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City of London Corporation (202322550)

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REPORT

COMPLAINT 202322550

City of London Corporation

30 April 2025

 

Our approach

The Housing Ombudsman’s approach to investigating and determining complaints is to decide what is fair in all the circumstances of the case. This is set out in the Housing Act 1996 and the Housing Ombudsman Scheme (the Scheme). The Ombudsman considers the evidence and looks to see if there has been any ‘maladministration’, for example whether the landlord has failed to keep to the law, followed proper procedure, followed good practice or behaved in a reasonable and competent manner.

Both the resident and the landlord have submitted information to the Ombudsman and this has been carefully considered. Their accounts of what has happened are summarised below. This report is not an exhaustive description of all the events that have occurred in relation to this case, but an outline of the key issues as a background to the investigation’s findings.

The complaint

  1. The complaint is about the landlord’s response to the resident’s queries and concerns about a major works programme.
  2. The Ombudsman has also considered the landlord’s complaint handling.

Background

  1. The resident and her husband are leaseholders. They rent the property to a private tenant. The property is a 2-bedroom flat in a block that comprises 4 buildings. The block has a listed status for planning purposes. It is near a conservation area. The landlord is a local authority. The resident complained to the landlord on behalf of a group of leaseholders. She has brought an individual complaint to the Ombudsman. During the complaint timeline, the landlord received multiple queries and concerns from other leaseholders in the block.
  2. The resident’s complaint relates to a major works programme that the landlord is undertaking. It includes window replacement and redecoration works to the block. The programme has been hampered by delays and rising costs. The resident is obliged to contribute towards the landlord’s costs through service charges. She has various concerns about its handling of the project. From around March 2023 onwards, she raised these concerns with the landlord frequently. The landlord accepts it did not reply to her corresponding emails.
  3. In June 2023 the resident complained to the landlord. She felt its project manager was responsible for significant delays. She also felt they lacked the required expertise to oversee its major works programme. The landlord issued a stage 1 response later that month. It acknowledged there were issues with its communication. It did not agree that it was responsible for serious failures. The resident escalated her complaint in July 2023. She said the landlord had shown a lack of accountability. She expanded on her initial complaint at this point.
  4. The landlord issued a stage 2 response later that month. It fully upheld the resident’s complaint. It said it would take several actions to address her concerns. It did not provide a clear timescale to complete them. Subsequently, the resident chased the landlord about outstanding actions. She approached the Ombudsman soon afterwards. By 12 October 2023, the landlord had taken steps to address each of the commitments in its stage 2 response. The information it provided prompted the resident to raise new queries and concerns. The parties remained in contact about these subsequently.
  5. In April 2025 the Ombudsman contacted both parties to obtain an update. The landlord told us it had responded to further queries from the resident until July 2024. These comments suggest the landlord believes it did not receive any further queries from her subsequently. In her update to the Ombudsman, the resident said that she felt the landlord was not being open and transparent about its costs for the programme. She also said that, more recently, she had requested information about the landlord’s service charges but it not respond.

Assessment and findings

Scope of investigation

  1. Where a landlord wants to undertake major works to a block, it must usually complete a formal consultation with its leaseholders. This is called the Section 20 (S20) process. It has various stages and is governed by the Landlord and Tenant Act 1985. The First-Tier Tribunal (Property Chamber) has powers to determine S20 matters. It can also establish whether service charges are reasonable or payable. If a landlord does not complete the S20 process correctly, it may be unable to recover a significant portion of its related service charges. If the resident has procedural concerns about the landlord’s S20 process, or the reasonableness of its service charges, these are better suited to the First-Tier Tribunal. We can consider a landlord’s response to concerns of this type.
  2. On 24 July 2023 the landlord responded to the resident’s complaint at stage 2. Around 10 months later (in May 2024), it issued a stage 1 response. This largely addressed multiple concerns which the resident raised from October 2023 onwards. However, it briefly referenced 2 points that were relevant to her previous complaint (which is the subject of this report). In summary, it said it had already addressed one of her points and it would issue more information about the other in due course. There is no indication the resident asked the landlord to escalate her new complaint subsequently. This suggests she was satisfied by its approach at this time. However, her recent update to the Ombudsman suggests her position may have changed since then.
  3. In line with our remit, the Ombudsman may not consider complaints which have not completed a landlord’s internal complaints process. This is because, in general, landlords need to be given a fair opportunity to investigate and respond to any issues prior to our involvement. In this case, there is no evidence to support a related complaint handling failure by the landlord. We have therefore applied our usual approach. Due to the above, any events that occurred after 12 October 2023 are out of scope for this report. If the resident has any more recent concerns, she can bring these to the Ombudsman after they have completed the landlord’s internal complaints process.

