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Internal Audit - 25-05 - Housing Regulator Submission

Perth and Kinross Council · 23 March 2026
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Internal Audit Report
Housing & Communities
25-05 Housing Regulator Submission
March 2026
Final Report
(Report No. 26/71)
Legal and Governance
Perth & Kinross Council
Council Offices
2 High Street
Perth
PH1 5PH

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25-05 Housing Regulator Submission
Contents by Section
1. Introduction
2. Audit Background Information
3. Scope and Limitations
4. Assessment of the Control Environment
5. Summary of Findings
6. Conclusions
7. Acknowledgement
8. Action Implementation & Follow Up
9. Management Action Plan
10. Authorisation
11. Distribution
12. Assessment Definitions

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1. Introduction
1.1 The audit of the Housing Regulator Submission was undertaken as part of the
Internal Audit Plan for 2025/26, which was approved by the Audit and Risk
Committee on 25 June 2025. The period under review for the purposes of the
audit exercise was the financial year 2024-25. 
1.2 The indicative scope for the audit was to review arrangements for the
compilation of the annual submissions to the Housing Regulator.
1.3 The audit is not directly linked to any particular risk on the Strategic Risk
Register, however, forms the basis for external assurance provider, which
may be relied on by Internal Audit as part of planning, in accordance with the
Global Internal Audit Standards in the UK Public Sector.
2. Executive Summary 
2.1 The audit has found that Substantial Assurance can be placed on the
Council’s internal controls in relation to the review for the compilation of the
annual submissions to the Housing Regulator by the Council, with no
improvement actions arising from the Internal Audit (Objectives 1 and 2
below). Areas of good practice have been highlighted within Section 5 of this
report.
2.2 Whilst reviewing the arrangements for the compilation of the annual
submission, Internal Audit reviewed in detail the content of the Submission
(Objective 3 below). We found that the Service were aware of these and were
taking actions to address the issues, where possible. These findings are
captured in Section 6 and an action plan in Section 10 includes the actions
which are on-going to address the issues raised. As a result of this part of the
audit, there are ten actions arising. These actions are designed to enhance
performance as reported in the Submission.
3. Audit Background Information
3.1 The Scottish Housing Regulator (SHR) was established on 01 April 2011 in
accordance with the Housing (Scotland) Act 2010. Its objective is to protect
and promote the interests of tenants and other service users of Local
Authorities and Registered Social Landlords (RSLs).
3.2 The Regulatory Framework states that each landlord is responsible for
delivering good outcomes and services for its tenants and service users.
Landlords need to be self-aware, analytical, open and honest about their
performance, and identify and drive improvement.
3.3 Section 2.4 of the Regulatory Framework requires landlords to prepare and
publish an Annual Assurance Statement. This statement serves to confirm to
both tenants and the Scottish Housing Regulator that the landlord is meeting
the relevant regulatory requirements applicable to Local Authorities and
Registered Social Landlords (RSLs).

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3.4 In accordance with section 2.9 of the Framework, the main risks that they
consider are:
 poor outcomes for tenants, people who are homeless and other service
users
 poor quality or safety of tenants’ homes
3.5 Further, the Regulatory Framework advises that landlords should consider
how best to utilise Internal Audit as a source of independent assurance when
preparing their Annual Assurance Statements. This includes providing
assurance on compliance with regulatory requirements, such as the
Standards of Governance and Financial Management applicable to
Registered Social Landlords (RSLs).
3.6 According to section 4.2 the statement should be completed and agreed by
the governing body or local authority committee. It is mentioned that the
governing body or committee should confirm that they have appropriate
assurance that they comply with:
 all relevant regulatory requirements set out in Chapter 3 of the
Regulatory Framework
 all relevant standards and outcomes in the Scottish Social Housing
Charter
 all relevant legislative duties
 the Standards of Governance and Financial Management (RSLs only)
 any specific assurance requirements asked landlords to cover in their
Statement.
4. Scope and Limitations
4.1 The Audit has reviewed the relevant standards and outcomes in the Scottish
Social Housing Charter and identified the arrangements for the compilation of
the annual submissions to the Housing Regulator (HR).
4.2 To arrive at an opinion on the achievement of the control objective, the review
included,
 Document reviews concerning Housing Regulator submission
 Interviews with key staff who are responsible for the various indicators
 Reviewing of any third-party documents and arrangements with relevant
performance indicators
 Ensuring lessons learned from previous non-compliance are incorporated
into future planning.
4.3 There were no limitations identified that would impact the Audit.
4.4 The details of the control objectives reviewed and the Internal Audit’s
assessment of their strength of control in each area are contained within
Section 5 of this report.

