common themes set out below:

A. General queries on TSM requirements: relating to all TSMs

B. Complaints: TSMs CH01, CH02

C. Neighbourhood management: Anti-Social Behaviour TSM NM01

D. Repairs and stock condition: TSMs RP01, RP02

E. Tenant perception surveys: used to generate TSMs TP01-TP12

F. Building safety: TSMs BS01-BS05.

This note was updated on 2 April 2024, in order to reflect the new Transparency, Influence and Accountability Standard and to address queries on how complaints TSMs (CH01 and CH02) relate to the Housing Ombudsman Service’s new 2024 Complaints Handling Code.

Responses to FAQs – common themes

The starting point in answering all queries on TSM requirements is the specific wording of the TSM Technical Requirements and TSM Tenant Survey Requirements. When the regulator comes to assess whether a provider has delivered the outcomes of the ​Transparency, Influence and Accountability Standard, this will ultimately be with reference to the Standard and these two documents. We would encourage all providers to ensure that they have closely reviewed these documents as an initial step.

Many provider queries concern how the TSM requirements apply to particular circumstances. The TSMs necessarily include broad definitions which must be applied across diverse tenants, service models, and stock in the sector. The regulator is not always able to confirm how these broad definitions will apply in particular scenarios as relevant local circumstances differ. In some cases, providers must determine how definitions apply to specific circumstances, using external advice if required. In these cases, providers must be able to demonstrate that their approach is consistent with TSM requirements and ensure reported information is a transparent reflection of their performance.

Some TSM requirements reflect wider legal definitions. For example, the building safety TSMs must reflect statutory obligations for undertaking specified safety checks. The regulator cannot interpret the detail on these legal requirements on behalf of providers, or confirm whether they apply in different circumstances. We appreciate that these legal requirements can be complex, and providers should take external advice if required.

Some queries concern the scope of reporting under TSM requirements. As underlined in technical requirements, providers are not restricted from collecting or publishing additional performance measures or information alongside the TSMs. In addition to its specific expectations, the ​Transparency, Influence and Accountability Standard includes the required outcome that providers must collect and provide information to support effective scrutiny by tenants of their landlord’s performance – providers need to determine what additional information they need to report to meet this outcome beyond the TSMs specified in the requirements.

A: General queries on technical requirements

What stock types must be included in calculating the TSMs?

Specifically, should the following be included or excluded: (a) shared ownership, (b) market rent, (c) Rent to Buy, (d) gypsy and traveller accommodation, (e) temporary social housing, (f) temporary accommodation, (g) almshouse accommodation, (h) leasehold stock?

Paragraphs 11-14 of the technical requirements state that all TSMs must be reported for ‘Low Cost Rental Accommodation’ and/or ‘Low Cost Home Ownership’, depending on what is specified for the relevant TSM in Section 2 of those technical requirements.

LCRA stock and LCHO are defined according to Sections 69 and 70 of the Housing and Regeneration Act 2008. The TSM technical requirements sets out some examples of stock types which – conventionally defined – would fall within LCRA and LCHO:

  • LCRA – This includes for example general needs, supported housing, intermediate rent and temporary social housing.

  • LCHO – This includes, for example, shared ownership properties (which have not been fully staircased).

These stock types are intended to illustrate what typically constitutes LCRA and LCHO. However, the key requirement for registered providers in calculating TSMs is to understand which of their dwelling units meet the legal definitions of LCRA or LCHO under the HRA 2008, taking external legal advice if required. This understanding is fundamental and will need to be reflected in the collection and calculation of all TSMs.

For reference, LCRA is defined in the HRA 2008 as accommodation that is: (a) made available for rent, (b) has rent that is below the market rate, and (c) made available to people whose needs are not adequately served by the commercial housing market. LCHO is defined in the HRA 2008 as accommodation that is (a) occupied or made available for occupation in accordance with shared ownership arrangements, shared equity arrangements, or shared ownership trusts; and (b) made available to people whose needs are not adequately served by the commercial housing market. Other aspects of the HRA 2008 may relate to these definitions.

What this implies for the following specific stock types is as follows:

a. Shared ownership units that have not been fully staircased typically fall under the legal definition of LCHO and hence within the scope of the TSMs. As clarified in the TSM technical requirements (para 13), ‘reporting of TSMs for LCHO must not include fully staircased properties i.e. properties once occupied under LCHO arrangements but where the occupier for example acquired a 100% share of a shared ownership property’.

b. Standard market rent properties cannot meet the definition of LCRA (or LCHO) in HRA 2008, since the rent is not below the market rate, and therefore must not be included in the calculation of the TSMs.

c. Providers must determine whether Rent to Buy dwellings meet the definition of LCRA or LCHO, with reference to the HRA (2008) definitions and the legal and other features of these dwellings at the time of reporting. For example, if a Rent to Buy dwelling is made available for (sub-market) rent then – assuming other aspects of the HRA (2008) definition are met – it will fall under the definition of LCRA and must be included in TSM calculations on that basis.

d. Providers must determine whether gypsy or traveller accommodation meets the definition of LCRA or LCHO, with reference to the HRA (2008) definitions and the legal and other features of these dwellings. Given the range of accommodation this may comprise it is not possible to confirm if it will generally meet the definition of LCRA (or LCHO) or not.

e. Temporary social housing, as defined in the Government’s Policy Statement on Rents for Social Housing 2022, is by definition LCRA and hence must be included in calculating TSMs.

f. Temporary accommodation is a term that is sometimes used in different ways by private and local authority registered providers. Providers must determine whether such stock meets the definition of LCRA (or LCHO), taking external legal advice if required. We are aware that some local authorities own stock that is used for temporary housing but that does not meet the definition of LCRA (or LCHO) in HRA 2008 – for example, where rent is set at market rate.

g. As long as it meets the definition of LCRA or LCHO, almshouse accommodation must be included in the calculation of TSMs. We are aware that some almshouse residents may technically be licensees rather than legal tenants – however as clarified in technical requirements (para 13), for the purposes of the TSMs ‘the term tenant refers to any resident of LCRA or LCHO stock owned by a provider’.

h. Leasehold stock is defined in TSM requirements as a dwelling for which a leasehold interest has been sold to an occupier and that does not fall under the definition of LCRA or LCHO (para 14) (^2). Such stock must be excluded from the calculation of the TSMs. Leasehold units owned by providers typically include Right to Buy or fully staircased shared ownership units where the provider has sold a leasehold interest to a residential occupier but retains an interest (freehold or leasehold) of its own.

