Main messages
- Most social landlords continue to perform well in delivering homes and services to their tenants and other service users despite significant demands to invest in their existing homes, cost pressures (including from higher national insurance contributions, inflation and higher interest rates), and the need to deliver much needed new homes.
- Systemic failure continues to impact the delivery of homelessness services in some areas of Scotland. Three local authorities are impacted by systemic failure and a further seven are at heightened risk of systemic failure.
- Some local authorities remain non-compliant with their tenant and resident safety obligations on fire and smoke detection systems and / or certification of electrical systems.
- It is important that landlords continue to have a full and on-going understanding of their housing stock including whether they have RAAC or cladding issues. If and where identified the landlord should take immediate action to ensure the safety of tenants and residents.
- We found serious issues at three Gypsy/Traveller sites after concerns were raised to us by residents, even though the landlords had reported the site as meeting the Scottish Government’s Minimum Site Standards.
About our annual risk assessment
The annual risk assessment is a principal way in which we carry out our statutory functions including how we plan the engagement we need with social landlords. We published information on our approach and the risks we would focus on in our annual risk assessment in The risks we will focus on (November 2024).
For both local authorities and RSLs, we monitor, assess, report and intervene (as appropriate) on their performance of housing activities. This means how they deliver housing services to:
- tenants;
- people who are homeless;
- Gypsy/Travellers; and
- factored owners.
For RSLs, we also monitor, assess, report and intervene (as appropriate) on their governance and financial wellbeing. We do not have this role with local authorities.
We publish information on our assessment and planned engagement in an engagement plan for each social landlord, and we publish a regulatory status for every RSL. The regulatory status shows whether an RSL complies with regulatory requirements, is non-compliant and working towards compliance or where the landlord is non-compliant and we are taking statutory action. We also highlight where a regulatory status is under review.
The engagement plan for each landlord is available in our Landlord Directory. You can find out more about our risk assessment process, how we regulate and regulatory status in our Regulatory Framework.
Key strategic risks
Financial challenges for tenants, other service users and landlords
Inflation is now much lower than when it peaked at 11.1% in October 2022. Much of the inflation then was caused by accelerating food and energy prices. The most recent figures show inflation rising from 2.5% in December 2024 to 3% in January 2025 – which was the fastest pace in 10 months – before falling back to 2.8% in February 2025. Annual food price inflation is running higher at around 4.5%. Energy prices are predicted to rise in April 2025 and council tax will also increase from April 2025 with the average Band D property rising by between 6% and over 15% depending on the local authority area.
Cost of living challenges therefore remain for many households especially those on lower incomes. The Bank of England forecasts inflation to peak at 3.7% in the third quarter of this year though the path of inflation is unclear in the short to medium term because of:
- significant uncertainty in the scale of international trade tariffs which could raise the price of imported goods and services;
- the inflationary impact of rising costs on many employers because of increases in national insurance employer contributions and the national minimum wage; and
- continuing geopolitical instability and uncertainty in the Middle East and Ukraine which could further affect energy prices.
Despite rising inflation, the Bank of England cut interest rates in February to 4.5% from 4.75% in January. They remained at 4.5% in March. This is the lowest base rate since June 2023 but is still significantly higher than it was for much of the last decade. The Bank’s monetary policy committee cut rates in February partly because of anticipated low or zero economic growth in the short to medium term, and because it judges that inflation will return to the 2% target in 2027. The path of interest rates is uncertain though the Bank of England may be reluctant to cut the rate further given the inflation dynamic or is unlikely to do so aggressively.
Lower interest rates are good news for social landlords that have variable rate borrowings and/or who undertake new borrowing. However, as our recent report on RSL finances shows, RSLs operated in tough economic and operating conditions in 2023/24. Liquidity remained strong and most RSLs have successfully raised the necessary funds to invest in both new and existing homes. But the report also shows weaker financial performance and that record investment levels impacted RSLs’ cash and cash equivalents which have decreased for a third year in a row to £685 million. RSLs are also facing increasing demands around housing quality and decarbonisation, all whilst working to continue to deliver homes and services for new and existing tenants and service users at a price they can afford.
Overall, RSLs are operating in a challenging environment that is unlikely to improve in the short term.
Systemic failure continues to impact on the provision of services to people who are homeless
In our homeless thematic review which we published in February 2023 and updated in December 2023 we highlighted that systemic failure is now impacting the homeless services provided by a number of local authorities.
