Complaint Handling Code 2024 FAQs

Landlords are expected to use the definition of a complaint set out in the Code in its complaints policy (and any other relevant policies and/or procedures). This is as follows: 

‘An expression of dissatisfaction, however made, about the standard of service, actions, or lack of action by the landlord, its own staff, or those acting on its behalf, affecting a resident or group of residents’. 

Where a landlord may receive complaints from other groups of service users or individuals that are not residents, the landlord can add a further explanation in its policy to confirm that the definition and complaints policy will apply to all. This way, the landlord can use the same complaints policy rather than having separate policies. The landlord can also provide this explanation in its self-assessment. 

It is reasonable for landlords to have an opportunity to respond to a service request for issues reported for the first time. Where a landlord decides to respond to a report from a resident by raising a service request, the resident should be informed of the decision and the next steps. 

Residents that express dissatisfaction with the landlords’ approach to resolving the substantive issue, or the outcome, must be given the opportunity to make a complaint. The complaint should be raised at stage 1 of the complaint’s procedure. 

The landlord should continue its efforts to resolve the service request even if a complaint has been made. A landlord should not wait for the outcome of the complaint investigation to progress the service request. 

Informal complaint stages are not permitted in landlord complaints policies. 

It is reasonable for landlords to have an opportunity to respond to a service request for issues reported for the first time. If the resident is clear that they wish to raise a complaint, it would not be reasonable for the landlord to refuse this. 

Landlords should have a separate policy for handling reports of anti-social behaviour (ASB). Reports of instances of ASB experienced by a resident should not be recorded as a complaint but rather dealt with in line with a landlord’s ASB policy. 

However, if a resident expresses dissatisfaction with the landlord’s handling of their reports of ASB or the handling of their ASB case, the landlord should raise a complaint and carry out a review of its handling of the ASB case as part of its complaint investigation

A service request is a first request from a resident to the landlord requiring action to be taken to put something right. 

If a resident specifically asks that a complaint is not logged landlords should record the decision and reason(s) to ensure a clear audit trail which should include: 

• acknowledging the resident does not wish to raise a formal complaint. 

• providing details of how the resident can raise a complaint if they change their mind and the timeframe for this. 

• contact details for the Housing Ombudsman's if the resident wishes to seek further advice. 

Landlords may wish to use this opportunity to understand why a resident does not want a complaint and ensure that it is addressing any actual or perceived barriers to the process. 

Landlords must ensure that efforts to resolve a resident’s concerns do not obstruct access to the complaints procedure at any point or result in any unreasonable delay. 

For clarity landlords are expected to use the definition of a service request set out in the Code in its complaints policy (and any other relevant policies and/or procedures).  

Provision 1.4 states:  

 'A service request is a request from a resident to the landlord requiring action to be taken to put something right.'  

 Where a landlord may receive service requests from other groups of service users or individuals that are not residents, the landlord is permitted to add a further explanation in its policy to confirm that the definition and complaints policy will apply to all. This way, the landlord can use the same complaints policy rather than having separate policies. 

The Ombudsman is not prescriptive on how landlords should record, monitor and review service requests. The way in which it records this information and how regularly it reviews it will be led by the individual landlord. Landlords may find it helpful to review our Spotlight light report on Knowledge and Information Management (KIM)

Provision 1.5 of the Code states: 

A complaint must be raised when the resident expresses dissatisfaction with the response to their service request, even if the handling of the service request remains ongoing. Landlords must not stop their efforts to address the service request if the resident complains. 

No. A complaint regarding a failed service request or dissatisfaction with the handling of a service request is not the same as a service request in itself. 

The complaint should be logged at stage 1 and handled in accordance with the landlord’s stage 1 process. 

This is because it is the first time it has been notified of the resident’s dissatisfaction with the handling of the service request and should have the opportunity to address the complaint as it would any other. 

We understand that not every resident will present their complaint in the same way, and it may not always be obvious whether something is intended as a complaint. 

Landlords should ensure staff have received sufficient training to equip them with the skills to identify complaints, even where it may not be explicitly stated. Examples of this may include: 

• “You have sent someone out three times to fix the communal door intercom, but it is still not working, and it is impacting on my deliveries.” 

• “The lift is still broken, and I have been unable to get out of the flat for several days as I am in a wheelchair.” 

• “You have done nothing about the anti-social behaviour I have been reporting to you over the last year. I do not think you’re taking the case seriously.” 

A landlord should also have clear definitions of both complaints and service requests detailed within their complaints policy to reduce ambiguity. 

If it remains unclear whether an expression of dissatisfaction is intended as a complaint, the landlord should be proactive in clarifying this with the resident. 

It is especially important that staff can identify where a resident may be vulnerable and has difficulty articulating their complaint or accessing and following the landlord’s complaints procedure. Landlords should ensure there are appropriate procedures in place to support vulnerable residents through the complaints process. 