For the avoidance of doubt, the definition of leasehold stock in the TSM requirements depends on whether a leasehold interest is owned by a residential occupier (and not whether the landlord owns a leasehold or freehold interest in a property). If a landlord owns LCRA through a leasehold interest, for example, this is still defined as LCRA.

For reference, a provider owns a dwelling unit for the purposes of the TSMs when it: ‘(a) holds the freehold title or a leasehold interest in that property; and (b) is the body with a direct legal relationship with the occupants of the dwelling unit (this body is often described as the landlord)’ (para 19).

Why is certain stock (e.g. non-social or leasehold stock) not included within the scope of the TSMs? What should we report for this stock?

Units that are not LCRA or LCHO must not be included in calculating the TSMs. This issue was considered carefully, and rationale was set out in the consultation document published in December 2021. We concluded that collecting TSM data on non-social and leasehold stock would not be consistent with the remit of the Regulator of Social Housing, and the aims of TSMs set out in the Social Housing White Paper.

However, as underlined in the technical requirements (para 2), the TSM requirements in no way prevent providers from publishing performance information relating to leasehold or non-social stock alongside the TSM information (or making this information available to residents through other routes).

To avoid any confusion, for the purposes of this note and the TSMs, leasehold stock in this note is defined as per technical requirements (para 14, see above).

What about dwellings that are managed by another entity (e.g. an agent, ALMO or under PFI arrangements)? What about dwellings where another entity owns a freehold (or superior leasehold) interest?

Technical requirements (para 19) state that: ‘For the purposes of reporting TSMs, a provider owns a dwelling unit when it: (a) holds the freehold title or a leasehold interest in that property; and (b) is the body with a direct legal relationship with the occupants of the dwelling unit (this body is often described as the landlord). Dwelling units owned by one provider but managed by another organisation – such as a managing agent, Arms Length Management Organisation or Tenant Management Organisation, or under a Private Finance Initiative arrangement – must be reported by the owner. Dwelling units must not be reported as being owned by more than one provider’.

In summary, therefore, it is the responsibility of the landlord that owns a dwelling – as defined under TSM requirements – to calculate and report the TSMs for that dwelling. This applies even where another entity manages the property, or where another organisation owns a freehold (or superior leasehold) interest and may be directly responsible for management of a building containing the dwelling. This was an issue that was included in the consultation on the introduction to TSMs, and a rationale for this was set out in the consultation document published in December 2021. In short, this reflects the aims of the Social Housing White Paper and the fundamental approach in other regulatory data returns.

Do we need to report TSMs at a group level or for individual entities too? How do TSMs apply to ALMOs and PFIs?

The TSM requirements apply at a registered group level. This means, as set out in technical requirements (paras 9-10), that registered group parents must report consolidated TSMs for the group (and are not required to report separate TSMs for individual registered provider entities within the group).

We are aware that some organisations both manage units for other providers (such as an ALMO for local authority units) and own their own stock. These organisations will need to consider their particular structure, including the definitions of ownership and the registered group basis set out in TSM requirements to confirm their reporting requirements. Where more than one registered group has a legal interest in a property (e.g. freehold or leasehold) the key consideration in interpreting TSM requirements is the definition of ownership set out above and which provider has the direct legal relationship with the tenant.

Providers need to determine what information they need to report beyond the TSMs specified in the requirements, in order to support effective tenant scrutiny of performance. For some providers this may include reporting TSMs for different entities and management organisations in addition to those reported at group level.

How do TSMs apply to small providers?

I know we need to calculate perception TSMs at least every two years; does the same apply to management information TSMs or is that annual?

The ​Transparency, Influence and Accountability Standard requires all providers to collect and annually publish TSMs following specified requirements. This applies to TSMs collected from both perception surveys and management information, and to large and small providers. As underlined in technical requirements (para 6): ‘All registered providers that own relevant social housing stock must calculate and publish all TSMs on an annual basis in accordance with all requirements of this document and TSM tenant survey requirements’. The technical notes set out proportional requirements as to how these TSMs must be collected and reported for small providers with fewer than 1,000 units of relevant social housing units.

In summary, as set out in tenant survey requirements (Annex A), small providers must carry out perception surveys at least once every two years whereas larger providers must carry out surveys at least once a year. However, for the TSMs that are generated from management information, all providers (large and small) must collect and publish data for these TSMs on an annual basis.

If a small provider conducts tenant perception surveys once every two years, they must still present the latest tenant perception measures available as part of the TSMs published each year. All providers must explain the timing of the survey used to generate the published tenant perception measures in their published summary of survey approach (tenant survey requirements, para 35).

To note, while large providers must adhere to the reporting year 1 April to 31 March, small providers have flexibility to choose a different reporting year (see technical requirements, para 21).

We have an entity registered with the Scottish Housing Regulator – can we include data for that in our published group-level TSMs? More generally, should we include non-English stock in the TSMs?

In response to the first query, providers must only include data from provider entities registered in England in the reported TSM data. More generally, the regulator regards the TSM requirements as applying to stock located in England only. This means that providers should exclude data from stock located outside of England from reported TSMs. Technical requirements (para 9, page 5) state that TSMs must be reported on the following basis: ‘Registered group parents must report consolidated TSMs for the group, calculated on the basis of all relevant social housing stock owned by themselves and all subsidiary registered providers’ (^3). For the purposes of the TSMs we regard ‘registered providers’ as organisations registered with the Regulator of Social Housing (RSH) in England. If there are entities that are registered social landlords with the Scottish Housing Regulator (and not registered providers with the English RSH), then data for these entities must not be included in reported TSMs – this applies both to measures drawn from perception surveys and those from management information.

As underlined in technical requirements, providers are not restricted from collecting or publishing additional performance measures or information alongside the TSMs as defined by the regulator. Additional information could include, for example, TSMs calculated for the wider group (including Scottish subsidiaries or stock outside of England). However, performance against TSMs as defined by the RSH (calculated on basis of entities registered with RSH only, and for relevant stock in England) must be set out in published performance reporting in a clear and easily accessible way.