The landlord’s response to the resident’s queries and concerns around a major works programme

  1. For context, the landlord obtained planning permission for its major works programme in late 2019. There is evidence it issued some S20 documents to the block’s leaseholders at this point. By January 2022 the project had still not started. This was more than 2 years after planning permission was granted. In July 2022 the landlord received various queries from leaseholders. That month, it drafted a detailed update to address these questions. It accepted that, among other issues, delays had occurred due to its own project management strategy. In November 2022 its appointed contractor arrived on site. The landlord’s planning permission for the project expired soon afterwards. This is concerning.
  2. Later, the resident emailed the landlord’s project manager on 20 March 2023. She referenced a recent letter from the landlord. She said it referred to “discrepancies” in the landlord’s (new) planning application. She suspected these were errors and she wanted the landlord to explain them. She was concerned about further delays and rising costs. She felt the reported discrepancies were avoidable. She said the landlord had shown “incompetence bordering on negligence”. For clarity, the Ombudsman is unable to establish liability or award damages. This means we are unable to determine if the landlord’s actions were negligent. These are matters for the courts to consider. If she wants to pursue them, the resident is encouraged to seek legal advice.
  3. The resident chased the landlord on 30 March and 27 April 2023. She said it had not replied to her email. The landlord may have prevented these chasers if it had acknowledged her initial email. Its acknowledgement could have included a response timescale to manage her expectations. It is reasonable to conclude that chasing the landlord was avoidable and inconvenient for the resident. The landlord’s communication was inadequate. Subsequently, it held an online meeting with the block’s residents on 10 May 2023. This was a reasonable step. Subsequent events indicate that, during the meeting, it promised to cover some costs which had arisen due to delays. It was appropriate for the landlord to address this matter, which had serious implications for its leaseholders.
  4. The resident emailed the landlord around 10 days later. She wanted further clarification about some ongoing issues with the programme. She emphasised that it had not replied to her previous emails. She said that, as a result, she had reviewed her previous questions and rearranged them. This was to ensure that all of her queries were answered. She said this process was time-consuming. She asked the landlord to respond by 31 May 2023. There is no indication the landlord was obliged to do this. However, it should have acknowledged the resident’s email. If it needed more time to respond, it should have promptly told the resident. This would have been a reasonable approach. The landlord did not do this. Subsequent events show this prompted the resident to complain.
  5. The resident complained to the landlord on 7 June 2023. She was unhappy with its project manager’s performance. She said they had not provided regular updates to the block’s leaseholders. She also said they often “ignored” emails. She felt they were responsible for various delays and cost increases. She said they had incorrectly omitted some important works from the landlord’s plan. She also said retrospective amendments were required as a result. She said leaseholders had previously told the manager (in advance) about some of the missing works. Overall, she felt the manager lacked the required “experience or expertise” to supervise the landlord’s major works. Her other key points were:
    1. The landlord’s manager had assured leaseholders that the landlord would improve its communication. The landlord had not fulfilled this commitment.
    2. The manager had promised to complete several actions during the recent meeting. Some of these were still outstanding. They included providing a sample and distributing a frequently asked questions (FAQs) document.
    3. The landlord had promised to cover the cost of some delays. Leaseholders had asked it to provide a detailed written confirmation of the costs it would cover. The landlord had not supplied this.
  6. On 28 June 2023 the landlord issued a stage 1 response. It did not accept that its project team (including the manager) was responsible for any delays. It said it had a number of ongoing projects across several estates. It also said this involved a significant amount of engagement work. However, it felt it could have done more to keep the block’s leaseholders updated and manage expectations. It identified a lack of communication that occurred before works began at the block. It partly upheld the resident’s complaint and apologised for any inconvenience caused. The landlord’s other key points at this stage were:
    1. It had recently arranged “drop-in events” for residents to attend. This would provide a forum for any queries or concerns. The landlord often relied on specialist consultants. It would ask them to participate in its new events.
    2. It had drafted an FAQs document as requested. It would distribute this to the block’s leaseholders within the next 7 days.
    3. Its project manager had almost caught up with a backlog of enquiries. The landlord was working hard to handle an increased volume of emails.
    4. A sample of its specified windows had been made available. Residents could view the sample on site. The landlord acknowledged it had taken longer than expected to arrange this facility.
  7. The landlord felt it was only responsible for communication failures. While it rightly acknowledged these, the evidence also points to wider problems. As mentioned, it had previously accepted that delays had occurred due to its project management strategy. Prior to its stage 1 response, it had referred to discrepancies in its plans. It is reasonable to conclude the landlord was ultimately responsible for these plans. It did not refer to this matter in its response. It lacked a reasonable degree of openness and/or thoroughness. Its approach may have undermined the parties’ relationship. The evidence shows the landlord may have missed an opportunity to resolve the resident’s concerns at this point. It later accepted that it was responsible for some wider failures.
  8. The resident asked the landlord to escalate her complaint on 6 July 2023. This was 7 days after it had issued its stage 1 response. She said it had shown a lack of accountability. She also said its response was inadequate and there were inaccuracies in it. She arranged her complaint into several key topics. These related to the landlord’s communication, delays to the major works programme, a lack of technical knowledge on the landlord’s part, and cost concerns. She reiterated her request for a detailed summary of the costs which the landlord had agreed to cover. The resident’s other key points were:
    1. The block’s leaseholders had emailed the landlord around 10 times since May 2023. Its project manager had not responded to these enquiries. This was not consistent with the landlord’s promise to improve its communication.
    2. There were other communication problems. The landlord’s FAQs document was still outstanding around 8 weeks after it had promised to provide this. Similarly, it had not arranged any drop-in events as stated in its response.
    3. In October 2022 the landlord had issued an information sheet to leaseholders. This contained various commitments around its communications. It had referenced weekly reports, meetings, newsletters, and regular updates about the programme. The landlord had not implemented these measures.
    4. If the landlord was struggling to manage its workload, then it should address this issue. Its delayed communications were impacting leaseholders. For example, the resident believed it had already ordered the replacement windows. However, it had not given leaseholders enough time to view the sample.
    5. The landlord had not supplied any evidence to show the delays were not its fault. The resident noted it had agreed to cover the cost of some delays. She felt this confirmed it was responsible for them. In any case, “numerous errors” had occurred during the programme and this was unacceptable.
    6. In relation to delays and the landlord’s technical understanding, there had been a problem with its proposed ventilation system. The landlord had recently told leaseholders that the system it specified did not comply with current building regulations, and it needed to be redesigned. There were logistical challenges around the type of ventilation system that was required.
    7. The landlord should take a number of actions to address her complaint. It should reconsider her original complaint, solve the logistical problems around the redesigned ventilation system, and provide detailed information about the landlord’s costs to date.
  9. On 21 July 2023 the landlord met with the resident and another leaseholder. It was represented by its senior project leader. Its related correspondence shows they had been assigned the resident’s stage 2 complaint. It shows the leader asked for a meeting because they wanted to discuss the resident’s concerns in detail. It was a positive step for the landlord to arrange this meeting. It was also positive that its senior leader attended. This shows the landlord was suitably mindful of its leaseholders’ concerns. Overall, it demonstrated good practice at this point.
