Two years of consumer regulation

The Regulator of Social Housing is now two years into proactive consumer regulation, which means it finally has evidence on what separates the landlords doing well from those who are struggling. At PfH Live 2026, Angela Holden, Director of Regulatory Engagement at the regulator, shared what those two years have shown. 

What stands out is that size and geography don’t decide how well a landlord performs. Governance, data, culture, and how seriously you listen to tenants, do. This article draws out the key lessons from Angela’s session and what they mean for landlords preparing for their next inspection. 

What two years of consumer regulations inspections show 

The regulator inspects every landlord with more than 1,000 homes at least once over a four-year period. Alongside that, it responds to information that comes to it and analyses the data landlords submit, any of which can trigger closer engagement or an inspection. Every process ends with a published grade, and any landlord without a top grade enters a period of landlord improvement with the regulator. Enforcement powers exist, but Angela was clear they’re rarely needed. Most improvement comes from constructive work with landlords. 

So far, the consumer grades break down like this: 

• C1 (meeting the standards): about a third of landlords inspected 

• C2: 41% 

• C3: about a fifth 

• C4 (very serious failings): a small handful 

There was an early worry that the regulator would place everyone in the middle. That hasn’t happened. The grades reflect a genuine spread in the quality of homes and services, and the vast majority of landlords have something to improve. For some that’s minor. For others it means a root and branch review of their whole housing service. 

Private registered providers have tended to sit higher up the grades than local authorities, although Angela stressed this isn’t universal and some councils are providing very good homes and services. 

Size and location don’t predict performance 

One of the questions the regulator is asked most often is whether bigger or smaller landlords perform better. The data shows no correlation. There are very large landlords doing an excellent job and very large landlords with serious work to do, and the same is true of small landlords. 

Tenant satisfaction measures tell a similar story. The clearest driver of high TSM scores is the quality of homes and services, not stock type or geography. Landlords with high TSMs do tend to get higher consumer grades, but not always. The regulator has found serious failings at some landlords whose satisfaction scores looked good, so TSMs on their own aren’t a reliable proxy. 

What well-performing landlords have in common 

The landlords reaching C1 and C2 grades share five features. None of them depend on how big a landlord is. 

1. Strong governance 

Governance is one of the clearest markers of a well-run landlord. That means the right arrangements for managing risk, controls that work, and external assurance that tests whether services are really delivering. When weaknesses are found, these landlords act quickly. 

2. Good data that’s actually used 

Well-performing landlords have a strong and improving understanding of both their homes and their tenants. What makes the difference is that boards, councillors and executives use that data to shape services, tailor them to tenants’ needs and step in when the numbers show something isn’t right. 

3. A relentless focus on quality and safety 

These landlords keep asking what it’s like to live in their homes. Health and safety is consistently well managed. Things still go wrong sometimes, but they spot it when something is off track and respond. 

4. Tenant voice at every level 

Tenants’ views shape decisions from frontline services right through to the board. There’s a wide range of ways for tenants to get involved, and their voices are genuinely heard rather than simply recorded. 

5. A proactive mindset 

The best performers are never complacent. Even when services are good, they recognise there’s more to do. They prepare early for policy and regulatory change, and they deal with issues before they crystallise. 

Where landlords are struggling 

The landlords in the C3 and C4 space tend to show the opposite picture. Angela was careful to say these aren’t the most common findings, and most landlords provide good homes and services. But where things go wrong, the same issues come up again and again. 

Relying on reassurance instead of assurance 

Boards and councillors can’t see everything, so they have to decide where to focus. The problem comes when they rely on officers telling them everything is fine, rather than genuine or third-party assurance that it is. Without strong governance behind them, these boards struggle to get the right level of detail. 

Poor data and systems 

Almost every landlord in the lower grades has issues with its data. Health and safety records aren’t where they should be, repairs data isn’t helpful, and information sits in disjointed systems or on spreadsheets that anyone can edit. Angela gave the example of tenant vulnerability recorded on one system while repairs contractors work from another, so the contractor turning up at the door can’t see that a tenant needs something specific. 

Homes that aren’t safe or decent 

This isn’t the majority of cases, but it does come up. Some landlords don’t know enough about their homes because stock condition surveys haven’t been done or only partly done. Others have invested in understanding their stock but haven’t taken the next step of improving it. Health and safety checks are sometimes carried out, but the actions aren’t followed through to actually make the home safe. 

