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Half 1: Introduction and scoping
1.1 Abstract and scope
Coverage overview
The buyer requirements set out our regulatory necessities that registered suppliers should meet. We set these in step with our revised targets, which have been expanded by the Social Housing (Regulation) Act 2023 (the Act) to incorporate security, transparency, and power effectivity.
The Social Housing White Paper, (the White Paper) set out the federal government’s intention to create a proactive client regulatory regime. The Act implements the regulatory measures within the White Paper. Following in depth engagement with tenants, landlords and different stakeholders, we intend to introduce a revised set of client requirements. As a part of our work to develop draft new client requirements, we’ve thought-about how our present client requirements might be revised and strengthened to ship a set of requirements which might be strong, updated and match for function. In doing so we’ve sought to fulfill commitments set out within the White Paper, ship on our expanded targets, and tackle points impacting the social housing sector which might be inside our remit.
In creating the proposed client requirements, we’ve been guided by the three checks we’ve set ourselves for creating our strategy to client regulation:
- It should make a significant distinction to tenants.
- Landlords should be capable to ship its expectations .
- We should be capable to regulate towards it.
In creating the requirements, we’ve been aware of:
- our statutory obligation to train our features in a method that minimises interference and (as far as is feasible) is proportionate, constant, clear, and accountable (part 92K(5) of the Housing and Regeneration Act 2008)
- the Authorities’s Regulators’ Code
- our statutory obligation, in setting client requirements, to have regard to the desirability of registered suppliers being free to decide on methods to present providers and conduct enterprise (part 193(3) of the Housing and Regeneration Act 2008).
We now have additionally been aware of our obligation to adjust to the Public Sector Equality Obligation as set out at part 149 of the Equality Act 2010. The broad intention of PSED (also referred to as the final equality obligation) is to combine issues of equality and good relations into the day-to-day enterprise of public authorities, in order that when exercising their features, they’ve due regard to the necessity to:
- remove discrimination, harassment, victimisation, and every other conduct that’s prohibited by or below the Equality Act 2010
- advance equality of alternative between individuals who share a related protected attribute and those that don’t
- foster good relations between individuals who share a related protected attribute and those that don’t.
The final equality obligation covers the next protected traits: age (together with youngsters and younger individuals), incapacity, gender reassignment, being pregnant and maternity, race, faith or perception, intercourse, and sexual orientation. Marriage or civil partnership can be a protected attribute below the Equality Act 2010, though that is solely related to the primary intention of the final equality obligation (eliminating discrimination and many others.)
Scope of the Equality impression evaluation
This Equality impression evaluation (EQIA) has repeatedly formed our pondering as we’ve developed the necessities in our proposed requirements. We now have thought-about the impacts (optimistic, detrimental, impartial and none) of the proposed necessities on tenants who share totally different protected traits and can proceed to take action.
The Act has given the regulator the ability to situation a Code of Follow on the buyer requirements, to assist tenants and landlords perceive how compliance with the brand new requirements is likely to be achieved. We’re publishing a draft Code of Follow alongside the revised client requirements, and its contents have additionally been formed by this evaluation.
The buyer requirements embrace areas the place we’re directed by authorities. The wording of the instructions has been reproduced within the requirements. The place that is the case, we’ve not assessed the equality impacts of these necessities as they’re mounted.
This EQIA doesn’t embrace an evaluation of our revised strategy to regulation.
Our intention is that the variety necessities within the revised client requirements will act as a driver for change, by influencing the sector to raised perceive their tenant base, together with in relation to the protected traits, which can present a greater baseline of proof sooner or later.
1.2 Who’re the primary stakeholders that could be affected by these proposals?
- Tenants
- Registered suppliers
- RSH colleagues
1.3 May the proposal(s) have a cumulative impression on individuals who share multiple protected attribute?
The evaluation of potential impacts in part 3 displays areas the place proof reveals cumulative impacts the place protected traits intersect.
1.4 Do the proposals relate to RSH’s equality targets?
Our present equality targets are to:
- 1 – be certain that the place equality and variety considerations are raised by our enquiries course of, they’re thought-about in step with our statutory targets
- 2 – assessment our strategies of speaking to make sure that we achieve this in an inclusive method
- 3 – present a supportive and inclusive working atmosphere for all.
The proposed requirements are most related to goal two. We might want to think about how to make sure that our communication strategies to advertise the brand new client requirements are inclusive.
We now have not too long ago consulted on a revised set of equality targets:
- 1 – We are going to encourage the sector to raised perceive the variety of the communities that they serve and that measures are in place to advertise fairness in relation to their service supply.
- 2 – We might be respectful and inclusive in our engagement and communication.
- 3 – We are going to present a supportive and inclusive working atmosphere for all.
Proposed equality goal one relates intently to particular expectation 2.1.1 within the proposed Transparency, Affect and Accountability Customary.
Half 2: Data gathering
Summarise beneath what present information/ proof you might have used to undertake the evaluation. Are there any gaps in proof and if that’s the case, how do you intend to gather this as the method develops?
2.1 Present information/proof
A spread of knowledge taken from open-source analysis, information and proof has been thought-about as a part of this evaluation, influencing the proposed necessities so the buyer requirements assist us in contemplating our PSED, in addition to serving to to evaluate the place any potential mitigation could also be required. To keep away from duplication, reasonably than set out the proof on this part, we’ve referenced it in part 3 beneath.
DLUHC’s not too long ago printed English Housing Survey 2021/22 information has not been thought-about as a part of this evaluation. This info might be thought-about earlier than the ultimate equality impression evaluation is printed.
With regard to English Housing Survey information referenced on this doc, please be aware that, in response to the Covid pandemic, inside inspections of properties for the English Housing Survey have been suspended for a time frame. This may occasionally impression housing high quality information from the 2020-2021 and 2021-2022 fieldwork durations. Additional info on the impression of Covid on the English Housing Survey could be discovered on Gov.uk.
2.2. Knowledge gaps
We didn’t discover any statistical information concerning the following in relation to social housing tenants:
- the variety of social housing tenants who’re married or in a civil partnership or their particular experiences of social housing
- the precise experiences of social housing tenants from totally different spiritual teams. We discovered information on anti-social behaviour and hate crime victims damaged down by faith which helped to tell this evaluation
- the variety of social housing tenants who’re pregnant or who’ve not too long ago had a child or their particular expertise of social housing.
We now have not tried to fill these info gaps ourselves, because of the time and sources it might demand. The place new equality information turns into accessible that could be related to the buyer requirements, together with in relation to the recognized gaps, we’ll think about reviewing the EQIA.
Half 3: Assessing the impression
That is our evaluation of the potential equality impression of the proposed client requirements.
We now have rigorously thought-about equality issues and related proof all through the event of the proposed client requirements. The place we’ve recognized facets of the present requirements which may profit from being strengthened or amended to handle any potential detrimental equality impression, or the place we’ve recognized a possibility to create a optimistic equality impression by our proposed requirements, we’ve taken the chance to take action. Due to this strategy, we’ve not recognized any potential detrimental equality impression at this level.
Security and High quality: Inventory high quality
Potential impression on totally different protected traits:
There’s inadequate proof of any impression on the opposite protected teams.
Proposal
Required consequence
Registered suppliers should have an correct, up-to-date and evidenced understanding of the situation of their properties that reliably informs their provision of fine high quality, nicely maintained and secure properties for tenants.
Particular expectations
2.1.1 Registered suppliers should have an correct report at a person property degree of the situation of their inventory, based mostly on a bodily evaluation of all properties and hold this updated.
2.1.2 Registered suppliers should use information from throughout their information on inventory situation to tell their provision of fine high quality, nicely maintained and secure properties for tenants together with:
a) Compliance with well being and security authorized necessities
b) Compliance with the First rate Properties Customary
c) Supply of repairs, upkeep, and deliberate
d) Allocating properties with diversifications appropriately
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us:
- Poor high quality, hazardous lodging can contribute to decreased mobility, social isolation, and melancholy for older individuals. [footnote 1]
- Social renters in a single individual households or {couples} with no youngsters have been extra more likely to dwell in a non-decent residence than lone mother and father with both impartial youngsters solely or dependent youngsters. [footnote 2]
- Social renters have been no extra more likely to dwell in a non-decent residence if the family reference individual [footnote 3] was white or was from an ethnic minority background. [footnote 4]
- Asset administration databases weren’t at all times saved updated. 26 per cent of housing affiliation survey respondents stated that tailored properties weren’t clearly recognized inside asset administration databases. [footnote 5]
- Levelling Up, Housing and Communities Committee’s inquiry into social housing regulation heard proof concerning the high quality of social housing, which included examples of poor-quality properties, disrepair and damp and mildew. [footnote 6]
- 10 per cent of households with a member with a long-term sickness or incapacity dwell in a non-decent residence in comparison with 13 per cent with none. [footnote 7]
- Evaluation of English Housing Survey information by the Social Market Basis forecasts a 25 per cent improve in social housing tenants over 65 years and with a long-term sickness or incapacity dwelling in non-decent properties between 2021 and 2031. [footnote 8]
- 5 per cent of social rented properties had an issue with damp, at 198,000 households. It is a larger proportion than proprietor occupied properties (2 per cent or 335,000 households), however decrease than personal rented properties (10 per cent or 409,000 households). [footnote 9]
- 10 per cent of dwellings within the social rented sector failed to fulfill the First rate Properties Customary. That is decrease than the proportion of personal rented (23 per cent) and all proprietor occupied (13 per cent) properties (970,000 and a pair of.1 million properties respectively). [footnote 10]
Our proposed necessities
We think about that PSED intention two is related to this requirement.
Registered suppliers having a greater understanding of their properties could assist to enhance the situation of social housing, which can have a optimistic impression on older and disabled tenants, who usually tend to be impacted by poor high quality housing.
We now have taken the chance to make it clear within the draft Code of Follow that suppliers ought to use info along with that about inventory situation to make sure they’ve a rounded view which incorporates the wants of particular person tenants dwelling in these properties.
General evaluation
General, for the explanations said above, we consider our necessities referring to inventory high quality could have a optimistic impression on tenants who share the protected traits age and incapacity.
Security and High quality: Decency
Potential impression on totally different protected traits:
There’s inadequate proof of any impression on protected teams.
Proposal
We now have solely assessed the proposed modifications to the present commonplace as we’re directed on the required consequence.