  10. On 24 July 2023 the landlord issued a stage 2 response. It agreed with the resident’s concerns about its project manager. It also agreed with the actions she had asked it to complete in her escalation request. It said it should have managed its major works programme “more effectively”. It also said the resident’s complaint had highlighted issues with its strategic planning and resourcing operations. It said its project manager was in “a challenging situation” (the wording of its response indicates the landlord believed that it had put them there). The landlord upheld each aspect of the resident’s complaint. However, it did not apologise to the resident or award any compensation. Its main points at stage 2 were:
    1. Its manager had not replied to numerous emails recently. It was evident that its communications had not improved.
    2. The resident was right about the communication measures that were detailed in its October 2022 information sheet. Although it had issued an FAQs document on 13 July 2023, its communication was still inadequate (in comparison). It would implement several measures to address this.
    3. It would arrange an online meeting for the block’s residents within 2 weeks. Its design consultant and contractor would attend. In the meeting, it would explain key project milestones, and technical solutions to issues such as the ventilation system. It would record the event for those who could not attend.
    4. It would arrange additional meetings if needed. It would also provide information about its revised communication strategy at the upcoming meeting. The block’s residents could help to decide the frequency of any further meetings.
    5. Its project team would create and manage a “communications tracker” to monitor enquiries from residents. This would ensure it responded to them promptly. It would also review and update its FAQs document regularly.
    6. It had reviewed its previous explanation about why the project was delayed. Having done so, it felt its previous explanation was vague and lacked “credibility”. It had stressed the impact of the COVID-19 pandemic. However, restrictions had not been in place for some time. The landlord would issue “a more considered” explanation for the delays in due course.
    7. The resident had raised understandable concerns about the cost of the project. The landlord would review its predicted costs and issue an updated statement to each of the block’s leaseholders. It would also supply details of the costs it would absorb.
  11. The landlord’s approach was more consistent with the evidence at this stage. It was also more open and transparent. This was appropriate given the circumstances. Ultimately, the landlord identified its key failures and detailed various steps it would take to address them. The solutions it offered were reasonable. The parties’ subsequent correspondence shows the resident was initially satisfied with its response.
  12. The resident contacted the landlord again in late August 2023. She referred to a more recent meeting. She said the landlord had not adequately prepared for this. She also said all of its agreed actions were still outstanding. She felt leaseholders wanted “clarity and confidence”. She supplied an example of mounting costs. She said scaffolding had been in place at the block for around 9 months. She also said no works had started yet. The landlord replied on the same day. It said it was monitoring her complaint. However, it had notified its complaints team about the outstanding actions. This was a reasonable step.
  13. On 31 August 2023 the resident approached the Ombudsman. She reiterated the concerns in her escalation request. She stressed that the landlord’s agreed actions were outstanding. She did not provide any new information at this point. The parties’ records and correspondence show the following events subsequently occurred between 5 September and 6 October 2023:
    1. The landlord emailed its leaseholders a projected cost for the programme. It subsequently completed an online presentation for them. This fulfilled some of the commitments in its stage 2 response.
    2. On 22 September 2023 the landlord missed an agreed deadline. It was due to provide a breakdown of its costs to leaseholders at this point (it is unclear when the landlord agreed to this deadline).
    3. The landlord subsequently held another online meeting with its leaseholders.
    4. The resident updated the Ombudsman. She said the landlord had supplied some information, but there was a lack of transparency about its costs. She said it would soon invoice its leaseholders for service charges.