Tenant engagement that doesn’t change anything 

There’s often plenty of activity, but it can be tokenistic. A cup of tea or an estate walkabout with tenants might be a perfectly pleasant afternoon, but if it doesn’t lead to an outcome, nothing changes for the people living in your homes. 

Staying reactive 

Repairs and complaints backlogs are common, and Angela recognised that repairs is a hard service to run while complaints are rising across the board. The difference is whether backlogs are managed or simply stack up. Struggling landlords also miss risks on the horizon, respond too late to procurement challenges and contractor issues, or wait until new legislation is in force before working out how to comply. There’s usually a long lead-in before legislation arrives, and that’s the time to check your systems and data are ready. 

What will make the difference? 

Angela closed with four areas she’d encourage every landlord to take back to their organisation. 

1. Leadership and culture 

It isn’t formally part of how the regulator grades landlords, but Angela said you can see the culture as soon as you walk into an organisation. Are tenants at the forefront of what you do, or an afterthought? In the best organisations, teams feel able to raise problems early and get a constructive response rather than blame. Issues left to fester do lasting damage, both to the culture and to tenants’ trust in you as a landlord. 

2. Governance that holds people to account 

That means the right reporting at every level, from management teams to senior leaders to boards and councillors, built on accurate data. Decisions need to be made at the right level, with accountability throughout. When the regulator starts working with a struggling landlord, getting reporting and governance structures right is often the first priority. 

3. Listening that leads somewhere 

Knowing who lives behind your doors lets you tailor services in a systematic way. Just as important is closing the loop. A “you said, we did” approach shows tenants their views made a difference, which builds trust. 

4. Data across the board, not just in pockets 

There’s been big investment in data, but it’s sometimes narrow. Gas safety data matters, but so does knowing what every home needs, what health and safety checks are due, and whether repairs are clustering in a particular type of home. Angela also warned against treating a new system as a cure-all. A new system can help, but it won’t fix anything on its own if the data going into it isn’t good quality. 

Looking ahead 

Two years of evidence point the same way. The landlords doing well aren’t defined by their size. They’re the ones with honest governance, data they trust and use, a culture that surfaces problems early, and tenants whose voices change things. 

Angela’s session gives every landlord a set of questions worth taking to the next board or leadership meeting: 

• Is our board getting assurance, or reassurance that everything is fine? 

• Do we know what every one of our homes needs, not just where we have gas safety data? 

• Can our repairs contractors see the vulnerability information they need at the door? 

• Are we following through on the actions from our health and safety checks? 

• Can we show tenants what changed because of what they told us? 

• Are we preparing for the next change in legislation now, or waiting until it arrives? 

Which of these would your organisation find hardest to evidence today? 

How PfH can help

Many of the challenges Angela described come back to the same things: knowing your homes, acting on what you find, and having contractors and suppliers you can rely on. We give members compliant routes to the specialist support that helps with each of these, so you can act quickly and evidence every decision to your board and the regulator. 

For health and safety compliance, surveying and remedial works, please check out our Compliance Solutions Framework and DPS. 

For managing repairs backlogs, urgent repairs and disrepair works, please check out our Responsive Repairs Framework and DPS. 

For decency works and long-term property improvement, please check out our Planned Works Framework. We also offer digital innovation solutions, including monitoring property health, through our SHED Frameworks. 

If you want a clearer view of your spend and contract data to support board reporting and supplier oversight, Quantum brings it together in one place. And if you’d like hands-on support with a procurement or contractor challenge, our team is here to help. 

Sources 

• Regulator of Social Housing https://www.gov.uk/government/organisations/regulator-of-social-housing 

• Regulatory standards https://www.gov.uk/guidance/regulatory-standards 

• RSH: Key findings from 2023 to 2024 consumer regulation work.  https://gov.uk/government/news/rsh-publishes-key-findings-from-its-2023-24-consumer-regulation-work July 2024 

• RSH: evaluating the impact of consumer regulation https://www.gov.uk/government/news/regulator-of-social-housing-to-evaluate-the-impact-of-consumer-regulation June 2026 

• Updated Housing Health and Safety Rating System guidance.  https://www.housinglin.org.uk/Topics/type/Updated-Housing-Health-and-Safety-Rating-guidance-released/ June 2026 

This article is based on Angela Holden’s talk at PfH Live 2026, chaired by Neil Butters, Operations Director at PfH. If you’d like to hear the original talk, please watch the video below. 

---

---