B: Complaints

How do we define complaints for calculating CH01 and CH02?

Specifically:

(a) Should this only include complaints that come directly from tenants, or can it include those made by third parties on behalf of tenants?

For the purposes of calculating CH01 and CH02, technical requirements (pages 22-25) state that ‘providers must follow the definition of ‘complaint’ set out in the Housing Ombudsman’s Complaint Handling Code’. We are aware that some organisations may use more specific local definitions to manage the process of handling complaints, but we anticipate that the definition of complaints in the Code will generally be sufficiently broad to accommodate more specific local practice. Providers must ensure that any local definitions of a complaint used to collect data for CH01 and CH02 are consistent with the definition of complaint in the Code, in order to deliver the outcomes of the Transparency, Influence and Accountability Standard.

In response to the specific query, the Complaint Handling Code (CHC) defines a complaint as: ‘an expression of dissatisfaction, however made, about the standard of service, actions or lack of action by the landlord, its own staff, or those acting on its behalf, affecting an individual resident or group of residents’. Moreover, it states that ‘a complaint that is submitted via a third party or representative must be handled in line with the landlord’s complaints policy’. In summary, the regulator considers that under the Complaint Handling Code all such complaints (submitted via a third party or representative) must be reflected in the calculation of CH01 and CH02.

(b) What about complaints from tenants whose dwellings are managed by a third party?

The Code underlines that it is the responsibility of the landlord to ensure that all complaints are handled in line with the Code and the landlord’s complaint policy. The regulator considers that this is consistent with the definition of ownership reflected in the technical requirements (para 19): For the purposes of reporting TSMs, a provider owns a dwelling unit when it: ‘(a) holds the freehold title or a leasehold interest in that property; and (b) is the body with a direct legal relationship with the occupants of the dwelling unit (often called the landlord)’.

In summary, it is therefore the responsibility of the landlord that owns a dwelling – as defined under TSM requirements – to calculate and report complaints through CH01 and CH02 for residents of those dwellings, including for any dwellings managed by a third party. Following this definition of ownership, for the purposes of CH01 and CH02 complaints must not be reported by more than one provider.

(c) If a complaint progresses to stage two, should it be removed from stage one complaints?

For the purposes of calculating CH01 and CH02, technical requirements state that all complaints at each stage must be reflected in reported performance for each stage respectively – a complaint should not be removed from reported performance under stage one if it progresses to stage two.

Technical requirements set out that for the purposes of CH01 and CH02, ‘stage one’ and ‘stage two’ complaints have the same meanings as they do for the purposes of the Complaint Handling Code (pages 22-25). The Complaint Handling Code describes how all stage two complaints must necessarily have been through stage one, and maximum timescales for responding to complaints at each stage.

The Complaints Handling Code and associated guidance is available on the Housing Ombudsman’s website. Queries which relate to the Code directly (rather than the TSM requirements) should be addressed to the Housing Ombudsman Service.

The Housing Ombudsman has published a new 2024 Complaint Handling Code. Which Code is relevant to CH01 and CH02?

The Housing Ombudsman published an updated version of the Complaint Handling Code in February 2024. This 2024 Code sets out requirements that will apply to landlords from 1 April 2024. This replaces the 2022 Code that was applicable from 1 April 2022. The Code is available on the Housing Ombudsman’s website.

The relevant version of the Code for the purposes of TSMs is the version which was applicable during each TSM reporting year. For example, CH01 and CH02 data reported for the year 1 April 2023 to 31 March 2024 must follow relevant definitions in the 2022 Complaint Handling Code; CH01 and CH02 data for reporting years starting from 1 April 2024 or later must follow the relevant definitions in the 2024 Complaint Handling Code. This is clarified in the TSM technical requirements (as updated in March 2024).

To note, while large providers must adhere to the reporting year 1 April to 31 March for the purposes of TSMs, small providers have flexibility to choose a different reporting year (technical requirements, para 21). If a small provider has a TSM reporting year in which more than one version of the Code applied, we would expect them to take a reasonable approach to calculating CH01 and CH02, and for this approach to be transparently reported alongside published TSM data.

If a small provider has a 2023/24 reporting year that ends after 1 April 2024, for example, it is in principle permissible to either (a) use the 2022 Code as the basis for collecting and reporting 2023/24 TSM data for all complaints made in the reporting year or (b) use the 2022 Code as the basis for collecting and reporting data on complaints received until 31 March 2024 and the 2024 Code as the basis for subsequent complaints. We would expect providers to communicate the basis of collection alongside their published TSMs CH01 and CH02.

If we grant extensions as per the Complaint Handling Code for responding to certain individual complaints, does this count as responding within the maximum CHC timescales for purposes of CH02? Do we need to report each extension?

For the purposes of CH02, providers must report the number of complaints made during the reporting year that were responded to within the Housing Ombudsman’s Complaint Handling Code timescales. In calculating this TSM, providers must follow the ‘the timescales for responses for each complaint stage set out in the Housing Ombudsman’s Complaint Handling Code and associated guidance’.

The Complaint Handling Code sets out timescales for responding to complaints at each stage, including standard timescale plus the ability of providers to apply extensions for individual complaints in certain cases. The 2022 Code states that extensions may be applied under certain exceptional circumstances, whilst the 2024 Code states that landlords must decide whether an extension is needed when considering the complexity of the complaint and appropriately inform the resident. The permitted timescales for extensions have been updated between the two versions of the Code. 

To confirm, if an extension to the standard Code timescale has been appropriately applied to a particular individual complaint – and this extension is no more than the permitted extension set out in the Code – the regulator would regard this response as within CHC maximum timescales for the purposes of reporting CH02. We expect CH02 data reported for the year 1 April 2023 to 31 March 2024 to adhere to this general principle.

The technical requirements (as updated in March 2024) clarify how the use of extensions permitted by the 2024 Code must be reflected in CH02 for reporting years starting from 1 April 2024 or later. This clarifies that where the response to any complaint exceeds the extension timescales specified in the 2024 Code then this cannot be reported as responded to within Code timescales for the purposes of TSMs. This means that any complaint where a full response was not issued within 20 working days after acknowledgement at stage one - or within 40 working days after acknowledgement at stage two – must not be reported as responded to within Code timescales for the purposes of CH02. This applies even if there is good reason for a complaint response to exceed these specified extension timescales (as described in the Code). 