Required consequence
Registered suppliers should be certain that tenants’ properties meet the usual set out in part 5 of the Authorities’s First rate Properties Steering and proceed to take care of their properties to at the very least this commonplace until exempted by the regulator.
Particular expectations
None
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
In 2021/22, 10 per cent of dwellings within the social rented sector failed to fulfill the First rate Properties Customary, down from 11 per cent within the earlier 12 months’s survey. This equates to round 400,000 properties. The proportion of non-decent properties within the social rented sector is decrease than within the personal rented sector (23 per cent), and amongst proprietor occupied dwellings (13 per cent).
Predictive modelled information indicated that:
- 4 per cent of dwellings within the social rented sector had a class 1 hazard below the HHSRS, in comparison with 14 per cent within the personal rented sector and 10 per cent amongst proprietor occupied dwellings
- 4 per cent of dwellings within the social rented sector had a major diploma of damp, in comparison with 11 per cent within the personal rented sector and a pair of per cent amongst proprietor occupied dwellings.
The 2021/22 EHS SAP [footnote 11] information confirmed that dwellings within the social rented sector had the best imply SAP ranking of the tenures with housing associations and native authorities each at 70, which signifies that social rented properties have been extra power environment friendly than proprietor occupied properties (averaged a decrease ranking of 66) and personal rented properties (ranking of 65). [footnote 12]
Ethnicity Information and Figures from 2017/19 (nothing extra not too long ago accessible) confirmed variations between households from totally different ethnic teams dwelling in non-decent properties:
- 17 per cent of households in complete in England lived in a non-decent residence.
- 18 per cent of white British households lived in a non-decent residence.
- The best proportions from particular ethnic teams dwelling in non-decent properties have been combined white/black African 33 per cent, Bangladeshi 24 per cent, and black Caribbean 20 per cent.
The identical supply confirmed differential charges amongst households dwelling with damp, as follows:
- Damp in at the very least one room of the house seems to be extra prevalent amongst sure ethnic minority teams – 3 per cent of households in England in complete.
- White British households 3 per cent, combined white and black Caribbean 13 per cent, Bangladeshi 10 per cent, black African 9 per cent, and Pakistani 8 per cent.
- Though households from Blended white and black African (11 per cent) and black different (10 per cent) backgrounds have been additionally extra probably than white British households to have damp, findings for these teams are based mostly on a small variety of households and might not be dependable.
From People without decent homes – GOV.UK Ethnicity facts and figures)
General, 10 per cent of social renter households containing a member with a long-term sickness or incapacity have been dwelling in a non-decent residence in 2020/21, a decrease proportion than these with no member with a long-term sickness or incapacity (13 per cent) [footnote 13].
The Institute of Well being Fairness’s 2011 Marmot Evaluate [footnote 14] discovered that the established hyperlink between housing and well being has implications for youngsters. Important detrimental results of chilly housing are evident by way of infants’ weight achieve, hospital admission charges, developmental standing, and the severity and frequency of asthmatic signs and impacts on the psychological well being of adolescents.
Our proposed necessities
We think about that PSED goals two and three are related to those necessities.
We now have simplified some remaining parts in our present Residence Customary to keep away from repetition with necessities within the First rate Properties steerage and in step with our strategy to regulation. We now have eliminated the requirement 1.1.b to fulfill the requirements of design and high quality that utilized when the house was constructed and have been required as a situation of publicly funded monetary help if these requirements are larger than the DHS. We now have additionally eliminated the requirement 1.1.c that in agreeing an area supply, suppliers ought to be certain that it’s set at a degree not lower than DHS. The previous will already be lined below contractual necessities, and we really feel that the latter requirement is pointless because the requirement is that each one properties have to be maintained to DHS commonplace, and we’ve eliminated reference within the requirements to native provides.
We thought-about whether or not eradicating the stipulation to fulfill design requirements on the time the housing was constructed might result in a discount in accessible housing, the place properties designed for disabled and older tenants aren’t maintained to acceptable requirements, leading to a detrimental equality impression for disabled and older tenants. Nevertheless, the place requirements have been agreed over and above the DHS as a part of funding agreements, together with in relation to accessibility, registered suppliers in receipt of that funding might be contractually obliged to proceed to fulfill these requirements for a set interval or in perpetuity in step with these contracts; due to this fact, we predict that elimination of this requirement is very unlikely to end in a discount of accessible housing.
General evaluation
Taking the above into consideration, we think about that this requirement is more likely to have a impartial equality impression on tenants who share totally different protected traits.
Security and High quality: Well being and security
Potential impression on totally different protected traits
There’s inadequate proof of any impression on the opposite protected teams.
Proposal
Required consequence
When performing as landlords, registered suppliers should take all cheap steps to make sure the well being and security of tenants of their properties and related communal areas.
Particular expectations
2.2.1 Registered suppliers should establish and meet all authorized necessities that relate to the well being and security of tenants of their properties and communal areas.
2.2.2 Registered suppliers should be certain that all required actions arising from legally required well being and security assessments are carried out inside acceptable timescales.
2.2.3 Registered suppliers should be certain that the protection of tenants is taken into account within the design and supply of landlord providers and take cheap steps to mitigate any recognized dangers to tenants.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
- Social renters [footnote 15] have been no extra more likely to dwell in a non-decent residence if the HRP was white or was from an ethnic minority background.
- General, 10 per cent of social renter households containing a member with a long-term sickness or incapacity have been dwelling in a non-decent residence. This was a decrease proportion than these with no member with a long-term sickness or incapacity (13 per cent).
- 5 per cent of social rented properties had at the very least one class 1 hazard, a decrease proportion than each owner-occupied (9 per cent) and personal rented properties (13 per cent).
- Throughout the social rented sector, dwellings rented from native authorities have been extra more likely to have a Class 1 hazard (6 per cent) than dwellings rented from housing associations (4 per cent) [footnote 16]
- Poor high quality, hazardous lodging can contribute to decreased mobility, social isolation, and melancholy for older individuals [footnote 17]
- Renters have been extra more likely to really feel unsafe at residence (8 per cent for each personal and social renters) than proprietor occupiers (4 per cent). These from an ethnic minority background have been extra involved than these from a white background (13 per cent in comparison with 5 per cent) [footnote 18].
- In each 2020 and 2010 native authority owned properties have been extra more likely to have class 1 hazards than these owned by HAs (6 per cent and 4 per cent respectively in 2020) [footnote 19]
- The primary forms of older individuals’s lodging include some type of communal space [footnote 20].
Our proposed necessities
Primarily based on the proof, tenants throughout the sector who could also be positively impacted by necessities referring to well being and security are those that share the protected traits of age, incapacity, and race. We think about that PSED intention two is related to those necessities.
The brand new necessities set a extra specific expectation for registered suppliers to fulfill their authorized well being and security necessities in respect of communal areas, which have expanded with current laws e.g., the Hearth Security Act 2021 and Constructing Security Act 2022, which can result in a larger focus by suppliers on tenant security.
Requiring suppliers to contemplate the protection of communal areas could end in safer communal areas, which can have a optimistic impression on tenants who share the protected attribute(s) age and incapacity. It is because people who share these protected traits are more likely to have totally different (presumably further) wants relating to the protection of communal areas in comparison with those that don’t share these protected traits.
Making certain that registered suppliers perform the actions from well being and security assessments in a well timed method could have a optimistic impression on tenants who’re extra susceptible to a security failure on account of non- compliance due to their protected attribute, particularly age; older individuals and kids and disabled individuals.
2.2.3 requires registered suppliers to make sure the protection of tenants within the design and supply of landlord providers. We now have taken the chance within the draft Code of Follow to exemplify actions that suppliers could take to make sure the broader security of tenants; responding promptly and successfully to reviews of ASB together with the place the sufferer is susceptible, and considering particular person tenants’ security, safety, and well being when prioritising repairs.
General evaluation
For the explanations said, we consider that our necessities referring to well being and security could have a optimistic impression on tenants who share the protected traits age, incapacity, and race.
Security and High quality: Repairs, upkeep and deliberate enhancements
Potential impression on totally different protected traits
There’s inadequate proof of any impression on the opposite protected teams.
Proposal
Required consequence
Registered suppliers should present an efficient, environment friendly, and well timed repairs, upkeep and deliberate enhancements service for the properties and communal areas for which they’re accountable.
Particular expectations
2.3.1 Registered suppliers should allow repairs and upkeep points to be reported simply.
2.3.2 Registered suppliers should set timescales for the completion of repairs, upkeep, and deliberate enhancements, clearly talk them to tenants and take acceptable steps to ship to them.
2.3.3 Registered suppliers should hold tenants knowledgeable about repairs, upkeep, and deliberate enhancements to their properties with clear and well timed communication.
2.3.4 Registered suppliers should perceive and fulfil their upkeep duties in respect of communal areas.
2.3.5 Registered suppliers should be certain that the supply of repairs, upkeep and deliberate enhancements to properties and communal areas is knowledgeable by the wants of tenants and gives worth for cash, along with the requirement at 2.1.2.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
See proof above below Decency referring to households from some minority ethnic teams being extra more likely to dwell in non-decent lodging. There’s a clear hyperlink between housing which isn’t compliant with the DHS, and the standard of the owner’s service on repairs, upkeep and deliberate enhancements.
- The EHS 2020/21 reveals that 49 per cent of the households in social rented housing that had dependent youngsters have been lone father or mother households (in comparison with 34 per cent within the personal rented sector, and 12 per cent in owner-occupation). With 90 per cent of lone father or mother households led by girls, how versatile and well timed repairs providers are, could be of great impression to girls [footnote 21].
- Proof to the Levelling Up Housing and Communities Committee Inquiry on the Regulation of Social Housing from the Merton Centre for Unbiased Dwelling and Motion Incapacity Coaching and Consulting confirmed that having no management over when contractors are coming can create difficulties for disabled tenants who must handle their routines and power rigorously [footnote 22].
- The primary forms of older peoples’ lodging include some type of communal space [footnote 23].
Satisfaction with repairs and upkeep is decrease amongst social renters (66 per cent) than personal renters (75 per cent). The most typical causes for dissatisfaction with repairs and upkeep amongst social renters are the owner being sluggish to finish repairs (29 per cent), the owner not bothering to do the repairs (26 per cent), and the work being of poor high quality (17 per cent) [footnote 24].
