16 Mar 2026
CIH responds to the HOS' consultation on its role in complaints about STAIRs
We welcome the opportunity to respond to the consultation on the role of the Housing Ombudsman Service (HOS) in complaints about the Social Tenant Access to Information Requests (STAIRs), and the proposed changes to its scheme through the additional Section 2B.
Summary
Overall, CIH welcomes and agrees with the proposed changes to the HOS scheme and the way forward to manage STAIRS complaints. Our main concerns or points for consideration are:
- A clear, shared, and consistent communication strategy is needed to explain the difference between this scheme and the wider complaints framework. Guidance and/or explanatory notes would be helpful on how the HOS expects to use some of the flexibilities allowed in the proposed scheme, i.e. how and when it might bundle complaints together, when it might look at cases outside time limits, etc.
- We have concerns over the capacity within the HOS to respond to complaints and manage responses in appropriate time scales.
- We would like to see monitoring to inform further changes and improvements to the scheme as well as guidance and/or explanatory notes, once the system has been in place (for example, after 12 to 18 months).
Fair
We agree that the proposed changes make it clear that someone who is or was a tenant or shared owner at the time of the complaint can refer concerns to the HOS, following a review from their landlord.
It is also clear that a representative can refer the complaint on behalf of a tenant. The government’s policy statement requires the tenant to identify their representative to the landlord. It would be helpful if the scheme, any guidance and/or explanatory material underlined that and set out when and how the HOS will ensure that this also applies when complaints are referred to them by an appropriate representative.
Moderately helpful
The scheme, in paragraph 76, allows the HOS flexibility in respect of cases it might consider or not (in addition to the question of time frames). In time, it would be valuable for tenants, representatives and landlords to understand what factors the HOS considers when deciding to investigate or not, through guidance and/or explanatory notes.
In terms of flexibility in approaching complaints, we agree that the proposed changes to the scheme give the HOS flexibility to address multiple complaints together where the facts and landlord are the same (with care being taken in respect of tenants’ confidential details).
Both landlords and tenants would benefit from some examples of when this might happen. The flexibility seems reasonable considering concerns about capacity, but it should be reviewed to ensure satisfaction with the process.
Moderately clear
STAIRS is a different process from the wider complaints handling framework. Effectively, it is a one stage process, where complaints can be referred following a review by the landlord.
Potentially, confusion may occur for both tenants and landlords as to the main differences between this process and the existing framework under the complaints handling code. This includes the different time limit, and the ability to refer after a landlord’s review. There is a strong case for developing clear, shared messages and communication strategies across the HOS, landlords and sector bodies, to ensure that there is a clear and consistent language and route map for tenants.
No
Overall, we agree that the planned approach can provide fair outcomes, and we agree with the flexibility to address the issues raised with a range of appropriate responses.
However, given that this is a different process to the general complaints framework, it would be helpful for the HOS to issue guidance as to when different remedies might be applied, and how these differ from the complaints scheme – for example, around compensation – so that both landlords and tenants might know what is reasonable to expect. This should also be part of the review of the process.
About right
The HOS will accept complaints usually within a three-month period after a landlord has responded to and completed a review requested by a tenant or representative. This seems reasonable. We think it is useful that there is sufficient flexibility in how the time limits are framed, and that the HOS could investigate a complaint outside that limit, if deemed appropriate.
It would be useful for the HOS to explain how and when it anticipates using these flexibilities. This could be expanded or revisited during a review of the new process – for example, with information about how many, if any, complaints are considered outside the time limits and why.
We appreciate, given the different circumstances that each complaint may raise, that there is no time limit set for the HOS to investigate. However, we note the concerns that landlords have expressed as to the length of time taken to address complaints under the complaints handling code.
With this being an additional and different process, it is vital that the HOS ensures that sufficient resources are dedicated to undertaking STAIRs complaints, and that there is adequate monitoring of timings, to shape any future amendments to the process. This would also be valuable to inform tenants and landlords what they might expect.
For further information, contact Sarah Davis, CIH policy manager at sarah.davis@cih.org