As set out in the technical requirements, providers are not restricted from collecting or publishing additional performance measures or information alongside the TSMs. Therefore, if there is explanatory information that would ensure that the published information is a more transparent reflection of performance this can be included alongside CH02. This could potentially include the number of complaints responded to within Code timescales that required the use of extensions (as specified in the Code), and those responded to within standard Code timescales. To note, the regulator anticipates collecting this data from all large providers as part of the TSM data return (^4).

The technical requirements (page 24) specify that ‘providers may only use different maximum timescales if a valid exception as set by the relevant Complaint Handling Code and associated guidance applies’. If CH02 has been calculated using timescales that differ from those set in the Code, providers must ‘report the maximum timescales used alongside the TSM and clarify that these diverge from the standard timelines in the Complaints Handling Code.’ This reporting requirement only applies where, for example, the standard timescale used for responding to complaints at a certain stage used to calculate CH02 differs from that set out in the Code – it does not apply to extensions for individual complaints permitted by the Code. To clarify, the 2024 Code requires that all providers must use the timescales set out in the Code; however under previous versions of the Code providers were permitted to diverge from the standard timelines of the Code under certain circumstances.

In order to report that we have responded to a complaint within the maximum Complaint Handling Code timescales for the purposes of CH02, do we need to ensure that we have met maximum timescales for both (a) acknowledgement/logging and (b) responding to the complaint?

The Complaint Handling Code sets out timescales for responding to complaints at each stage. The relevant version of the Code for the purposes of TSMs is the version which was applicable during each reporting year. CH02 data reported for the year 1 April 2023 to 31 March 2024 must follow the relevant timescales in the 2022 Code; CH02 data for reporting years starting from 1 April 2024 or later must follow the relevant timescales in the 2024 Code.

The 2022 Complaint Handling Code includes two timescales for responding to stage one complaints: (a) acknowledging/logging the complaint after it has been made, and (b) responding to the complaint once it has been logged. For the purposes of calculating CH02 for the year 1 April 2023 to 31 March 2024, the regulator regards both these timescales as part of the maximum timescales for responding to stage one complaints. To confirm, therefore, it is necessary for the provider to ensure both timescales (a and b) have been met in order to report that a complaint was responded to within the Housing Ombudsman’s Complaint Handling Code timescales. The regulator is not prescriptive about exactly how providers monitor this for different types of complaints. For email or telephone complaints, for example, providers’ processes may ensure that the acknowledgement/logging of complaint is effectively instantaneous and hence timescales for logging a complaint does not need to be tracked specifically.

The 2024 Code includes updated timescales for responding to complaints. As set out in TSM technical requirements (as updated in March 2024), for the purposes of CH02 data collected for a reporting year starting 1 April 2024 or later, the Complaint Handling Code timescales are defined as follows:

Stage one

  • Landlords must acknowledge, define and log stage one complaints within five working days of the complaint being received.
  • Landlords must issue a full response to stage one complaints within 10 working days of the complaint being acknowledged, or within 20 working days of acknowledgement for complex complaints (where, as per the Code, more time is needed, and the resident has been informed of the expected timescale in a manner consistent with the Code).

Stage two

  • Landlords must acknowledge, define and log stage two complaints within five working days of the escalation request being received.
  • Landlords must issue a final response to stage two complaints within 20 working days of the complaint being acknowledged, or within 40 working days of acknowledgement for complex complaints (where, as per the Code, more time is needed, and the resident has been informed of the expected timescale in a manner consistent with the Code).

If any of the above timescales have not been met then a complaint (at stage one or stage two) must not be counted within part A of CH02 calculated for a reporting year starting 1 April 2024 or later.

Do we count complaints made within a reporting year for CH01 and CH02, even if we have not responded to them by (or not had opportunity to respond to them) by the end of the reporting year?

In summary, all complaints made within a reporting year must be counted within CH01 and CH02. The technical requirements (pages 22-25) state that for reporting CH01 and CH02, the number of stage one/stage two complaints made during the reporting year must be defined as follows: ‘Every complaint must be allocated to a single reporting year – as specified in Section 1 of this document – based on the date the complaint was made.’ Further, Part A of CH02 is as follows: ‘Number of stage one/two complaints made by tenants during the reporting year for the relevant stock type that were responded to within the Housing Ombudsman’s Complaint Handling Code timescale’ (page 23).

Take for example a provider with a reporting year of 1 April 2023 to 31 March 2024. A complaint that was made in March 2023 (i.e. before the reporting year) must be excluded from CH01 and CH02 for 2023/24, even if it was responded to in April 2023. A complaint made in March 2024 must be included, even if it was responded to in April 2024 (i.e. the response was after the reporting year). We anticipate this data will be compiled after year end and will include those responses to complaints made by 31 March that were responded to during the next reporting year (but within the Complaint Handling Code maximum timescales).

C: Neighbourhood management – Anti-social behaviour

What is the definition of an anti-social behaviour case for NM01?

Specifically: (a) does it include noise issues? (b) does it include all ASB cases that are handled by a local authority?

The technical requirements state that for the purposes of NM01, ASB is defined as per the Anti-Social Behaviour, Crime and Policing Act 2014 and an anti-social behaviour case is ‘a log of activity undertaken by a provider in response to a report of anti-social behaviour to the provider from a tenant, representative, provider or contractor staff, service users or other individual or organisation’. Moreover, requirements clarify that ‘local authority registered providers must only include ASB cases where they have undertaken activity in their capacity as a registered provider of social housing in response to a report of ASB’ (page 25) – the same principle would apply to any other organisation.

It is ultimately for providers to ensure that they use this definition of an ASB case in calculating NM01, taking advice if necessary. For example, in response to the first specific query, providers must appropriately determine whether noise issues class as ASB using the above definition. Providers may find it helpful to note that the government guidance to social landlords on ASB includes examples of noise issues which might be regarded as ASB (and those which may not).

Many local authorities have a general role on ASB that extends beyond their landlord function. On the second specific query, the technical requirements clarify that in calculating NM01 ‘local authority registered providers must only include ASB cases where they have undertaken activity in their capacity as a registered provider of social housing in response to a report of ASB’ (page 25). NM01 must not include other ASB cases handled by local authorities that do not meet this definition.

