Written evidence submitted by Professor Mike Raco and Dr Sonia Freire-Trigo, Bartlett School of Planning, University College London [RSH 091]



About us


We are academic researchers based at the Bartlett School of Planning, University College London.  We are currently leading on a 3-year cross-national UKRI-funded project that is examining the planning and regulation of housing delivery in major cities[1].  We have undertaken over a hundred interviews in the UK with public, private, and voluntary sector respondents from across the housing sector. 


We are submitting this evidence as our research has involved in-depth work on the social housing sector and its regulation.  It focuses on how different organisations and actors interpret and understand the role of regulators and how regulations across the sector impact on strategies and practices of delivery. We use our findings to address Qs 3, 4, and 11.



Q3.              Is the current regime for regulating social housing fit for purpose?



Figure 1: Fields of Regulation, Public Policy Requirements and the Regulatory Tensions Faced by Housing Associations


Field of Regulation

Public Policy Requirement

Regulatory Tension Faced by Housing Association

Housing Delivery and Supply

  • Objective to deliver more housing supply in areas of strong demand;
  • Ensure that a wider range of affordable housing is available to citizens;
  • Meet housing needs by providing a range of tenures.



  • Generate sufficient revenues through (housing) market sales and rents to provide affordable housing without undermining financial viability;
  • Build more housing versus need to maintain/improve the quality of existing stock



Financial Viability and Corporate Governance

  • Maintain the financial viability of Housing Associations;
  • Ensure that Housing Association credit ratings remain positive to ensure supply of affordable credit;
  • Direct Housing Associations to act in compliance with public and private codes of practice and corporate law codes
  • Build more units to generate income but in turn take on more financial risks;
  • Challenge of meeting short-term viability objectives and balancing with longer-term costs and regulatory demands (for decent and/or carbon-neutral housing);
  • Set up corporate good governance arrangements, whilst acting as a public organisation dealing with multiple (social and environmental) demands

Obligations to Existing and Future Tenants

  • Ensure that residents’ rights are protected and that they are included in key strategic and operational decisions by Housing Associations;
  • Maintain affordable levels of rent for existing and new tenants;
  • Maintain welfare traditions by creating housing options for people in severe housing need (e.g. homeless and vulnerable groups)
  • Finding adequate financial resources to meet social priorities whilst maintaining financial viability;
  • Using tenant income streams to re-invest in housing or use assets as collateral to borrow and spend more on market housing




Q4.              How clearly defined are the roles of the Regulator of Social Housing and the Housing Ombudsman?



Q11.              What challenges does the diversification of social housing providers pose for the regulatory system?



Recommendations for Reform




December 2021

[1] ‘WHIG - What is Governed in Cities?’ (https://whatisgovernedincities.eu/)

[2] In 2016/17 the contribution of Housing Associations to total public debt for the UK was £69.6billion.  By 2017/18, with rule changes, this had fallen to £6.6billion, then to just £0.6billion the following year, even though the actual financial position of HAs showed no change (Office for National Statistics (2019) Impact of the reclassification of housing associations into the public sector, HMSO: London).

[3] https://www.campbelltickell.com/wp-content/uploads/2021/03/Moodys-UK-HA-Issuer-Briefing_25Feb2021.pdf

[4] Inside Housing (2020) Full list: 45 housing associations have credit ratings affirmed, accessed at: https://www.insidehousing.co.uk/news/news/full-list-45-housing-associations-have-credit-ratings-affirmed-68414