Housing Landlord Compliance – Bi-annual Performance Report - Report
Renfrewshire Council · 28 October 2025
Back to Communities and Housing Policy Board — 28 October 2025 and its agenda
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PUBLIC ___________________________________________________________________ To: Communities and Housing Policy Board On: 28 October 2025 ___________________________________________________________________ Report by: Director of Environment, Housing, and Infrastructure ___________________________________________________________________ Heading: Housing Landlord Compliance – Bi-annual Performance Report 1. Summary 1.1 All social landlords must ensure they meet all duties in relation to tenant and resident safety and have an effective system in place to ensure compliance with statutory, legislative and regulatory responsibilities. 1.2 The Housing Landlord Compliance Strategy 2025-2028 was approved by the Policy Board on 11th March 2025 and Section 7 of the strategy provided details of the internal governance arrangements for performance management, which includes a bi-annual report to be presented to the Communities and Housing Policy Board. 1.3 This report is the bi-annual performance report for the six-month period from April 2025 to September 2025. 1.4 The report also includes details of the Asbestos Management Action Plan as requested by the Scottish Housing Regulator within the 2025/26 Engagement Plan. ___________________________________________________________________ 2. Recommendations It is recommended that the Communities and Housing Policy Board: 2.1 Notes the content of the Landlord Compliance Performance Report and the suite of Key Performance Indicators (KPIs) at Appendix 1 of the report. 2.2 Notes the Asbestos Management Action Plan which has been provided to the Scottish Housing Regulator as required as part of our Engagement Plan for 2025/26.
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PUBLIC ___________________________________________________________________ 3. Background 3.1 The Housing Landlord Compliance Strategy 2025-2028, which sets out the strategic approach to compliance across the six key areas of compliance relating to Council Housing assets (gas safety, electrical safety, fire safety, lift safety, asbestos management and water safety) was approved by the Communities and Housing Policy Board on 11th of March 2025. 3.2 There are six landlord compliance policies in place to support the Housing Landlord Compliance Strategy, each with a suite of key performance indicators and detailed performance reporting arrangements which include a bi-annual report to the Communities and Housing Policy Board. Each of the policies is reviewed on a regular basis and further policies will be created for any new areas of compliance regulation that are introduced. 4. Housing Landlord Compliance Performance Report 4.1 The bi-annual housing Landlord Compliance Performance Report covering the period April – Sept 2025 is set out in Appendix 1 of this report. There are 26 key performance indicators covering the six compliance areas. 23 indicators are showing greater than 99% compliance, demonstrating an improved position on the year-end report for 2024/25. 1 performance indicator is designated amber status indicating a compliance level between 85% and 99% (an improvement from year end position of 5 at amber status) and 2 performance indicators are designated as a red status, indicating a compliance level lower than 85% (an improvement from year end position of 3 at red status). All compliance indicators at amber and red status have actions in place for improvemen and the report will update on progress made The indicators at red and amber status are: • Properties with automated doors, gates, and barriers where Maintenance visits have been completed (amber) • Common Area Electrical Installation Condition Report (EICR) (red) • Re-inspections of common areas with Asbestos Containing Materials (red) These areas are prioritised for improvement during 2025/26 with actions already underway to achieve full compliance which are set out in each of the relevant paragraphs below in section 4.2. 4.2 The key points to note for each area of compliance are as follows: • Gas Safety The Council are required to carry out annual gas safety inspections on all 10574 residential properties that have a gas supply. There were 5 properties where the gas service was not completed within the 12-month timescale during the 6-month period from April – Sept. All five are now complete.
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PUBLIC All communal heating systems with gas boilers have had their annual safety checks completed within timescale. • Electrical Safety 1005 EICRs were completed within the first six months of 2025/26 with a further 539 properties due to have their EICR checks by 31st March 2026. With the backlog of inspections now cleared, there are robust processes in place to ensure that future EICRs are scheduled to be complete within timescale. There are currently 52 EICRS overdue; 26 of these are due to environmental issues, 3 are due to meter issues and the remainder are either booked in or in the process of having access arranged. The compliance team continue to engage with colleagues in the wider housing team and other service areas to support tenants to ensure EICRs can be completed as quickly as possible. Follow on work classed as C1(danger present) is always addressed immediately to make safe. Follow on work classed as C2 (potentially dangerous) is, in the majority of cases, carried out at the same appointment as the electrical check with just a small number that require a new appointment to be arranged. There were 2 properties with outstanding C2 work at the end of August requiring additional appointments. Work has been undertaken in conjunction with ICT to introduce automated letter production for EICRs. This went live on 1st September and will streamline the previously manual labour-intensive process. The success of this will be monitored over the coming months. The programme of common area electrical checks which commenced in November 2024 is being carried out by our in-house Building Services team and is running in line with agreed timescales indicating an improvement from 21% at year end to 40% of the 953 common areas completed to date. The remainder are programmed over 2025/26 to ensure full compliance with this indicator by March 2026. There is one property where we are awaiting confirmation that door automation is no longer required. • Fire Safety All Fire Risk Assessments (FRAs) required for multi-storeys, sheltered complexes, HMOs and common areas of all blocks are up to date. Ongoing review will continue with some requiring 6 monthly review and others 12 monthly. Actions identified from FRAs are followed up promptly with repairs instructed where required. Along with the EICR programme, the rollout of the fire safety detection interlinked alarms in domestic properties has been ongoing.