Within provision 4.3 it states:  

‘All relevant staff must be suitably trained in the importance of complaint handling.’  

We would also recommend that customer service and customer vulnerability training is refreshed regularly. 

If a landlord specifies in its complaints policy that it does accept complaints through its social media channels, then these should be logged and responded to in line with the landlord’s complaint process. 

Where it is not specified in a landlord’s complaint policy that it accepts complaints made via social media channels any negative comments or messages on social media do not need to be tracked or logged as complaints. However, the landlord should signpost these to its complaints process. 

Landlords should outline how it will handle complaints raised by third parties/ representatives in its complaints policy. Landlords should ensure this meets the requirements of relevant legislation. 

Landlords should handle Members Enquiries (from MPs or Councillors) in the same way it would handle contact made by a resident. Often, Members Enquiries start as enquiries and lead to service requests being raised. 

It is reasonable for landlords to have an opportunity to respond to Members Enquiries as service requests for issues reported for the first time. Where a landlord decides to respond in this way, the Member should be informed of the decision and the next steps. 

Members or residents that express dissatisfaction with the landlords’ approach to resolving the substantive issue, or the outcome, must be given the opportunity to make a complaint. The complaint should be raised at stage 1 of the complaint’s procedure. 

The landlord should continue its efforts to resolve the service request even if a complaint has been made. A landlord should not wait for the outcome of the complaint investigation to progress the service request. 

Where landlords receive Members Enquiries on behalf of a resident and its records show previous repeat contact from that resident about the same issue, the landlord should contact the resident to explore the reasons they remain dissatisfied and ask if they would like the matter investigated as a complaint. The landlord can still respond to the Members Enquiry to explain the action it has taken. 

Landlords should outline how it will handle complaints raised by third parties/ representatives in its complaints policy. Landlords should ensure this meets the requirements of relevant legislation.

Landlords should handle Members Enquiries (from MPs or Councillors) in the same way it would handle contact made by a resident. Often, Members Enquiries start as enquiries and lead to service requests being raised.

It is reasonable for landlords to have an opportunity to respond to Members Enquiries as service requests for issues reported for the first time. Where a landlord decides to respond in this way, the Member should be informed of the decision and the next steps.

Members or residents that express dissatisfaction with the landlords’ approach to resolving the substantive issue, or the outcome, must be given the opportunity to make a complaint. The complaint should be raised at stage 1 of the complaints procedure.

The landlord should continue its efforts to resolve the service request even if a complaint has been made. A landlord should not wait for the outcome of the complaint investigation to progress the service request.

Where landlords receive Members Enquiries and its file shows previous repeat contact from a resident about the same issue, this indicates the resident is still dissatisfied with the handling or outcome of the issue/concern and that they have had to escalate the matter to try and get it resolved. In this scenario, the landlord should contact the resident to explore the reasons they remain dissatisfied and ask if they would like the matter investigated as a complaint. The landlord can still respond to the Members Enquiry to explain the action it has taken.

Landlords are responsible for determining where a complaint may be excluded, and these reasons must be clearly set out in its complaints policy. The landlord must satisfy itself that it has acted fairly and reasonably. 

As set out in provision 2.2 of the Code acceptable exclusions may include: 

• the issue giving rise to the complaint occurred over 12 months ago 

• legal proceedings have started. This is defined as details of the claim, such as the Claim Form and Particulars of Claim, having been filed at court 

• matters that have previously been considered under the complaints policy 

It is not appropriate to take a blanket approach to excluding complaints from individuals with challenging behaviour. 

The landlord’s complaint policy should set out how a landlord will handle these complaints. The landlord should also have a managed behaviour policy, or similar, supporting this. We will expect this policy to be made available on the landlord’s website if they have one. 

A landlord must not confuse a resident requiring reasonable adjustments with unacceptable behaviour.  

Provision 5.15 states: 

‘Any restrictions placed on contact due to unacceptable behaviour must be proportionate and demonstrate regard for the provisions of the Equality Act 2010’. 

Landlords must be able to evidence reasons for putting any restrictions in place and must keep restrictions under regular review. 

If a landlord decides not to accept a complaint based on unacceptable behaviour or puts restrictions in place, via the application of its managed behaviour policy, an explanation must be provided to the resident setting out the reasons why and the right to take that decision to the Ombudsman.  

Provision 2.4 states: 

‘If a landlord decides not to accept a complaint, an explanation must be provided to the resident setting out the reasons why the matter is not suitable for the complaints process and the right to take that decision to the Ombudsman. If the Ombudsman does not agree that the exclusion has been fairly applied, the Ombudsman may tell the landlord to take on the complaint.’ 

The landlord should also clearly set out any exclusion categories within its complaint policy. 

The landlord must ensure it keeps a record of complaints it refuses to accept and should include a summary of the volumes and types of complaints that it has refused to accept in its annual complaint’s performance and service improvement report. 