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5. Assessment of the Control Environment
5.1 The table below contains a summary of the findings against each control
objective and Internal Audit’s assessment of the adequacy and effectiveness
of the controls in place to meet each of the objectives agreed for this audit.
Further details, including any improvement actions, are set out in the
Management Action Plan.
Action RatingNo. Control Objective
5 4 3 2 1
Control
Objective
Assessment
1 To ensure appropriate evidence
has been gathered to support
the level of assurance.
Substantial
Assurance
2 To assess whether the
conclusion arrived at is
appropriate based on the
evidence available and satisfies
the governance requirement.
Substantial
Assurance
3 To ensure all relevant standards
and outcomes in the Scottish
Social Housing Charter and
legislative duties have been
achieved.
7 2 1 Reasonable
Assurance
5.2 The auditor has assessed that Substantial Assurance can be placed on
controls overall in relation to the arrangements for the compilation of the
annual submissions to the Housing Regulator. Meaning:
“A sound system of governance, risk management and control exists, with
internal controls operating effectively and being consistently applied to
support the achievement of objectives in the area audited”.
5.3 A summary of the key findings and actions is provided in section 6. Please
note, however, the following areas of good practice which have been
highlighted during the audit:
5.3.1 The submission of Annual Assurance Statements commenced in 2018/19,
and over the past six years, there has been a consistent demonstration of
commitment and the delegation to ensure timely submission. Cross functional
teams worked together for the compilation of the Annual Assurance
Statement for the 2024/25 and to meet the 31 October 2025 deadline.
5.3.2 There are certain delegated authorities have been appointed to oversee all
aspects related to the housing regulator submission and delivery of the
different services to the tenants. Service performance is reported regularly to
the Housing Management Team, Communities Senior Management Team
and Executive Leadership Team.

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5.3.3 According to the Scottish Housing Regulator website 8,226 homes are owned
by Perth and Kinross council as of 31 March 2025. The total rent due to this
landlord reported for the year 2024/25 was £32,978,973.
It further mentioned that the PKC increased its weekly rent on average
by 6.0% from the previous year but it is still below the Scottish average weekly
rents.
5.3.4 Our observations confirm that appropriate measures have been implemented
to ensure all the houses achieve the Gas Servicing Compliance requirements
2024/25 year. We commend the Housing Compliance Team for their
dedication and performance in achieving this target and encourage the
continued application of the Gas Servicing Quality Assurance Framework.
5.3.5 Our review indicates that PKC remains committed to delivering home
adaptations, with 404 completed during 2024/25. Notably, the number of
households waiting for adaptations was reduced from 45 to 32. While the
average completion time has slightly decreased, it remains better than the
Scottish average. The efficient use of resources has also led to a significant
reduction in total expenditure. The dedication of the Property - Housing
Capital Projects and New Builds team, in collaboration with the Occupational
Therapist, is commendable in achieving these outcomes.
5.3.6 It has been noticed that PKC charges the lowest factoring fee of £20
compared with the Scottish Average and other Registered Social Landlords.
Currently, there are 116 owners across multi-storey and other blocks who are
subject to this fee. Satisfaction with factoring services has increased over the
year, reflecting strong performance in delivering good value for money
(outcome 13), communication (outcome 2) and participation (outcome 3) in
line with the Scottish Social Housing Charter.
5.3.7 According to Social Housing Allocation Guidelines, in allocating housing,
social housing landlords need to balance a range of factors such as, the
individual's housing need, the suitability of the house for that applicant and the
needs of the community. In April 2025, PKC revised the Common Allocation
Policy (CAP) to better identify the priority tenants in response to housing
pressure. We appreciate the steps taken to implement Perth and Kinross
Common Housing Register (CHR), a computer-based, single waiting list
shared by PKC, Caledonia Housing Association, Hillcrest Homes and
Kingdom Housing Association. This system uses Group Plus Points System to
ensure fair and consistent allocations, in alignment with relevant housing
legislation and the Scottish Social Housing Charter.
5.3.8 The preparation of Assurance Statements requires the collection and input of
various data into the Scottish Housing Regulator’s system. This process has
been effectively coordinated by a designated officer who possesses
comprehensive knowledge across all relevant areas. The officer has provided
consistent support to the Team Leader, ensuring that all necessary evidence
has been appropriately gathered. The resulting Assurance Statement
addresses all key indicators in accordance with the requirements of the
Regulatory Framework.
5.3.9 In our observation, the Assurance Statement was prepared well in advance,
with all supporting documentation clearly itemised in a separate annexe. The