Our proposed necessities
Primarily based on the proof above, tenants who could also be impacted by these necessities are those that share the protected traits of race, age, incapacity, and intercourse. We think about that PSED intention two is related to those necessities.
We predict that the next assist to make our necessities extra tenant and outcomes centered, which can have a optimistic impression on tenants who share the protected traits of race, incapacity, and age:
- Requiring suppliers to make sure repairs and upkeep points could be reported simply could have a optimistic impression on tenants who expertise communication obstacles attributable to a incapacity or whose first language is just not English.
- Requiring suppliers to maintain tenants knowledgeable about repairs, upkeep and deliberate enhancements could have a optimistic impression on tenants who expertise communication obstacles attributable to a incapacity or whose first language is just not English. From our engagement with tenants, we’ve heard that good communication with them concerning the progress of repairs is a precedence.
- Changing the ‘proper first time’ repairs goal with necessities to set and meet timescales and clearly talk them to tenants. We perceive from our stakeholder engagement that ‘proper first time’ is measured and outlined in numerous methods by registered suppliers and so doesn’t present a constant efficiency goal for providers to tenants. As an alternative, we’re proposing that landlords set timescales for repairs, which ought to present registered suppliers with flexibility to fulfill tenants’ totally different wants. This flexibility could have a optimistic impression on older tenants, these with younger youngsters and disabled tenants, with larger transparency on timescales in order that tenants can maintain landlords to account on supply.
- Requiring suppliers to know and fulfil their upkeep duties in respect of communal areas could have a optimistic impression on older and disabled tenants, as most designed or tailored lodging for individuals who share these protected traits has communal areas. This may occasionally assist to make sure communal areas are accessible and secure to make use of each by way of accessing and leaving the house in addition to making use of communal areas. This may occasionally assist to minimise the drawback disrepair or poor high quality of communal areas might in any other case trigger, significantly to tenants with decreased mobility.
Eradicating the precise reference within the present Residence Customary to providing selections to tenants is more likely to have a impartial equality impression. It is because we’re requiring suppliers to make sure that the supply of repairs, upkeep and deliberate enhancements to properties and communal areas is knowledgeable by the wants of tenants, which can have a optimistic impression on all tenants. Within the Transparency, Affect and Accountability Customary, we require suppliers, working with tenants, to usually think about methods to enhance and tailor their strategy to delivering landlord providers.
Elsewhere within the requirements, we’re strengthening necessities for registered suppliers to make sure that their providers present equitable outcomes for all tenants; and to fulfill the varied wants of tenants in all their actions. This general strengthening could present an incentive for registered suppliers to handle discrepancies in experiences and outcomes from repairs, upkeep and deliberate enhancements providers for tenants who share sure protected traits.
We now have eliminated reference to diversifications in relation to repairs, upkeep and deliberate enhancements however we’ve set a separate requirement on diversifications below the Security and High quality Customary. This may occasionally have a optimistic equality impression, because it makes diversifications extra of a spotlight of our necessities.
We now have taken the chance within the draft Code of Follow to emphasize that suppliers’ insurance policies, procedures, and processes on this space ought to take note of tenant views and numerous wants, which can embrace, for instance, growing the precedence of repairs for some older and disabled tenants, and putting in further locks and safety lights for tenants experiencing home abuse, as a way to safeguard them.
General evaluation
Taking the above into consideration, we think about that the proposed necessities could have a optimistic impression on tenants who share the protected traits race, incapacity, and age.
Security and High quality: Variations
Potential impression on totally different protected traits
There’s inadequate proof on the impression of the requirement on the opposite protected teams.
Proposal
Required consequence
Registered suppliers should help tenants searching for housing diversifications to entry acceptable providers.
Particular expectations
2.4.1 Registered suppliers should clearly talk to tenants and related organisations how they are going to help tenants searching for housing diversifications providers.
2.4.2 Registered suppliers should co-operate with tenants, acceptable native authority departments and different related organisations so {that a} housing diversifications service is supplied to tenants.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
- 40 per cent of social housing tenants are disabled, considerably larger than the nationwide common (22 per cent) [footnote 25]
- 56 per cent housing affiliation tenants who’ve a long-standing bodily or psychological well being situation lack the diversifications they want.
- 25 per cent of LA tenants and 21 per cent of HA tenants that required diversifications stated their residence was unsuitable for his or her wants.
- The most typical group within the social rented sector have been households with a HRP aged 65 or over (26 per cent) [footnote 26].
- Disabled individuals can expertise severe deterioration of their psychological wellbeing attributable to dwelling in unsuitable lodging, however diversifications assist to revive dignity and larger independence and assist to cut back depressive signs.
- Working age disabled individuals with an unmet want for accessible housing are 4 instances extra more likely to be both unemployed or not searching for work in comparison with these with no unmet want.
- Residence diversifications could make a major distinction to the pressures going through households with disabled youngsters the place their circumstances are exacerbated by low incomes, isolation, and lack of assist result in excessive ranges of household breakdown.
- Ethnic minority households seem to have fewer diversifications than white households and are twice as more likely to haven’t any diversifications in any respect, even with proof of upper ranges of limiting long-term sickness in ethnic minority households [footnote 27].
- Accessing acceptable and well timed diversifications can scale back the danger of emergency admission to hospital, velocity up hospital discharge, enhance independence and scale back the necessity for bodily help for older individuals. [footnote 28]
- Robust engagement and communication between LAs and personal registered suppliers are necessary for profitable coordination and supply of diversifications to make sure the most effective consequence for tenants. [footnote 29]
- Whereas residents reported discovering it simpler to have diversifications put in in social housing than different tenures “the method … was described as prolonged, and individuals typically struggled to get the modifications they wanted”. [footnote 30]
Authorities’s ambition is to offer extra individuals the selection to dwell independently and healthily in their very own properties for longer. [footnote 31]
Our proposed necessities
Primarily based on the proof, tenants throughout the sector who could also be impacted by housing adaptation providers are those that share the protected traits of age, incapacity, and race. We think about that PSED goals one and two are related to this requirement.
We’re growing our expectations of registered suppliers in relation to housing diversifications, by requiring registered suppliers to help tenants searching for housing diversifications to entry acceptable providers. Our necessities could enhance entry to diversifications providers, significantly for older tenants and those that are bodily disabled, which in flip could enhance the accessibility of properties and areas across the residence for tenants who want diversifications, permitting them to stay of their properties independently for longer.
Bettering accessibility to and from the house could assist to enhance entry to alternatives for disabled and older individuals to take part in public life, the place the dearth of diversifications could have created a barrier to such participation and the enjoyment of their residence.
Requiring registered suppliers to be clear about the kind of help they’ll present to tenants searching for housing diversifications could assist to lift tenants’ consciousness and scale back obstacles to the diversifications course of for tenants who want a housing adaptation, significantly for older and disabled individuals and tenants from ethnic minority teams (who could at present expertise difficulties accessing such providers) when in comparison with people who don’t share these protected traits. While this requirement doesn’t assure {that a} tenant might be equipped with the difference they want, it seeks to minimize the obstacles to accessing assist and help that some tenants could expertise.
Requiring registered suppliers to co-operate with LAs in order that diversifications could be supplied to these in want of them could assist to cut back obstacles for tenants when accessing diversifications and having the works accomplished through the LA. We make it clear within the draft Code of Follow that suppliers shouldn’t unreasonably withhold permission for companies to put in diversifications of their properties, nor ought to they unreasonably refuse to put in an adaptation of their residence the place they supply that service immediately.
General evaluation
For the explanations given, we consider that our necessities referring to housing diversifications could have a optimistic impression on tenants who share the protected traits.
Transparency and accountability to tenants – Equity and respect
Potential impression on totally different protected traits
- Age
- Incapacity
- Gender reassignment
- Race
- Intercourse
- Sexual orientation
There’s inadequate proof of any impression on the opposite protected teams. Nevertheless, it may be fairly assumed that the requirement is related to all protected traits because the stigma that social housing tenants can face can intersect with different protected traits.
Proposal
Required consequence
Registered suppliers should deal with all tenants with equity and respect.
Particular expectations
None
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
Analysis on ethnicity and social housing in 2018 discovered that:
- 16 per cent of households with an ethnic minority HRP felt they have been handled worse than different races by their landlord. That is in comparison with 9.5 per cent of households with a white HRP. The share of people that felt they have been handled higher than different races is broadly comparable, at 4 per cent for each white and ethnic minority HRPs.
- 64 per cent of white social tenants agree their social landlords deal with them pretty (and solely 17 per cent point out a notion of unfairness), towards 53 per cent of ethnic minority social tenants agreeing with this assertion, and 24 per cent believing they’re handled unfairly. Perceptions of equity fluctuate between particular person ethnic minority teams [footnote 32].
- Outcomes are constantly decrease in households with a minority ethnic HRP than a white HRP, throughout a variety of questions together with whether or not the owner’s workers have been pleasant and useful (65 per cent towards 73 per cent); whether or not they trusted their landlord (55 per cent towards 63 per cent); and whether or not the owner’s providers have been good general (42 per cent towards 58 per cent). [footnote 33]
Analysis on the expertise of LGBT+ social housing residents [footnote 34] has discovered:
- 37 per cent of survey respondents agreed that housing supplier workers have been at all times aware of their considerations
- 29 per cent agreed that workers have been delicate to the wants of LGBT+
- 56 per cent felt that their housing supplier was approachable.
The researchers reported repeated examples given by individuals of poor workers understanding of LGBT+ lives and, in some circumstances, outright discrimination.
A 2021 survey [footnote 35] of 161 LGBT+ individuals aged 16-25 who had skilled homelessness discovered that:
- Over half of LGBT+ younger individuals have confronted some type of discrimination or harassment whereas accessing housing and homelessness providers.
- Solely half (56 per cent) of LGBT+ younger individuals who accessed housing assist providers whereas homeless have been happy with their expertise.
- Over a 3rd (39 per cent) of LGBT+ younger individuals have confronted discrimination from providers attributable to an sickness, incapacity, or psychological well being situation.
Peer analysis carried out for Shelter with 34 girls dwelling in a variety of various housing conditions (2021) discovered that two-thirds of individuals (23) on this small research reported poor remedy by their landlord (personal or social) or lodging supplier. Members described being spoken to rudely, being made to really feel like a burden or that their issues weren’t extreme sufficient or being proven a scarcity of empathy or understanding [footnote 36].