    5. The landlord issued a further clarification to the leaseholders. It said it would not charge them for any costs that resulted from delays in obtaining planning permission. It confirmed this included additional costs for scaffolding, and extra time claimed by contractors.
  14. The resident contacted the landlord on 11 October 2023. Her email shows it had recently supplied a spreadsheet to the block’s leaseholders, along with a letter. These contained information about its service charges. The Ombudsman has not seen copies of the communications in question. However, it was positive for the landlord to supply additional information about its charges. The resident said its relevant communications lacked clarity. She felt the landlord had not supplied detailed information about its costs as promised. The resident listed around 38 questions that she wanted the landlord to answer. Many of these were detailed, specific, and technical in nature. The evidence indicates the parties had different expectations about the level of detail that was required.
  15. On 12 October 2023 the resident contacted the landlord again. Her email shows it had supplied a statement which explained why the programme was delayed from its perspective. The parties did not provide a copy of this document. It is noted the resident was unhappy with the rationale it contained. It is also noted the landlord had already upheld her stage 2 complaint. In addition, it had previously said it would cover the costs associated with some key delays. Given the landlord had accepted that it contributed to some delays, it was reasonable for it to cover the costs linked to any errors it had made. There is no indication its statement contained any conflicting information about its approach to these costs.
  16. The evidence shows that, at this point, the landlord had taken steps to address each of the actions it agreed in its stage 2 response. From the evidence provided, these steps were reasonable in the Ombudsman’s opinion. There is no evidence to show it was obliged to do more, or that it did not comply with any specific commitments it had made. However, based on the period between 24 July and 12 October 2023, it took the landlord around 11 weeks to complete the agreed actions. This was not an ideal timeframe. The evidence points to a  procedural issue which relates to the landlord’s complaint handling. We have considered the matter in the relevant section below.
  17. After 12 October 2023, the resident raised more queries and concerns with the landlord. The evidence provided shows the landlord ultimately responded to these. In general, the Ombudsman expects landlords to engage with any queries or concerns. In other words, the parties’ subsequent pattern of contact was broadly consistent with our expectations (though there may have been some delays).
  18. In summary, the resident emailed the landlord at least 4 times between 20 March and 31 May 2023. The landlord did not respond to her communications. This caused avoidable distress and/or inconvenience to the resident. When she subsequently complained, the landlord apologised for this. However, its initial response lacked a reasonable degree of openness and/or thoroughness. It may have compounded the situation. The landlord may have missed an opportunity to resolve her concerns at this point. Later, it identified its key failures at stage 2. It also agreed with the resident’s requested actions. It subsequently took reasonable steps to implement these. It did not offer any additional redress.
  19. The landlord’s relevant compensation policy says it can compensate residents in “exceptional circumstances”. It shows payments are often prompted by a corresponding request from a resident. In this case, the resident did not ask the landlord for compensation during the complaint timeline. However, its policy shows the landlord should also consider the extent of any resulting impacts (such as the amount of inconvenience caused). Given this wording and the level of inconvenience to the resident, it could have reasonably awarded her some compensation. In the Ombudsman’s opinion, its initial apology and the steps it took at stage 2 were not sufficient to rectify the inconvenience that arose from its accumulated failures. We have ordered the landlord to pay the resident a proportionate amount of compensation. Our award reflects the evidence we have seen, the individual case circumstances, the landlord’s compensation procedure, and our own guidance on remedies.
  20. Overall, we find there was service failure by the landlord in respect of this complaint point. This is based on the disparity between the landlord’s overall redress and the impact to the resident. The landlord has avoided a more severe finding because the resident did not ask for compensation, and its approach was largely consistent with the wording in its relevant compensation policy.