As set out in the technical requirements, providers are not restricted from publishing additional information alongside the TSMs. Therefore, if there is explanatory information around the approach to logging ASB cases that would ensure that published information is a more transparent reflection of performance against the TSMs then providers can publish this alongside NM01. The regulator plans to review providers’ TSM data in the round – alongside other sources of information – to inform our approach to regulating consumer standards. We are conscious that there may be some issues around interpretation for TSMs such as NM01 which mean that this approach will be particularly important for certain measures.

D: Repairs and stock condition

What repairs are included in the scope of RP02 – Repairs completed within target timescale?

Specifically, do these include: (a) repairs to roofs or external communal areas (e.g. washing line for communal use, car parks), (b) repairs identified through safety checks (e.g. Housing health and safety rating system inspections)?

Technical requirements define responsive repairs for calculating RP02 as follows: ‘A responsive repair is a reported defect to the property occupied by one or more tenants that is the landlord’s responsibility to make good. It includes any such repairs within individual dwelling units, as well as communal areas or other parts of buildings that are occupied by at least one tenant. It does not include any repairs that are part of planned or cyclical works.’

All repairs that meet this definition must be included within the calculation of RP02. The regulator’s intention is for this to include responsive repairs within both internal and external communal areas of buildings occupied by tenants. On the first specific query, providers will need to judge whether specific defects meet the above definition. RP02 would certainly include any responsive repairs on roofs. However, on external communal areas, providers will need to determine whether a defect on parts such as a washing line or car park is within the communal area of a building occupied by at least one tenant.

On the second query, any defect identified through any HHSRS (or other) safety inspection that meets the above definition must be recorded as a responsive repair for calculating RP02.

Do all responsive repairs need to be included in the calculation of RP02?

Specifically, do we need to include: (a) specific types of repairs where we have not previously applied standard target timescales for emergency/non-emergency repairs (e.g. leaks)? (b) repairs where a tenant has agreed for them to be carried out later than the target timescale?

The technical requirements for RP02 confirms that providers must establish target timescales for all responsive repairs as follows: ‘A target timescale represents the maximum end-to-end completion time (days or hours) for a particular type of responsive repair that the provider has set as a service standard. For the purposes of this TSM, all providers must set such target timescales for emergency and non-emergency responsive repairs as a minimum. Providers are permitted to set more than one target timescale corresponding to different types of non-emergency or emergency responsive repair. For example, within non-emergency responsive repairs providers may set different target timescales for ‘urgent’ and ‘non-urgent’ repairs (or for different stock types or management areas).’

On the first specific query, therefore, for any responsive repairs not previously measured against standard timescales, providers must ensure that there is a target timescale for completion set in line with technical requirements, and that performance is measured against this. To note, providers are permitted to set more than one target timescale corresponding to different types of non-emergency (or emergency) responsive repairs.

On the second specific query, if a tenant has agreed for a responsive repair to be carried out later than the target timescale, the timing of the completion of this repair must still be reported in line with the technical requirements for RP02. This means that this repair must not be included in Part A of RP02 (number of responsive repairs completed within the provider’s target timescale) but must be included Part B (number of responsive repairs completed during the reporting year). This applies even if the later completion date has been requested by the tenant.

The regulator is required to take a proportionate approach and recognises that there are many reasons why target timelines may not be met for all responsive repairs (including access issues). As underlined in the consultation and technical requirements, the TSM requirements do not prevent providers from arranging mutually convenient appointments with tenants or publishing additional information alongside the TSMs. This information could potentially include, for example, material reasons for TSM performance or additional performance metrics.

The definition of RP02 was carefully considered through TSM design and consultation. We considered alternative measures of repairs timeliness – including those based on average days’ completion time or appointments agreed with tenants for each repair. Compared to these alternatives, we concluded that RP02 represented the most robust and transparent measure that meets the aims of the Social Housing White Paper. We noted that a minority of providers may not have established target timescales for responsive repairs but concluded that it is proportionate to require target timescales to be established for the purposes of transparently communicating repairs.

When measuring completion time of each responsive repair to calculate RP02, does this completion time start when (a) a defect is reported by a tenant, or (b) when this reported defect is inspected by an operative to determine required works?

The technical requirements for RP02 state that: ‘The completion time for each responsive repair must measure the end-to-end time, from the date that the repair was first brought to the landlord’s attention by the tenant (or other party) until the date that the repair was completed, as confirmed by the contractor/operative’.

This means that for the purposes of calculating RP02, the measured completion times start when a defect is reported by a tenant, and not when an operative inspects a property following a reported defect to determine required works. If, following such an inspection, it is determined that a responsive repair is not required then no responsive repair has been completed and this case would not be included in the calculation of RP02 (in either Part A or B).

How do we report RP02 when our group has multiple entities with different repairs timelines?

All TSMs must be reported on a registered group basis as defined in technical requirements (paras 9-10). In particular, ‘registered group parents must report consolidated TSMs for the group, calculated on the basis of all relevant social housing stock owned by themselves and all subsidiary registered providers.’

Technical requirements for RP02 state that: ‘Providers are permitted to set more than one target timescale corresponding to different types of non-emergency or emergency responsive repair. For example, within non-emergency responsive repairs providers may set different target timescales for ‘urgent’ and ‘non-urgent’ repairs (or for different stock types or management areas)’. Further, ‘where different target timescales for emergency or non-emergency repairs are used, providers must combine results to generate the two metrics above with each repair considered against the target timescale pertaining to it’. The requirements set out an example of how multiple timescales are to be reflected in the calculation and reporting of RP02.

On the specific query, where there are two group entities with different target repairs timescales, these must be reflected in calculations and reporting following the same technical requirements summarised above. For example, if two entities A and B have different target timescales for completing non-emergency responsive repairs, RP02 Part 1 would be calculated as follows: if entity A completed 50 of 100 (50%) non-emergency repairs within target (10 days), and entity B completed 90 of 100 (90%) non-emergency repairs within target (20 days), then the non-emergency repairs metric is calculated as (50+90)/ (100+100) = 70%. As set out in the technical requirements, overall performance (70%) must be published alongside the specific target timelines used to calculate this.