Proof [footnote 37] to the Inquiry on Regulation of Social Housing by the Levelling up Housing and Communities Committee from the authors of the Stigma and Social Housing in England report quoted from their analysis findings, that the stigma associated to social housing is complicated and intersects with different societal stigmas corresponding to poverty, unemployment, psychological well being and disabilities and race and immigration. Their analysis uncovered a paternalistic perspective amongst housing affiliation workers. The analysis additionally included a number of examples of social housing professionals and contractors stigmatising tenants by their lack of respect when partaking with them, ignoring restore requests, ignoring ASB complaints, and utilizing derogatory rhetoric [footnote 38].
Our proposed necessities
Primarily based on the proof above, being handled with equity and respect by their landlords could have a optimistic impression on tenants who share the protected traits race, age, incapacity, sexual orientation, gender reassignment, and intercourse. We make it clear within the draft Code of Follow that suppliers ought to think about how they’ll adapt their providers and communications to fulfill particular person tenants’ wants. We think about that each one three PSED goals are related to those necessities.
By making this a standalone required consequence, we hope that suppliers make this a precedence throughout all interactions with tenants.
General evaluation
We think about that this measure could have a optimistic impression on tenants who share the protected traits race, age, incapacity, sexual orientation, gender reassignment, and intercourse.
Transparency and accountability to tenants – Various wants
Potential impression on totally different protected traits
- Age
- Incapacity
- Gender reassignment
- Race
- Intercourse
- Sexual orientation
There’s inadequate proof of any impression on the opposite protected teams.
Proposal
Required consequence
Registered suppliers should take motion to ship honest entry to, and equitable outcomes of, housing and landlord providers for all tenants.
Particular expectations
2.1.1 Registered suppliers should use related info and information to:
a. perceive the varied wants of tenants, together with these arising from protected traits, language obstacles, and extra assist wants; and
b. assess whether or not all tenants have honest entry to, and equitable outcomes of, housing and landlord providers.
2.1.2 Registered suppliers should be certain that communication with and data for tenants is obvious, accessible, related, well timed and acceptable to the varied wants of tenants.
2.1.3 Registered suppliers should be certain that landlord providers are accessible, and that the accessibility is publicised to tenants. This consists of supporting tenants and potential tenants to make use of on-line landlord providers if required.
2.1.4 Registered suppliers should enable tenants and potential tenants to be supported by a consultant or advocate in interactions about landlord providers.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
- As set out in proof above below the Security and High quality Customary and the requirement to deal with tenants pretty and with respect, households from sure ethnic minority backgrounds usually tend to dwell in non-decent housing, and really feel they’re handled worse than these from different races. Black African, combined white and black African, and black Caribbean, households are most probably to hire social housing out of all ethnic teams, and black households are over-represented in new social housing lettings [footnote 39]. [footnote 40]
- There’s a a lot larger proportion of households with at the very least one disabled member within the social rented sector than different tenures (54 per cent in contrast with 37 per cent for outright house owners (regardless of these two teams having an identical age profile) and 30 per cent for personal renters)). [footnote 41]
- 20 per cent of social renters are from an ethnic minority background in comparison with 15 per cent in 2011 and in comparison with the nationwide common of 15 per cent [footnote 42].
- 57 per cent of social housing tenants are aged 50 and over. Older tenants could require cheap changes to entry landlord providers, dwell of their residence and to take part in public life.
- Practically a 3rd of households in social housing comprise both a feminine dwelling alone or a feminine single father or mother. [footnote 43]
- There’s some analysis displaying how girls can expertise obstacles when accessing recommendation and assist with their housing. [footnote 44]
- In 2021-22, 93 per cent of households in England had web entry at residence, however social renters have been the least probably out of all tenures to have this entry, at 83 per cent. [footnote 45]
- Cross-tenure analysis by OFCOM in 2021 discovered that amongst these aged 65+, solely 77 per cent used the web at residence [footnote 46].
- Solely 35 per cent of LGBTQ+ younger individuals who have accessed a service while homeless recall being requested by service suppliers to supply details about their gender identification and sexual orientation [footnote 47]. Analysis in 2017 on the expertise of LGBT+ social housing residents discovered that 59 per cent of survey respondents had by no means been requested for details about their gender identification or sexual orientation by their housing supplier. [footnote 48]
- 3% of these dwelling in social housing establish as LGBT+ [footnote 49]
- 0.8% of social housing residents don’t establish with the intercourse registered at start [footnote 50].
Our proposed necessities
We’re proposing to strengthen our necessities on this space, setting clear expectations that landlords should act to ship honest entry to, and equitable outcomes of, housing and landlord providers for all tenants. The Tenant Involvement and Empowerment Customary at present expects landlords to display they perceive the totally different wants of tenants. The proposed Transparency, Affect and Accountability Customary goes additional, requiring landlords to make use of info and information to tell their understanding of how they are going to meet the totally different wants of tenants. The requirement makes clear that this pertains to wants arising from tenants’ protected traits, as outlined within the Equality Act 2010, in addition to extra broadly (see 2.1.1 beneath). We think about that these proposed necessities could result in registered suppliers doing extra to gather and keep higher information about tenants and their numerous assist wants, which signifies that they are going to be higher capable of tailor providers to fulfill their wants.
We’re additionally proposing expectations of landlords on how they convey with tenants (2.1.2), guarantee their providers are accessible together with the place these providers are accessed on-line (2.1.3); and permitting tenants to be supported by advocates or different representatives (2.1.4). The intention of all these modifications is to affect the social housing sector to fulfill the vast and ranging vary of tenant wants by understanding these wants and decreasing obstacles for tenants in accessing their landlord and its providers.
The proposed necessities assist our proposed equality goal 1, which is to raised perceive the variety of the communities that they serve and that measures are in place to advertise fairness in relation to their service supply.
General evaluation
By introducing these necessities, landlords must think about how they intend to fulfill them, which in flip could profit tenants general however significantly these tenants who share the protected traits of race, age, incapacity, sexual orientation, gender reassignment and intercourse, given the proof demonstrates that there are some disparities for these teams. We take the chance within the draft Code of Follow to amplify our necessities referring to numerous wants.
We think about that PSED goals one and two are related to those necessities.
Taking the above into consideration, we think about that the proposed measures could have a optimistic impression on tenants who share the protected traits of race, age, incapacity, sexual orientation, gender reassignment and intercourse.
Transparency and accountability to tenants – Engagement with tenants
Potential impression on totally different protected traits
- Age
- Incapacity
- Gender reassignment
- Race
- Intercourse
- Sexual orientation
There’s inadequate proof of any impression on the opposite protected teams.
Proposal
Our evaluation pertains to the required consequence and particular expectations 2.2.5 and a pair of.2.6 solely.
Required consequence
Registered suppliers should take tenants’ views into consideration of their decision-making about how landlord providers are delivered.
Particular expectations
2.2.5 Registered suppliers, working with tenants, should usually think about methods to enhance and tailor their strategy to delivering landlord providers together with tenant engagement. They need to implement modifications as acceptable to make sure providers ship the meant goals.
2.2.6.The place a registered supplier is contemplating a change in landlord for a number of tenants, or a major change in administration preparations, it should seek the advice of affected tenants on its proposals at a formative stage and take these views into consideration in reaching a choice. The session should:
a) be honest and accessible;
b) present tenants with sufficient time, info and alternatives to contemplate and reply;
c) set out precise or potential benefits and downsides (together with prices) to tenants within the speedy and long term; and
d) display to affected tenants how the session responses have been taken into consideration in reaching a choice.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
- Within the part on Equity and Respect we’ve referred to analysis from the Human Metropolis Institute which indicated differential ranges of belief and confidence in landlords based mostly on ethnicity. Lack of belief and feeling that you’re not handled with respect are more likely to act as obstacles to partaking together with your landlord.
- We now have referred within the part on Various must analysis from the EHS and OFCOM which units out potential decrease charges of these having web entry at residence in social housing typically, but additionally throughout all tenures amongst older households.
- Analysis commissioned by the Native Authorities Affiliation and developed with TPAS requires suppliers to do extra to have interaction with youthful tenants (age is just not specified). It talks concerning the significance of utilizing quite a lot of engagement strategies to advertise accessibility and to make sure engagement is consultant and asks suppliers to contemplate what steps they take to extend illustration and goal all areas of the neighborhood. [footnote 51]
- As a part of the EHS in 2020/21, social renters with a incapacity have been requested which areas have been affected by their incapacity. The most typical points reported by HRPs with a incapacity have been mobility (54 per cent, 1.2 million households), stamina (45 per cent, 1 million households), psychological well being (43 per cent, 950,000 households) and dexterity (35 per cent, 760,000 households. All of those are more likely to have an effect on disabled tenants’ capability to have interaction with their landlord. [footnote 52]
- Joint analysis based mostly on the views of individuals with a label of gentle/average studying incapacity known as for higher alternatives for the voices of individuals with studying disabilities to be heard and to affect housing coverage and famous that relations are sometimes left to supply assist. [footnote 53]
- Shelter’s report Fobbed Off, referred to above, discusses the significance of involving girls with lived expertise within the design and supply of housing and homelessness providers as a way to overcome obstacles girls face, significantly in relation to women-specific providers.
- CIH’s 2011 briefing on delivering housing providers to LGBT+ tenants that, attributable to historic discrimination many LGBT+ individuals have been reluctant to articulate their wants or have been marginalised in session processes. [footnote 54]
- An akt 2022 report really helpful that the housing and homelessness sector ought to contain younger individuals within the design of providers, and fee coaching programmes for housing workers to lift consciousness of the wants of LGBTQ+ younger people who find themselves homeless or susceptible to homelessness. [footnote 55]
Our proposed necessities
Our expectations on suppliers on this space have been elevated, requiring common and ongoing consideration of how to enhance and tailor their strategy to tenant engagement, in addition to all different landlord providers. This may occasionally result in tenants who’re much less more likely to be engaged with their landlord to participate.
The proposed necessities on resident engagement recognise that the strategies used ought to fluctuate to fulfill a variety of wants and pursuits, as some tenants could need to interact proactively with their landlord’s insurance policies, and others could choose to be saved knowledgeable.
