Introduction
In September 2024, we launched a consultation on proposed changes to the Annual Return on the Charter (ARC).
Following stakeholder feedback on our earlier proposals to amend some of the ARC indicators as part of our overall review of our Regulatory Framework in 2023, we decided to take some time to undertake a more comprehensive review of the ARC indicators and involve relevant experts and people from the social housing sector in this review.
We established two Advisory Groups – one for tenant and resident safety and one for the general indicators – to help us develop our proposals. The groups consisted of relevant experts and people from the social housing sector, and the groups’ feedback informed the proposals within our consultation which ran from 16 September 2024 and closed on 8 November 2024.
We received 71 responses from individuals and organisations. You can read the responses from those who agreed we could publish here, and read the consultation document here.
During our formal consultation, we also held discussions with tenant representatives, social landlords, organisations who work with people who are homeless and other service users, and with our wider stakeholders. And we spoke about consultation at various conferences and events.
We have also published a full analysis of the consultation responses, which can be read here.
This document describes the changes we have made to the ARC, taking account of the responses to the consultation. We have also made some other minor changes to the Technical Guidance which supports the ARC.
Proposals to remove indicators
There are some indicators which we proposed to stop collecting.
- Indicator 14: Tenancy offers refused during the year
We do not routinely use Indicator 14 in our regulatory assessment of social landlords’ performance, and we currently collect data on the number of lets made by social landlords, and on the average time taken to re-let homes by social landlords. While respondents recognised the value in landlords collecting and monitoring refusals within their own organisations, most agreed with our proposal to remove this indicator from the ARC.
We will therefore stop collecting indicator 14.
- Indicator 20: Total cost of adaptations completed in the year by source of funding
There was a fairly even split amongst respondents about our proposal to remove indicator 20. Those that disagreed highlighted recent Scottish Government cuts to adaptation funding, which, respondents said, has an impact on the number of adaptations that can be delivered and how long these can take. However, most respondents agreed that this indicator should be removed.
We do not routinely use this indicator in our regulatory assessment. We currently collect data from other indicators on the number of households waiting for adaptations and the average time to complete adaptations. Both of these indicators will continue to provide information on the demand for and extent of adaptation work being carried out in the sector.
We will therefore stop collecting indicator 20.
- Indicators 23 and 24: Homelessness referrals.
Members of the Advisory Groups told us that these indicators are confusing, onerous to collect and rarely used for benchmarking.
Most respondents to the consultation agreed with this and so were supportive of these being removed. Respondents welcomed our proposal to expand Indicator C2 (see section 3 – proposals to amend indicators) where RSLs to report their lets to homeless households by local authority area as an alternative way to understand RSLs’ contribution to addressing homelessness.
We will therefore stop collecting Indicators 23 and 24.
- Indicator C3: Number of lets during the reporting year split between general needs and supported housing
We do not routinely use Indicator C3 in our regulatory assessment. Most respondents agreed that this indicator should be removed, with some highlighting that Indicator C2 already measures lets made by social landlords, broken down by source of let, and that this is sufficient.
We will therefore stop collecting Indicator C3.
- Indicator C4: Abandoned homes
Over half of respondents disagreed with our proposal to stop collecting data on the number of abandoned homes. In our consultation, we referred to already collecting data on abandonments within Indicator 22 (court actions which resulted in eviction), however some respondents highlighted that this only measures abandonments after a decree has been obtained. Retaining Indicator C4, however, would mean measuring all homes that were abandoned which, respondents said, gives an indication of tenancy sustainment.
We will therefore continue to collect Indicator C4.
Proposals to amend indicators
We had proposed to amend several indicators to ensure the indicators we collect are easy to understand, to collect and allow for meaningful benchmarking across the sector.
- Indicator 10: Reactive repairs completed right first time
Members of the Advisory Group told us that there are too many recording anomalies across social landlords with Indicator 10, particularly in relation to what repairs and what timescales are and are not to be included. Most respondents to the consultation agreed with this, and so welcomed this indicator being amended.
We will therefore amend Indicator 10 by simplifying it so that landlords will report reactive repairs which were completed and reported again in the reporting year only.
- Indicator 15: Anti-social behaviour cases resolved
Members of the Advisory Group highlighted concerns that Indicator 15 did not include all anti-social behaviour cases, and that the indicator in its current form does not allow for meaningful benchmarking. This was echoed by most respondents to the consultation, who welcomed this indicator being amended. Most respondents agreed that cases which remained open from the previous year should be considered. Some respondents disagreed with our proposal to reintroduce measuring whether cases were resolved against locally agreed targets, as they did not think that this would add value to the data. Respondents did, however, welcome our proposal to measure the number of anti-social behaviour cases per 100 homes.
We will therefore amend indicator 15, to include cases opened in the previous year and to measure cases per 100 homes, but not to measure whether cases were resolved against locally agreed targets.
