Avoiding or Overcoming RSH Failures: How Landlords Can Respond

By Paul O’Callaghan · 9 October 2025

The Regulator of Social Housing (RSH) introduced its new Consumer Standards in April 2024. The standards apply fully to housing associations and local authorities in England, and the regulator has been busy, spending the past 16 months carrying out inspections and issuing regulatory judgements. Several landlords have received C3 ratings following inspections from the regulator, while some have received C4 ratings. From the published list of gradings, it appears that most landlords are performing better in relation to the Governance and Financial Viability Standards, although some are still graded as V3/G3.

What does failure against the standards mean?

The RSH defines failures as the following:

C3: Our judgement is that there are serious failings in the landlord delivering the outcomes of the consumer standards and significant improvement is needed.

C4: The RSH judgement is that there are very serious failings in the landlord delivering the outcomes of the consumer standards. The landlord must make fundamental changes so that improved outcomes are delivered.

G3: The judgement is that the landlord does not meet the RSH governance requirements. There are issues of serious regulatory concern and in agreement with the RSH the landlord is working to improve its position.

V3: The judgement is that the landlord does not meet the RSH viability requirements. There are issues of serious regulatory concern and in agreement with the RSH the landlord is working to improve its position.

C, G and V ratings apply to Housing Associations, while local authorities only receive C ratings.

The most common reasons landlords have received these ratings include:

Poor data quality on stock condition
Underdeveloped resident engagement services
Health and safety compliance failings (particularly around carrying out inspections and completion of remedial works)
Poor repairs performance
Financial strain due to budget cuts or investment backlogs
Governance issues such as lack of oversight or weak risk management

The challenges landlords are facing

There are many reasons why local authorities and housing associations are facing challenges to comply with the regulator’s expectations. Years of spending cuts have led to staff shortages and a lack of investment in training. The post-COVID world has seen major changes in working habits, including more working from home and a shift in organisational culture.

Many teams are stretched thin, with fewer experienced housing professionals to manage increasingly complex responsibilities. This has been compounded by a wave of retirements in the years since COVID 19, creating knowledge gaps that are difficult to fill. At the same time, there is a shortage of younger people joining the housing sector, as highlighted by The Chartered Institute of Housing’s CIH Futures.

This has left many organisations facing a shortage of skilled staff in key areas such as compliance, governance, operations and resident engagement. Even when dedicated teams exist, they are often under-resourced.

One of the biggest problem areas is data. Many organisations still rely on housing or asset management systems that don’t provide a clear picture of their housing stock or their residents. Even where modern systems are in place, there may be a skills or resource gap in using them effectively, as reported in our recent blog.

These data issues can lead directly to failures, particularly under the new Safety and Quality Standard, where the Regulator expects clear, up-to-date information on areas such as damp and mould, fire safety, and property condition. Without this, it becomes difficult to evidence compliance, or to plan effectively. This also restricts the ability of an organisation to plan and deliver their property investment budgets accordingly.

Leadership and management is another area where landlords face structural challenges. Housing services often sit within wider corporate frameworks that dilute focus, create complex reporting lines, or lead to gaps in accountability.

Risk management may be underdeveloped, and boards or committees may lack the specialist housing knowledge required to challenge performance or assure compliance effectively.

Lastly, resident engagement has become a core focus for the Regulator under the new Transparency, Influence and Accountability Standard. Organisations that have under prioritised engagement are at real risk of falling short of expectations, particularly where tenants feel disconnected or unheard. Being able to triangulate across all sources of resident feedback (such as TSMs, Complaints or transactional surveys) is essential to gain a rounded picture of the resident voice.

How ARK Supports Landlords

A. Preventing a failure

We can help you get ahead of issues with a range of services:

Health checks on compliance, governance and financial viability
Mock inspections to prepare for engagement with the Regulator of Social Housing
Improving stock data and asset management strategies
Strengthening resident engagement frameworks
Governance reviews and Board/Member training

It’s vital that social landlords take an honest and proactive approach when issues are likely to lead to non-compliant ratings. We can support you by identifying areas for improvement and work with you to put actions in place.

B. Recovering from an RSH failure

If you have received a non-compliant rating and need to take steps to improve your position, we can help:

Rapid response improvement planning
Delivery of corrective action plans
Provision of interim experts in governance, asset management, compliance, and strategy
Ongoing mentoring and monitoring to regain compliant status

We can provide the skills and the experience needed to address the areas requiring improvement, and put plans and systems in place that will have a long-lasting effect on your performance, improving the quality of your homes and the lives of your residents.

Next steps for social landlords

Acting early is paramount to avoiding or recovering from a failure. Get in touch with us to arrange a briefing, where we will review existing governance, compliance and consumer standards delivery.

For more than 35 years, ARK has worked alongside social landlords to deliver the compliance, systems and standards needed to achieve our shared goal: to provide safe, warm, and decent homes.