Primarily based on the proof above, all tenants throughout the sector could also be positively impacted by necessities referring to tailoring of providers, tenant engagement and session. This impression could also be extra optimistic for many who share the protected traits of race, age, incapacity, sexual orientation, gender reassignment, and intercourse. We think about that PSED intention two is related to those necessities.
We now have additionally clarified our expectations on landlords when contemplating important modifications in administration preparations. This has been carried out to handle a few of the points we’ve seen in our client regulation case work since 2017 when the requirement at present within the present Tenant Involvement and Empowerment Customary was first launched. The expanded expectations ought to encourage simpler session apply that improves the flexibility of those that share a number of protected traits (the place it has been proven that participation / engagement ranges are low) to offer their views.
We now have taken the chance within the draft Code of Follow to be clear that suppliers ought to take cheap steps to make sure that all tenants have an equitable alternative to be concerned in influencing and scrutinising methods, insurance policies, and providers, considering the varied wants of tenants.
General evaluation
Taking all of the above into consideration, we think about that these necessities could have a optimistic impression on tenants who share the protected traits of race, age, incapacity, sexual orientation, gender reassignment, and intercourse.
Transparency and accountability to tenants – Details about landlord providers
Potential impression on totally different protected traits
There’s inadequate proof of any impression on the opposite protected teams. It’s recognised that communications and the usual of service acquired by tenants could be influenced by stigmatisation. Analysis means that social housing stigma is complicated and intersects with different points corresponding to poverty and immigration [footnote 56].
Proposal
Required consequence
Registered suppliers should talk with tenants and supply info so tenants can use landlord providers, perceive what to anticipate from their landlord, and maintain their landlord to account.
Particular expectations
2.3.1 Registered suppliers should present tenants with details about the:
a) accessible landlord providers, methods to entry these providers, and the requirements of service tenants can anticipate;
b) requirements of security and high quality tenants can anticipate properties and communal areas to fulfill;
c) rents and repair costs which might be payable by tenants; and
d) duties of the registered supplier and the tenant for sustaining properties, communal areas, shared areas [footnote 57] and neighbourhoods.
2.3.2 Registered suppliers should talk with affected tenants on progress, subsequent steps and outcomes when delivering landlord providers.
2.3.3 Registered suppliers’ housing and neighbourhood insurance policies have to be honest, cheap, accessible, and clear. The place related, insurance policies ought to set out decision-making standards and appeals processes.
2.3.4 Registered suppliers should make info accessible to tenants concerning the related roles and duties of senior degree staff or officers, together with who has accountability for compliance with the buyer requirements.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
- There’s a a lot larger proportion of households with at the very least one disabled member within the social rented sector than different tenures (54 per cent in contrast with 37 per cent for outright house owners (regardless of these two teams having an identical age profile) and 30 per cent for personal renters)).
- 57 per cent of social housing tenants are aged 50 and over. [footnote 58]
- 2.7% of social rented households have a HRP that has little/no proficiency within the English language [footnote 59].
- 36% of social rented HRPs would not have any academic {qualifications}. Comparatively the nationwide common is 20% [footnote 60].
- Ladies can expertise obstacles when accessing recommendation and assist with their housing [footnote 61].
- In 2021-22, 93 per cent of households in England had web entry at residence, however at 83 per cent, social renters have been the least probably out of all tenures to have this entry [footnote 62].
- Cross-tenure analysis by OFCOM in 2021 discovered that amongst these aged 65+, solely 77 per cent used the web at residence [footnote 63].
Our proposed necessities
We’re increasing necessities on transparency, so suppliers should hold tenants knowledgeable of plans and progress throughout the supply of providers.
To help transparency, tenants should be capable to entry insurance policies that relate to landlord providers and these insurance policies have to be honest and cheap, setting out the factors for making choices and processes tenants should observe ought to they select to enchantment a choice (2.3.3). We’re proposing so as to add to those an additional requirement for landlords to have a devoted individual chargeable for complying with the buyer requirements (2.3.4).
We think about that PSED intention two is related to those necessities. These necessities could result in an enchancment in how registered suppliers present info to tenants and the scope of that info, significantly to these tenants who usually tend to expertise obstacles to communication and/or engagement.
General evaluation
Taking the above into consideration, we think about that these necessities could have a optimistic impression on tenants who share the protected traits age, race, incapacity, and intercourse.
Transparency and accountability to tenants – Efficiency Data
NB. EXCLUDES particular expectations 2.4.1 – 2.4.3 referring to tenant satisfaction measures as they’re lined by a separate EQIA
Potential impression on totally different protected traits
There’s inadequate proof of any impression on protected teams.
Proposal
Required consequence
Registered suppliers should gather and supply info to assist efficient scrutiny by tenants of their landlord’s efficiency in delivering landlord providers.
Particular expectations
2.4.4 Registered suppliers should present tenants with details about:
a) how they’re performing in delivering landlord providers and what actions they are going to take to enhance efficiency the place required;
b) how they’ve taken tenants’ views into consideration to enhance landlord providers, info, and communication
c) how revenue is being spent; and
d) their administrators’ remuneration and administration prices.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
We didn’t discover any proof which is immediately related to the supply of knowledge to tenants by suppliers. Nevertheless, we acknowledge that our proposed common requirement for registered suppliers to contemplate how they convey and or current info to their tenant populations is more likely to assist this particular proposal.
Our proposed necessities
Whereas all tenants could also be positively impacted by necessities referring to the supply of efficiency info, as it’ll assist them to raised maintain their landlord to account, there isn’t a proof of a particular optimistic or detrimental impression on tenants who share totally different protected traits.
General evaluation
Taking the above into consideration, we think about that these necessities are more likely to have a impartial impression on tenants who share totally different protected traits.
Transparency and accountability to tenants: Complaints
There’s inadequate proof of any impression of the requirement on the opposite protected teams.
Proposal
Required consequence
Registered suppliers should guarantee complaints are addressed pretty, successfully, and promptly.
Particular expectations
2.5.1 Registered suppliers should guarantee their strategy to dealing with complaints is easy and accessible.
2.5.2 Registered suppliers should publicise their complaints course of and what tenants can do if they’re dissatisfied with the result of a criticism or how a criticism was dealt with.
2.5.3 Registered suppliers should present tenants with details about the kind of complaints acquired and the way they’ve learnt from complaints to repeatedly enhance providers.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
- Within the final 12 months, 32 per cent of social renters had thought-about making a criticism. In comparison with personal renters, social renters are twice as more likely to think about complaining. Older renters have been much less more likely to think about complaining than youthful renters (20 per cent of these aged 65 or over thought-about making a criticism in comparison with 34 per cent of these below 65). [footnote 64]
- Most social renters who selected to not make a criticism made this resolution due to the trouble and time required to take action (43 per cent), or as a result of they believed that nothing can be carried out in response to their criticism (27 per cent). Most social renters who made a criticism have been sad with the response to their criticism (63 per cent) [footnote 65].
- Social renters with an HRP from an ethnic minority background have been extra more likely to think about complaining than these with a white HRP, 38 per cent versus 30 per cent (this distinction is likely to be because of the youthful age profile of ethnic minority households, as youthful tenants have been extra more likely to think about complaining than older renters over aged 65). The proportion of social renters who, after contemplating a criticism, went on to make one was the identical for households with an ethnic minority HRP and people with a white HRP, 85 per cent in each teams. [footnote 66]
- Proof offered by Social Housing Motion Marketing campaign to the Levelling Up Housing and Communities Committee’s Inquiry into the regulation of social housing indicated that for disabled individuals the complaints course of might be draining and demoralising when met by landlords who (SHAC alleged) deliberately protract the method or fully ignore their complaints. The complaints course of itself is just not at all times accessible relying on the tenant’s incapacity, and landlords typically refuse to make cheap changes to facilitate this [footnote 67].
Our proposed necessities
The necessities referring to complaints dealing with ought to end in registered suppliers making tenants conscious of methods to make a criticism to their landlord, which, given the proof, could have a optimistic impression on tenants who share the protected traits of race, age, and incapacity. We think about that PSED goals one and two are related to those necessities.
The expanded necessities on suppliers relating to complaints ought to assist to make sure that registered suppliers have an accessible and responsive complaints system which doesn’t place obstacles in the way in which of any tenants. Our proposed commonplace operates alongside the work of the Housing Ombudsman Service, setting expectations about how registered suppliers are anticipated to deal with complaints, and incorporating necessities round transparency to tenants.
General evaluation
Taking the above into consideration, we think about that these necessities could have a optimistic impression on tenants who share the protected traits of race, age, and incapacity.
Transparency and accountability to tenants: Self-referral
Potential impression on totally different protected traits
There’s inadequate proof of any impression on protected teams.
Proposal
Particular expectation
Registered suppliers should talk in a well timed method with the regulator on all materials points that relate to non-compliance or potential non-compliance with the buyer requirements.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
We didn’t discover any equality proof which is immediately related to this requirement.
Our proposed necessities
The Governance and Monetary Viability Customary requires personal registered suppliers to speak to the regulator on materials points that relate to their non-compliance or potential non-compliance with the requirements and the Hire Customary requires this of each personal registered suppliers and native authority registered suppliers the place there are materials points associated to non-compliance in respect of rents. This proposed requirement will clarify that that is additionally a requirement in respect of our client requirements.
Whereas all tenants are more likely to be positively impacted by necessities on suppliers to speak with the regulator on materials points relating non-compliance with the buyer requirements, there isn’t a proof of any impression on tenants who share totally different protected traits.
General evaluation
Taking the above into consideration, we think about at this stage, we’ve not recognized any equality impacts related to this requirement.
Neighbourhood and Neighborhood: Upkeep of shared areas
Potential impression on totally different protected traits
There’s inadequate proof of any impression on the opposite protected teams.
Proposal
Required consequence
Registered suppliers should work co-operatively with tenants, different landlords and related organisations to contribute to the maintenance and security of shared areas related to their properties.
