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Agenda Document Pack - Housing and Community Safety Committee - 12/03/2026

Moray Council · 12 March 2026
Back to Housing and Community Safety Committee — 12 March 2026 and its agenda

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Housing and Community Safety Committee 
Thursday, 12 March 2026 
NOTICE IS HEREBY GIVEN that a Meeting of the Housing and Community Safety
Committee is to be held at Council Chambers, Council Office, High Street, Elgin,
IV30 1BX on Thursday, 12 March 2026 at 09:30. 
BUSINESS 
1. Sederunt 
2. Declaration of Group Decisions and Members Interests * 
3. Resolution
Consider, and if so decide, adopt the following resolution:
"That under Section 50A (4) and (5) of the Local Government (Scotland)
Act 1973, as amended, the public and media representatives be excluded
from the meeting for Item 12 of business on the grounds that it involves
the likely disclosure of exempt information of the class described in the
relevant Paragraphs of Part 1 of Schedule 7A of the Act.”   
4. Minute of meeting dated 18 November 2025 7 - 12
5. Written Questions ** 
6. Local Housing Strategy 2025-2030
Report by Executive Director for Education, Housing and Communities  
13 - 20
7. Moray Affordable Housing Investment Programme
Report by Executive Director for Education, Housing and Communities  
21 - 28
8. Housing Investment Plan Update to 31 December 2025
Report by Executive Director for Education, Housing and Communities  
29 - 42
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9. Common Repairs Policy Review Update
Report by Executive Director for Education, Housing and Communities  
43 - 86
10. Domestic Abuse Policy – Consultation Results
Report by Executive Director for Education, Housing and Communities  
87 -
128
11. Housing and Property Services Budget Monitoring to 31
December 2025
Report by Executive Director for Education, Housing and Communities  
129 -
140 
Item(s) which the Committee may wish to consider with the
Press and Public excluded   
12. Building Services Budget 2025-26 – Budget Monitoring [Para
9]
• 9. Any terms proposed or to be proposed by or to the authority in the
course of negotiations for a contract for the acquisition or disposal of
property or the supply of goods or services. 
Summary of the Housing and Community Safety Committee
functions:
To deal with matters relating to Housing/HMOs, Housing Regeneration,
Homelessness, Social Inclusion, Equalities, Community Safety, Anti-
Social Behaviour (including road accidents) and Community Liaison.     
Watching the Meeting
You can watch the webcast live by going to: 
http://www.moray.gov.uk/moray_standard/page_43661.html    
Webcasts are available to view for 1 year following the meeting.  
You can also attend the meeting in person.  If you wish to attend
in person, please come to the High Street entrance door and a
member of staff will let you into the Chamber. 
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GUIDANCE NOTES 
* Declaration of Group Decisions and Members Interests - The Chair of the
meeting shall seek declarations from any individual or political group at the
beginning of a meeting whether any prior decision has been reached on how the
individual or members of the group will vote on any item(s) of business on the
Agenda, and if so on which item(s).  A prior decision shall be one that the
individual or the group deems to be mandatory on the individual or the group
members such that the individual or the group members will be subject to
sanctions should they not vote in accordance with the prior decision.  Any such
prior decisions will be recorded in the Minute of the meeting. 
** Written Questions - Any Member can put one written question about any relevant
and competent business within the specified remits not already on the agenda, to
the Chair provided it is received by the Proper Officer or Committee Services by
5pm three working days prior to the day of the meeting, please see Standing Order
36 for deadlines.  A copy of any written answer provided by the Chair will be
published on the Council’s committee management system by 12pm the day
before the meeting.  The Member who has put the question may, after the answer
has been published, may ask one supplementary question directly related to the
subject matter at the meeting, but no discussion will be allowed. 
No supplementary question can be put or answered more than 10 minutes after
the Council has started on the relevant item of business, except with the consent
of the Chair. If a Member does not have the opportunity to put a supplementary
question because no time remains, then he or she can submit it in writing to the
Proper Officer who will arrange for a written answer to be provided within 7
working days. 
