Introduction
The Financial Reporting Council (FRC) issued a revised version of Financial Reporting Standard (FRS) 102 which applies to accounting periods commencing on or after 1 January 2026. This will be supported by an updated Housing Statement of Recommended Practice (SORP).
SHR can also require RSLs to adhere to additional accounting and disclosure requirements over and above those required by FRS 102 and the Housing SORP by issuing a Determination of Accounting Requirements (the Determination). In light of the changes in the revised FRS 102, especially lease accounting and revenue recognition, we have taken the decision to review the content of the Determination to ensure that the required disclosures remain appropriate and relevant.
The ability to issue a Determination is set out Section 68(1) of the Housing (Scotland) Act 2010 (the Act). Section 68(3) of the Act specifies that a consultation must be undertaken before making, withdrawing or revising a Determination as well as specifying who must be consulted. Section 68(5) of the Act specifies that the Determination must not relate to a period beginning before it is published. As the effective date for FRS 102 is 1 January 2026, we published the updated Determination in advance of that date to ensure that it applies from the same date.
On 20 October 2025, we issued a consultation on proposed amendments to the Determination and the related guidance notes. The consultation sought to obtain comments on the proposed amendments as well as identifying where any further improvements could be made.
The consultation closed on 14 November 2025. The responses received demonstrated support for the Determination and provided useful suggestions on how it could be improved.
This is our response to the feedback we received.
The Consultation Process
The consultation took place over a 4 week period in October and November 2025. It was sent directly to all Registered Social Landlords (RSLs), the Scottish Federation of Housing Associations, the Glasgow and West of Scotland Forum of Housing Associations, UK Finance, the Regulator of Social Housing, auditors who are active in the sector and a number of other stakeholders. The consultation was also published on the SHR website.
We received 14 consultation responses in total: 12 from organisations and 2 from individuals. Of the organisations, 8 were RSLs. Four organisations did not give consent for their comments to be published, and one individual agreed to publication but asked to remain anonymous.
Where we have permission to publish them, the detailed comments received are available on the SHR website.
Proposals, Consultation Responses, and Resulting Changes
Sections 1–5
We asked respondents whether they agreed with the proposed changes in sections 1–5 of the draft Determination, which updated relevant references and made minor amendments to the layout of the interpretations section.
All respondents supported the changes, so no further amendments were made.
Withdrawal of Guidance Notes / Changes to Sections 6–7
We proposed withdrawing the Preparation of Financial Statements guidance note and the Statement of Internal Financial Controls advisory guidance, and incorporating relevant requirements into sections 6 and 7.
Respondents generally supported reducing the number of documents. Some asked for clarifications to sections 6 and 7, particularly around auditor responsibilities and how requirements apply to group structures.
We reviewed these suggestions and updated both sections to improve clarity.
Sections 8–12
Respondents supported the proposed revisions to certain phrases within these sections, recognising that the changes enhanced clarity. One comment requested that the wording relating to surplus and deficit reporting be updated.
We made an additional small amendment to improve accuracy.
Defined Benefit Pension Schemes
We proposed a new disclosure requirement for defined benefit pension schemes.
Most respondents did not support this, noting potential conflicts with FRS 102 and pension scheme rules.
We therefore removed the proposed requirement entirely.
Notes 1 and 2 (Part 1 of the Schedule)
We sought respondents’ views on whether they agreed that notes 1 and 2 in part 1 of the schedule did not require any amendments to their form or content.
Two comments were received: one on splitting depreciation and impairment lines, and one requesting clarification of what falls under affordable lettings versus other activities.
We retained the split for depreciation and impairment and added clarifying footnotes to note 1.
Note 3 (Part 1 of the Schedule)
We asked respondents whether they agreed with the proposed addition of categories in note 3 of part 1 of the schedule, covering community centre activities, energy distribution/supply, renewable energy generation, other non‑current asset depreciation, and management charges to subsidiary organisations.
Respondents sought additional clarity on the categories, and one suggested changing operating cost categories.
We kept all categories to support better analysis and data collection. We will consider the operating cost categories in a future consultation.
New Mandatory Note 4 – Units Owned
Respondents generally supported adding this new note. Some suggested combining categories and standardising disclosures for units owned but not managed.
We merged the lines for units sold and other units lost, and added a standard table for units owned but not managed.
Key Management Personnel Emoluments
We proposed removing this requirement as it will be covered by the Housing SORP.
Most respondents agreed. One queried whether the disclosure would still be clear.
Since it is included in the SORP, we removed the duplicate requirement.
Sections 4 and 7 (Part 2 of the Schedule)
Respondents were content with the clarifications on pension costs that were proposed in section 4 and the addition of interest payable on lease payments to section 7.
The only change made was correcting paragraph references.
New Disclosures – Contracted‑Out Services & Heat With Rent
There was broad support for both new disclosure requirements. Comments focused on clarifying scope and definitions.
We included both requirements, added clarifications (including for group structures), and refined wording where needed.
Other Changes to Part 2
We received one request for additional guidance.
After consideration, no further amendments were made.
Financial Viability Guidance Note and Withdrawal of Two Guidance Notes
No comments were received.
We will proceed with the proposed updates and withdrawals.
Other Comments
One respondent asked us to consider cyber security readiness across the sector—an issue we recognise as a key risk but cannot address within the Determination. Another respondent requested updates to key term definitions to stay aligned with FRS 102.
We have made the necessary changes.
Actions Undertaken and Future Steps
Having considered all of the responses that were received, we identified a number of specific actions:
- Where amendments to the Determination were identified, we incorporated these into the final version. We published the final version on 19 December 2025.
- We finalised the final version of the Financial Viability of RSLs guidance note and published this on 19 December 2025.
- We removed the two guidance notes, Preparation of Financial Statements and Statement of Financial Control, from our website as their content is now fully incorporated into the Determination.
- We will continue to assess and enhance our online data collection systems to ensure they collect all pertinent data and facilitate the calculations needed to discharge our regulatory responsibilities.
Conclusion
The consultation demonstrated strong support for the Determination while also offering valuable insights into potential improvements. We have reflected these in the final version wherever practicable.
The Determination remains fully consistent with FRS 102 and the Housing SORP, thereby ensuring that the financial statements of RSLs provide users with the information necessary to understand each organisation’s financial position.
We extend our appreciation to all consultation respondents for their constructive input in shaping the revised Determination.