31 Mar 2026
CIH response to the Housing Ombudsman Service Business Plan 2026-27 consultation
We welcome the opportunity to respond to the Housing Ombudsman Service’s (HOS) consultation on its proposed business plan for 2026-27. Many of our members work in organisations that deliver social housing and are registered with the Regulator of Social Housing, making them mandatory members of the HOS scheme. They will therefore be affected by the proposals, whether directly by involvement with complaints services, or indirectly by the overall impact the HOS has on its operations and practices.
Summary
CIH supports a robust and independent Ombudsman for the sector and recognises that the role of the Housing Ombudsman Service (HOS) has led to the generation of good practice (through its judgements, sector-wide Spotlight reports and other support). It has enabled many tenants to raise issues where these are unresolved or poorly addressed by landlords, providing some rebalance of power and opportunity for resolution.
CIH is concerned at the level of increase to fees proposed in the business plan and the timing of implementation. It is doubtful that any landlords will have factored such an increase into its business planning process, meaning this will be a direct loss from investment in existing/new homes. There should be a mandatory timeframe for such consultations, to allow landlords to plan appropriately.
We acknowledge that the HOS will have a new role and process to cover complaints in relation to Social Tenants Access to Information Requirements (STAIRs) and we have called for the HOS to adequately resource this. This process will not apply to council and ALMO landlords and so should not be factored into their costs. The level of increase proposed is significant (32 per cent) and raises questions about value for money for both landlords and residents, especially given the length of time taken to investigate and respond to complaints.
This has a detrimental impact for social housing residents, and for landlords which have frequently made changes in the meantime that are not always acknowledged in published judgements. The rapid and significant increase in complaints referred to the HOS – estimated in the business plan at 500 percent for 2025-26 compared to five years ago – demonstrates the challenges remaining for the sector. It also indicates a greater focus is required from the HOS on monitoring compliance with the Code, proactive engagement with landlords to improve complaints services, and encouragement/support for resolution prior to any referral to HOS (building on valuable guidance on compensation and apologies). This needs to go alongside the proposals to further drive down both costs and length of time for investigations, and mechanisms to identify and address those of most serious concern.
Answers to individual questions
CIH broadly supports the priorities set out. Given the level of fee increases proposed, (on what the HOS acknowledges are estimates that can be affected by minor changes in factors) the timing is inappropriate. In the future, there must be a longer lead in time for discussion with the sector. We urge the HOS to work with the sector to develop an approach that targets additional resources and support (and costs) for those landlords that dominate the HOS’s open caseload.
CIH broadly supports the approach to reduce volume and age of cases. However, it will still mean that 50 per cent of cases will take over six months for determination, which is a significant delay for tenants who will have already gone through the landlord complaint process. So, further steps need to be considered to drive quicker resolution times, and a speedier process overall. For example, HOS should explore how it might combine cases, applying judgments and lessons across similar complaints against individual landlords (as proposed in relation to STAIRs); take a stronger approach where there are vexatious complaints; and work with landlords to streamline the process for information requirements and questions (both in terms of requests and formats of responses). These would provide opportunities to make the process easier and support quicker responses and judgements.
The business plan references the use of AI to support a more effective and swift investigative process. It is important that the HOS is clear on how and when AI will be used (for administration and ordering material for example), and that there is reassurance for residents and landlords that the final review and decisions will be done by expert investigators, so any unintended biases are designed out of the system.
Landlords report the increased generation of complaints using AI which is increasing their own workload. Many are also exploring how best to utilise AI effectively across complaints and other services. This is an evolving area, and HOS could play a valuable role in supporting a sector-wide approach to using this effectively within a person-centred complaints service.
The consultation highlights that 30 per cent of open caseloads are generated by 10 landlords. Given the additional costs and fees being proposed by the HOS, it should work with the sector to agree a way to provide additional support to these landlords at additional costs (on top of the flat rate fee per home) so that proportionate costs are borne by landlords requiring the greatest focus and resources from the HOS.
HOS could also share information with the Regulator of Social Housing (RSH), to explore if it requires use of its own powers to require/develop improvement plans and additional support to address repeated failings.
Given the impact of changes to the HOS’ service and fees on landlords’ business plans, there should be a mandatory consultation period of at least three months for any substantive changes, in line with best practice for government consultations. This would enable greater involvement in shaping the service, how it operates, and the tools and support it can provide for the sector, to improve the experience for residents and landlords alike, particularly in terms of what additional support and costs can be targeted where most needed.
For more information on our response, please contact Sarah Davis, policy manager at CIH, at sarah.davis@cih.org
