Preparing Annual Assurance Statements : a thematic review - 2025

All social landlords are required to submit to the Scottish Housing Regulator an Annual Assurance Statement (Statement) about their compliance with regulatory requirements. Landlords submitted their most recent Statement to us by the end of October 2024. 

In this thematic review we set out our findings following our recent visits to seven Registered Social Landlords (RSLs) and three local authority landlords to find out more about the self-assurance work they did to enable them to submit their Statement. On the visits we focused particularly on how landlords assured themselves about meeting their tenant and resident safety duties and for RSLs, their approach to monitoring and reporting on compliance with their financial covenants. 

Further information on what we covered during the visits is set out in Appendix One. 

The Statement is a way for RSL governing bodies and local authority committees to assure themselves and their tenants, people who are homeless or threatened with homelessness, Gypsy/Travellers, other service users and us that they comply with regulatory requirements, or to disclose areas where they need to improve. We set out the requirements for the Statements in our guidance on Annual Assurance Statements. 

Landlords have a range of ways through which they assure themselves that they meet regulatory requirements, including their legal obligations on housing and homelessness services, equalities and human rights, and tenant and resident safety. The Statement is the outcome of that self-assurance. We worked with landlord representative bodies to produce a Toolkit to support landlords’ self-assurance. This work was led by the Scottish Federation of Housing Associations (SFHA). 

We consider each landlord’s Statement as part of our annual risk assessment. We then publish the outcomes of this in engagement plans at the end of March each year. For RSLs the engagement plan will include a regulatory status. 

• 155 landlords (98%) submitted their Annual Assurance Statements by the deadline on 31 October. 

• Four landlords (2%) submitted within three weeks of the deadline. 

• 20 landlords (12%) disclosed what they judged to be material non-compliance with regulatory requirements. 

• 21 landlords (13%) disclosed what they judged to be non-material non-compliance with regulatory requirements. 

Landlords continue to engage positively with the Annual Assurance process, and many have told us that it is valuable in providing them with the necessary assurance. 

Local Authorities accounted for all four of the statements which were submitted after the deadline. The common cause cited for late submission related to the scheduling of committee meetings to approve the Statement. It is a regulatory requirement that landlords submit the Statement by 31 October each year and we will consider any necessary engagement following any late submissions. 

We reviewed all Statements as part of our annual risk assessment of all social landlords and reflected the outcome in engagement plans published at the end of March 2025.  

All of the landlords we visited told us they have embedded their processes for completing their statement into their annual cycles as with other regulatory returns, including submission by the deadline, and we observed evidence of an extensive, comprehensive, and robust process being in place for some of the landlords we visited. 

Some landlords acknowledged that whilst the process is resource intensive, this has lessened as landlords have become familiar with the process since the introduction of the Statement in 2019. Landlords continue to tell us that the process provides governing bodies/committees with detailed assurance on their compliance with regulatory requirements. 

The majority of the landlords we visited said that they utilise the SFHA Toolkit and find this a helpful framework for their self-assurance work. Some landlords told us they had developed and implemented their own framework. 

Many of the landlords we visited had appropriate measures in place to ensure the Governing Body is sufficiently assured regarding the organisation’s monitoring and reporting on compliance with their financial covenants. We observed evidence of regular reporting to governing bodies, clearly setting out covenant results compared to targets, both throughout the year and at year end. 

Tenant and resident safety was considered a key priority by all of the landlords we visited. Many landlords described the processes they had in place to assure themselves about their compliance with their tenant and resident safety duties. These included robust recording and reporting mechanisms, dedicated roles to monitor compliance, and seeking independent expert advice.  

In one of the landlords we visited, we identified that they had failed to include areas of material non-compliance, and the plans to address these, within their Statement. This related to failures to comply with tenant and resident safety duties. 

In some of the landlords we visited, we observed a lack of appropriate or up to date evidence being made available to the Governing Body/committee for consideration during the self-assurance process.  

The level of Governing Body/committee involvement in the self-assurance process also varied. In some cases, their sole involvement was reviewing a high-level report at a meeting in which the Statement was also approved. Landlords should be active in ensuring that they implement a Governing Body/committee led approach.  

A number of landlords that we visited also reported to us that they do not currently incorporate any tenant and service user feedback about the services that they deliver and the quality of their homes into their self-assurance processes.  

The regularity in which landlords reported on their covenant compliance varied across the landlords we visited. Whilst some reported regularly throughout the year, including forecasts to ensure effective monitoring by the Governing Body, others opted for annual reporting. 

Castle Rock Edinvar Housing Association (Places for People Scotland) provides Board members with additional support and advice from officers regarding risk management and any potential implications of decisions taken around treasury management, including future borrowing requirements and covenants. Treasury arrangements, including covenants, are also subject to regular review within the group’s business assurance programme. 

Clydesdale Housing Association commissioned an independent consultant to provide specific training to staff on the Statement process. The training highlighted that the Statement is the annual output from the association’s ongoing self-assurance process as well as allowing staff to understanding how they, in their individual roles, and the Governing Body can contribute effectively to the process. 