Where a landlord has decided to exclude elements of the complaint, this should be clearly communicated to the resident within the complaint acknowledgement.  

In its acknowledgement the landlord must provide a clear explanation of why these elements are not suitable for the complaints process, referencing the specific exclusion in its policy that applies. The landlord must also provide a clear complaint definition for the elements of the complaint it has accepted.  

The resident must also be advised of their right to approach the Ombudsman regarding the excluded elements of their complaint. 

All complaints raised to the landlord must be logged as complaints. 

Whether a matter falls outside of the Ombudsman’s jurisdiction is for the Ombudsman to determine and should not have any bearing on the landlord’s internal complaint process. 

It is not appropriate for the landlord to exclude complaints on this basis. 

For further information on our working partnership with the Local Government and Social Care Ombudsman. Please see the link below: 

Memorandum of Understanding with the LGSCO 

Yes. Landlords are expected to provide different pathways for residents to raise a complaint. These could include, but are not limited to, face to face meetings, telephone contact, the landlord's website or via a representative. 

The landlord should consider how to improve accessibility of to its complaint procedure when deciding which pathways to offer. The landlord's complaint policy must set out how it will publicise details of the policy, including information about the Ombudsman Scheme and this Code. 

Residents should be able to raise their complaint in any way and with any member of staff.  All staff should therefore be aware of the complaints process and be appropriately trained and equipped to pass details of the complaint to the appropriate person or team. 

Landlords should regularly review the accessibility of its complaint procedure to ensure barriers preventing access are identified and remedied. 

Landlords should ensure that complaint pathways are clear and accessible for residents. For example, if the landlord states that it accepts complaints via telephone, the telephone number should be clearly publicised in a variety of locations, this may include, but not limited to, the complaints policy; regular email or postal communications; in a clear and easy to find location on the website or on residential notice boards. 

A landlord may wish to seek resident engagement when reviewing the accessibility of its complaint’s procedure. 

Whilst the Ombudsman is not prescriptive regarding the channels through which residents are able to make a complaint. A landlord must consider its duties under the Equality Act 2010 and anticipate the needs and reasonable adjustments of residents who may need to access the complaints process. 

A landlord may wish to seek resident engagement when reviewing the accessibility of its complaint’s procedure. 

The Code makes it clear in provision 3.1 that: 

‘Landlords must make it easy for residents to complain by providing different channels through which they can make a complaint. A landlord must consider its duties under the Equality Act 2010 and anticipate the needs and reasonable adjustments of residents who may need to access the complaints process’ 

Landlords should ensure that relevant staff receive suitable training on vulnerable residents and reasonable adjustments to enable them to adequately support the needs and requirements of residents during the complaint process. 

Landlords should follow relevant legislation when considering accepting representatives on behalf of residents. Landlords should ensure that accurate records are kept of the residents agreed representative and these are regularly reviewed and updated when required.  

Landlords are expected to provide residents with the opportunity to nominate a representative to deal with their complaint on their behalf should they wish to do so. The landlord's complaint policy should clearly set out how it will handle requests for representatives and how they are able to access the landlord's complaint process. 

The Ombudsman recognises that there may be some landlords who do not have a website. In these circumstances, landlords must provide alternative ways in which its complaint policy and procedure is publicized and made available to residents. For example, the landlord could share this information by leaflets, tenant welcome packs, posters, newsletters and in a public area that is easily accessible. 

Where a landlord has published its complaints policy and procedure on its website it should ensure the information is available in a clear and accessible format.  A landlord's website should not require residents to sign-in or create an online account before they are able to raise a complaint. 

Residents have a right to come to us at any stage of the complaint process therefore landlords should publicise how residents are able to contact the Ombudsman Service. This information should be easily accessible and should be communicated in a variety of ways. This could include via its website, leaflets, posters, newsletters and correspondence relevant to their complaint.  

Landlords are expected to include details of the Ombudsman in their complaints policy.  

Landlords can refer to our Telling residents about our service - Housing Ombudsman helpful resources for more information about how this can be done effectively.  

The Ombudsman recognises that landlords will need to put in place structures and arrangements for complaint handling that will best suit its organisation. However, the landlord, no matter of size, is required to have a dedicated ‘complaints officer’ but this role may be in addition to other duties. 

The ‘complaints officer’ should also be responsible for reporting to the governing body (or equivalent) and be a point of contact when liaising with the Housing Ombudsman. 

Provision 4.2 states: 

‘The complaints officer must have access to staff at all levels to facilitate the prompt resolution of complaints. They must also have the authority and autonomy to act to resolve disputes promptly and fairly.’ 

Where a resolution or remedy will require further approval, the landlord must have a process in place to enable prompt internal approval to achieve a complaint response within the timeframes set out in the Code for responding to a complaint. 

Provision 4.2 states: 

‘The complaints officer must have access to staff at all levels to facilitate the prompt resolution of complaints. They must also have the authority and autonomy to act to resolve disputes promptly and fairly.’ 

