Duty to monitor
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About our duty to monitor
Our Complaint Handling Code is a statutory requirement which means we have a legal duty to check whether landlords follow it.
We do this through a range of monitoring activities, including:
- checking annual submissions meet the requirements of the Code
- reviewing individual landlord self-assessments and annual complaints performance and service improvement reports (annual report)
- conducting policy reviews
For questions about the annual submission and the Code, email compliance@housing-ombudsman.org.uk.
Annual submissions
Use our annual submissions page to access everything you need to complete the annual submission. From the latest online form to key deadlines so you can stay compliant.
It also brings together guidance, training modules, and support on completing the form and uploading required documents, helping you submit quickly, avoid errors, and clearly demonstrate compliance.
When we receive your annual submission
As part of the annual submission, we review your published self-assessment, annual report, governing body statement, and complaints policy against our minimum requirements for submission.
Minimum requirements
Your annual submission must meet our minimum requirements. Landlords are required to provide links to each of the following published documents, or where a landlord does not have a website, and suitable alternative means of publication are in place, upload copies of each document for review. Here is what we need from you.
Self-assessment
- Complete all evidence or commentary/ explanation columns in full. If you record ‘n/a’ you must provide a comment or explanation.
- The comply Y/N column must be completed for all Code provisions.
- If you state non-compliance anywhere in section 8, give your reason and the date you will meet compliance.
- If you state compliance in section 8, provide your final published documents, not drafts.
Annual report
- The report must cover the landlord’s full previous financial year.
- Explain any missing data during the 12-month period.
- A report is required even if no complaints have been received.
Governing body statement
- Either provide a separate statement or where the statement is included within the annual report this must be clearly identifiable.
- We do not accept minutes of meetings.
- Show evidence the statement is published. If it is included in the annual report, make the section clearly identifiable.
Complaint policy
- The policy must be published (if drafts are provided, this is acknowledged, but a date for publication must be provided, and commentary on the draft will not be given at the point of check – in).
- Group structures must make it clear which landlord the policy relates to.
- If you are part of a group structure or use third party arrangements for handling any housing related complaints this must be clearly detailed in your complaints policy.
Complaint Handling Code expectations
You must have:
- one policy, with only 2 stages that aligns with the Code
- a publicly available complaints policy, self assessment, annual report, and the governing body’s response (or equivalent) in a place residents can easily find
- fully completed and up to date self-assessment, even when compliance is not met (this shows you have scrutinised yourself against the Code)
- a named Member Responsible for Complaints (MRC) on the governing body to provide oversight and assurance
If you cannot meet the minimum requirements
If you do not meet compliance with a provision of the Code in your self-assessment, we would expect the landlord to set out within its commentary the actions it will take and a timeframe to reach compliance.
Each landlord must provide all the required documentation through its annual submission within 6 months of its financial year end. If a landlord is unable to provide its submission on time or experiences difficulties, it must contact the Duty to Monitor team at compliance@housing-ombudsman.org.uk
Landlord policy reviews
Over the next 3 years, we will review every member landlord’s complaint policy. We will let landlords know ahead of their review taking place.
Why are we doing this?
To ensure landlords have met the requirements of the Code based on what residents can reasonably expect to be included in a policy document.
What happens if your policy does not comply?
We will set out our findings and give you recommendations. You will have until your next annual submission to make the changes and ensure your policy is compliant with the Code.
We will set out our findings and give you recommendations. You have until your next annual submission to make the changes and ensure compliance with the Code. However, if we find significant non – compliance, or conflicting information on third party arrangements we will arrange a meeting with the landlord to discuss recommendations and support.
After your next annual submission, we will review your policy again to check that you have adopted the recommendations. If the changes have not been implemented, we will contact the landlord.
Issuing a Complaint Handling Failure Notice
What is a Complaint Handling Failure Notice (CHFN)
Within Duty to Monitor we previously issued landlords with a Complaint Handling Failure Orders (CHFO). This has now changed to Complaint Handling Failure Notices (CHFN). The reason for this change is that a Notice notifies a landlord of non-compliance but, unlike an Order, does not order compliance within a specified timeframe.
Issuing a Complaint Handling Failure Notice (CHFN)
Before issuing a Notice, we will take all reasonable steps to engage and support landlords. If following our intervention, a landlord fails to meet the annual submission requirements either by not submitting or by providing incomplete or incorrect documentation we may issue a Complaint Handling Failure Notice (CHFN).
A Notice may also be issued if a landlord does not engage or implement recommendations made during the policy review process.
All Notices will be shared with the Regulator of Social Housing. We may also refer Notices not resolved through action to the governing body.
Centre for Learning
A range of Code Compliance microlearning modules are available on the Learning Hub to support landlords to understand and meet their requirements.
Annual self-assessment
Get confident with your annual self-assessment.
This module shows you each step so you can complete it clearly and confidently.
Annual submissions
Understand and master your annual submissions with ease.
This quick course breaks down each step. It helps you stay compliant, meet deadlines, and submit confidently.
Annual complaints performance and service improvement report
Create your annual report with confidence. This short microlearning shows you what to include and how to structure it.
It helps you cover the right period, present your complaint data clearly, and explain any service improvements. It also gives examples for common situations, including when you received no complaints, and answers frequent questions.
Governing body’s response
Discover the key requirements of the governing body’s response in just 15 minutes.
This microlearning covers:
- what should be included
- examples
- how to provide a response
- who provides the response
- publishing requirements