RPs will be all too familiar with the long line of events leading up to the implementation of the Social Housing (Regulation) Act 2023 and its purpose to reform the regulatory regime and drive significant change in landlord behaviour.
A key part of the Act is the reform of the consumer regulatory regime and, in particular, revisions to the consumer standards. Drafts of the new consumer standards have been out for consultation with the intention that they will apply from April 2024. The changes centre around two main themes, being 1) the adequacy of the safety and quality of housing; and 2) the importance of tenant influence in the heart of decision making and the importance of scrutiny by tenants of their landlords.
Over the last few months Trowers have run several events looking at the changing landscape of consumer regulation. These events have been very well attended and well received. Following the success of those events, we have also recently held a more targeted session looking at the "golden thread" of tenant voice and engagement and how providers should work that into their organisations. We hosted what was an incredibly valuable session, with insights being shared from three RPs and also TPAS as leading tenant engagement experts.
To use the Regulator's language, the 'desired outcome' is clear. RPs need to embed the tenant voice within their decision making structures, making sure that they can evidence that tenant views are actually influencing decisions taken at board level. How RPs reach that desired outcome is up to them. What is clear from talking to a number of RPs is that there is no one size fits all approach. Similarly, there is no single engagement structure an RP can adopt to completely satisfy the expectations. RPs will have to tailor their engagement approach according to their tenants and implement a number of different tenant touch points within their business to make sure they are feeding through truly representative tenant views.
Anecdotally we hear from RPs that they try and fail to engage with their tenants because those tenants are not interested in being engaged. This is not enough. RPs need to take the view that lack of engagement is a failing of the engagement structure itself and a failure to properly tailor to their residents. RPs need to think more creatively about how to engage their tenants. We heard a number of great examples from RPs, including a "chips and chat" Friday. An RP arranged for a chip van to drive around its estates and set up tables with different staff teams available for chats. Tenants who engaged and shared views would receive fish and chips to have with their neighbours. This was effective not just in driving engagement, but helping foster a better sense of community amongst residents.
We have also heard from RPs who might have thought that their tenants would oppose rent increases to the maximum cap level. In fact, by involving tenants in business considerations, those tenants articulated that a higher priority for them was continued investment in housing stock and so the tenants advocated for higher rent increases. This may come as a surprise to some RPs and illustrates that if you make assumptions about your tenants wishes you may, even if well intentioned, move in a direction that actually does not represent your tenant voice.
In creating an engagement structure, RPs might consider the TPAS pyramid approach. This is where tenant engagement is embedded at each level of decision making. This should start with some influence at board level and then feed down through to the day-to-day contact that employees of the RP are having with residents. It is important that everyone within an RP understands that engagement, even if just informal, is part of everyone's job.
Of course, knowing what your tenants want and what engagement structure will work for your tenants comes back to another key point the Regulator is keen to stress – the importance of underlying data. RPs must understand who their tenants are and what their needs and wishes are. For example, do you know how many of your tenants have difficulty using computers or difficulty reading? Simply, an RP that does not have accurate underlying data about its tenants and about its stock cannot tailor an appropriate engagement structure, cannot interpret the views of their tenants correctly and cannot comply with the regulatory standards.
It is though not just the RP itself which must have access to accurate data. In order for tenants to be able to properly scrutinise their landlord, they too must have access to data, information and resources within their landlord.
Establishing engagement structures is though only half the battle. A point the Regulator is keen to stress is that those engagement structures must actually then result in outcomes. In other words, can your RP evidence that the engagement is actually influencing the decision making? To what extent have things actually changed because of what your tenants' views are?
As mentioned, there is no one size fits all approach to tenant engagement and RPs are going to have to tailor their approach accordingly. Nevertheless, it can be invaluable to share experiences and ideas with other RPs. To help facilitate this, we will be running further events on issues relating to the new consumer standards.