This should also extend to external contractors or third parties where necessary. 

The landlord is expected to suitably resource complaint handling. While an increase in complaints may be seen in the short term, the landlord will start to notice the benefit of having increased oversight of service provision through complaints. Prioritising complaint handling and providing a robust complaint service will support the landlord by providing insight on recurring issues, highlight the strengths and weaknesses within the landlords' services and opportunities for the landlord to review and make improvements.  

When residents start to see the improvements, landlords have been able to make by having oversight of its complaint handling, this may then reflect in a reduction of complaints.  

Landlords should provide suitable guidance and training to all staff that will be involved with complaint handling and not just its ‘complaint officer’. This will ensure that staff understand what is required within their role when dealing with complaints. This may include how to recognise and pass on a complaint to the appropriate person within the landlord, how to log complaints, the timescales involved and what a resident can expect in during the process. Information about a landlord’s complaints procedure should be available in several ways and this should include via its staff. 

Training should be refreshed on a regular basis but sooner if there are significant changes to the structure of the organisation or there are changes to the landlord's complaint policy. Landlords can find a range of tools, documentation and learning including good practice examples, e-learning, microlearning, webinars, videos, toolkits and podcasts at our Centre for Learning.  

Provision 5.1 of the Code states: 

‘Landlords must have a single policy in place for dealing with complaints covered by this Code. Residents must not be treated differently if they complain’. 

Landlords must deal with complaints consistently, regardless of the tenure of the resident (i.e. whether they are a tenant, leaseholder, shared owner, etc.). and should therefore not operate separate complaints policies or procedures for different users. 

Landlords must ensure that there is one policy in place for complaints that is compliant with the Code. Landlords are not permitted to have extra named stages (such as ‘stage 0’ or ‘informal complaint’) as this causes unnecessary confusion and a barrier in accessing the complaints procedure. 

Landlords have the opportunity to resolve service requests (that meet the criteria set out in Section 1 of the Code) within its usual processes, prior to the issue becoming a complaint. 

A process with more than 2 stages is not permitted when dealing with complaints covered by this Code.  

Provision 5.3 of the Code sets out that: 

‘A process with more than two stages is not acceptable under any circumstances as this will make the complaint process unduly long and delay access to the Ombudsman’. 

Where a landlord’s complaint response is handled by a third party (such as a contractor) at any stage, it must form part of the two stage complaints process set out in the Code. Landlords are responsible for ensuring that any third parties handle complaints in line with the Code. 

Residents must not be expected to go through two complaints processes. 

If any aspect of the complaint is unclear, the resident must be asked for clarification. It is important that the landlord considers it duties under the Equality Act 2010 and anticipate the needs and reasonable adjustments of residents who may need to access the complaints process.  

If the landlord has been unable to ascertain a full understanding of the complaint at the point it is received, it should set out to the resident in its complaint acknowledgement its current understanding of the complaint and the outcomes the resident is seeking. This will give the resident a further opportunity to contact the landlord to clarify the complaint. If the resident does not, the landlord should continue with the investigation based on the information and complaint definition it has. 

The Code is clear that landlords must have policies and procedures in place for managing unacceptable behaviour from residents and/or their representatives. The Code requires landlords to be able to evidence reasons for any restrictions put in place and that these are kept under review. 

Landlords must also ensure that any restrictions placed on contact are proportionate and consider the provisions of the Equality Act 2010. They should also be communicated to the resident. 

Landlords can refer to the Ombudsman’s Managed behaviour policy for examples of action that we will take and how this is managed.  

The Code refers to ‘working days’ and not calendar days. 

A landlord should acknowledge a complaint at stage 1 within 5 working days of it being received as set out in provision 6.2 of the Code. 

A landlord should acknowledge a complaint made at stage 2 within 5 working days of the complaint escalation being received as set out in provision 6.11 of the Code. 

The 5 working days should commence from the date the resident raises the complaint, with the next working day being ‘day one’. Delays in the landlord forwarding a complaint to the correct person/department or delays logging the complaint on its system should not have an impact on the date the acknowledgement is provided to the resident. 

How often a landlord needs to update a resident will depend on the nature of the complaint, how long it anticipates the outstanding actions to remain and how often the resident feels they need updating. The landlord is expected to agree this with the resident. 

No. A landlord should escalate a complaint to stage 2 if a resident remains dissatisfied with the outcome at stage 1. If the landlord has reason to exclude the complaint at stage 2, this must be in line with its complaints procedure and a letter should be sent to the resident confirming its reasons for this and signposting the resident to the Housing Ombudsman. 

The Code does not stipulate a timeframe for residents to escalate their complaint. 

If the landlord wishes to implement a time limit, it must ensure that: 

• this is clearly detailed its complaints policy. 

• this is clearly stated in the landlord’s stage 1 response letter. 