Providers need to determine what information they need to report beyond the TSMs specified in the requirements in order to support effective scrutiny by tenants of their landlord’s performance (a general requirement of the ​Transparency, Influence and Accountability Standard). For some providers this may include reporting RP02 (or other TSMs) for different entities and management organisations in addition to those reported at group level.

For RP01 – Homes that do not meet the Decent Homes Standard, should we include units where tenants refuse works that are preventing the unit from reaching the decency level?

Technical requirements for RP01 address this issue as follows: ‘Providers must use Decent Homes Standard Guidance published by the Government to determine whether a dwelling unit meets this Standard. This guidance sets out certain circumstances in which a dwelling unit should not be reported as non-decent (for example if making a home decent is against a tenant’s wishes); dwelling units to which these specific circumstances apply should not be included in Part A of the TSM calculation.’ In summary, therefore, providers should not report units where tenant refusal is preventing works necessary to meet the standard as failing DHS in RP01.

Providers should also note the reporting requirements on DHS compliance in data returns to the regulator and to the government’s Department for Levelling Up, Housing and Communities (for local authority registered providers). In particular, the Statistical Data Return requires private registered providers with more than 1,000 units to report the number of units that are not reported as non-decent due to particular reasons set out in the Decent Homes Standard guidance (see NROSH+ website for details).

E: Tenant perception surveys

How specifically should we meet requirements on representativeness?

Specifically:

(a) How exact does representativeness needs to be – for example, if there is a 5% difference between the proportion of the tenant population and survey responses that share a certain characteristic, would this be classed as representative for the purposes of TSMs?

Ensuring that responses used to generate TSMs are representative is a key component of the TSM survey requirements. As an overarching principle, providers ‘must ensure that, as far as possible, survey responses used to calculate perception TSMs are representative of the relevant tenant population’ (para 48). More specifically, providers ‘must undertake reasonable checks for differences between total survey responses and the relevant tenant population in terms of characteristics associated with different average satisfaction scores’ (para 49). Further, ‘if this assessment confirms the sample is unrepresentative, and this is likely to have a material impact on satisfaction scores, then providers must appropriately weight the responses to ensure the TSMs reported are representative as far as possible’ (para 54).

To respond the specific query, given the variation of providers and their stock, there is no one-size-fits-all answer as to how exact representativeness needs to be. Survey requirements state that ‘the scope of the assessment of representativeness must be proportionate to the size and complexity of each provider’s stock, tenant base and sampling approach’ (para 53). In particular, small providers with fewer than 1,000 dwelling units are ‘only required to undertake a high-level assessment of representativeness’ and ‘are not required to weight responses, unless it is possible to generate a sample large enough to meet minimum statistical accuracy and there is strong evidence of a significant bias in estimated scores’ (paras 53, 56).

When deciding on weighting, providers must assess how far any difference between the survey responses and the tenant population is likely to have a material impact on satisfaction scores – drawing on expert input if required. The regulator recognises that it may not be feasible to achieve exact representativeness – in particular this may be practically difficult if responses are weighted by several characteristics. Ultimately, however, providers must ensure that, as far as possible, responses used to generate TSMs are representative.

Providers with 1,000 or more units are required to publish a summary of their approach, including their assessment of representativeness and any weighting applied (para 35). Providers are able to use this summary to explain decisions around their weighting approach.

(b) Are we expected to ask respondents characteristics such as age and ethnicity in the survey and use these responses to compare to our data, or are we expected to identify them in our system and use the data we already hold on these characteristics for this analysis?

In summary, in order to satisfy tenant survey requirements, providers may use previously held data on tenant characteristics or collect this information as part of the tenant perception survey (or some combination of the two). The regulator recognises that some providers may need to use survey responses to populate and update underlying data on tenant characteristics.

Survey requirements state that ‘providers must reach a balanced judgement as to which characteristics to include in this assessment of representativeness based on their particular tenant profile, evidence or rationale for potential different satisfaction scores by characteristic, and available data’ (para 50). It also states that ‘providers must ensure they hold requisite information on tenant characteristics to undertake this analysis. This includes ensuring data for the relevant tenant population is sufficiently robust’ (para 51).

What approach should we take to surveying tenants with specific complex need or disabilities?

For example: (a) We have some tenants with intensive care needs and limited decision-making capability. Can these be exempted from the survey? (b) We have clients with learning difficulties, and we would like to be able to send our survey using an easy read questionnaire. Are we able to do that or do we still need to use the wording set out in the requirements?

The survey requirements include significant information on accessibility and barriers to responding (page 24). In general, ‘providers must take reasonable steps to assess, identify and remove barriers to certain groups of tenants participating in surveys used to generate the TSMs’. We clarify that ‘where necessary to overcome barriers to participation, it is permissible for surveys to be completed by a carer, another household member on behalf of a tenant or through an interpreter’ (para 63).

Survey requirements also state that ‘under exceptional circumstances, providers are permitted to remove some tenant households from the sample frame where there are significant capacity issues or health and safety risks that cannot be reasonably surmounted. Such capacity issues are those that are likely to prevent a meaningful response to the vast majority of the TSM questions’ (para 64).

In summary, in response to the specific query, providers can exempt tenants with significant learning difficulties or care needs from the survey as long as the circumstances described in paragraph 64 apply. Providers must reach a view on the extent to which these circumstances apply, based on their assessment of specific needs and capacity issues of tenants. All providers must publish the number of tenants that have not been included in the sample frame due to these circumstances, with a broad rationale for their removal, as part of their published summary of approach (para 35).

The use of easy read questionnaires is addressed in the requirements as follows: ‘In exceptional cases where a material number of tenants have been removed from the sample frame, providers must take an appropriate approach to seek the views of these tenants on relevant topics covered by tenant perception measures. This may include using ‘easy read’ versions of the TSM questions suitable for these tenants. Providers must communicate a summary of results from these approaches in a manner they consider appropriate to support effective scrutiny by tenants of their landlord’s performance’ (para 65).

To confirm, therefore, ‘easy read’ surveys can be used for tenants exempted from the survey under the exceptional circumstances described in paragraph 64. However, any data derived from surveys that use different versions of the TSM question wording (e.g. easy read surveys) must not be included in the calculation of perception TSMs. This is because the results of surveys cannot be robustly compared without consistent wording of questions and response options.

