CIH Scotland comments on Cost of Living (Tenant Protection) (Scotland) Bill

In the Programme for Government (PfG) published on 6 September 2022, the Scottish Government announced plans for emergency legislation covering the social and private rented sector to freeze rents and impose a moratorium on evictions until at least 31 March 2023. The Cost of Living (Protection of Tenants) (Scotland) Bill 2022 has now been introduced as part of the Scottish Government’s response to the cost of living crisis.

Commenting on the Bill, CIH Scotland’s national director Callum Chomczuk said:

“CIH Scotland recognises the policy intent behind the rent freeze and eviction protection. It is understandable that the Scottish Government wants to do what it can to protect tenants from cost-of-living increases. However, we are concerned that the policy will have significant unintended consequences which will undermine Government ambition for the housing sector as well as tenants’ housing outcomes.

"In the social rented sector, landlords reported the highest level of rent arrears since the introduction of the Scottish Social Housing Charter, currently just under £170 million.

"For private landlords, rising levels of interest rates have led to many private rental properties being sold off and landlords leaving the market, reducing the supply of rented accommodation available.  

"The decision to introduce a rent freeze and eviction protection has the potential to exacerbate these trends and undermine social and private landlords’ efforts to maintain and improve existing homes, provide services for tenants, and in the case of social landlords, fund the development of new affordable housing. These improvements, alongside our plans to decarbonise Scotland’s rented sector, are predicated on stable rental income.

"As Parliament considers, and likely passes, the legislation this week, the Scottish Government must also provide more clarity around what evidence and benchmarking will be required in the review/reporting process to ensure that these measures are temporary and are only in place for as long as they are necessary.”