For many local authorities the demands in the homelessness system – the number of people who are homeless, and the level of need they have – continue to exceed the capacity in the system to respond. Some local authorities are now at, or are approaching, the limits of their capacity to do more. This is what we mean by systemic failure.
The latest Scottish Government data shows:
- continued increases in homelessness applications, households assessed as homeless, households and children in temporary accommodation, and open applications (in the period April-September 2024);
- the number of households and children in temporary accommodation reached the highest on record (since 2002), with the number of children in temporary accommodation now at 10,360 (at 30 September 2024);
- the average time spent in temporary accommodation for closed cases increased from 222 days in 2023 to 234 days in 2024;
- the number of times that there were failures to offer temporary accommodation when it should have been increased markedly from 2,000 in 2023 to 7,545 in 2024; and
- the number of breaches of the Scottish Government’s Unsuitable Accommodation Order (UAO) increased from 3,665 to 4,085 in the six months between April and September 2024 compared to the same period in 2023.
The most acute impact of this is where a local authority does not have suitable temporary accommodation available when someone needs it. This results in the local authority breaching its statutory duties by either having to place the person in temporary accommodation that breaches the UAO or not providing any temporary accommodation at all.
Of the 7,545 instances of households not being offered temporary accommodation, the vast majority (6,320) of these were in Glasgow, where prior to July 2023 it had none. Glasgow City Council says that this is due to the increased demand on homelessness services including from increased numbers of presentations from asylum seekers granted leave to remain. City of Edinburgh Council reported 1,015 instances of households not being offered temporary accommodation. Nineteen local authorities reported breaches of the UAO over the six months to September 2024 with Glasgow accounting for 1,650 and Edinburgh 945.
The Scottish Government has declared a national housing emergency. Thirteen local authorities have also declared local housing emergencies, including in the provision of their homelessness services. Each of the local authorities has its own reasons for calling these emergencies, but they cite common issues around availability of permanent housing, a fundamental imbalance between the demand for homelessness services and the supply of temporary accommodation and pressure on local authority finances.
Our latest analysis shows that RSLs are projecting building 22,600 new homes over the five year period to 2028/29; this rate of build is slower than previous years and the number of RSLs building has fallen.
In our most recent programme of annual structured conversations with all local authorities about their homelessness service we were told that:
- failure of the local housing market, with too little supply to meet rising demand, is cited as the main reason behind the challenging situation;
- the changes to local connection rules have caused an increase in applications in some areas; and
- whilst the Scottish Government data showed falling numbers of applicants in around half of all Scottish local authorities, the rise in demand across other areas was given as the main reason why certain local authorities are struggling. This was particularly the case for those local authorities impacted by, or are at heightened risk of being impacted by, systemic failure.
Overall, many local authorities describe system wide issues severely restricting their capacity to manage homelessness, with the issues especially acute in Glasgow and Edinburgh.
We will continue to monitor, assess and report on councils’ performance in discharging their duties to people who are homeless, and we will engage with councils to promote improvement where this is possible.
Persistent non-compliance with tenant and resident safety obligations for some landlords but for local authorities in particular
Most homes provided by social landlords meet the Scottish Housing Quality Standard (SHQS) and statutory requirements on tenant and resident safety, but it remains essential that landlords have a robust understanding of their housing stock and its condition. This will help ensure that the landlord’s business plan, financial projections, asset management strategy and investment plans are based on reliable, and up to date information. In our business planning advisory guidance, we said that financial projections should be supported by an independent stock condition survey normally no more than five years old.
Stock condition surveys can also support landlords’ achievement of the outcomes and standards in the Scottish Social Housing Charter (the Charter), particularly the:
- quality of housing outcome - ‘tenants’ homes, as a minimum, are always clean, tidy and in a good state of repair, meet SHQS, and any other building quality standard in place throughout the tenancy; and also meet the relevant Energy Efficiency and Zero Emission Heat Standard’; and
- repairs, maintenance and improvements outcome - ‘tenants’ homes are well maintained, with repairs and improvements carried out when required’.
Element 35 of the SHQS is that electrical systems must be safe. In order to demonstrate this, landlords must arrange for an Electrical Installation Condition Report (EICR) to be carried out every five years. If the EICR finds the system is safe, the property passes SHQS. If the EICR finds the system is unsafe, the property fails SHQS until the remedial work is completed. The five-year requirement was introduced to SHQS in 2020, but the Scottish Government gave landlords until March 2022 to complete any outstanding EICRs because of the pandemic.