Can we include other questions in the survey questionnaire, in addition to the specified TSM survey questions?

To confirm, as set out in tenant survey requirements, survey questionnaires can include questions in addition to the TSM questions. However, providers must ensure that any expanded questionnaire is compliant with tenant survey requirements.

Tenant survey requirements state the following: ‘In addition to the questions above, providers are permitted to include other questions in the same tenant perception survey questionnaire. These additional questions may be used, for example, to better understand responses to the TSM questions, seek responses on wider or more detailed aspects of performance, or to generate data on tenant characteristics. Additional questions can be in any appropriate format (e.g. lists or free text), and can include questions that seek more information about a tenant’s response to TSM questions’ (para 14).

However, there are specific requirements around the length and structure of the resulting survey questionnaire (paras 13-17). For example, ‘the question to generate overall satisfaction (TP01) must appear as the first question in any perception survey questionnaire used to generate TSMs’ and ‘questions to generate the other TSMs must precede any other question(s) that a provider chooses to include on the same topic’. Moreover, ‘providers must take reasonable action and care when undertaking or commissioning surveys to ensure that participants are not led toward a particular point of view. In particular, beyond any necessary clarification, providers must avoid introducing any additional wording or preceding questions that are likely to have a significant impact on responses to TSM questions’.

All providers are required to publish a summary of the survey approach used to generate published tenant perception measures. To note, alongside this summary, ‘all providers must publish the questionnaire(s) used to generate survey responses. This must include any additional questions and introductory or explanatory wording communicated to tenants alongside the TSM questions’ (para 36).

F: Building safety

We carry out safety checks x, y, z…. can the regulator confirm our approach is compliant for the purposes of reporting BS01-BS05?

The technical requirements describe the safety checks to be reflected in building safety TSMs BS01-BS05 (pages 30-35). These require providers to ensure that all statutory obligations in relation to carrying out the specified safety checks have been met in order to report compliance for the purposes of the TSM. Providers must determine what statutory obligations with respect to safety checks apply to their stock. In part because of their complexity and contingency to specific situations, we cannot interpret the detail of these legal requirements on behalf of providers and confirm whether they apply in different circumstances. We appreciate that these legal requirements can be complex, and providers should seek external advice if they require additional support.

On BS03: Asbestos safety checks, we understand that there are no statutory obligations to undertake checks for many of our dwelling units. What do we report if we do not have any properties that require checks?

Technical requirements state that BS03: Asbestos safety checks must be calculated as follows (page 33):

A. Number of dwelling units owned within properties that required an asbestos management survey or re-inspection for which all required asbestos management surveys or re-inspections were carried out and recorded as at year end.

Divided by

B. Number of dwelling units owned within properties for which an asbestos management survey or re-inspection was required to have been carried out at year end.

Carrying out an asbestos management survey or re-inspection is defined as ensuring that ‘all statutory obligations in relation to carrying out asbestos management surveys or re-inspections for a particular property were met’. The regulator cannot interpret the detail on these legal requirements on behalf of providers and whether they apply in certain circumstances. We appreciate that these legal requirements can be complex, and providers should seek external advice if they require additional support.

A ‘property’ in this context is defined as ‘a building that requires asbestos management surveys or re-inspections’ under statutory obligations. Such properties typically include, for example, block of flats that contain multiple dwellings. Many dwelling units owed by providers will not be in buildings that require asbestos management surveys or re-inspections under statutory obligations – these dwelling units must not be included in Part A or Part B of the calculation above.

We also recognise that good practice in building safety checks can sometimes exceed the statutory obligations described in the building safety TSMs. This may include, for example, measures to manage asbestos where it has been identified in individual domestic dwellings. In these instances (unless where specifically stated, such as lift safety BS05) TSMs must reflect the extent to which providers have met statutory obligations in respect to specified safety checks rather than any broader standards of good practice.

In response to the specific query, if a provider does not own any dwellings within properties that required an asbestos management survey or re-inspection (i.e. B in the formula above is zero), mathematically the ratio is undefined. In this case, it would be reasonable to report BS03 as ‘N/A’ and, for transparency, to note the basis for the calculation alongside the published TSM i.e. that there were no properties that required an asbestos management survey or re-inspection.

What level of evidence do we require from third parties to report compliance for BS01-BS05?

The TSM requirements state that TSMs BS01-BS05 must reflect all specified safety checks that affect dwelling units owned by a provider, even if the statutory responsibility for carrying out these checks lies with a third party (sometimes called a ‘legal dutyholder’). For example, requirements for BS01 states that: ‘The calculation of this TSM must reflect all gas safety checks that relate to dwelling units owned by the provider, including checks for which a third party is responsible. These may include, for example, checks on a communal boiler in a building owned by a third party landlord, which serves LCRA and/or LCHO units owned by the provider’ (page 30).

This means that providers must obtain documentary evidence that relevant safety checks have been carried out by responsible third parties in order to report that all relevant safety checks have been carried out for affected dwelling units (Part A of the calculation for BS01-BS05). There are no specific requirements on the precise form of this documentary evidence.

Following TSM requirements however, this would need to be documentary evidence sufficient to give the provider adequate assurance that all statutory obligations in relation to carrying out the specific area of checks (for BS01-BS05 respectively) had been met by the relevant date and that these were appropriately recorded. It is ultimately the responsibility of boards of private registered providers and governing bodies of local authority registered providers to get assurance that the TSMs have been calculated accurately and in accordance with regulatory requirements.

The treatment of checks by third parties in calculating building safety TSMs was an issue the regulator considered carefully leading up to and through the consultation on the introduction of TSMs. We concluded from the consultation that the position on third party checks reflected in the TSM requirements is proportionate given the aims of the Social Housing White Paper and the TSMs.

To calculate the number of dwelling units for which all required checks have been undertaken for BS01-BS05, how do we treat safety checks on communal parts or blocks rather than individual dwellings?

BS01-B05 require providers to report the number of dwelling units for which all specified safety checks have been carried out. These checks include those within individual dwellings but also any relevant checks on communal areas or whole buildings containing multiple dwellings. In order to report compliance for building safety TSMs, providers must ensure that all specified checks that could affect the safety of individual dwellings units have been carried out.

