Social Housing (Regulation) Bill, Consideration of Lords amendments, House of Commons, 17 July 2023

Councils are determined that all tenants should have the security of a safe and well-maintained home, with any issues quickly and satisfactorily addressed.


Key messages

  • Councils are determined that all tenants should have the security of a safe and well-maintained home, with any issues quickly and satisfactorily addressed. Local government shares the Bill’s ambition to improve the quality of social housing and we are working with Government to ensure it delivers on these aims.
  • During its Commons stages, Government amended the Bill and introduced a requirement that senior social housing managers and senior housing executives have, or are working towards, appropriate level housing management qualifications within two years. During the consideration of the Commons amendments, Government amended the Bill to extend this requirement to relevant senior staff in organisations that deliver housing management services on behalf of registered providers of social housing. 
  • In May to June 2023 the LGA conducted a survey of Directors of Housing across all housing-stock owning councils in England, to understand the impact these new standards will have on the housing sector. 42 councils responded to the survey, equating to 16 per cent of stock holding local authorities. It found that:

o  66 per cent of senior housing managers and 54 per cent of senior housing executives at respondent councils require further qualifications to meet the new requirements.

o  62 per cent reported that they would not feasibly be able to ensure 100 per cent compliance with the required level of qualifications within a two-year period, given their current resources.

o  English councils are likely to face £17.9 million in additional costs resulting directly from these requirements for the first two years, and £3.7 million per annum on an ongoing basis after the end of the first two years.

 80 per cent of respondents anticipated great or moderate disruptive impacts on their recruitment and retention of housing officers and 68 per cent anticipated a disruptive impact on their service provision as a result of the requirements.

  •  It is right that senior staff who are managing social housing have appropriate training and qualifications. However, council housing management teams are already facing significant pressures due to resourcing and recruitment challenges. It is therefore important that the introduction of these new requirements is properly managed, to avoid risking any disruptions to service delivery which will be felt by social tenants.
  •  We are calling on Government to work with us to develop a comprehensive strategy for implementation, to mitigate any impacts on workforce retention, recruitment and housing teams’ capacity to deliver. It is vital that councils are properly resourced and the timescales for implementation are realistic. Government will need to consider a range of factors including how quickly the market can deliver a sharp increase in training places and the impact of diverting staff from frontline service delivery to undertake training. Given that staff structures and roles vary across councils, there must also be sufficient local flexibility to ensure the requirements are applied to appropriate roles.
  • The requirements will likely cost councils £17.9 million in the first two years, and then £3.7 million per annum. It is essential that Government provides councils with adequate new burdens funding for all costs to prevent them falling on over-stretched Housing Revenue Accounts (HRAs). We have long raised with Government that HRAs are already facing unsustainable financial pressures, which are increasingly impacting councils’ ability to deliver their responsibilities and ambitions as local housing authorities. 

Further information

The scope of the requirement  

Currently, it is not clear what constitutes a “senior housing executive” or “senior housing manager,” or what type of roles within councils will be required to hold relevant housing management qualifications. For example, it is unclear if managers working within council Customer Service teams or finance roles within housing teams will be in scope of the requirement or whether it only relates to tenancy management staff.

There is also a lack of clarity on what qualifications are considered sufficient, especially relating to historic qualifications gained decades ago, and Chartered Institute fellowships and qualifications. Councils report that housing officers hold a wide proliferation of different types of qualifications and expressed uncertainty as to whether these will be considered sufficient.

The Department of Levelling Up, Housing and Communities (DLUHC) are working to clarify which roles will be in scope of the requirement and what qualifications will be considered ‘appropriate.’ Given that staff structures and roles vary across councils, we are keen to ensure that there is sufficient local flexibility so that the requirements are applied to appropriate roles. 

Disruptive impacts on the workforce and service delivery

Workforce

A total of 80 per cent of respondents anticipated great or moderate disruptive impacts on their recruitment and retention of housing officers as a result of the requirements. 

Housing teams report that they are already struggling to recruit suitable candidates for senior roles. In the short-term, there is a risk that the new requirement will exacerbate these challenges by causing staff to leave the sector. This may be a particular issue for staff who are approaching retirement age and do not want to undertake training for a new qualification. Exemptions could be considered for those approaching retirement age, to help retain these staff while others undertake training.

In the longer-term, professionalisation of these roles and guarantee of in-role learning and development could help attract new applicants. However, this might require increasing salaries for these roles to reflect the additional eligibility requirements. 

Service delivery

A total of 68 per cent of respondents anticipated a disruptive impact on their service provision as a result of the requirements. Training the workforce will take time and money, which risks diverting staff time and resources away from frontline service delivery. 

Councils have reported that they might need to recruit additional staff to give their existing staff the time required to complete the necessary qualifications. These roles will require additional funding and will likely be difficult to recruit to, given their short-term nature.

A comprehensive strategy for implementation

We are calling on Government to work with us to develop a comprehensive strategy for implementation, to mitigate any impacts on workforce retention, recruitment and housing teams’ capacity to deliver. 

It is vital that councils are properly resourced and the timescales for implementation are realistic. Government will need to consider a range of factors including how quickly the market can deliver a sharp increase in training places and the impact of diverting staff from frontline service delivery while training. 

A phased approach to implementation could be considered, requiring, for example, 50 per cent of applicable staff to be sufficiently qualified within two years, 75 per cent in three years, and 100 per cent in five years.

New burdens funding must also encompass the costs of backfilling staff, to cover existing staff while they are undertaking training.