Ewan Fraser Blog: Systemically Important Forum – 2 June 2026
We held one of our regular meetings with the Systemically Important (SI) landlord group on 2 June 2026. We refer to a small number of Registered Social Landlords (RSLs) as Systemically Important because of their stock size, turnover or level of debt, or because of their significance within their area of operation.
Ewan Fraser, our Deputy Chair, led a wide ranging discussion reflecting events since the Group last met in October 2025. This included the recent parliamentary election and new Scottish Government, the passage of the Housing Bill into an Act, the outcome of the spending review, and the continued challenges of the national housing emergency.
We were joined by colleagues from the Scottish Government to discuss early priorities following the election, the Housing Act, and plans for the proposed new housing agency.
Scottish Government officials highlighted that it is still early in the new administration but noted that housing now sits within the Social Justice portfolio, reflecting a stronger alignment with child poverty priorities and wider public sector reform.
Officials highlighted this would lead to some change and the need for flexibility and outlined a phased approach to priorities, focusing initially on early 100 day commitments, followed by delivery of the Housing Act and then longer‑term strategic priorities over the next five years. The proposed new housing agency remains a key part of this approach, intended to support delivery across tenures and operate with greater agility, although its precise scope is still being developed.
The Group raised a wide range of strategic and operational issues. On development costs and benchmarking, several Group members highlighted increasing cost pressures, particularly in relation to benchmarking guidance. Concerns were raised about regional variations in costs and the difficulty of delivering developments within benchmarks, with many projects exceeding them. The Group expressed concern about the lack of clarity on timescales and requirements for net zero standards, which continued to make it challenging for landlords to plan investment decisions and assess viability. There was also discussion around the need to plan for an ageing population, both in terms of housing, and in terms of funding to promote and support independent living.
The Group discussed the status of the new agency and whether it would allow a more flexible, risk‑based approach to delivery. Group members also highlighted tensions between increasing delivery, maintaining quality, and meeting rising standards, particularly given escalating costs of retrofit and net zero compliance. Some Group members pointed to mismatches between supply and demand in certain areas, the challenges in re‑using existing stock, and barriers created by local authority policies.
Questions were raised about the increased emphasis on home ownership and its potential implications for Housing to 2040 and addressing the housing emergency. Members also sought clarity on what “value for money” means in practice and highlighted wider funding pressures, including competing demands across public services.
Scottish Government officials reaffirmed the £4.9 billion multi‑year settlement for the Affordable Housing Supply Programme, providing greater financial certainty than in previous years, while acknowledging that pressures and uncertainties remain. On benchmarking and development viability, officials indicated a willingness to maintain an open dialogue and to continue to show flexibility where needed, recognising geographical differences and cost pressures.
The Group acknowledged the uncertainty around net zero standards and timelines for this. The Group also acknowledged the trade‑offs between standards, cost and delivery, noting that choices may be required and that the Government is keen to work with the sector to identify solutions.
We presented the key outcomes from our annual risk assessment and our analysis of RSL audited financial statements. As in previous discussions, financial pressures across the sector remain a key focus, alongside wider risks and uncertainties.
We also outlined our current work, including an internal review of our operating model. This work is considering how we can continue to deliver effective regulation with the resources available to us.
Members raised a number of related points. The Group was interested in whether further analysis could be undertaken on financial capacity across different parts of the sector, including smaller organisations. Questions were asked about whether approaches used in other jurisdictions, such as charging for regulation, might be considered. Members also expressed a desire to engage early in discussions about any changes to SHR’s operating model. We emphasised that all options are being considered at this stage and that ongoing engagement with the sector will be an important part of this work.
There was support from members for continuing direct engagement with Scottish Government alongside SHR at future Forum meetings. Members also suggested topics for future discussions, including emerging UK policy issues, new technologies, and tenant and resident safety.
The Forum recognised the significant challenges facing the sector but valued the opportunity for open, constructive dialogue. We will continue to use these discussions to inform our understanding of the risks and pressures facing Systemically Important RSLs.
We are due to meet again later this year.