East Dunbartonshire Council developed a "Smartsheet” model which was designed to record and monitor compliance more effectively and support the implementation of a new Integrated Housing Management System. The Smartsheet is a live document, which allows the Council to monitor and update on areas of compliance throughout the year as opposed to on an annual basis. This has helped support effective performance against the Charter outcomes and allows for potential compliance issues to be identified and addressed promptly.  

Fife Housing Association engaged its tenants in its assurance work by facilitating tenant led inspections of void properties against Fife’s property letting standards. The process allowed the tenants to identify potential works they would recommend to the association, including addressing potential tenant and resident safety issues.   

Fife also incorporate revised year-end projections in their quarterly management accounts to clearly present the overall financial position and demonstrate compliance with covenants, ensuring it is evident that all covenant requirements will be met at year-end. 

Forgewood Housing Co-Operative utilises the Statement process to continually identify areas for development and improvement, promoting an ongoing learning culture within the organisation. Building on the organisation’s existing focus on tenant engagement, whereby they have sought views from tenants on the Statement, Forgewood plans to establish a tenant working group, specifically to provide input on their annual assurance process. 

Hanover (Scotland) Housing Association undertakes an organisation wide involvement in the Statement process ensuring, where applicable, that it is integrated into the roles and remits of staff. The process is viewed as a live task that is ongoing as opposed to an annual exercise. Hanover also conducted a survey of Governing Body members to ensure that they felt actively involved in, and were directing, the process to allow for sufficient oversight and informed approval of the Statement.  

Hanover also incorporate revised year-end projections in their quarterly management accounts to clearly present the overall financial position and demonstrate compliance with covenants, ensuring it is evident that all covenant requirements will be met at year-end. 

Linstone Housing Association delivers workshops for the Governing Body on different aspects of the Statement process. This provides Governing Body members with the opportunity to review specific areas and seek additional evidence and assurance where required. This is supported by relevant staff members who will also attend and answer any queries directly. Linstone reported this process has been of particular use for newer Governing Body members who may be unfamiliar with the process. 

Partick Housing Association includes a dedicated background documents section at the conclusion of each Board report which links all policies, procedures, events and training relevant to the matter being presented. This forms part of the organisation’s “strategic agenda footprint” approach, whereby planned areas of focus over a period of years are outlined in advance, providing a structured outlook for the ongoing programme of assurance.  

Scottish Borders Council, as a stock transfer authority, has established quarterly meetings with each of its RSL partners to discuss accommodation standards, compliance and any tenant and resident safety issues for properties used for temporary accommodation by the Council. This open and transparent relationship also includes the council having shared access to RSL partners online portals which hold relevant tenant and resident safety compliance information, including relevant certificates. 

South Ayrshire Council actively involve tenants in its self-assurance process via its discussions and tenant engagement meetings with its Tenants Monitoring Group, which take place on a quarterly basis. Out with these meetings, during the year, there is one session specifically relating to the Statement process and a second session in relation to performance in the Annual Return on the Charter (ARC). This allows tenants to provide valuable feedback and insight into the council’s performance and approach. Elected members are also invited to the sessions, with the portfolio holder for housing being present at all sessions. 

• Where landlords identify areas of material non-compliance, these should be disclosed in the Statement. Landlords should also set out in the Statement what action(s) they are taking to address the non-compliance within an appropriate timeframe. 

• Landlords should consider how they get tenants and other service users views on the organisations’ performance as part of their assurance framework and governing bodies and local authority committees should take account of this feedback when assuring itself against regulatory requirements, for example, whether the organisation is achieving Charter outcomes. Landlords can get advice on getting tenant and service user feedback in our advisory guidance ‘Conducting Reviews of Compliance with the Regulatory Standards of Governance and Financial Management’. 

• Landlords should consider the frequency and level of information being providing to its Governing Body/committee regarding tenant and resident safety, to provide it with sufficient assurance about compliance with requirements. For example, ensuring reports are regular enough to give assurance about compliance throughout the year, and cover all of the organisation’s tenant and resident safety duties. 

• The Governing Body/committee should ensure it leads and has ownership of the self-assurance process. Landlords can get advice on Governing Body/committee involvement in the self-assurance process in the SFHA Toolkit and in our advisory guidance ‘Conducting Reviews of Compliance with the Regulatory Standards of Governance and Financial Management’.  

• Whilst the majority of landlords submitted their Statements by the deadline, landlords, and in particular Local Authorities, should ensure their processes and Governing Body/committee meeting cycle allow for the Statement to be considered and submitted on time. 

• RSLs should consider how financial information is presented to governing bodies to ensure it is clear, accessible, timely, and supports effective scrutiny and challenge. RSLs should also consider the frequency with which they report on covenant compliance and whether the Governing Body is satisfied it is able to have effective oversight in this area.

The landlords we visited 

To help ensure a good mix, the landlords we visited are located across Scotland, and of different sizes, structures, and level of complexity. We also selected the landlords to reflect the different types of Statement that were submitted. 

Who we visited 

•    Castle Rock Edinvar Housing Association (Places for People Scotland) 
•    Clydesdale Housing Association 
•    East Dunbartonshire Council 
•    Fife Housing Association 
•    Forgewood Housing Co-operative 
•    Hanover (Scotland) Housing Association 
•    Linstone Housing Association 
•    Partick Housing Association 
•    Scottish Borders Council 
•    South Ayrshire Council