The landlord’s complaint handling

  1. The resident complained on 7 June 2023. The landlord issued a stage 1 response on 28 June 2023. This was 15 working days later. Its relevant complaints policy says the landlord should acknowledge complaints within 2 working days at stage 1. From the evidence provided, there is no indication it did this. The policy also says the landlord should issue a stage 1 response within 10 working days. It did not do this. Its handling at stage 1 was not consistent with its policy. The evidence points to a short delay of up to 5 working days. Given its duration, an apology may have been sufficient to address it. However, the landlord did not acknowledge a delay in its response. It should routinely consider its own complaint handling at each complaint stage. This will allow it to address any procedural delays and failures accordingly.
  2. The evidence points to further problems at stage 1. For example, the landlord said it would issue an FAQs document within the next 7 days. The parties’ subsequent correspondence shows it did not do this. Similarly, soon after the response was issued, the resident disputed the landlord’s assertion that it had arranged drop-in sessions. The evidence suggests these issues may have occurred because the landlord did not monitor or follow up its agreed complaint actions adequately. The resident was impacted because she had to raise issues again. Subsequent events show there were similar problems at stage 2.
  3. The resident escalated her complaint on 6 July 2023.The landlord issued her a stage 2 acknowledgement 7 working days later. Its complaints policy does not include a timescale for issuing acknowledgements at stage 2 (although the 2-day timeframe for stage 1 acknowledgements is highlighted).Overall, there is a lack of evidence to support a related delay. Still, it may have benefitted the resident if the landlord had acknowledged her escalated complaint sooner. The landlord potentially missed an opportunity to promptly reassure her that it was acting on her escalation request. Subsequently, it issued a stage 2 response on 24 July 2023. This was 12 working days after the resident’s request. Its policy says the landlord should respond to complaints within 20 working days of an escalation request at stage 2. The landlord adhered to its relevant timescale.
  4. In its response, the landlord promised to take a number of actions to resolve the resident’s complaint. For example, it agreed to supply a breakdown of its costs for the major works programme. However, it did not say when it would supply this information. Similarly, it did not say how it would ensure that its relevant teams completed the actions it had agreed to. The resident began to chase it around 1 month later. She questioned its commitment to some of its agreed actions. It is reasonable to conclude this was avoidable. It is likely that chasing the landlord was distressing and/or inconvenient for her. Ultimately, the landlord could have done more to manage the resident’s expectations. She may not have needed to approach the Ombudsman if it had done this.
  5. The landlord’s policy says, when it offers a remedy, it will set out what it intends to do and the relevant timescales. This is consistent with the applicable version of the Ombudsman’s Complaint Handling Code (‘the Code’). Section 6.5 says a “remedy offer must clearly set out what will happen and by when”. In this case, the landlord’s stage 2 response lacked an appropriate degree of clarity. Subsequently, it took the landlord around 11 weeks to complete its agreed actions. If it was unsure of the relevant timescales, the landlord could have offered to update the resident regularly until these were resolved. This would have been a reasonable and solution-focused approach. The evidence suggests the landlord was monitoring the complaint following its stage 2 response. However, it could have proactively chased its relevant teams. The onus should not have been(by default) on the resident to follow up its actions.
  6. In summary, the landlord did not adhere to its relevant timescale at stage 1. There was a related delay of up to 5 working days. It did not fulfil commitments it made in its stage 1 response. Contrary to the Code, its stage 2 response lacked an appropriate degree of clarity about when the landlord would complete agreed follow-up actions. The resident incurred additional inconvenience as a result of its inadequate monitoring and lack of follow-up. The landlord has not recognised any of these failures or attempted to address them. As a result, we find there was maladministration in respect of its complaint handling. In line with the approach set out in the previous section, we have ordered it to pay the resident a proportionate amount of compensation to put things right.

Determination

  1. In accordance with paragraph 52 of the Housing Ombudsman Scheme there was:
    1. Service failure in respect of the landlord’s response to the resident’s queries and concerns about a major works programme.
    2. Maladministration in respect of the landlord’s complaint handling.

Orders and recommendations

Orders

  1. The Ombudsman orders the landlord to apologise to the resident in writing. The apology must reflect the key failures highlighted in this report. It must also reflect the Ombudsman’s apologies guidance, which is available on our website. The landlord must provide the Ombudsman a copy of its letter within 4 weeks.
  2. The Ombudsman orders the landlord to pay the resident a total of £200 in compensation within 4 weeks. The compensation should be paid directly to the resident and not offset against any arrears. It comprises:
    1. £100 for the distress and inconvenience the resident was caused by the landlord’s response to her queries and concerns about its major works.
    2. £100 for the distress and inconvenience she was caused by its complaint handling.
  3. The Ombudsman orders the landlord to share our report’s key findings with its relevant staff for learning and improvement purposes. It must share a copy of its relevant internal correspondence with the Ombudsman within 4 weeks.

Recommendations

  1. If the resident requests this, the landlord should escalate her second complaint (stage 1 response issued in May 2024). If it does issue a stage 2 response, the landlord should ensure any remedy it offers reflects the extent of the distress and inconvenience caused by its failures.