The government’s new proposals for supported housing regulation could make some homelessness services unviable

Riverside wholeheartedly supports the move to introduce national quality standards for supported housing, because we have seen the benefits of high-quality regulation before.

Within the past two decades, supported housing in England was well-funded and benefitted from a national quality framework that delivered consistent standards across the country. The Supporting People programme proved government investment in long-term, ringfenced funding, underpinned by national quality standards (the Quality Assessment Framework), delivered transformational outcomes for homelessness services.

The impact of Supporting People was remarkable: the number of homeless households living in temporary accommodation in England more than halved in less than five years.

“While we very much support the purpose of the Supported Housing (Regulatory Oversight) Act, safeguarding residents from abuse and unsafe practice, some proposals give us significant cause for concern”

While we very much support the purpose of the Supported Housing (Regulatory Oversight) Act, safeguarding residents from abuse and unsafe practice, some proposals contained in the government’s live consultation give us significant cause for concern.

One such area relates to the question of who holds the licence, and therefore the liability for the quality of support, in cases where the landlord and the support provider are two different organisations.

These changes mean that, in addition to looking after the building and monitoring compliance with the management agreement, we also need to monitor the quality of support provided and then work with the provider to improve areas of concern.

“Making us, the landlord, become the licensee and be responsible for the quality of the service providers’ support, creates a number of significant additional challenges”

Supported housing landlords would become, in essence, quasi-regulators of the providers that deliver support from their properties. This would come with significant unintended consequences.

Riverside would be required to hire additional staff with the correct skills to monitor the quality of support being delivered by third-party organisations, to mitigate the risk to us of providers failing to meet the licensing conditions.

This would also place additional costs and burden on landlords to introduce systems to monitor provider complaints, safeguarding alerts and customer and staff incidents, which will be a duplication of the support provider’s own processes and that of the commissioner. This comes at a time where the registered provider sector is already facing significant financial pressure.

The Regulator of Social Housing’s Global Accounts 2024 show the sector’s surplus has reduced from £3.6bn in 2018 to £2.7bn in 2020, and to £1.6bn in 2024. Total spending on major repairs has increased from £5.7bn to £8.8bn in five years, and this is before the impact of the increase in employer National Insurance contributions, which for Riverside equates to an additional £1.2m in 2025-26, and the impact of Awaab’s Law and the updated Decent Homes Standard.

Any additional cost has the potential to make the model unviable.

From the provider’s point of view, they would have triple accountability – the commissioner, the licensing authority and us – increasing their administrative burden and costs.

Riverside alone has more than 2,400 units of supported accommodation across 398 properties which would be affected by these new regulations.

Riverside has continued to be a direct deliverer of care and support, but many large registered providers exited direct delivery some time ago on the basis that it was too expensive, too risky and too complicated.

Any future licensing regime that introduces additional cost, risk and complexity could have the unintended consequence of registered providers deciding that continuing to allow third-party providers to use their properties could also be too expensive, too risky and too complicated, resulting in properties being withdrawn from the supported housing market.

In London, 41% of single homeless provision, and in Greater Manchester 43% of supported housing, are delivered via management agreements. Any significant withdrawal of registered providers from the managed agent market would significantly reduce the available supported housing, resulting in increases in unmet need.

The Supported Housing Regulatory Oversight Act can be, and needs to be, a force for good in safeguarding vulnerable people. But adding additional cost, risk and complexity to registered providers which currently allow third-party agencies to deliver support from their properties could cause significant harm to the very people we all want to protect.

Section 3.11 of the consultation states: “The Act defines a licensee as the person ‘having control of or managing’ supported housing”, whereas Section 3.12 states: “The person in control of or managing supported housing will usually be the person who receives rent for the supported housing”.

Under managed agent agreements, we believe that the agent has greater control of the management of the property, as defined in the management agreement. As such, it is our view that where a management agreement exists, it should be possible for the managing agent to act as the licensee. As well as having greater control, this will prevent duplication of expensive quality assurance structures and avoid registered providers exiting the managed agents sector.

However, this does not mitigate the risks to the directly managed sector. As such, it is our recommendation that consideration should be given to dual licensing, where landlords are licensed for housing standards and support providers for support standards.

Lee Buss-Blair, director of operations, Riverside care and support