• any time limit for a resident to escalate should be fair, reasonable and proportionate - this should also allow for residents who may adopt a ‘wait and see’ approach to see whether the actions proposed in the stage 1 response resolve the complaint. 

• it must consider whether to apply discretion to accept complaints made outside this time limit where there are good reasons to do so - this may include but is not limited to; extenuating circumstances, vulnerable residents, and making reasonable adjustments to maximise accessibility and efficiency of the complaint handling process. 

Landlords must operate a 2 stage complaints process for handling complaints covered by this Code. A landlord is not permitted to have any informal complaint stages, additional stages beyond stage 2 or any less than 2 stages. 

To make the complaints process clear to residents, landlords should refer to the two stages as stage 1 and stage 2. 

From the date the acknowledgment is provided to the resident, landlords are expected to provide a written response at stage 1 within 10 working days and a written response at stage 2 within 20 working days. Please see provisions 6.3 and 6.14 of the Code.   

If landlords identify that more time is required to investigate and respond to complaints at stage 1 or 2 provisions 6.4 & 6.15 of the Code allow this. At stage 1 the extension should be no more than a further 10 working days and at stage 2 the extension should be no more than a further 20 working days.   

Landlords should not use an extension greater than the additional timeframes set out in the Code without good reason.  The reasons for extending the timescale must be clearly explained to the resident. Additionally, the landlord must agree suitable intervals for keeping the resident informed about their complaint.  

We would encourage landlords to provide an update to residents where an extension is required at the earliest opportunity, rather than waiting until the response is due. 

No, a landlord is not required to complete all outstanding actions offered in resolution to the complaint before providing its complaint response.  

A complaint response must be provided to the resident when the answer to the complaint is known, not when the outstanding actions required to address the issue are completed. Outstanding actions must still be tracked and actioned promptly with appropriate updates provided to the resident.   

As an example, if the resident’s complaint is in relation to outstanding repairs, the landlord is not expected to complete all the repairs within the complaint response timeframe. Instead, an action plan should be provided in the response setting out when the repairs are due to be completed. 

A resident can request to escalate all or parts of their stage 1 complaint. The resident does not have to be dissatisfied with all stage 1 issues to have their complaint reviewed at stage 2.  

For example, should the complaint include outstanding repairs to the roof and to the boiler, but the resident is dissatisfied with the outcome of the roof repair, the complaint issue surrounding the roof repair should be escalated to stage 2.  

Effective communication is key in establishing which parts of the complaint the resident remains dissatisfied with. Landlords should use the stage 2 acknowledgement to set out which parts of the complaint will be considered.  

Provision 6.12 of the Code sets out that: 

‘Residents must not be required to explain their reasons for requesting a stage 2 consideration. Landlords are expected to make reasonable efforts to understand why a resident remains unhappy as part of its stage 2 response’. 

If a resident does not set out their reasons for dissatisfaction with the response at stage 1, or the desired outcome is unclear, landlords should make reasonable efforts to understand this. If the landlord has been unable to communicate with the resident it can set out its understanding as part of the stage 2 complaint acknowledgement. This provides the resident with a further opportunity to contact the landlord to clarify the complaint. If no further information is provided the stage 2 response should be a review of the initial stage 1 investigation. 

The Code does not require the person investigating stage 2 complaints to be of a specific level or job role. 

However, as the investigation of a complaint at stage 2 involves a review of that at stage 1, landlords should consider whether the person has the appropriate authority to do this. In addition, the person considering the complaint at stage 2 must not be the same person that considered the complaint at stage 1. 

Landlords should ensure that the focus of its complaint handling remains on resolving issues and providing remedies where things have gone wrong.  This could include: 

• apologising 
• acknowledging where things have gone wrong. 
• providing an explanation, assistance or reasons 
• taking action if there has been delay. 
• reconsidering or changing a decision 
• amending a record or adding a correction or addendum 
• providing a financial remedy 
• changing policies, procedures or practices 

When considering an appropriate remedy, as far as possible, the landlord should aim to return the resident to the position they would be in had the service failure not occurred and additionally, account for the fact it did occur. For example, where a complaint is about a reoccurring leak the landlord could consider the following: 

• carrying out the required repair work 
• any other potential remedial works/damages 
• length of time the situation has been ongoing. 
• number of service failures 
• severity of any service failure or omission 
• impact on the resident 
• particular circumstances or vulnerabilities 
• any wider learning 

Landlords should take account of guidance issued by the Ombudsman when deciding on appropriate remedies. Any compensation awarded by the landlord should align with its published compensation policy. 

Landlords can find further information in our Guidance on remedies | Housing Ombudsman 

It may benefit the landlord if the case remained open on the landlord's system as this would provide oversight and enable the landlord to track outstanding actions. The monitoring should not affect the timescales for providing the complaint response as this would occur after response was issued to the resident. 

Yes. Where the outstanding issues involve undertaking work which may take weeks or months to complete, the landlord should inform the resident of the intended timescale for these works. Outstanding actions must still be tracked and actioned promptly with appropriate updates provided to the resident.

