What the SHR’s Shift Towards Landlord-Led Improvement Means for RSLs

If a tenant safety backlog starts to grow, how soon will your Governing Body know? Who will decide what action to take, and when will members see evidence that the action worked? Those questions go to the heart of the Scottish Housing Regulator’s (SHR) 10 November letter to landlords.

The SHR says it will concentrate more of its direct engagement on landlords that present the greatest risks to tenants’ interests. It expects more Engagement Plans to focus on improvement led by landlords themselves. It also aims to visit each social landlord at least once every three years where it has had no direct engagement through its annual risk assessment. The scope of those visits is still to be developed. The published Regulatory Framework stays in place. SHR operating model letter, 10 November 2026

For registered social landlords (RSLs), the practical question is whether their existing arrangements will spot a problem early, bring it to the right people and show when it has been fixed. That starts with the papers members receive throughout the year.

Show Members Who Is Still Waiting

The SHR’s September review found that social landlords took an average of 26 days to resolve damp and mould cases in 2025/26. Structural cases took 36 days on average, compared with 24 for condensation. At year end, 7,169 cases were still open. The resolution figures describe completed cases. Members also need to see how long tenants in open cases have been waiting and what is being done for them in the meantime. SHR damp and mould thematic review

Use the existing safety report to show the number and age of overdue cases, the reason for delay and the next action. When a case is marked complete, sample the underlying record to check what happened, whether the tenant was told and whether the issue recurred. Complaints and repeat reports can show where the process still leaves tenants waiting after management believes the work is finished.

Know When Financial Headroom Will Tighten

At 31 March 2026, RSLs had £1.74 billion in cash and undrawn facilities across the sector, according to the SHR’s October review. The November letter also describes the position of most RSLs as stable while noting that headroom is becoming more constrained. Each Governing Body needs a view of its own position, including when cash is at its lowest and how close it could come to a lender covenant limit. SHR annual review of RSL loan portfolios · SHR operating model letter

Ask finance and asset teams to test a combined scenario using your own plans. What happens if essential work to existing homes costs more than expected and a grant payment or refinancing is delayed? Ask management to show when it would bring a decision to members, which commitments can be rescheduled and which work must be protected. Build those trigger points into the regular finance report so members can act while options are still available.

Check That the Action Fixed the Problem

An improvement plan should show what needs to change, who is responsible and when members will see evidence of the result. If a landlord introduces a new process to follow up overdue safety checks, test whether cases are now being escalated on time and whether the oldest cases have been dealt with. Use Internal Audit or another independent source where the potential impact is significant or the evidence is uncertain. The SHR’s 2026 Assurance visits highlighted the value of giving members access to supporting evidence and drawing on tenant feedback and independent review. SHR 2026 Annual Assurance Statement thematic review

Where a development materially changes the level of Assurance in the Annual Assurance Statement, RSLs must notify the SHR during the year in line with its Notifiable Events guidance. The November letter signals a consultation on possible refinements. The existing guidance continues to apply. SHR Annual Assurance Statement guidance · SHR Notifiable Events guidance

Three Questions for the Next Governing Body Meeting

• Which risks could worsen before our next meeting, and what would trigger an earlier report?
• Which improvement action have we recently closed, and what evidence shows that the problem has been resolved?
• If our level of Assurance changes materially, who will assess it, who will inform members and who will notify the SHR?