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assurance provided is consistent with the evidence presented, which has
been reviewed and found satisfactory by the Internal Audit.
5.3.10We observed that appropriate governance arrangements were in place for the
submission to the Scottish Housing Regulator. This was evidenced by
participation in the Housing and Social Wellbeing Committee meeting held on
01 October 2025. During this meeting, the Assurance Statement along with
the relevant appendices was formally approved for submission to the
Regulator. This approval aligns with the Framework’s requirements and was
granted by the Committee on the same day.
5.3.11As internal audit we agree with the conclusion derived in the Assurance
Statement which states that “during 2024/25 Perth and Kinross Housing
Service complied with all except one regulatory requirement as set out in
Chapter 3 of the Scottish Housing Regulator's Framework.” Also, we are
satisfied with the explanation provided in relation to the recognised non-
compliance.
5.3.12During 2024/25, Perth and Kinross Council reported non-compliance in
relation to the management of Gypsy/Traveller sites. The details of this non-
compliance have been outlined in our findings. However, the Assurance
Statement clearly highlights the steps taken to address the issue, including
the provision of quarterly updates to the Scottish Housing Regulator. We
acknowledge and commend the ongoing efforts made throughout the year to
achieve and maintain full compliance in the management of Gypsy/Traveller
sites.
6. Summary of Findings
6.1 Below is a summary of key findings and actions, which are reflected in the
Management Action Plan, detailed in section 10. 
6.2 The assurance process was conducted effectively, and sufficient evidence
was gathered to support the expressed opinion.
6.3 As part of the audit, whilst testing was undertaken for the third control
objective, as detailed in Section 5 above, Internal Audit has identified areas
where additional controls could be beneficial particularly in relation to certain
national key performance indicators.
6.4 Our observation confirm that the Customer Satisfaction Survey was
conducted by an independent, third-party organisation, Knowledge
Partnership, using a representative sample to assess overall tenant
satisfaction. Key areas evaluated included keep tenants informed,
opportunities to participate, housing quality, repairs, neighbourhood
management and rent value. During 2024/25 most of these indicators showed
a decline compared to the previous year and indicating a downward trend in
tenant satisfaction.
[Action point 01]