Landlords with over 1,000 homes need to submit information to the Ombudsman by 30 September each year. Submissions for landlords with under 1,000 homes will be 6 months after the financial year-end.  

Landlords will receive notification from the Ombudsman confirming its submission date and this information will also be available on our website and via our newsletter. Landlords can sign up for our newsletter here: Housing Ombudsman Service 

As part of its submission the landlord must provide the following: 

• its Complaints policy. 
• a completed self-assessment. 
• an annual complaints performance and service improvement report. 

 A response from its governing body (or equivalent) to demonstrate that they have scrutinised the contents of the report and the self-assessment and are satisfied that the report is an accurate reflection of the landlord’s complaint handling service position. 

The date by which voluntary members must make their annual submission, and provide relevant documents are the same as mandatory members. Therefore, the timescales are as follows: 

• landlords with 1,000 homes or more are required to submit by 30 September each year. 
• landlords with less than 1,000 properties are required to submit 6 months after its year-end. 

Find our self-assessment guidance and annual submissions guidance below: 

Self-assessment guidance - Housing Ombudsman (housing-ombudsman.org.uk) 

Guidance on Annual Submissions | Housing Ombudsman Service (housing-ombudsman.org.uk) 

Where a landlord is not satisfied that it complies with the Code, it must provide a detailed explanation for non-compliance in its self-assessment and the date by which it intends to comply. 

In circumstances where a landlord is unable to cannot meet a specific requirement of Code, the Ombudsman will take a proportionate approach. An example of this could be a small landlord who does not have a website but gives a detailed explanation of how it will provide the information to its residents in an alternative way such as notice boards and newsletters.  

More details about completing the self-assessment are covered in our published guidance. 

We will make all reasonable efforts to engage with landlords to ensure that the submission is provided. We will consider any requests for extensions, where these are made before the submission’s deadline. 

We may issue a Complaint Handling Failure Notice if a landlord fails to provide the submission, and they refuse to engage with us to comply with the obligations set out in the Scheme. 

Landlords experiencing exceptional circumstances, for example a cyber-attack, should inform the Housing Ombudsman if it results in it being unable to comply with the Code. They should do this as soon as possible, by emailing compliance@housing-ombudsman.org.uk. 

Landlords must provide information about the services affected, any changes to contact information and the impact on complaint handling processes.  The landlord will need to set out where compliance with the Code is not being met, any procedures it has put in place to mitigate this and provide an expected date for when it intends to become compliant. 

Additionally, the landlord must make residents aware as soon as possible and publish this on its website. The landlord should highlight key information such as interim contact methods, web complaint forms, web forms to log repairs, ASB reporting tools and any revised timeframes for response. 

We expect all landlords to have published their annual complaint handling and service improvement report, which includes the self-assessment and governance statement at the point a submission is provided. It is for this reason that the timescale for submission was extended to 6 months after year ends. 

If this is not possible, the landlord must still complete their submission and provide their reasons in Section 8 of the Code. They must also set out when the required documents will be published. 

Landlords can refer to our wider guidance on the self-assessment and annual submission using the links below. 

Self-assessment guidance - Housing Ombudsman (housing-ombudsman.org.uk) 

Guidance on Annual Submissions | Housing Ombudsman Service (housing-ombudsman.org.uk) 

Find our self-assessment guidance and annual submissions guidance below: 

Self-assessment guidance - Housing Ombudsman (housing-ombudsman.org.uk) 

Guidance on Annual Submissions | Housing Ombudsman Service (housing-ombudsman.org.uk) 

Add in reference to the online training available through the Centre for Learning? 

The governing body is responsible for scrutiny and oversight of the annual report and self-assessment. They should be supported by the Member Responsible for Complaints to assure that the information included is complete and accurate. 

We appreciate that our membership is diverse and that this may look slightly different for each organisation type.  

Our expectation is that the governing body response would be provided by the Board / Chair / CEO or equivalent.   

As a minimum, the governing body is expected to scrutinise: 

• the annual complaint handling and service improvement report 

• the self-assessment 

The governance statement must confirm that these have been assured as complete, accurate and a true reflection of the landlord’s complaint handling service. Governing bodies should use the statement as an opportunity to set out how they have scrutinised these documents.  

Please note, copies of minuted meetings are not sufficient as a governance statement. Whilst they provide clear confirmation that approval has been given, landlords are expected to provide a statement that gives more detail about what has been considered, and how this has informed the decision made in any formal meetings. 

 There is further information about the governing body’s response in our self-assessment guidance. 