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PUBLIC Robust processes have been introduced to ensure that detectors are checked during the annual gas service and that expiry dates are updated to enable future replacement programmes to be programmed. Feedback is also provided from surveyors carrying out stock condition surveys where missing or faulty detectors are identified. There is a quarterly meeting with Scottish Fire and Rescue Service and other Council teams to discuss fire safety. There are major capital investment works planned within the multi storey blocks over the next five years. The Scottish Government have provided grant funding to carry out Single Building Assessments (SBAs) in multi storey blocks which will identify fire safety measures that may be required. A cross departmental thematic group has been established to consider and prioritise the future investment requirements which will be further informed by the findings from the SBAs. The SBAs will be carried out on a phased basis with the first two already procured. A larger procurement exercise is underway for the remainder. Updates on this will be provided within future service update reports. The compliance team continue to deliver fire safety training to staff across Housing Services. • Lift Safety All lifts examinations and maintenance are fully up to date. The compliance team have been pro-active in ensuring that access is ensured for all regulatory lift examinations carried out by our appointed insurance contractor. • Water Safety Statutory legislation requires Legionella Risk Assessments (LRAs) to be in place with water safety management plans and monitoring in place for those identified as high risk. This includes carrying out temperature checks where communal water tanks or heating cylinders are present such as in sheltered complexes and multi-storeys. There is a contract in place for water sampling and LRAs for multi storeys, sheltered housing and non-domestic premises. Building Services carry out the monthly, quarterly, six-monthly and annual monitoring of all sites as prescribed within the guidance. There is also a requirement to carry out LRAs within all domestic properties. Current performance indicators show full compliance with water safety management with LRAs for domestic properties currently in place by archetype. The intention is to update these LRAs on an individual property basis which will require a procurement exercise to be undertaken. • Asbestos Safety Housing Services have contracts in place for asbestos surveying, asbestos removal and analytical services within domestic properties.
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PUBLIC There are currently two short term contracts, one for void properties and general repairs and the other for capital investment external works. Longer term contracts are in the process of being procured. A contract for common area asbestos management will be procured following the outcome of an ongoing external review which is described below. Housing Services have engaged external consultants to assist with the review of current asbestos management documentation, carry out a gap analysis, review asbestos management working practices, review training provisions and requirements and associated roles and responsibilities. Housing Services continue to participate in a corporate Health and Safety-led asbestos working group which oversees the council’s approach to asbestos to ensure consistency and good practice. 5. 2025/26 Key Actions • The 2025/26 Scottish Housing Regulator engagement plan notes that in October 2024 in our annual assurance statement that we said were taking steps to review and consolidate our tenant and resident safety responsibilities. In addition to further updates on EICR and fire detection compliance, the Regulator is seeking further information and assurance about our asbestos management processes and planned improvements. An Asbestos Management Action Plan was provided to the Regulator 25th Sept September and is appended to this report at Appendix 2. Actions 1 and 2 are now complete. • Ongoing review of policies, procedures and processes including the identification of new policy requirements. A Damp and Mould policy is being developed and will be brought to Board in early 2026. • Longer term contracts will be put in place for asbestos surveys. The contract awards for both external and internal surveys is targeted for Spring 2026. • A contract will be put in place for domestic legionella risk assessments, with contract award targeted for April 2026. • A contract will be put in place for common area asbestos management following the conclusion of the external review of asbestos management arrangements described above. _________________________________________________________________ Implications of the Report 1. Financial – Compliance costs are met from the HRA budget. 2. HR & Organisational Development – None.