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6.5 Regarding the complaint handling, all the complaints are received via email or
telephone and are recorded in Firmstep (Case Viewer), before being
downloaded to Excel for verification. Housing-related complaints are manually
identified, sorted, and documented as a part of this process. Although
discussions have taken place regarding the implementation of a complaint’s
dashboard, it should be noted that the dashboard was not fully operational
during the 2024/25 reporting period and therefore was not utilised for the
Housing Regulator submission.
[Action point 02]
6.6 The review of documents and discussions with the Corporate Complaints
Team Leader revealed an increase in Stage 2 complaints rising from 60 to 80
from 2023/24 to 2024/25. Stage 2 Complaints means if the complainant is
dissatisfied with the Stage 1 outcome or if the issue remains unresolved, the
complaint is escalated to Stage 2. Additionally, more serious complaints may
be classified directly as Stage 2. These are typically resolved within 20
working days. It was noted that 9 of the 80 complaints received during the
year were carried forward to 25/26 financial year and resolved fully. Actions
have already been implemented in this area; therefore, no further actions are
currently required.
6.7 The audit has identified that a substantial amount of information in relation to
the social housing is publicly available in the PKC website. This includes the
access to applications, common allocation policy and clarifications addressing
misconceptions regarding the allocation process. However, it was noticed that
certain information on the website is outdated. For instance, the update
provided for the Common Housing Register Waiting List is dated 13
September 2021 which may lead to confusion or misinformed expectations
among applicants.
[Action point 03]
6.8 According to the Scottish Housing Quality Standards (SHQS), social landlords
must ensure that their tenants’ homes:
 energy efficient, safe and secure,
 not seriously damaged
 have kitchen and bathrooms that are in good condition.
Landlords are expected to maintain these standards unless otherwise they
prevent by social or technical reason from completing improvements required
by SHQS. It is mentioned that in general, SHQS should be achieved rather
than avoided.
6.9 From our observation, we found that there are 1662 houses which do not
pass this minimum SHQS in 2024/25; from these, 123 houses are in
abeyance (refers to the situation where planned work cannot be completed
due to social reasons such as tenant behaviour), and 417 houses are under
exemption (due to technical or economic reasons).

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1082 houses have fully failed to meet the standards. Specifically, 999 houses
failed on one criterion, while 83 houses failed on two or more criterion. The
most common failures notified were roof structure and common floor/parts
failures. For the year 2024/25 SHQS pass rate is 80.28%, reflecting an
improvement from the previous year pass rate of 76.32%. It is noted that the
Council will not achieve 100% conformance in this area, due to reasons such
as tenant preference, the type of housing stock etc, and that the Council’s
performance is above the local authority average; the Service continues to
progress towards achieving the maximum compliance rate possible.
[Action point 04]
6.10 The Energy Efficiency Standard for Social Housing (EESSH) was introduced
to improve the energy efficiency of social housing in Scotland, with the aim of
reducing energy consumption, fuel poverty and greenhouse gas emissions.
As part of our review, it was identified that a significant number of properties
failed to meet EESSH requirements. Specifically, 1055 properties did not
comply with the standard in 2024/25; 451 of these properties are under
exemption (due to technical or economic reasons) or an abeyance (tenant
issues, for example, opting out of the improvements required or not allowing
access).
[Action point 05]
6.11 The status of the Energy Performance Certificate (EPC) of PKC Housing
Stock as of 31 March 2025 has been observed as follows.
Following the introduction of the Energy Team, the number of properties without
an EPC has significantly decreased from 919 to 198. As of 31 March 2025,
there were 210 properties with Energy Performance Certificates (EPC) rated in
Bands E and F, comprising 170 properties in Band E and 40 in Band F.
6.12 As per the updated figures as of 30 June 2025, we noted that there are 185
properties without Energy Performance Certificate (EPC) and 874 out of date
which require attention from the Housing Capital Projects & New Builds team
in Property Services. It is appreciated that these figures can be impacted by
lack of access provided to carry out the EPC surveys.
[Action point 06]