We have a suite of guidance and tools for governing bodies and MRCs available on our website:  

Member Responsible for Complaints (MRC) | Housing Ombudsman 

For further information, guidance and FAQ’s please visit Member Responsible for Complaints (MRC) | Housing Ombudsman (housing-ombudsman.org.uk) 

The following information must be expected to be included in the report:  

• the annual self-assessment against the Code to ensure their complaint handling policy remains in line with its requirements. 
• an analysis of the landlord’s complaint handling performance – volumes of complaints, categories of complaints, number and summaries of complaints the landlord has refused to accept, how many complaints handled at within the timescales at each stage,  
• Any service improvements made in the previous financial year, particularly where the learning has come from complaints. 
• any findings of non-compliance with the Code by the Ombudsman. This will only be relevant to landlords that have had a case determined by the Ombudsman. 
• any annual reports produced by the Ombudsman about the landlord’s performance. This will only be relevant where the Ombudsman has made findings on five or more cases in a 12-month period.  
• any actions following any other relevant reports or publications produced by the Ombudsman in relation to the work of the landlord, e.g. KIM report, damp and mould report, etc. 

Landlords will be expected to report on its complaint performance from the previous financial year in the annual complaints’ performance and service improvement report.

For example: 

• a large landlord submitting on the 30 September 2025, the complaints report must cover it's financial year April 2024 to March 2025
• a small landlord with a financial year end of 31 December 2025 must provide its annual submission no later than 30 June 2026 (6 months after its year-end) and the complaints report must cover the period 1 January 2025 – 31 December 2025

Yes. You are required to share the most recent landlord performance report from the Ombudsman as published on the website, which may be for the year prior to the year that the landlord is creating a report for. 

On the surface, high volumes of complaints must not be seen as a negative as they can be indicative of a well-publicised and accessible complaints process. Low complaint volumes may be a sign that individuals are unable to complain. 

Being open and transparent about complaints should be seen as a positive way for a landlord to promote learning and understanding, review lessons learned and to make any improvements to service provision. 

Landlords are now required to publish Tenant Satisfaction Measures (TSM’s); these will include information on complaint handling and therefore this information will already be available to residents. 

Publishing complaint information can also be used to promote any positive feedback that has emerged from complaint handling. 

The purpose of publishing the governing body’s response is: 

• to demonstrate the landlord has reviewed the self-assessment and annual report. 
• to provide assurance that the self-assessment and annual report are a true reflection of the landlord’s complaint handling practice. 

The self-assessment forms part of the annual report. Some landlords may choose to present this as an appendix to the report, and some as a standalone document. In all cases, the governing body should address both documents.  

The response should set out how the governing body has scrutinised and challenged the report and the self-assessment and how any risks identified as part of the review have been addressed. 

The response can also highlight lessons learnt, areas of achievement and any challenges that the landlord has faced during the reporting year. Landlords are encouraged to take an open and transparent approach to demonstrate accountability to their residents and other stakeholders. Landlords can refer to the Ombudsman’s Guidance for Governing Bodies for more information about effective involvement and assurance.  

In terms of formatting, the landlord may include the governing body response as a foreword to the report, or as a stand-alone document.  

This should come from the Board/Chairperson/CEO or equivalent.  

We would expect that this includes: 

• any Complaint Handling Failure Orders the Housing Ombudsman has issued against the landlord. 
• any findings of maladministration made by the Housing Ombudsman in our determinations, including both about the substantive issue and complaint handling

If these are not applicable, landlords are still expected to confirm this in the report. This is to support landlords to demonstrate openness and transparency to residents as well as full compliance with the Code. 

The Code sets out what must be included in the annual complaint handling and service improvement report. The Ombudsman has not issued a template for landlords, and it is up to individual landlords to decide how to ensure all the points are covered in the report. This allows landlords to set out important information that meets the expectations and needs of residents.  

We would encourage landlords who may require further assistance with this to reach out to any appropriate trade body or contact us individually at compliance@housing-ombudsman.org.uk if you are not a member of a trade body. 

This is aligned with the Regulator, who has published definitions of the TSMs, and landlords should refer to the Regulator’s guidance for definitions of key metrics. 

For other key data reporting we would encourage the landlord to apply the same time periods. 

From April 2024, landlords were expected to be recording this information and presenting it within its reports. We recognise that some were not recording this information prior to April 2024, which meant that it was not possible to include within its annual report covering the period 2023-2024.  

If a landlord did not record the complaints it refused to accept in 23/24, the landlord should explain this and the changes it has made so that this is incorporated into the data captured for 24/25. 

From the 2024-2025 submission onwards, this information should always be included.  

Provision 8.2 of Code sets out that: 

‘The annual complaints performance and service improvement report must be reported to the landlord’s governing body (or equivalent) and published on the on the section of its website relating to complaints. The governing body’s response to the report must be published alongside this’. 

While the Code only sets out a requirement to publish the current year’s annual report and governing body response landlords are encouraged to provide documents from previous years. This supports landlords to demonstrate openness and transparency about previous service provision and/or performance. 

When landlords publish historic information about complaint handling, they should ensure that this is clearly dated and that residents are able to easily access the most recent reports. 