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PUBLIC 3. Community/Council Planning – • Our Renfrewshire is safe – ensuring tenants have a safe place to live. To manage risk to for staff, contractors or members of the public within council housing properties. 4. Legal – None. 5. Property/Assets – Ensuring assets are protected from risk. 6. Information Technology – None. 7. Equality & Human Rights (a) The Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report. If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and the results of the assessment will be published on the Council’s website. 8. Health & Safety – The strategy and policies align with the Council’s Corporate Health and Safety Policy. 9. Procurement – None. 10. Risk - Failing to meet KPIs could put the Council at risk of failing to comply with statutory duties for landlord compliance and could be reputationally damaging. 11. Privacy Impact – None. 12. COSLA Policy Position – None. 13. Climate Risk – None. 14. Children’s Rights – None. _____________________________________________________________ List of Background Papers Appendix A – Housing Landlord Compliance Performance Report April – Sept 2025/26 Appendix B – Asbestos Management Action Plan ___________________________________________________________________ Author: Karen Sillars, Housing Asset & Investment Manager Email: karen.sillars@renfrewshire.gov.uk
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P a g e | 1 PUBLIC Performance Monitoring Report Housing Landlord Compliance April 2025 – September 2025
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P a g e | 2 PUBLIC Contents 1. Position summary for year 2025 - 2026. ................................................................................................................................................................................. 3 2. GAS .......................................................................................................................................................................................................................................... 4 3. ELECTRICAL .............................................................................................................................................................................................................................. 5 4. ASBESTOS ................................................................................................................................................................................................................................ 7 5. FIRE .......................................................................................................................................................................................................................................... 8 6. WATER ..................................................................................................................................................................................................................................... 9 7. LIFTS ...................................................................................................................................................................................................................................... 10
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P a g e | 3 PUBLIC 1. Position summary for year 2025/26 at September 2025. Category Total Number of KPI’s Gas 3 3 0 0 Electrical 8 6 1 1 Asbestos 2 1 0 1 Fire 4 4 0 0 Water 4 4 0 0 Lifts 5 5 0 0 26 23 1 2 >99% Pass rate 85-99% Pass rate <85% Pass rate
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P a g e | 4 PUBLIC 2. GAS Cat Indicator Q1 Q2 Q3 Q4 25/26 24/25 Notes KPI G.01 Number of times in current reporting year Housing failed to meet statutory obligation to complete a Gas Safety Check within 12 months of a gas appliance being fitted or last checked (Charter Indicator 11) 0 5 5 5 Q2 Administrative errors. Officers have now implemented revised procedures and will keep under review. KPI G.02 Landlord’s Gas Installations with a valid LGSR (CP12) within its due date in the last 12 months as a % of Total Landlord Requirement 100% 99.69% 99.84% 99.9% KPI G.03 Number of Communal / District Boilers with valid certification as a % of Total Landlord Requirement 100% 100% 100% 100%
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P a g e | 5 PUBLIC 3. ELECTRICAL Indicator Q1 Q2 Q3 Q4 25/26 24/25 Notes KPI E.01 Domestic properties with a satisfactory EICR within its due date as % of total dwellings requiring an EICR. 80% 97% 97% 94% Of those outstanding 1.8% are due for demolition. 0.6% are void and will be complete before let. 0.6% are tenanted and are in progress. KPI E.02 Non-domestic properties (including Common Areas) with a satisfactory EICR within its due date as % of total non-Dwellings requiring an EICR 27% 40% 40% 21% Programme commenced November 2024. To be completed by March 2026. KPI E.03 Percentage of domestic properties with no outstanding C1, C2, F1 works. - 99.8% 99.8% 99% 2 properties with outstanding C2s at time of report. KPI E.04 Percentage of non-domestic properties with no outstanding C1, C2, F1 works 100% 100% 100% 100% Sheltered Housing, High Rise and Launderettes KPI E.05 Percentage of Sites with Portable Appliance Tests (PAT) completed. 100% 100% 100% 100% Covers Housing owned appliances in Sheltered Housing & High Rise
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P a g e | 6 PUBLIC Indicator Q1 Q2 Q3 Q4 25/26 24/25 Notes KPI E.06 Percentage of properties with Lightning Protection Systems (LPS) inspected and tested. 100% 100% 100% 100% KPI E.07 Percentage of properties with automated doors, gates, and barriers with a valid Risk Assessment. 100% 100% 100% 82.14% FRA takes account of equipment KPI E.08 Percentage of properties with automated doors, gates, and barriers where Maintenance visits have been completed. 96% 96% 96% 96% One domestic property outstanding – awaiting confirmation that door automation is no longer required.
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P a g e | 7 PUBLIC 4. ASBESTOS Cat Indicator Q1 Q2 Q3 Q4 25/26 24/25 Notes KPI A.01 Non-Dwellings (common areas) with a valid asbestos survey and re-inspections of all ACMs (where required) within its due date as a % of non- Dwellings requiring one. 0% 0% 0% 75% All sites have been surveyed with some sites requiring reinspection. New contract to be procured following external review of asbestos management plan and processes. KPI A.02 Number of safety occurrences - including any reported asbestos related occurrence reporting (e.g., to the HSE or Regulator) during the reporting period. 0 0 0 0
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P a g e | 8 PUBLIC 5. FIRE Cat Indicator Q1 Q2 Q3 Q4 25/26 24/25 KPI F.01 % Of Properties with a Completed and In Date Fire Risk Assessment (FRA) where required. 100% 100% 100% 100% All High flats, Sheltered, HMOs and common areas are completed and reviews ongoing. KPI F.02 Total No. of Fire Risk Assessment Actions Outstanding (but In Date) and total number of actions overdue 2 0 0 252 16 repair actions were identified through the fire risk assessments during 2025/26. All 16 are now complete. KPI F.03 % Of Buildings with Fire Safety Systems/Equipment present where all Systems/Equipment has been Tested/Maintained in accordance with Policy 100% 100% 100% KPI F.04 Number of Notices received from the Fire and Rescue Services with actions required Number of outstanding 3 1 2 3 5 4 10 Outstanding actions to be picked up in capital investment programme.