Particular expectation
2.1.1 Registered suppliers should work co-operatively to help in resolving points affecting the maintenance and security of the shared areas related to their properties.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
- Specialist older individuals’ housing is more likely to be flatted lodging, the place communal areas are necessary for accessibility and create areas that assist fight isolation. These must be secure and nicely maintained. Whereas there’s a distinction between communal areas (that are lined below the Security and High quality Customary) and shared areas, older individuals’s housing could also be additionally extra more likely to have shared areas in addition to communal. Authorities planning steerage signifies the significance of the standard and accessibility of shared areas for the wellbeing of older residents. [footnote 68]
- 45 per cent of social housing tenants dwell in a flat (in comparison with 22 per cent for all tenures) and 48 per cent of disabled social housing tenants dwell in a flat, maisonette or condo [footnote 69].
- Accessibility and social cohesion are two of essentially the most important elements affecting how older individuals expertise their neighbourhood. [footnote 70]
- Analysis by Foundations in 2022 additionally emphasised the significance of shared areas and their accessibility to the lives of disabled individuals. [footnote 71]
- The Housing Ombudsman in his proof to the Levelling Up Housing and Communities Committee’s Inquiry on the regulation of social housing advocated that as a part of a reviewed DHS, a minimal commonplace ought to apply to communal areas together with exterior areas corresponding to gardens, together with lighting, bin areas and bin chutes. [footnote 72]
- In social housing between 2016 and 2019, 6 per cent of households with a white British HRP have been overcrowded in comparison with 17 per cent of these with a HRP from an ethnic minority. Households with the best charges of overcrowding have been these with HRPs from the next teams: Bangladeshi (24 per cent), Pakistani (18 per cent), black African (16 per cent), Arab (15 per cent) and Blended white and black African (14 per cent). [footnote 73]
- Ethnic minority social tenants are twice as more likely to dwell in overcrowded properties [footnote 74].
Our proposed necessities
Responses to the Social Housing Inexperienced Paper highlighted tenants’ considerations concerning the high quality and maintenance of the areas round their properties. These proposed necessities set expectations in relation to ‘shared areas’, which the owner doesn’t have accountability for however the place, with efficient contribution and cooperation with others, they’ll enhance tenants’ expertise of utilizing the shared areas round their properties.
Primarily based on the proof, older individuals could also be extra more likely to dwell in lodging the place shared areas are a function. Disabled individuals want shared areas to be accessible and secure. Individuals from some minority ethnic teams usually tend to dwell in overcrowded circumstances and due to this fact have most to achieve from high quality shared areas. The requirement to contribute to the maintenance and security of shared areas could due to this fact have a optimistic impression on tenants who share the protected traits of age, incapacity, and race. We think about that PSED intention two is related to those necessities.
General evaluation
Taking the above into consideration, we think about that these necessities could have a optimistic impression on tenants who share the protected traits age, incapacity, and race.
Neighbourhood and Neighborhood: Native cooperation
Potential impression on totally different protected traits
- Age
- Incapacity
- Gender reassignment
- Race
- Intercourse
- Sexual orientation
There’s inadequate proof of any impression on the opposite protected teams.
Proposal
Required consequence
Registered suppliers should co-operate with related companions to advertise social, environmental, and financial wellbeing within the areas the place they supply social housing.
Particular expectations
2.2.1 Registered suppliers, having taken account of their strategic targets, the views of tenants and their presence throughout the areas the place they supply social housing, should:
a) establish and talk to tenants the roles registered suppliers play in selling social, environmental, and financial wellbeing and the way they are going to obtain them; and
b) co-operate with native partnership preparations and the strategic housing perform of native authorities the place they’re able to help them in reaching their targets.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
2020 Authorities information [footnote 75] for essentially the most disadvantaged 10 per cent of neighbourhoods reveals that:
- White British individuals have been the least more likely to dwell within the neighbourhoods most disadvantaged in relation to dwelling atmosphere (9.2 per cent), crime (8.9 per cent) and obstacles to housing and providers (8.2 per cent)
- Out of the 18 particular person ethnic teams, black African (32.3 per cent), black Different (31.6 per cent), and black Caribbean (29.2 per cent) individuals have been the most probably to dwell within the neighbourhoods most disadvantaged in relation to housing and providers
- Individuals from the Pakistani ethnic group have been the most probably to dwell within the 10 per cent of neighbourhoods most disadvantaged in relation to training, expertise, and coaching (27.4 per cent), well being and incapacity (16.0 per cent), crime (21.2 per cent) and the dwelling atmosphere (28.2 per cent).
A Bristol College report The Inequality of Poverty [footnote 76] from 2021 signifies the next:
- Individuals from Bangladeshi and Pakistani ethnic minorities have the best charges of poverty (at 23-26 per cent), adopted by Indian, black Caribbean and black African teams (September 11 per cent). The white majority has the bottom poverty fee at (6 per cent).
- Some protected traits are related to an elevated danger of poverty within the UK: race, intercourse (within the case of single moms), and incapacity. In relation to age, whereas pensioner poverty has fallen over the previous few a long time youthful employees are more likely to be in poverty than different age teams. We additionally discovered that intersectionality performs a big position; the extra protected traits an individual has, the extra danger they bear of being in poverty.
- Poverty amongst minority ethnic teams arises largely from the place within the labour market. General individuals from minority ethnic teams usually tend to work in low-paid occupations or earn beneath the dwelling wage. There are additionally larger unemployment charges in some minority ethnic teams, and employees from black minority ethnic teams usually tend to have insecure work.
A Houseproud mission report from the College of Surrey in 2018 discovered that:
- Practically 50 per cent of LGBT+ survey respondents in social housing don’t really feel a way of belonging of their local people.
- 25 per cent reported feeling lonely within the space they dwell and solely 31 per cent of LGBT+ survey respondents felt their housing supplier might deal successfully with problems with harassment. [footnote 77]
- The poverty fee is constantly larger for disabled individuals (32 per cent in 19/20) in comparison with 20 per cent not disabled). [footnote 78]
- Within the 12 months ending March 2021, disabled individuals have been extra more likely to report emotions of loneliness “typically or at all times” (15.1 per cent) than non-disabled individuals (3.6 per cent). [footnote 79]
Our proposed necessities
Primarily based on the proof, requiring suppliers to co-operate with companions to advertise social, environmental, and financial wellbeing could have a optimistic impression on tenants who share the protected traits age, race, incapacity, intercourse, gender reassignment, and sexual orientation. We think about that each one PSED goals are related to those necessities.
Requiring registered suppliers to set out how they are going to obtain their position within the promotion of social, environmental, and financial wellbeing strengthens the present expectation as it’s extra clear and lively.
General evaluation
Taking the above into consideration, we consider this requirement could have a optimistic impression on tenants who share the protected traits age, race, incapacity, intercourse, gender reassignment, and sexual orientation.
Neighbourhood and Neighborhood: Safer neighbourhoods
Potential impression on totally different protected traits
- Age
- Incapacity
- Gender reassignment
- Race
- Faith or perception
- Intercourse
- Sexual orientation
There’s inadequate proof of any impression on the opposite protected teams.
Proposal
Required consequence
Registered suppliers should work in partnership with acceptable native authority departments, the police, and different related organisations to discourage and deal with ASB within the neighbourhoods the place they supply social housing.
Particular expectations
2.3.1 Registered suppliers should have a coverage on how they work with related organisations to discourage and deal with ASB within the neighbourhoods the place they supply social housing.
2.3.2 Registered suppliers should have clearly set out their strategy for the way they deal with and deter hate incidents in neighbourhoods the place they supply social housing.
2.3.3 Registered suppliers should allow ASB to be reported simply and hold tenants knowledgeable concerning the progress of their case.
2.3.4 Registered suppliers should present immediate and acceptable motion in response to ASB, having regard to the total vary of instruments and authorized powers accessible to them.
2.3.5 Registered suppliers should assist tenants who’re affected by ASB, together with by signposting them to companies who may give them acceptable assist and help.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
Authorities 2021/22 hate crime figures [footnote 80]:
- 70 per cent (109,843) of hate crimes have been racially motivated – racially motivated hate crimes elevated by 19 per cent between 12 months ending March 2021 and 12 months ending March 2022.
- Non secular hate crimes elevated by 37 per cent between 12 months ending March 2021 and 12 months ending March 2022 (from 6,383 to eight,730). In 12 months ending March 2022, the place the perceived faith of the sufferer was recorded, two in 5 (42 per cent) of non secular hate crime offences have been focused towards Muslims (3,459 offences). The following most focused group have been Jewish individuals, who have been focused in just below one in 4 (23 per cent) of non secular hate crimes (1,919 offences).
- Sexual orientation hate crimes rose by 41 per cent (to 26,152 offences). This was the biggest proportion annual improve in these offences for the reason that time sequence started in 12 months ending March 2012.
- Incapacity hate crimes elevated by 43 per cent (from 9,945 to 14,242) during the last 12 months, the biggest proportion annual improve seen since 12 months ending March 2017 (53 per cent).
ONS crime figures 2020 [footnote 81]:
- 40 per cent of white British households skilled ASB within the native space in comparison with 46 per cent white and black African and 55 per cent different combined ethnic background.
- 50 per cent of Jewish households skilled ASB within the native space.
- 52 per cent of homosexual/lesbian households and 49 per cent of bisexual households skilled ASB within the native space in comparison with 42 per cent of heterosexual households.
ONS notion of non-public security and experiences of harassment 2022 [footnote 82]
London Councils’ 2014 report [footnote 85] on ASB and psychological well being discovered that:
- Individuals with studying disabilities and psychological well being issues can generally be perceived as perpetrators of ASB by displaying behaviours attributable to their impairment.
A Cambridge College analysis mission [footnote 86] discovered very differing concepts about what constitutes ASB between adults and other people aged 11-15 throughout the similar space.
- Social housing tenants usually tend to expertise ASB and be victims of crime than these in different tenures [footnote 87].
Our proposed necessities
Primarily based on the proof, tenants who share the protected traits age, race, faith or perception, incapacity, intercourse, gender reassignment, and sexual orientation could also be extra positively impacted by necessities referring to ASB and hate crime. We think about that each one PSED goals are related to those necessities.
The brand new expectation that suppliers set out their strategy to tackling and deterring hate incidents could have a optimistic impression on tenants who share the protected traits race, gender reassignment, incapacity, sexual orientation, and age, as suppliers might want to outline their coverage and strategy, considering the wants of their tenants and present sector good apply on this space.
Some perpetrators of ASB endure with psychological well being issues. 2.3.5 requiring suppliers to assist these affected by ASB reasonably than limiting assist to victims of ASB could assist to facilitate the suitable assist and interventions being put in place for these perpetrators and obtain a optimistic consequence that reduces additional offending and helps them to take care of their tenancy.