Element 11A of the SHQS is that landlords must install interlinked smoke and heat detectors in all properties. The deadline for having these installed in every home was February 2022.
Some landlords continue to not meet these obligations particularly local authorities. At the conclusion of last year’s risk assessment we decided to engage with 19 landlords about EICRs only, or EICRs and smoke detectors. 17 of these were local authorities which meant that of the 26 local authorities with homes 65% had either one breach or both.
This year we will engage with 14 landlords about EICRs only, or EICRs and smoke detectors. 13 of these are local authorities. Non-compliant landlords must have a plan for becoming compliant with urgency. We will monitor this through on-going engagement with the landlords and highlight this in engagement plans.
Identifying issues relating to RAAC and cladding
We wrote to all social landlords in October 2023 to request information about RAAC. We requested this information to help provide a clear national assessment of RAAC in social housing in Scotland and to assist Scottish Government in the development of an appropriate policy response. We published updates in December 2023 and March 2024.
Following the Grenfell Tower Fire in 2017, legislation to ban combustible cladding on high-risk buildings, and the highest risk metal composite cladding material from all buildings, was passed by the Scottish Parliament on 22 April 2022. The Grenfell Inquiry’s final report was published in September 2024. In June 2024, the Scottish Government published the Single Building Assessment (SBA) specification including the methodology for carrying out an assessment of cladding risk, and in January this year the SBA standards.
It might be that some RSLs undertook a detailed assessment before the publication of the SBA or British Industry Standard PAS 9980. The Scottish Government encourages landlords to understand what assessment has been done for buildings over 11 metres. Where there has been no assessment, or the landlord is not assured of the standard of the assessment, then the landlord should consider undertaking a robust assessment using the specification and standards.
The Scottish Government has recently announced that it will consider funding SBAs for social housing buildings that meet criteria on eligibility such as height and age of the building.
It is important that landlords continue to have a full and on-going understanding of their housing stock including whether they have RAAC or cladding issues. If and where identified the landlord should take immediate action to ensure the safety of tenants and residents.
We will engage with social landlords who have RAAC or potentially unsafe cladding where we need further assurance.
Providers of Gypsy/Traveller sites should comply with Minimum Site Standards and all outcomes and standard in the Charter on an on-going basis
We published the outcome of our thematic inquiry into tenant and Gypsy/Traveller participation in Scottish social housing. For providers of Gypsy/Travellers sites its recommendations included that:
- they consider and deliver further and improved cultural awareness and equalities training to staff, to support their work with Gypsy/Travellers and to consider cultural sensitivities;
- whilst the accurate number of Gypsy/Travellers within landlords’ tenant/resident base is unknown, and members of the Gypsy/Traveller community may choose not to identify as such to landlords, landlords should ensure they are actively promoting participation and seeking feedback from Gypsy/Travellers to ensure suitable participation opportunities are made available;
- they should ensure that participation is promoted and offered to all Gypsy/Travellers, including those living on sites and those residing in properties; and
- they ensure they understand the barriers to involving Gypsy/Travellers in participation and landlords should identify and implement a range of accessible options and solutions to address these barriers.
All site providers must ensure that they comply with all 16 outcomes and standards in the Charter, and implementing the recommendations of our inquiry will help ensure that. We found in two Serious Concerns at one site in Fife and two sites in Perth and Kinross that not all outcomes and standards were being met. We further found that there was some non-compliance with Minimum Site Standards at each site despite the site providers reporting compliance.
It is important that all site providers ensure full and on-going compliance with the Charter and site standards. Or if they are not, they should make us aware of this and what they are doing to remedy the position. Site providers must also ensure they effectively communicate and engage with residents about this.
We will engage with all site providers to gather further information and assurance about the management of their sites.
Our engagement with RSLs
Regulatory status
We publish an engagement plan with a regulatory status for each RSL to provide a single view of the RSL’s governance, financial well-being and performance.
This year:
- 132 RSLs are Compliant, meaning they meet regulatory requirements, including the Standards of Governance and Financial Management, with an additional one RSL under review (129 last year with an additional three under review); and
- Five RSLs are Non-compliant – working towards compliance, meaning they do not meet regulatory requirements including the Standards of Governance and Financial Management, and are working to achieve compliance (seven last year were working towards compliance).
We are not currently using statutory powers in any RSLs. We did not use statutory powers last year.