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P a g e | 9 PUBLIC 6. WATER Cat Indicator Q1 Q2 Q3 Q4 25/26 24/25 KPI W.01 % of Priority Scheme Properties (against the stated Total Landlord Requirement) with a valid Legionella Risk Assessment 100% 100% 100% 100% There are 41 priority schemes all of which have a valid risk assessment. KPI W.02 % of General Needs Properties (against the stated Total Landlord Requirement) with a valid desktop Risk Assessment. 100% 100% 100% 100% Tender for domestic LRA’s to be prepared and procured. KPI W.03 % of Properties (against the stated Total Landlord Requirement) with a valid Written Scheme where a requirement has been identified. 100% 100% 100% 100% KPI W.04 % of Properties (against the stated Total Landlord Requirement) within a Legionella Maintenance Regime 100% 100% 100% 100% 41 properties have a maintenance regime in place.
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P a g e | 10 PUBLIC 7. LIFTS Cat Indicator Q1 Q2 Q3 Q4 25/26 24/25 KPI L.01 Assets with a Passenger Lift having valid Thorough Examination within its Due Date as a % of total assets with a Passenger Lift 100% 100% 100% 100% KPI L.02 Assets with a Passenger Lift where all Maintenance and Inspection activity is within its Due Date as a % of total assets where a Passenger Lift is present 100% 100% 100% 100% KPI L.03 Assets with Vertical Through Floor Lifts that have valid Thorough Examination within its Due Date as a % of total assets with other Lifts 100% 100% 100% 100% KPI L.04 Assets with Vertical Through Floor Lifts where all Maintenance and Inspection activity is within its Due Date as a % of total assets where other Lifts are present 100% 100% 100% 100% KPI L.05 Assets with Actions arising from Thorough Examinations, Inspection or Maintenance activity that are Overdue as a % of total assets where a Lift is present 100% 100% 100% 94%
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Page 1 of 4 PUBLIC Renfrewshire Council Housing Landlord Compliance ASBESTOS MANAGEMENT ACTION PLAN
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Page 2 of 4 PUBLIC Item no Action required Responsible officer(s) Date for Completion Comments/ update 1 Appointment of ACS Learning and Consultancy to assist identifying opportunities of improvement & assist in implementing any changes. K Sillars Housing Asset & Investment Manager 31 August 2025 Meetings ongoing. ACS assisting with all actions within the Action Plan. 2 Review of Current Asbestos Management Documentation (i) A detailed review of the current Asbestos Management Plan, Policy and Internal Guidance document for the Department. (ii) Comparison with the Corporate policy on Asbestos Management. (iii) Identification and repair of any anomalies S Reid Statutory Compliance Coordinator (Asbestos) 30 September 2025 Review of current documentation is underway 3 Gap Analysis (i) Comparison of action 2 (iii) with requirement of CAR 2012. (ii) Carry out Gap Analysis and amend documents where necessary. S Reid Statutory Compliance Coordinator (Asbestos) 31 October 2025
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Page 3 of 4 PUBLIC Item no Action required Responsible officer(s) Date for Completion Comments/ update 4 Review of Asbestos Management Working Practices (i) Carry out a detailed review of current asbestos working practises in relation to domestic properties. (ii) Compare with 3.0 (ii) with particular emphasis on data collection, storage, dissemination to planners/operational staff, updating of Asbestos Register after work. S Reid Statutory Compliance Coordinator (Asbestos) 31 October 2025 5 Review of Training Provision and Requirements (i) Training needs analysis for all staff in the communications chain for planned and unplanned work. (ii) Comparison with existing training. (iii) Identify additional training requirements as necessary. S Reid Statutory Compliance Coordinator (Asbestos) 30 November 2025
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Page 4 of 4 PUBLIC Item no Action required Responsible officer(s) Date for Completion Comments/ update 6 Review of Elected Members’ Roles and Responsibilities (i) Review Elected Member’s roles and responsibilities. (ii) Review and strengthening of policy/procedures to reflect above. (iii) Identify training requirements for Elected Members. A McGuire Housing Maintenance Manager 30 November 2025 7 Assist in the development of the Asbestos Management module in the computerised system (NEC) for property management. ALL ongoing