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MORAY COUNCIL 
Housing and Community Safety Committee 
SEDERUNT 
Councillor Amber Dunbar  (Chair)
Councillor Paul McBain  (Depute Chair)  
Councillor Neil Cameron  (Member)
Councillor Tracy Colyer  (Member)
Councillor John Divers  (Member)
Councillor Jérémie Fernandes  (Member)
Councillor Donald Gatt  (Member)
Councillor David Gordon  (Member)
Councillor Juli Harris  (Member)
Councillor Sandy Keith  (Member)
Councillor Marc Macrae  (Member)
Councillor Shona Morrison  (Member)
Councillor Derek Ross  (Member)
Councillor John Stuart  (Member)  
Ms Beverley Davenport  (Non-Voting Member)
Ms Elizabeth McKnockiter  (Non-Voting Member)
Clerk Name: Lissa Rowan
Clerk Telephone: 07765 741754
Clerk Email: committee.services@moray.gov.uk 
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MORAY COUNCIL 
Minute of Meeting of the Housing and Community Safety Committee 
Tuesday, 18 November 2025 
Council Chambers, Council Office, High Street, Elgin, IV30 1BX 
PRESENT 
Councillor Neil Cameron, Councillor Tracy Colyer, Ms Beverley Davenport, Councillor
John Divers, Councillor Amber Dunbar, Councillor Jérémie Fernandes, Councillor
Donald Gatt, Councillor David Gordon, Councillor Juli Harris, Councillor Sandy Keith,
Councillor Marc Macrae, Councillor Paul McBain, Ms Elizabeth McKnockiter,
Councillor Derek Ross 
APOLOGIES 
Councillor James  Allan, Ms Alison Angus, Councillor Shona Morrison, Councillor John
Stuart 
IN ATTENDANCE 
Executive Director Education, Housing and Communities; Head of Housing, Property
and Communities; Service Manager Housing Strategy; Service Manager Property,
Estates and Assets; Service Manager Housing Operations; Service Manager Building
Services; M Gray, Senior Housing Officer; G Henly, Senior Housing Officer; G
Anderson, Senior Solicitor and L Rowan, Committee Services Officer.   
1         Chair 
Councillor Amber Dunbar chaired the meeting.    
2 Welcome 
The Chair welcomed the Executive Director Education, Housing and Communities to
her first meeting of the Committee since the Corporate restructure. 
3         Declaration of Group Decisions and Members Interests 
In terms of Standing Orders 21 and 23 of the Councillors’ Code of Conduct, there
were no declarations from Group Leaders or Spokespersons in regard to any prior
decisions taken on how Members will vote on any item on the agenda or any
declarations of Member’s interests in respect of any item on the agenda.    
4         Resolution 
Item 4.
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The meeting resolved that in terms of Section 50A (4) and (5) of the Local Government
(Scotland) Act 1973, as amended, the public and media representatives be excluded
from the meeting for Item 15 of business on the grounds that it involves the likely
disclosure of exempt information of the class described in the relevant Paragraphs of
Part 1 of Schedule 7A of the Act.  
Para Number of the Minute Para Number of Schedule 7a 
15 Para 9 - Information on terms proposed or to be
proposed by or to the Authority. 
5         Minute of meeting of 9 September 2025 
The Minute of the meeting of the Housing and Community Safety Committee dated 9
September 2025 was submitted and approved. 
6         Written Questions 
The Committee noted that no written questions had been submitted.    
7         Housing and Property Budget Report to 30 September 2025 
Under reference to paragraph 4 of the Minute of the meeting of Moray Council dated
26 February 2025, a report by the Executive Director Education, Housing and
Communities asked the Committee to note the budget position for the Housing
Revenue Account (HRA) and General Services Housing and Property Budget for the
period up to 30 September 2025, as well as a projected outturn for the financial year
2025/26.  
Following consideration, the Committee unanimously agreed to note the budgetary
position for the period to 30 September 2025, consisting of an overspend of £283k for
the HRA and an underspend of £81k for General Services Housing and Property. 
8         Housing Investment Plan Update to 30 September 2025 
A report by the Executive Director Education, Housing and Communities informed the
Committee of the progress on the Housing Investment Plan to 30 September 2025
and provided an update on the Housing and Property Scottish Housing Quality
Standards (SHQS) Compliance Improvement Plan.  
Following consideration, the Committee unanimously agreed to note: 
(i) planned works which will improve the Council’s housing stock;
(ii) current progress of the improvement plan; and
(iii) plans to ensure compliance continues to improve. 