The main reasons for our engagement with RSLs
We are engaging with:
- Four RSLs about tenant and resident safety (five last year);
- 18 RSLs about governance (18 last year) of which five are about planned organisational changes or transfers of engagements (eight last year);
- 29 RSLs about finance (32 last year);
- Nine RSLs about service quality (five last year);
- Eight RSLs about the quality of homes they provide (10 last year);
- 25 RSLs about development (31 last year); and
- 25 RSLs because they are systemically important (24 last year).
We are engaging with a number of RSLs for more than one reason.
Where we are engaging with an RSL about finance and considering its business plan, we will also discuss with the RSL how it has satisfied itself that its rents are affordable for its tenants.
Ancho transfers its engagements (including its homes) to Cairn Housing Association on 1 April 2025. Link Housing Association which has no homes plans to transfer its engagements to Link Group on 1 July 2025.
Our engagement with local authorities
The main reasons for our engagement with local authorities
Given that some local authorities are now at, or are approaching, systemic failure impacting the delivery of services to homeless people and households, during 2025/26, we will speak again to every local authority to gather further information and assurance about their homelessness services. Our conversations with local authorities will continue to have a focus on how they are delivering appropriate temporary accommodation for people experiencing homelessness.
We will engage with three local authorities who we regard as being impacted by systemic failure (two last year), and a further seven (eight last year) who are at heightened risk of being impacted by systemic failure.
We will engage with 19 local authorities about specific aspects of their homelessness service (25 last year). We will engage with:
- six local authorities about access (nine last year);
- two about assessment (five last year);
- 14 about temporary accommodation (18 last year); and
- eight about outcomes (15 last year).
We are engaging with some local authorities in more than one specific area of their services to people experiencing homelessness.
We are also engaging with local authorities on the following basis:
- two local authorities about progress with ensuring that Gypsy/Travellers sites meet the Scottish Government Minimum Site Standards and/or requirements in relation to fire safety (two last year). Four local authorities about residents’ satisfaction with the management of their sites (we are also engaging with one RSL about satisfaction at its site);
- a further two local authorities about Serious Concerns at their Gypsy/Traveller sites;
- 14 local authorities about tenant and resident safety (17 last year);
- five local authorities about service quality (six last year); and
- six local authorities about stock quality (10 last year).
We are engaging with some local authorities in more than one of these areas.
Other strategic risk areas
Our annual risk assessment identified a number of notable risk areas, some of which have been evident for a while and others which have arisen more recently.
Development of new affordable homes
Social landlords make a significant contribution to the number of affordable homes being built. However, this has become more challenging in recent years given issues including high construction cost inflation, higher borrowing costs and a reduction in the Affordable Housing Supply budget.
This highlights the importance of effective oversight and management of development risk by social landlords. Our 2015 development thematic remains an important reference for social landlords when they are making decisions about whether to undertake a new build project, and how they should manage risk when they decide to build new homes.
RSLs must have an up to date and robust business plan, be alive to all the risks they may face and have adequate risk management and mitigation measures in place to help ensure that their viability and the interests of tenants and other service users are protected. Our Business Planning Advisory Guidance says more about this.
Mould and damp
We wrote to all social landlords in December 2022 about mould and damp. We emphasised that landlords should continue to ensure they have systems in place to ensure their tenants’ homes are not affected by mould and damp and that they have appropriate, proactive systems to identify and deal with any reported cases of mould and damp timeously and effectively. We introduced new indicators to the Annual Return on the Charter (ARC) which landlords will collect from 1 April 2025.
Data accuracy
It is critical that social landlords have good quality data on their performance, their compliance with obligations and on the condition of their homes. We continue to find that some social landlords had not accurately reported their compliance with the SHQS in the ARC or have a clear record of their compliance with their tenant and resident safety obligations. To enable social landlords to make the best decisions for their tenants and other service users, it is essential that they maintain robust and accurate data.
Governance
We reviewed all social landlords’ Annual Assurance Statements and found that the vast majority of social landlords reported compliance with regulatory requirements and other obligations, and we agreed with those assessments on the basis of other information we consider in our risk assessment.
In Annual Assurance Statements, social landlords should continue to:
- set out any areas of material non-compliance, and describe briefly how it is planning to improve in those areas and the timeframe for improvement;
- confirm it has seen and considered appropriate evidence to support the level of assurance it has;
- confirm the date of the governing body meeting at which it considered and agreed the statement; and
- notify us during the year if anything happens which materially changes the level of assurance in its statement.