In summary, technical requirements set out specifically how required checks on communal parts or blocks must be treated in the calculation of each TSM BS01-BS05 (pages 30-35). For example, BS02 Fire safety checks reporting is based on the number of dwellings owned within properties (e.g. blocks of flats) where all required fire risk assessments have been carried out. In contrast, for BS01 Gas safety checks, reporting is on the basis of all checks required inside each dwelling and on any communal or relevant part that serves each dwelling. This general principle is set out alongside two worked examples (pages 7-8).

How do we report BS01 – Gas safety checks for LCHO stock with gas boilers in a communal block? What about leasehold stock?

Technical requirements set how required checks and stock types must be treated in the calculation of BS01 (page 30). The requirements state that BS01 must be reported for LCRA and LCHO stock only (combined). For this TSM, this includes all such units that require gas safety checks within the dwelling, and all such units served by communal or other relevant parts that require gas safety check.

In summary, if there is an LCHO unit where there are no gas safety checks required either within the dwelling or on any communal or other relevant part serving the dwelling, then this unit would be excluded from the calculation of BS01. This might include some LCHO units with individual gas appliances within their dwelling but where there are no statutory obligations in relation to carrying out gas safety checks within these units.

However, if there is an LCHO unit that is served by a communal part that does require a gas safety check (e.g. a communal boiler), then this unit must be reflected in the calculation of BS01. Providers must ensure that required gas safety checks have been carried out on all communal or relevant parts serving this unit has been carried out in order to report compliance for this LCHO unit. More detail in set out in the technical requirements (see BS01 requirements on page 30, and an illustrative calculation on pages 7-8)

Leasehold stock is not LCRA or LCHO by definition and therefore should not be included in the calculation of BS01 or any other TSMs (see general queries above, and TSM requirements para 14). If there is a tower block where the provider owns 50 dwelling units served by a communal gas boiler – of which 10 are leasehold, and 40 LCRA and LCHO – BS01 must be calculated on the basis of the 40 LCRA and LCHO units only.

If we have gas boilers serving communal areas (e.g. lounge, kitchen), rather than dwellings directly, would gas safety checks on this communal boiler be reflected in the calculation of BS01?

Technical requirements for BS01 state: ‘Gas safety checks relating to a dwelling unit include all checks required both inside the dwelling and on any communal or relevant part that serves the dwelling. For example, if a gas safety check is required on a communal boiler that serves a number of relevant dwelling units, providers must ensure that this check is carried out to be able to report compliance for these units’ (page 30).

In general, for the purposes of defining BS01 the regulator would regard all dwellings whose residents are supplied with heating or hot water from a communal gas boiler as being ‘served’ by this communal boiler. This would be irrespective of whether this boiler only directly serves communal areas (e.g. kitchens, bathrooms) used by residents of non-self-contained accommodation. Moreover, it would also be irrespective of whether this communal boiler was housed in the same or a different building to the residents. As set out in worked examples in technical requirements, the intention is that in general gas safety checks on communal boilers would be reflected in the calculation of BS01.

For some building safety TSMs, whether a communal part ‘serves’ a particular dwelling may be a matter of reasonable judgement. The TSM requirements reflect a precautionary principle on this issue: ‘The building safety TSMs require providers to report the number of dwelling units for which all specified safety checks have been carried out (BS01-BS05). Statutory obligations require providers to conduct a range of safety checks, including on individual dwelling units but also on communal parts or whole buildings that contain multiple dwellings units. For the purposes of the building safety TSMs, providers must ensure that all specified checks that could affect the safety of individual dwelling units have been carried out’ (para 17).

In summary, the regulator would regard a communal part intended to provide a service or benefit to the residents of a dwelling unit as ‘serving’ this dwelling unit for the purposes of reporting building safety TSMs. Moreover, if there is a check on a communal part that could affect the safety of individual dwelling then this must be reflected in relevant TSMs.

How do we define a ‘property’ for the purposes of calculating the building safety TSMs?

For example, if several tower blocks are linked by walkways – such that residents can potentially use lifts in other blocks – should BS05 Lift safety checks be calculated assuming all interlinked blocks are a single property or counting each block individually?

Some building safety TSMs are calculated on the basis of checks on ‘properties’, that is buildings that may include multiple dwelling units (^5). These TSMs require that all the specified safety checks must have been carried out for each property in order to report compliance for the dwelling units owned within each property.

In response to the first specific question, the technical requirements set out the definition of ‘property’ that applies for each TSM (pages 32-35). For example, the technical requirements state that BS05 – Lift safety checks must be calculated as follows:

A. Number of dwelling units owned within properties with communal passenger lifts for which all Lifting Operations and Lifting Equipment Regulations inspection reports were carried out and recorded as at year end.

Divided by:

B. Number of dwelling units owned within properties with communal passenger lifts as at year end.

The technical requirements (page 35) define a ‘property’ for the purposes of calculating BS05 as follows: ‘A communal passenger lift within a property is a lift provided for use of the occupants of a dwelling unit in common with the occupants of at least one other unit in the property. In this context, a property is a building with at least one such communal lift (e.g. a tower block)’.

On the second specific query, whether interlinked tower blocks should be classed as one property for calculating BS05, this depends on whether communal lifts have been provided ‘for use of’ the occupants of each individual block or for use of the occupants of all linked blocks. Given the specific local information required to answer this question, and the variation of these circumstances in the sector, it is not possible for the regulator to confirm the precise scope of individual properties in each case. Providers are best placed to reach a view on how the specific features of their stock meet this type of definition (taking external advice if required) – this may require a degree of reasonable judgement.

(^1): The standard incorporates the published requirements on TSMs that came into force from April 2023 under the TSM Standard. The new Transparency, Influence and Accountability Standard replaces the TSM Standard.

(^2): This definition of leasehold stock reflects that in wider regulatory data returns (e.g. 2023 Statistical Data Return).

(^3): The technical requirements confirm that ‘registered providers’ means ‘registered providers of social housing’.

(^4): https://nroshplus.regulatorofsocialhousing.org.uk/documents#

(^5): BS02 – Fire safety checks, BS03 – Asbestos safety checks, BS05 – Lift safety checks.

Published 23 March 2023

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