- Indicator C2: Lets in the reporting year by source of let
We had proposed that RSLs report their lets to homeless households by local authority area, and all respondents to the consultation agreed. Some respondents also suggested that we collect the total number of lets made by RSLs in each local authority area, so as to understand what proportion of an RSL’s lets went to homeless households in each area.
We will therefore amend indicator C2, to collect the number of lets made by RSLs to homeless households and to all households for each local authority area they operate in.
New indicator: long term voids
We had proposed re-introducing a previous ARC indicator on the number of self-contained properties void at the year end, and of those the number that had been void for more than six months. Most respondents agreed with our proposals.
For this indicator, we had proposed that some voids should be excluded. This included properties being considered for demolition/reconfiguration; subject to insurance claims due to fire or flood damage; undergoing major repairs/structural works and decants. However, some respondents suggested it was important for these to be included in the data to show the true picture of voids in the sector.
We will therefore re-introduce this indicator, but without the exclusions that were initially proposed. Instead, we will ask landlords to provide a breakdown of the reasons why the properties are void, including normal lettable stock; demolition/reconfiguration; insurance claims; major repairs/structural works; decants; low demand, and other.
New indicators: tenant and resident safety
We had proposed to introduce new indicators on electrical and fire safety, and most respondents to the consultation agreed with this. Some respondents highlighted the importance of landlords being able to provide explanation and context for any non-compliance, which they said could be because the landlord has struggled to gain access to tenants’ homes.
A small number of respondents suggested that both indicators were already covered within SHQS (Scottish Housing Quality Standard), which landlords already report on in the ARC. However, the separate EICR (electrical condition installation report) indicator being proposed would measure instances within the reporting year where the 5-year anniversary date for the EICR has been missed, in the same way as our current indicator on gas safety. The current indicator on SHQS, however, measures point in time (year-end) compliance only.
The SHQS requirement related to fire safety (smoke and heat alarms) has been in place since 21 February 2022, there are still a number of these outstanding and, as an essential element of tenant and resident safety, splitting this into a separate indicator to give it cognisance and provides the ability to monitor compliance more closely.
A small number of respondents requested clarity in relation to outstanding works resulting from an EICR and whether or not this would be regarded as non-completion of an EICR. Others requested landlords be given more flexibility about the dates they would be permitted to carry out EICRs. Both of these issues are out with our powers to decide on, as they are set by the Scottish Government. We have, however, provided additional clarity in the Technical Guidance on how these issues should be reported in line with the current Tolerable Standard.
Most respondents agreed with our proposal not to collect specific indicators in relation to social landlords’ legal duties in relation to lift safety, fire risk assessments, asbestos and legionella. Respondents agreed that landlords should consider their compliance with these duties through their ongoing assurance processes and notify us of any non-compliance through their Annual Assurance Statement.
We will therefore introduce indicators on electrical and fire safety only, and this will include comments boxes for landlords to explain any non-compliance.
New indicators: damp and mould
Our proposals included three new indicators on damp and mould, which would measure the average length of time to resolve cases of damp and/or mould, how many cases were reopened and the number of open cases at the year end.
While most respondents agreed with the proposed indicators in principle, almost three quarters did not think that they were clearly defined.
There was no clear consensus amongst respondents for collecting either the average time to resolve cases or the median time to resolve cases. Some respondents said that the average will not provide an accurate picture of response times given the wide variation in terms of complexity and severity of damp and mould cases. Some respondents highlighted that median is not collected for any other ARC indicators, including those where there can also be a wide variation (for example Indicator 15 - anti-social behaviour cases resolved).
We will therefore introduce the three new indicators on damp and mould we proposed, but for each one, landlords will be asked to provide a breakdown of cases (i) caused by condensation and (ii) caused by structural issues.
For the indicator measuring length of time for cases to be resolved, we will therefore collect the average rather than median.
Stakeholders wanted additional clarity on defining damp and mould, and whether condensation cases should be included. In the Technical Guidance, we have therefore confirmed that cases of damp and/or mould should be based on the landlord’s own policies and procedures.
After the first submission of this data (in May 2026), we will review the usefulness of the new indicators and, if resources allow, carry out a thematic review of landlord’s approach to preventing and resolving cases of damp and mould. The outcomes from these will then inform any proposed changes to these indicators.
Some stakeholders expressed concern over how the data from the new damp and mould indicators would be presented and suggested that a direct comparison of performance would not be helpful. We will therefore not include the data within the National Report on the Charter that we publish each year but will publish a separate report which will provide additional context around the data.
Other changes
Within the updated Technical Guidance, we have also provided additional clarity on the definitions of some existing indicators which was previously provided in our published FAQs.
We have published two versions of the revised Technical Guidance – one showing tracked changes and a clean version.
Next steps
We have written to all social landlords about the changes we have made to the ARC. Landlords should start to collect data from 1 April 2025 to enable them to report on their performance in the ARC due to be submitted to us by 31 May 2026.
Landlords should continue to use the current version of the Technical Guidance for the upcoming 2024/25 ARC, which is due by 31 May 2025.