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6.13 Currently, there are multiple software solutions used by the Council to support
various aspects of housing management operations. The primary asset
database utilised by the Housing Capital Projects & New Builds Team is the
“Houses” Database, which is operated by BACRA. This system underpins
reporting requirements for both ARC (Annual Return on the Charter) and
SHQS (Scottish Housing Quality Standards). The Housing Service employs
the NEC Housing Management System to effectively manage and maintain a
range of functions including Housing Advice, Homelessness, Allocations,
Tenancies, Rents, Arrears, Customer Services, Planned Maintenance, and
Housing Online. Additionally, the Housing Repairs Service utilises the Total
Mobile (Total Connect) system for job management, scheduling, and mobile
delivery.
6.14 Whilst it is appreciated that the current reports and quality assurance
processes for the compilation of the submission to the Scottish Housing
Regulator ensure that the information is accurate, there is scope for
considering some improvement.  The audit identified the Council does not
maintain a centralised asset database accessible across all departments. For
instance, the “Houses” database is not integrated with other systems such as
NEC and Total Mobile.
[Action point 07]
6.15 Regarding the indicator Anti-social behaviour cases resolved, it was noted
that there is a 13.77% (From 91.37% to 79.60%) reduction from previous year
of resolving them within the agreed time.
[Action point 08]
6.16 We have observed positive progress in rent collection, accompanied by a
significant reduction in gross rent arrears. However, it has been identified that
there is currently no utilisation of advanced technologies to proactively detect
potential rent arrears at the tenant level. Several other councils have
successfully implemented predictive analytics to identify early indicators of
financial distress among tenants and this may be a route for PKC to consider. 
[Action point 09]
6.17 During the audit, we observed that concerns were raised in relation to the
safety, standards, communication and human rights concerns at
Gypsy/Travellers site by the Scottish Housing Regulator published on 21
March 2025. In the Double Dykes site, PKC failed to meet the minimum
standard for Essential Fabric Standards (Standard 1), Safety and Security
(Standard 4), Maintenance and Repairs (Standard 5), Fair Treatment
(Standard 6) and Consultation (Standard 7). In the Bobbin Mill site, PKC failed
to meet the Essential Fabric Standards (Standard 1), Energy Efficiency
(Standard 2), Safety and Security (Standard 4) and Consultation (Standard 7).
6.18 The Housing Regulator mentioned both Gypsy/Travellers sites are failing to
meet several Social Housing Charter Outcomes such as Equalities (outcome
1), Communication (outcome 2), Participation (outcome 3), Repairs,
maintenance and improvement (outcome 5), Gypsy/Travellers (outcome 16).

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There is an ongoing replacement of the chalets and general upgrades in both
sites. However, on the completion day of this audit, the Comprehensive
Satisfaction Survey has not been carried out.
[Action point 10]
6.19 The latest Stock Condition Survey was carried out in June 2021 and covered
30% of the housing stock at that time. As per Regulator guidance, the next
scheduled Survey is to be held before June 2026 and this was also due to
cover 30% of different houses for SHQS compliance, as per the Annual return
submitted. Since the Annual Return was submitted in May 2025, the Service
has reconsidered its position going forward, to improve the accurate
understanding of the condition of the housing stock. A new contract is being
progressed that will ensure that 100% of the properties are reviewed within
the lifetime of the contract, therefore within the five year period required for
the next Stock Condition Survey.
7. Conclusion
7.1 The Internal Audit review is able to place Substantial Assurance on the overall
control environment for arrangements for the compilation of the annual
submissions to the Housing Regulator. The agreed actions, once
implemented, should enable Internal Audit to place substantial assurance on
these.
8. Acknowledgements
8.1 Internal Audit would like to thank all officers who were involved in this audit,
Elaine Ritchie (Strategic Lead – Housing & Communities),
Calvin Cameron (Housing Development Worker, Communities - Performance
& Business Support),
Andrea McCallum (Service Manager - Housing - Communities),
Mark Weir (Team Leader - Income Maximisation, Communities - Performance
& Business Support),
June McColl (Service Manager (Housing) Communities - Repairs &
Improvements),
Nicola Lennon (Service Manager - Capital Projects & New Build),
Nicola Sworowski (Place Strategies Manager & Chief Planning Officer
Communities - Planning & Housing Strategy),
Martin Smith (Service Manager - Perth City and Specialist Services
Communities - Perth City & Specialist),
Connor Wilson (Business Support Service Manager – Finance & Business
Support),
Joy Mayglothling (Corporate Complaints Team Leader)
9. Action Implementation & Follow up
9.1 Responsibility for the maintenance of adequate and effective controls rests
with management. Where the audit has identified areas for management
action, these are identified in the Management Action Plan.

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Where a decision is taken by management not to act in response to findings
from this review, it is the responsibility of management to assess and accept
the risk arising from non-implementation.
9.2 Achievement of the agreed actions is monitored through Internal Audit’s
‘follow up’ arrangements.