We now have taken the chance within the draft Code of Follow to make it clear that suppliers ought to intention to remove any obstacles to reporting ASB and hate incidents to their landlord, which can have a optimistic impression on these tenants who could also be reluctant to report ASB and hate incidents or who expertise communications obstacles.
General evaluation
Taking the above into consideration, we think about that these necessities could have a optimistic impression on tenants who share the protected traits race, faith or perception, gender reassignment, incapacity, intercourse, sexual orientation, and age.
Neighbourhood and Neighborhood: Home abuse
Potential impression on totally different protected traits
- Age
- Incapacity
- Gender reassignment
- Pregancy and maternity
- Race
- Intercourse
- Sexual orientation
There’s inadequate proof of any impression on the opposite protected teams.
Proposal
Required consequence
Registered suppliers should work co-operatively with different companies tackling home abuse and allow tenants to entry acceptable assist and recommendation.
Particular expectations
2.4.1 Registered suppliers should have a coverage for the way they reply to circumstances of home abuse.
2.4.2 Registered suppliers should co-operate with acceptable native authority departments to assist the native authority in assembly its obligation to develop a method and fee providers for victims of home abuse and their youngsters inside secure lodging.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
ONS information on home abuse sufferer traits 21/22 [footnote 88]:
- 74 per cent of home abuse associated crimes recorded by the police the sufferer was feminine.
- Considerably larger proportion of adults aged 20 to 24 years have been victims of any home abuse in contrast with these in age classes of 55 years and over.
- 10 per cent of adults with a incapacity skilled home abuse in comparison with 4 per cent of adults with no incapacity.
- Variations between any home abuse estimates throughout totally different ethnic teams have been discovered to not be important.
- ONS statistics [footnote 89] present that, of all victims of any kind of home abuse, it was reported by 5.0 per cent of white individuals, 8.7 per cent of combined ethnicity individuals, 3.9 per cent Asian individuals, and 5.9 per cent black individuals. feminine victims solely, the figures have been 7.0 per cent white, 3.2 per cent Asian, and 10.2 per cent black.
- Home abuse can escalate throughout being pregnant [footnote 90].
- 1 in 15 survivors utilizing home abuse providers are pregnant girls. [footnote 91]
- The Secure at Residence Report [footnote 92] recommends making a home abuse coverage for employees and tenants as a way to increase consciousness of home abuse.
- The Residence Workplace states [footnote 93] that between an estimated quarter and a 3rd of kids have been uncovered to home abuse sooner or later of their lives; and that girls aged 16 to 19 years have been considerably extra more likely to be victims of any home abuse within the final 12 months than girls aged 25 years and over. It additionally discovered that disabled adults have been extra more likely to have skilled home abuse within the final 12 months than non-disabled adults.
- There’s additional proof to counsel that disabled individuals are at elevated danger of experiencing home abuse within the Crime Survey for England and Wales 12 months ending March 2020 [footnote 94]. This discovered that round 1 in 7 (14 per cent) disabled adults aged 16 to 59 years skilled home abuse, in contrast with 1 in 20 (5 per cent) non-disabled adults, and that disabled girls have been greater than twice as more likely to have skilled home abuse (18 per cent) than non-disabled girls (7 per cent).
- Whereas there are not any official statistics on the experiences of LGBT+ communities with home abuse, analysis [footnote 95] by GALOP suggests it is rather prevalent.
- A Stonewall research [footnote 96] discovered greater than 1 / 4 of British transgender individuals (28 per cent) in a relationship within the earlier 12 months had confronted home abuse from a companion.
Our proposed necessities
The White Paper commits the regulator to introducing a requirement for landlords to have a coverage setting out how they need to deal with points surrounding home abuse, working with different companies as acceptable, and the Act extends our powers to set requirements to incorporate insurance policies and procedures in connection to home abuse. That is mirrored within the proposed commonplace. We think about that each one PSED goals are related to those necessities.
Primarily based on the proof, requiring suppliers to work with others to deal with home abuse could have a optimistic impression on tenants who share the protected traits of being pregnant and maternity, gender, age, race, incapacity, gender reassignment, and sexual orientation. By working with different companies, registered suppliers might be able to obtain extra to deal with home abuse than they might by working alone, which can scale back disadvantages suffered by victims and survivors. The end result of such partnership working ought to assist to make sure that victims and survivors of home abuse can stay secure of their residence or transfer to a spot of security.
Having a home abuse coverage ought to increase consciousness of and improve understanding of home abuse and the assist accessible to victims and survivors of home abuse throughout the neighborhood and with a registered supplier’s workers. Having a coverage setting out how they reply to circumstances of home abuse may additionally assist to make sure that suppliers reply appropriately and constantly to reviews of home abuse. The Draft Domestic Abuse Statutory Guidance Framework states that it’s vital that housing suppliers are capable of recognise and reply to the indicators of home abuse. Its findings embrace the danger of housing suppliers misdiagnosing the results of home abuse as ASB, and the fee to suppliers of doing so.
Anticipating registered suppliers to have a transparent coverage and dedication to this strategy may additionally assist to contribute to a societal problem towards home abuse in direction of victims and survivors, the place there may be important correlation throughout protected traits, significantly for ladies.
The draft Code of Follow makes clear that suppliers ought to guarantee they’ve an appreciation of the totally different particular wants of tenants who expertise home abuse, together with these arising from the tenant’s protected traits, corresponding to incapacity and race.
General evaluation
Taking the above into consideration, we think about that these necessities could have a optimistic impression on tenants who share the protected traits being pregnant and maternity, intercourse, age, race, incapacity, gender reassignment, and sexual orientation.
Tenancy: Allocations and lettings
Potential impression on totally different protected traits
There’s inadequate proof of any impression on the opposite protected teams.
Proposal
Required consequence
Registered suppliers should allocate and let their properties in a honest and clear method that takes the wants of tenants and potential tenants into consideration.
Particular expectations
2.1.1 Registered suppliers should co-operate with native authorities’ strategic housing features and help native authorities to fulfil their duties to fulfill recognized native housing wants. This consists of help with native authorities’ homelessness duties, and thru assembly obligations in nominations agreements.
2.1.2 Registered suppliers should search to allocate properties which might be designated, designed, or tailored to meet particular wants in a method that’s appropriate with the aim of the housing.
2.1.3 Registered suppliers should develop and ship providers to handle under-occupation and overcrowding of their properties. These providers needs to be centered on the wants of tenants.
2.1.4 Registered suppliers should take motion to stop and deal with tenancy fraud.
2.1.5 Registered suppliers should have a good, cheap, easy, and accessible appeals course of for allocation choices.
2.1.6 Registered suppliers should report all lettings and gross sales as required by the Steady Recording of Lettings (CORE) system.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
Authorities figures on overcrowded households [footnote 97]:
- Households with a black lead applicant have been essentially the most disproportionately homeless at 9.7 per cent of these owed an obligation however solely 3.5 per cent of the inhabitants.
- Households with the best charges of overcrowding have been within the Bangladeshi (24 per cent), Pakistani (18 per cent), black African (16 per cent), Arab (15 per cent) and combined white and black African (14 per cent) ethnic teams. 2 per cent of white British households have been overcrowded.
- In social housing 6 per cent of white British have been overcrowded in comparison with 13 per cent of the inhabitants aside from white British.
- For susceptible Bangladeshi households, the commonest cause they got precedence was the necessity to transfer out of unsanitary, unsatisfactory, or overcrowded circumstances.
- White British households have been extra more likely to under-occupy their residence than households from all different ethnic teams mixed.
Authorities information on renting social housing [footnote 98]
- Black African (44 per cent), combined white and black African (41 per cent) and black Caribbean (40 per cent) households have been most probably to hire social housing out of all ethnic teams. Indian (7 per cent), Chinese language (10 per cent), and white different (11 per cent) households had decrease charges of renting social housing. Compares with 16 per cent of white British households rented social housing.
- In London, white British households have been much less more likely to hire social housing than households from all different ethnic teams mixed. Exterior London, white British households have been as more likely to hire social housing as households from all different ethnic teams mixed.
- Households with a HRP from black ethnic teams have been the most probably to dwell within the neighbourhoods most disadvantaged in relation to obstacles to housing and providers and people with a HRP from the white British ethnic group least probably.
- Households from the Pakistani ethnic group have been the most probably to dwell within the 10 per cent of neighbourhoods most disadvantaged in relation to training, expertise and coaching, well being and incapacity, crime, and the dwelling atmosphere.
Census 2021 information [footnote 99]
- Ethnic minority social tenants are twice as more likely to dwell in overcrowded properties
Analysis [footnote 100] by the Nationwide Institute for Well being Analysis, College for Social Care Analysis highlights a few of the difficulties these with gentle and average studying disabilities have with accessing social housing:
- Social housing was typically seen as the primary or most popular choice, however the sector was tough to entry.
- The method of making use of for social housing, typically by selection – based mostly lettings, is difficult, even the place an individual has advocates. The bidding course of is obscure and the aggressive nature of it locations important stress on individuals with studying disabilities.
- The selection based mostly letting system must be made way more accessible. Having a trusted and well-informed person that helps somebody by a transfer and sustaining their tenancy is crucial.
A few of the proof [footnote 101] supplied to the Levelling Up Housing and Communities Committee’s inquiries into the regulation of social housing, and into exempt lodging, indicated that unsuitable allocations can have a detrimental impact. SHAC’s written proof to the inquiry on the regulation of social housing means that assist supplied to disabled tenants experiencing ASB must be improved, with higher use manufactured from powers below the Anti-Social Behaviour, Crime and Policing Act 2014. West Midlands Police’s written proof to the inquiry on exempt lodging expressed concern about ‘concentrations of susceptible individuals, many with complicated wants’ in ASB hotspot areas because it gives ‘alternative for them to be exploited, to take advantage of others or for his or her vulnerabilities to be in any other case taken benefit of or uncovered’.
A 2019 report [footnote 102] from the APPG for housing and take care of older individuals highlighted that older tenants in social housing are most probably to under-occupy and that this will create a number of issues with gasoline poverty and upkeep value.
