02 Apr 2025
CIH response to the Housing Ombudsman’s consultation on its five year strategy and business plan for 2025/26
We recognise the value of a robust and effective Housing Ombudsman Service (HOS) to make the final decision on disputes between tenants and landlords, where a matter has not been able to be resolved through an organisation’s complaints procedure. The HOS also has a vital role in supporting landlords to develop their complaints services to ensure that increasingly there is a swift and appropriate resolution at the earliest opportunity. We welcome the consultation by HOS on its five year strategy for healthier homes, fairer services and trusting relationships, and the business plan for 2025/26. We will not be addressing all of the questions but making broader comments on objectives and aims across the corporate strategy and business plan. It would be helpful to understand the balance of priorities across the objectives given the scale of the HOS’s plans, and the additional work likely to be involved (the development of STAIRs and the reference to other potential operations in objective four for example).
CIH strongly supports the HOS’ objective to provide a positive customer service for residents. Enabling residents to have an independent, impartial and respected route for complaints, when local resolutions cannot be found or fail, is the most important objective of the HOS. The HOS’s role in supporting landlords to then understand the issues behind service failure and using the experience to improve their organisation’s complaints service (aim 1.5 and objective 2) adds to this objective.
We agree with the HOS’s aims to achieve this through providing a positive customer experience for residents (aim 1.1) and the use of a range of techniques to provide resolution at the earliest opportunity (aim 1.2). We welcome the identification of KPIs to ensure more cases receive faster resolution whilst maintaining case work quality and delivering effective remedies with which landlords comply (aim 1.3).
It is important to note that, whilst welcome, the timescales still mean a considerable delay for residents who have already gone through the local complaints process, which can add to dissatisfaction with both the landlord and HOS. It also complicates the picture for residents where the time lapse is so long that in the interim period landlords may have already addressed issues that the HOS identifies. Tackling this will require an ongoing focus to reduce timeframes, and to strengthen local complaints services to provide effective resolutions at source.
Effective remedies with which landlords comply would benefit from development in partnership with landlords and residents with experience of the HOS process, and could usefully include a focus on a stronger, transparent mediation service. We note the commitments in the business plan 2025-26 for research with landlords and residents on customer service offers and charter, and trial of techniques for early resolution as steps in achieving this.
CIH strongly supports this objective for the HOS, and sees this as a critical support for landlords, alongside its robust and impartial resolution service. It is important to note that there are significant differences across landlords in the sector, with some requiring more focused and targeted support where there are repeated failures of service.
The spotlight reports and learning tools in the Centre for Learning provide valuable good practice examples and demonstrations of service improvements for landlords to adapt and adopt within their own context and frameworks. Working with landlords to identify which are most useful, how frequently these are updated, and ways to support landlords’ capacity to use and adapt these tools would be helpful to maximise the take up of and benefit from the good practice and lessons to improve services and complaints handling within individual landlords (aim 2.2). It is important in the spotlight reports and other learning materials that the language and communication used is clear on how significant and widespread issues are (for a minority of landlords, rather than sector wide application etc.); this plays a role in supporting and repairing trust in landlords, and across the sector.
We support the HOS’ aim to focus help and support for boards and the Member Responsible for Complaints, to ensure that a positive learning culture and complaints approach is embedded across the organisation (aim 2.3).
We are encouraged that more residents are aware of and using the HOS service, and support further and ongoing work to ensure this through publicity on their right to complain and the role of the HOS within that (aim 2.4). In this it would also be helpful to include reference to other mechanisms that support residents in knowing their rights, such as the Four Million Homes programme.
We agree that the level of insight gathered by the HOS through its work provides useful information for landlords to understand when and why services fail, and to develop and improve services, particularly in cases with individual landlords where there are repeated and significant service failures. That may include referrals to the Regulator of Social Housing (the regulator). Greater transparency over why and when such referrals are made would be beneficial for landlords and their residents, to understand how this will be used for any service improvement plan or other regulatory interventions (aims 3.1, 3.2, 3.3).
We note the commitment in the business plan 2025-26 to work with landlords to establish ways to measure the impact of HOS work in supporting landlords to achieve fair services and healthier homes (and its support more widely to achieve improvements across several Tenant Satisfaction Measures).
Similarly, we appreciate that the understanding of landlords within the sector, gathered from the work of the HOS, is a useful resource to inform the wider policy debate, by being open and transparent about the issues it identifies and how landlords are addressing them (aims 3.4, 3.5). This is a valuable additional outcome from the work focused on positive customer services and supporting landlords in improvements.
The implementation of the Social Tenants Access to Information scheme (STAIRS) will require additional work by the HOS to apply its principles and process for redress in the case of complaints around this service, as acknowledged in the corporate and business plan (aim 4.2). This could be developed in partnership with landlords as they work on their own procedures to respond to requirements, including appropriate routes for complaints and resolution. The process and experience of the Information Commissioner would also be valuable in establishing an effective response.
We note the memorandum of understanding between the regulator and the HOS. Where relationships are developed with other regulators, it will be important for landlords and residents to have transparency and clarity on this, to understand the basis on which information and data will be shared, the purpose and aims of engagement, and the likely impacts for organisations and services.
Where there is the potential for new operational scope for the HOS (for example if it is extended to include the service for private rented tenants), it would be valuable for both landlords and residents to have assurance about how it will ensure it maintains the focus on timely responses and quality case work for social housing residents.
Visit the Ombudsman's website for more details on the consultation.
For more information on our response please contact Sarah Davis, senior policy officer, sarah.davis@cih.org or Dr Eve Blezard, policy officer, eve.blezard@cih.org.