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10. Management Action Plan
Action
Point
Para.
No Finding Risk
Rating Agreed Action & Evidence Action Owner
Target
Completion
Date
1 6.4 Our observations confirm that the
Customer Satisfaction Survey was
conducted by an independent,
third-party organisation, Knowledge
Partnership, using a representative
sample to assess overall tenant
satisfaction. Key areas evaluated
included keeping tenants informed,
opportunities to participate, housing
quality, repairs, neighbourhood
management and rent value.
During 2024/25 most of these
indicators showed a decline
compared to the previous year and
indicating a downward trend in
tenant satisfaction.
3 Agreed action:
The findings of the Satisfaction
Survey for 2025/26 are being
reviewed for any areas where
action can be taken to address
areas of concerns being raised.
Agreed evidence:
Outomes from the review of
tenant satisfaction within Perth
and Kinross.
A. McCallum
(Service
Manager -
Housing -
Communities)
May 2026
2 6.5 Regarding the complaint handling,
all the complaints are received via
email or telephone and are
recorded in Firmstep (Case
Viewer), before being downloaded
to Excel for verification. Housing-
related complaints are manually
identified, sorted, and documented
as a part of this process. Although
discussions have taken place
2 Agreed action:
A pilot dashboard has been
developed with managers
presenting live data, tracking and
themes with a view to resolving
complaints quickly and efficiently.
Roll out took place from January
2025, becoming fully operational
from April 2025.
C. Wilson
(Business
Support Service
Manager –
Finance &
Business
Support)
Completed

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regarding the implementation of a
complaints dashboard, it should be
noted that the dashboard was not
fully operational during the 2024/25
reporting period and therefore was
not utilised for the Housing
Regulator submission.
Agreed evidence:
Live dashboard
3 6.7 The audit has identified that a
substantial amount of information in
relation to the social housing is
publicly available in the PKC
website. This includes the access to
applications, common allocation
policy and clarifications addressing
misconceptions regarding the
allocation process. However, it was
noticed that certain information on
the website is outdated. For
instance, the update provided for
the Common Housing Register
Waiting List is dated 13 September
2021 which may lead to confusion
or misinformed expectations among
applicants.
1 Agreed action:
 We recognise the importance
of providing data that is
meaningful and relevant to
both applicants and tenants,
and significant progress has
been made in this area.
Agreed evidence:
 The updated waiting list
M. Smith
(Service
Manager -
Housing)
Completed
4 6.9 From our observation, we found
that there are 1662 houses which
do not pass this minimum SHQS in
2024/25; out of that 123 houses are
in abeyance (refers to the situation
where planned work cannot be
3 Agreed action:
 New Contract put in place for
Stock Condition Survey.
 New Asset Management
Database for all areas of
Housing to feed data into to
N. Lennon
(Service
Manager -
Capital Projects
& New Build)
October
2027

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completed due to social reasons
such as tenant behaviour), and 417
houses are under exemption (due
to technical or economic reasons).
1082 houses have fully failed to
meet the standards. Specifically,
999 houses failed on one criterion,
while 83 houses failed on two or
more criterion. The most common
failures notified were roof structure
and common floor/ parts failures.
For the year 2024/25 SHQS pass
rate is 80.28%, reflecting an
improvement from the previous
year 76.32%. It is noted that the
Council will not achieve 100%
conformance in this area, due to
reasons such as tenant preference,
the type of housing stock etc, and
that the Council’s performance is
above the local authority average;
the Service continues to progress
towards achieving the maximum
compliance rate possible.
ensure asset management
information is up to date.
 Review of SHQS failures and
targeted inspections carried
out to investigate elements
shown as failures
Agreed evidence:
 Appointment of contractor for
Stock Condition Survey and
commencement of contract
within 2026
 Appointment of new Asset
Management Database
provider and move from
current databases to new
Database undertaken
 Regular reports provided by
database to track reduction in
SHQS failures
 Data relating to each failure is
fully evidenced and shown
with a plan of how this will be
addressed
J McColl,
(Service
Manager
(Housing)
Communities -
Repairs &
Improvements
Nicola
Sworowski,
(Place
Strategies
Manager &
Chief Planning
Officer)