Overcrowding is way more prevalent amongst these aged 16 to 34. [footnote 103]
A 2021 publication [footnote 104] from the Home of Commons Library said that older households who need to transfer could wrestle to maneuver to an accessible residence attributable to a scarcity of accessible and specialist housing for older individuals (for instance, retirement housing, sheltered housing and housing with care) in each the personal and social sectors.
Our proposed necessities
Primarily based on the proof, tenants throughout the sector who could also be positively impacted by these necessities share the protected traits age, race, and incapacity. We think about that PSED intention two is related to those necessities.
We’re broadening the present requirement that suppliers take note of the housing wants and aspirations of tenants and potential tenants, to take note of the wants of tenants and potential tenants. This may occasionally encourage registered suppliers to contemplate the broader wants of tenants and potential tenants arising from their protected traits, or broader circumstances, of their allocations choices, and due to this fact assist to advance alternatives for some tenants who share a number of protected traits.
2.1.2 makes the necessity clear for suppliers to make finest use of the restricted inventory of tailored properties, which can enhance alternatives for many who share protected traits of incapacity and age.
2.1.5 requires that the appeals course of have to be honest, cheap, easy, and accessible, and reiterates necessities which might be elsewhere within the requirements for landlord providers to be accessible.
2.1.6 ensures the continued availability of information on social housing lettings which helps to extend info within the public area about who’s shifting into social housing, which is a elementary factor in making certain equitable entry and outcomes.
General evaluation
Taking the above into consideration, we think about that these necessities could have a optimistic impression on tenants who share the protected traits age, race, and incapacity.
Tenancy: Tenure
Potential impression on totally different protected traits
There’s inadequate proof of any impression on protected teams.
Proposal
We now have solely assessed the textual content marked with ~ beneath.
Required consequence
Registered suppliers should supply tenancies or phrases of occupation that are appropriate with the aim of the lodging, the wants of particular person households, the sustainability of the neighborhood, and the environment friendly use of their housing inventory.
~They shall meet all relevant statutory and authorized necessities in relation to the shape and use of tenancy agreements or phrases of occupation.~
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
We didn’t discover any proof which is immediately related to the requirement for registered suppliers to fulfill all relevant statutory and authorized necessities in relation to the shape and use of tenancy agreements or phrases of occupation.
Our proposed necessities
We thought-about whether or not this requirement could have a optimistic impression on tenants who share totally different protected traits. Whereas all tenants could also be positively impacted by this requirement, there isn’t a proof of any impression on tenants who share totally different protected traits.
General evaluation
Taking the above into consideration, at this stage we’ve not recognized any equality impacts related to this proposal.
Tenancy: Tenancy sustainment and evictions
Potential impression on totally different protected traits
There’s inadequate proof of any impression on the opposite protected teams.
Proposal
Required consequence
Registered suppliers should assist tenants to take care of their tenancy or licence. The place a registered supplier ends a tenancy or licence, they need to supply affected tenants recommendation and help.
Particular expectations
2.2.1 Registered suppliers should present providers that assist tenants to take care of their tenancy or licence and stop pointless evictions.
2.2.2 Registered suppliers should present tenants required to maneuver with well timed recommendation and help about housing choices earlier than the tenancy or licence ends.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
Authorities information on the social rented sector [footnote 105]:
- The youngest and oldest social renters (these aged 16 to 24, and 75 and over) had the best proportions within the lowest revenue quintile for his or her age (69 per cent and 73 per cent respectively), with the weekly revenue being lowest for 16- to 24-year-olds and people aged 75 and over, at £293 and £290 respectively.
- Amongst family varieties within the social rented sector, lone mother and father with dependent youngsters (49 per cent) and one individual households (79 per cent) had the best proportion within the lowest revenue quintile in comparison with different family varieties.
- Lone mother and father with non-dependent youngsters (56 per cent) and lone mother and father with dependent youngsters (60 per cent) had the bottom proportion saying they discovered it simple to pay hire in comparison with different family varieties.
- Youthful social renters have been extra more likely to have been in hire arrears throughout the earlier 12 months than older renters. Social renters aged 16 to 24 and 25 to 34 have been extra probably than all different age teams to have been in arrears within the final 12 months (44 per cent and 37 per cent respectively). Social renters aged 75 and over and people aged 65 to 74 have been the least more likely to be in arrears (6 per cent and 5 per cent respectively).
- Lone mother and father in social housing with dependent youngsters (42 per cent) have been extra more likely to have been in hire arrears throughout the earlier 12 months than every other family kind. This was adopted by {couples} with dependent youngsters (27 per cent). Within the social rented sector, these receiving housing profit have been extra more likely to have been in hire arrears within the earlier 12 months (30 per cent) in comparison with those that don’t (17 per cent).
The Inequality of Poverty report from the College of Bristol [footnote 106] additionally discovered important variations in charges of poverty, which appear to align with sure protected traits:
- Some protected traits are related to an elevated danger of poverty within the UK: race, intercourse (within the case of single moms), and incapacity. Individuals from Bangladeshi and Pakistani ethnic minorities have the best charges of poverty (at 23-26 per cent), adopted by Indian, black Caribbean and black African teams (September 11 per cent) with the white majority at (6 per cent). Their findings point out that youthful employees are more likely to be in poverty than different age teams. Intersectionality performs a big position; the extra protected traits an individual has, the extra danger they bear. In addition they discovered a really sturdy relationship between poverty and incapacity.
The Race Equality Basis’s work in its Housing Collaborative [footnote 107] reported that:
- Throughout all tenures and teams, round 6 per cent of households responding to the Understanding Society survey [footnote 108] have been in arrears with their housing funds. These born exterior the UK have been twice as more likely to be in housing arrears. Single mother and father and different households with dependent youngsters twice as probably. Social housing tenants have been two and a half instances as more likely to be in housing arrears. They recognized inequality by ethnicity with 1 / 4 of individuals with Bangladeshi ethnicity and a fifth of these with Pakistani or black African ethnicity being in housing arrears.
- This research additionally checked out those that had advised the survey that they meant to maneuver from their current lodging. Of the full who stated this, 4 per cent have been shifting due to the tip of their tenancy or eviction. The report doesn’t clarify its outcomes significantly clearly, nevertheless it does point out that the numbers of lone father or mother with dependent youngsters households who meant to maneuver due to the tip of their tenancy or eviction was disproportionately excessive, each in social housing and personal rented housing. In addition they point out that black Caribbean, Bangladeshi, white different and combined ethnic teams have been extra more likely to intend to maneuver due to the tip of tenancy or eviction.
Census 2021 information [footnote 109]:
- Social housing tenants have the second lowest employment fee behind house owners who’ve purchased their properties outright.
Our proposed necessities
Our draft necessities on tenancy sustainment and evictions give larger emphasis on landlords supporting tenants to take care of their tenancy, as we’re proposing to set a required consequence on this situation. Being in arrears with hire is a method by which a tenant could face eviction and the proof reveals us that sure teams e.g., younger individuals (age), individuals from sure ethnic minorities (race), lone mother and father (intercourse), and people with a incapacity usually tend to be in hire arrears throughout the social housing sector when in comparison with different teams who don’t share these protected traits. By introducing these necessities, registered suppliers must display how they assist tenants on this space. The place tenants can entry this extra assist, this may increasingly scale back the disparities.
We’re additionally being specific that this requirement applies not solely to tenancies, however to licences. These are generally granted as the premise of occupation in a supported housing context, the place licensees usually tend to share the protected attribute of incapacity. Registered suppliers might want to be certain that their strategy to tenancy sustainment and evictions covers licensees in addition to tenants.
The proof signifies that tenants throughout the sector who could also be positively impacted by this requirement are those that share protected traits of age, race, incapacity, and intercourse, as they’re extra more likely to be in poverty and to fall into hire arrears, and so at larger danger of eviction. Different protected teams can be susceptible to eviction, corresponding to households with assist wants, younger individuals leaving care, and single mother and father. Susceptible people are additionally extra more likely to be housed in supported lodging, together with individuals fleeing abusive relationships, refugees and migrants, younger care leavers and other people experiencing psychological well being issues.
We think about that PSED intention two is related to those necessities.
General evaluation
Taking the above into consideration, we think about that these measures could have optimistic impacts on tenants who share the protected traits age, intercourse, race, and incapacity.
Tenancy: Mutual change
Potential impression on totally different protected traits
There’s inadequate proof of any impression on the opposite protected teams.
Proposal
Our evaluation has been carried out on the required consequence and on particular expectation 2.2.4, that are proposed by the regulator.
Required consequence
Registered suppliers should assist related tenants dwelling in eligible housing to mutually change their properties.
Particular expectation
2.4.4 Registered suppliers should supply tenants searching for to mutually change with details about the implications for tenure, hire and repair costs.
Proof of potential impression(s) and an evaluation of our necessities and of the potential impression (optimistic, detrimental or impartial)
What the proof tells us
Shelter’s ‘Fobbed off’ report [footnote 110] identifies that girls face obstacles when accessing recommendation and assist with their housing together with lack of understanding of how the system works and poor remedy by professionals.
- Knowledge from the EHS and OFCOM reveals charges of residence web use decreasing with age and being lowest typically amongst social housing tenants in comparison with different tenures.
Our proposed necessities
We think about that PSED goals one and two are related to those necessities.
The required consequence ought to assist to make sure that all tenants are equally supported to mutually change their residence by their landlord. Equally, 2.4.4 ought to assist to make sure that those that want to change and are eligible can perceive the total implications of it, permitting them to make an knowledgeable selection about what’s finest for them. Each modifications could have a optimistic impression on feminine tenants, tenants who’ve communication difficulties, and people whose first language is just not English.
General evaluation
Taking the above into consideration, we think about that these necessities could have a optimistic impression on tenants who share the protected traits intercourse, age, incapacity and race.
Half 4: Monitoring and assessment
We’re asking respondents to the buyer requirements session whether or not they agree with the conclusions on this EQIA. Following the session, we’ll think about the responses in making ready a ultimate EQIA, which we intend to publish alongside the ultimate client requirements and related Code of Follow. This can embrace an evaluation of any further proof of potential impacts on equality acquired throughout this session.
If we make modifications to the buyer requirements following the session, we’ll think about whether or not to revise the EQIA. As well as, the place new related equality information turns into accessible, together with in relation to the recognized gaps, consideration to reviewing the EQIA may also be given at that time.
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