We also identified further instances where a small number of RSLs had not met our statutory guidance on Notifiable Events or had failed to adhere to constitutional requirements in managing their governing bodies. We took steps to engage with RSLs to seek assurance where we identified concerns. For the first time we published an annual report on notifiable events in response to feedback from landlords. It highlights the key issues that landlords notified us about during 2023/24 including governance and organisational issues, financial and funding issues and disposals of land and assets.
Cyber security
It is important that social landlords consider what security they need to put in place to protect their digital systems, including the personal data of tenants, other service users and staff. The National Cyber Security Centre has a wealth of material and tools on its website to help organisations defend themselves against the increasing cyber threat. Landlords should make proper provision for the costs associated with cyber security in business plans and financial forecasts.
Annex – risk assessment methodology
About the information we use
We use a range of information to inform our risk assessment. You can read more on this information in parts five and six of The risks we will focus on.
For all social landlords we gather information from past or current engagements, complaints, Serious Concerns and whistleblowing. We also ask all social landlords to tell us about any tenant and resident safety matter which has been reported to or is being investigated by the Health and Safety Executive or reports from regulatory or statutory authorities or insurance providers, relating to safety concerns.
RSLs
As our statutory remit is broader for RSLs than our remit for local authorities, we also consider a range of financial information including their Annual Financial Statements, financial forecasts and loan portfolio details, and information from their auditors.
Each year governance is a key focus of our risk assessment. We consider a range of information in our assessment including:
- quantitative information from ARC submissions received by May each year;
- notifiable events;
- any reports by auditors under S72 of the Housing (Scotland) Act 2010;
- Annual Financial Statements;
- a review of governing body minutes from RSL websites;
- a review of Annual Assurance Statements received by 31 October; and
- regulatory intelligence from current engagement.
We also used the quantitative and qualitative information we gather from social landlords in relation to:
- group structures (number of subsidiaries, complexity of arrangements and nature of subsidiary activity); and
- qualitative information including complaints about social landlords, whistleblowing and Serious Concerns.
As in previous years, we also considered:
- staff turnover and absence rates;
- how frequently the RSL rotates the appointment of its external auditor; and
- the RSL’s internal audit arrangements.
Systemically important RSLs
The measures we use to determine systemic importance have been chosen as indicators of the level of difficulty for us to fulfil our statutory objective of protecting tenants and other service users if the relevant RSLs were to experience financial difficulty. They are not an indication of the likelihood of that occurring.
The measures used this year for measuring systemic importance are:
- number of units owned;
- total turnover;
- peak debt; and
- debt per unit.
These measures are ranked and combined to give an overall score which is compared with the scores for other RSLs and a threshold we determine based upon the scores achieved. We also include any RSL that ranks highly in the first three measures and RSLs which have a strong geographic dependency.
We will engage with 25 RSLs on that basis in 2025/26 which is one more than last year. See which social landlords are systemically important. Eildon Housing Association became systemically important in 2025/26.
Local authorities
We use the Scottish Government’s official statistics on homelessness, and the outcomes of a programme of structured conversations that we undertake each year with all local authorities. We also work through the risk assessment process with our partner scrutiny bodies, participating in the Strategic Scrutiny Group (SSG) led by Audit Scotland, to consider the full range of scrutiny activity for each local authority.
For 26 of the 32 local authorities, we assess both their landlord and homelessness services. We assess the homelessness service only for the six local authorities who have transferred their homes to RSLs.
Our focus on homelessness has a strong emphasis on social landlords’ discharge of their statutory duties. We seek assurance that people who are homeless, or who may become homeless, are able to access the statutory homelessness process, and that local authorities are complying with statutory duties. We monitor and assess the outcomes for people at the following key stages of the homelessness process:
- Access: whether local authorities are complying with statutory duties to make inquiries into a person’s homelessness;
- Assessment: how long it takes to complete homelessness assessments and the decisions made;
- Temporary accommodation: whether local authorities are complying with duties to offer suitable temporary or emergency accommodation to people when they need it, the quality of temporary accommodation, and how long people spend there waiting on a permanent home; and
- Outcomes: how quickly people get settled accommodation after a local authority has assessed that it has a duty to provide this, the number of lets social landlords provide to people who are homeless, and sustainment of those lets.
How we review our engagement
We will review the engagement we will have with all social landlords in our next annual risk assessment. We may review our engagement with a landlord during the year if circumstances change or new information becomes available. If we do, we may publish an updated engagement plan for that landlord, and an updated Regulatory status for RSLs. We will set out the reasons for reviewing an RSL’s Regulatory status in an updated engagement plan.