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5 6.10 The Energy Efficiency Standard for
Social Housing (EESSH) was
introduced to improve the energy
efficiency of social housing in
Scotland, with the aim of reducing
energy consumption, fuel poverty
and greenhouse gas emissions. As
part of our review, it was identified
that a significant number of
properties failed to meet EESSH
requirements. Specifically, 1055
properties did not comply with the
standard in 2024/25; 451 of these
properties are under exemption
(due to technical or economic
reasons) or an abeyance (tenant
issues, for example, opting out of
the improvements required or not
allowing access).
3 Agreed action:
 Targeted plan to address
EESSH failures, taking into
account budgetary pressures
Agreed evidence:
 EESSH failures list
categorised into elements to
be addressed to improve
EESSH compliance and work
towards completion of delivery
of the required elements
N. Lennon
(Service
Manager -
Capital Projects
& New Build)
Overall
target:
March 2030
Interim
targets:
March 2026
– 114
properties
March 2027
– 306
properties
March 2028
– 182
properties
March 2029
– 1 property
March 2030
- 1 property
6 6.12 As per the updated figures as of 30
June 2025, we noted that there are
185 properties without Energy
Performance Certificate (EPC) and
874 out of date which require
attention from the Housing Capital
Projects & New Builds team in
Property Services. It is appreciated
3 Agreed action:
 Properties currently without an
EPC or with an out-of-date
EPC are being prioritised for
surveys through the current
contract that is in place; this
contract has a planned
N. Lennon
(Service
Manager -
Capital Projects
& New Build)
March 2027

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that these figures can be impacted
by lack of access provided to carry
out the EPC surveys.
delivery requirement to
guarantee it meets the
required deliverables.
Agreed evidence:
 Progress monitoring reports
provided fortnightly by the
contractor at the progress
meeting
 Bi-monthly Highlight Reports
provided to Housing
Management Team. 
7 6.14 Whilst it is appreciated that the
current reports and quality
assurance processes for the
compilation of the submission to the
Scottish Housing Regulator ensure
that the information is accurate,
there is scope for considering some
improvement in that the audit
identified the Council does not
maintain a centralised asset
database accessible across all
departments.
3 Agreed action:
 A comprehensive contract
strategy has been completed
to tender for a new system.
This strategy acknowledges
the limitations and sets out a
clear pathway for procuring a
new housing asset
management solution that
meets both current and future
operational and regulatory
needs. This process has taken
significant time given the
complexities involved. 
 Market testing has been
conducted to ensure the
proposed system will deliver
improved functionality,
integration, and data reliability.
N. Lennon
(Service
Manager -
Capital Projects
& New Build)
J. McColl
(Service
Manager
(Housing)
Communities -
Repairs &
Improvements
March 2026

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 However, the costs have
been passed to our Finance
colleagues for review and
comment, as the quotation
received far exceeds the
anticipated costs, therefore it
is unclear at this stage
whether we will have a budget
to meet the full requirements
Agreed evidence:
 Contract award document /
outcome from decision on
whether to proceed
8 6.15 Regarding the indicator Anti-social
behaviour cases resolved, it was
noted that the 13.77% (From
91.37% to 79.60%) reduction from
previous year of resolving them
within the agreed time.
3 Agreed action:
 Review and update the ASB
procedures.
 Deliver targeted staff training –
with a particular focus on
trauma informed approach.
 Encourage the use of a wide
range of interventions and
legal tools.
 Promote early intervention
through positive engagement,
education, mentoring, and
diversion activities
Agreed evidence:
 ASB indicator for 25/26
A.McCallum
(Service
Manager -
Housing -
Communities)
May 2026

Page 19

9 6.16 We have observed positive
progress in rent collection,
accompanied by a significant
reduction in gross rent arrears.
However, it has been identified that
there is currently no utilisation of
advanced technologies to
proactively detect potential rent
arrears at the tenant level. Several
other councils have successfully
implemented predictive analytics to
identify early indicators of financial
distress among tenants and this
may be a route for PKC to consider.
2 Agreed action:
 We are currently testing NEC
Analytics, which is a form of
AI, to help with the
identification of trends and
forecasting to target our work
and free up staff to focus on
those more complex and
challenging cases.
Agreed evidence:
 Reports run by NEC Analytics
A. McCallum
(Service
Manager -
Housing -
Communities)
Build
completion
December
2025
Phased go-
live Q1
2026
10 6.18 Housing Regulator mentioned both
Gypsy/Travellers sites are in
failures in meeting several Social
Housing Charter Outcomes such as
Equalities (outcome 1),
Communication (outcome 2),
Participation (outcome 3), Repairs,
maintenance and improvement
(outcome 5), Gypsy/ Travellers
(outcome 16). There is an ongoing
replacement of the chalets and
general upgrades in both sites.
However, on the completion day of
this audit, the Comprehensive
Satisfaction Survey has not been
carried out.
3 Agreed action:
 Tenant satisfaction surveys
are embedded within our
programme and scheduled in
accordance with both statutory
requirements and resident
feedback.
 Review the findings of the
Satisfaction Survey for
2025/26.  Consider the
potential to extend the current
contract or alternative means
of collecting the satisfaction
levels. The regulator only
requires updates every 3
years for these indicators.
A. McCallum
(Service
Manager -
Housing -
Communities)
April 2026