Landlords who have completed a merger, acquisition or amalgamation are required to provide an updated self-assessment within 6 months (previously 3 months) of the final change of arrangements. 

The Ombudsman maintains membership records that reflect the Regulator of Social Housing’s Statistical Data Return (SDR). For definitions relating to the SDR, landlords should refer to the technical notes and definitions published on the Regulator’s website. 

Technical notes and definitions  

For the purposes of this guidance, a ‘fully merged’ landlord refers to organisations that have transferred all stock into one landlord.  

A parent and subsidiary refer to organisations that have a group structure and have individual subsidiaries that are independently registered with the Regulator of Social Housing. 

This will depend on whether the members of the group are ‘fully merged’ or operating a group structure.  

Landlords should refer to Appendix Two of our self-assessment’s guidance for more details on what is required for submission where a group structure is in place following a merger. 

Where a new organisation has been set up through a merger, the annual submission will be required within 6 months of the financial year end. 

The Code is not prescriptive about how merged landlords must present data relating to performance within the annual complaint handling and service improvement report. 

Landlord should use the annual complaint handling and service improvement report to set out to performance before, during and after the merger. By doing so, landlords can demonstrate transparency to residents about how the merger has been handled. 

Landlords must carry out a self-assessment following a significant restructure or merger. On completion of the formal merger, the landlord will be required to submit its new self-assessment within 6 months using the link below. 

Annual submission key documentation form 

Landlords are not required to provide an updated complaint handling and service improvement report or updated governance statement. However, landlords are encouraged to do so, if this will build trust with residents. 

No. A landlord should select ‘annual submission’, even where it may be a resubmission.  

We would ask a landlord to use ‘On request by the Ombudsman’ where it may have been asked to do so following a determination of a case, a special investigation or part of a wider order. 

Where a landlord has put in place arrangements for complaints to be handled at either (or both) stages of the complaints process by a managing agent, it must set this out in its complaint policy and ensure that they have suitable contract management arrangements in place to ensure that complaints are handled and reported in line with the Code. This should be detailed in the self-assessment. Residents must not be expected to go through two complaints processes.

For reporting purposes, the landlord is responsible for providing an annual complaint handling and service improvement report that details the complaints made by tenants, regardless of the managing arrangements in place. The contract arrangements should therefore include provision of data about complaint handling. We would expect landlords with managing agents in place to be routinely reviewing performance of complaint handling for its tenants as part of the contract management. 

As the landlord is the member of our Scheme, it is responsible for ensuring that it is compliant with the Code and that the annual submission is completed by the deadline.  

Depending on its contractual arrangements with the managing agents, the agents may complete this on the landlord’s behalf, however, the landlord must satisfy itself that the policy, self-assessment and information in the annual report is Code compliant and accurate, and it is the landlord’s governing body which must provide the response to this – this element cannot be delegated. 

You can use the same email address / username for all of the submissions. The submission form asks you to provide the name of the landlord you are completing the submission for and how many units it has, so this will enable us to allocate the submission to the correct landlord regardless of the same username on the submission. 

No, each landlord must complete its own submission to us. Therefore, the landlord must complete one submission reflecting its own properties, and then whether it completes further submission/s for any landlord properties it manages will depend on the contractual arrangement. 

We would encourage landlords to keep the data and learning in the annual report limited to properties it owns as that is the information each governing body must scrutinise and respond to. It also makes it clear for residents. If the landlord decides to produce one report for both, then the data for each must be clearly disaggregated, and the governing body response must come from the respective landlord – not the managing agent. 

If a landlord operates one policy across all subsidiaries, then one self-assessment can be accepted provided that it is published and clearly states which subsidiaries it applies do. Further guidance can be found on our website: Self-assessment guidance.

If there is more than one policy in place, then each should have its own self-assessment. In this case, the landlord would be expected to publish the relevant policy and self-assessment on the website.

For the annual report, landlords with more than one policy are expected to provide separate annual complaint handling and service improvement reports, clearly stating which subsidiary it relates to.

In this instance, the landlord can provide one governing body statement, but it must be clear that the individual self-assessments have been assured.

Landlords can review our self-assessment guidance for more information on group structures.

Further guidance can be found on our website: Self-assessment guidance.

The Housing Ombudsman has been supporting The Almshouse Association & the Confederation of Co-operative Housing; in helping them provide additional support and guidance to their members.  Both organisations have designated pages on their websites for members that can provide this information.  

Links to external websites: 

Member area | CCH Confederation of Co-operative Housing 

Members login | The Almshouse Association 

The Ombudsman Service has also reached out to Abbeyfield England to provide additional support and guidance for their members. If you are an Abbeyfield, please contact Abbeyfield England directly  

Abbeyfield User Login Screen 

You can also email this Service at complaince@housing-ombudsman.gov.uk or visit our website Landlords | Housing Ombudsman Service and Centre for Learning | Housing Ombudsman Service