Page 20

Agreed evidence:
 Comprehensive Satisfaction
Survey

Page 21

11. Authorisation
11.1 The auditor for this assignment was D. Arachchilage.  The supervising auditor
was J Clark.
This report is authorised for issue:
12. Distribution
12.1 The final report will be issued to:
T Glen, Chief Executive
C Mailer, Depute Chief Executive
E Ritchie, Strategic Lead – Housing & Communities
S Marone, Strategic Lead – Economy, Development & Planning
S Walker, Strategic Lead – Finance & Business Support
J Beveridge, Strategic Lead – Property Services
A McCallum (Service Manager - Housing - Communities),
J McColl (Service Manager (Housing)Communities - Repairs & Improvements,
N Lennon (Service Manager - Capital Projects & New Build),
M Smith (Service Manager - Perth City and Specialist Services Communities -
Perth City & Specialist)
C Wilson (Business Support Service Manager – Finance & Business Support)
N Sworowski (Place Strategies Manager & Chief Planning Officer Communities
- Planning & Housing Strategy)
Committee Services
External Audit
13. Assessment Definitions
13.1 The following table contains the definitions of the control objective
assessment.
Control Objective Assessment
Level of assurance Definition
Substantial
Assurance
A sound system of governance, risk management and
control exists, with internal controls operating effectively
and being consistently applied to support the achievement
of objectives in the area audited.
Reasonable
Assurance
There is a generally sound system of governance, risk
management and control in place. Some issues, non-
compliance or scope for improvement were identified
which may put at risk the achievement of objectives in the
area audited.
Limited Assurance Significant gaps, weaknesses or non-compliance were
identified. Improvement is required to the system of
governance, risk management and control to effectively
manage risks to the achievement of objectives in the area
audited.

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No Assurance Immediate action is required to address fundamental gaps,
weaknesses or non-compliance identified. The system of
governance, risk management and control is inadequate to
effectively manage risks to the achievement of objectives
in the area audited.
13.2 The following table contains the definitions applied by Internal Audit in rating
audit findings/actions.
Risk Rating for Individual Findings
Rating Rating
description
Definition
5 Critical Significant observations / major concerns which require
immediate action. Management will need to add these to
the appropriate Service risk register
Issue represents a control weakness which could cause,
or is causing, severe disruption of the process or severe
adverse effect on the ability to achieve process
objectives
4 High Significant observations regarding the absence / failure
of key controls requiring urgent action. Management
should consider adding these to the appropriate Service
/ divisional risk register
Issue represents a control weakness which could have,
or is having, major adverse effect on the ability to
achieve process objectives
3 Medium Observations regarding the effectiveness of key controls
requiring reasonably urgent action. Management should
consider these when updating any divisional / team risk
registers
Issue represents a control weakness which could have,
or is having, significant adverse effect on the ability to
achieve process objectives
2 Low Minor observations regarding the adequacy of controls
which require action to improve the efficiency,
effectiveness, or economy of operations or which
otherwise require to be brought to the attention of Senior
Management
Issue represents a minor control weakness with minimal
but reportable impact on the ability to achieve process
objectives
1 Trivial / Minor Very minor observations which will be raised during the
audit and may not be included within the final report

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Issue represents a very minor control weakness with
negligible impact on the ability to achieve process
objectives. The issue will be raised during the audit and
may not be included within the final report.