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9         Performance Report (Housing and Property Services) - Period to September
2025 
A report by the Executive Director Education, Housing and Communities asked the
Committee to scrutinise performance in areas of Service Planning, Service
Performance, and other related data to the end of September 2025 and note actions
being taken to improve performance where required. 
During discussion surrounding the table which displays progress on service plan
priorities, Councillor Gatt noted that one area could be considered “green” with a
lower percentage than another area with a higher percentage be coloured “amber”
and it was queried whether narrative could be included to explain the progress in
future reports. 
In response, the Executive Director Education, Housing and Communities
acknowledged that this had also been raised at a recent meeting of the Corporate
Committee and advised that she had asked the Research and Information Officers
(RIOs) to provide further narrative in this regard. This was noted. 
During further discussion surrounding Complaints and MP/MSP Enquiries, Councillor
Cameron noted that Elected Members receive a number of complaints which they
address directly and therefore do not escalate to the complaints process and asked if
there was a way these could be recorded. 
In response, the Head of Housing, Property and Communities advised that he
appreciates that Elected Members field a lot of complaints and enquiries before they
get to service level and assured the Committee that these are monitored and could
be included in future reporting. This was agreed.  
Thereafter, the Committee unanimously agreed: 
(i) to note performance in areas of Service Planning, Service Performance, and
other related data to the end of September 2025 and note actions being taken
to improve performance where required;
(ii) to note that RIOs were considering ways to provide further clarification on the
Service Plan Progress tables in future reports; and
(iii) that future reports would display complaints/enquiries dealt with by Elected
Members.    
10         Scottish Social Housing Charter Compliance 
Under reference to paragraph 9 of the Minute of the meeting of this Committee dated
9 September 2025, the meeting had before it a report by the Executive Director
Education, Housing and Communities informing the Committee of the details of the
Council's 2024/25 performance following data published by the Scottish Housing
Regulator and compliance with both the Scottish Social Housing Charter and
Regulatory Framework. 
During discussion surrounding statistics displayed as percentages, Councillor Gatt
queried whether actual figures could be displayed for context. 
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In response, the Head of Housing, Property and Communities agreed to provide this
further detail following the meeting and in future reports.  
Thereafter, the Committee unanimously agreed to note:  
(i) the Council’s performance against the Scottish Social Housing Charter in
2024/25; 
(ii) the summary of performance on the key Annual Return on the Charter (ARC)
indicators against national/benchmarking results; and
(iii) that future reports will provide actual figures as well as percentages.    
11         Strategic Housing Investment Plan (SHIP) 2026-27 to 2030-31 
Under reference to paragraph 9 of the Minute of the meeting of this Committee dated
19 November 2024, the meeting had before it a report by the Executive Director
Education, Housing and Communities asking the Committee to approve the
Council's draft Strategic Housing Investment Plan (SHIP) 2026/27-2030/31.  
Following consideration, the Committee unanimously agreed:  
(i) to note the draft SHIP;
(ii) to approve the consultative draft SHIP submitted to the Scottish Government
on 30 October 2025; and
(iii) that further progress reports on the SHIP are presented to this Committee as
required.   
12         Rent Management Policy Review 
Under reference to paragraph 8 of the Minute of the meeting of this Committee dated
9 September 2025, the meeting had before it a report by the Executive Director
Education, Housing and Communities asking the Committee to note the results of
the Rent Management Policy consultation and approve the Rent Management Policy
for implementation.  
Following consideration, the Committee unanimously agreed to:  
(i) note the recent consultation feedback results at set out in Appendix I of the
report; and
(ii) approve the final revised Rent Management Policy for implementation as set
out in Appendix II of the report.    
13         Domestic Abuse Policy 
Under reference to paragraph 8 of the Minute of the meeting of this Committee dated
13 February 2024, the meeting had before it a report by the Executive Director
Education, Housing and Communities asking the Committee to consider and approve
the contents of the Housing Service's draft Domestic Abuse Policy and approve it to
progress to public consultation. 
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Councillor Cameron, welcomed the report  and the Council’s commitment to tackling
domestic abuse through policy and in collaboration with organisations such as Moray
Violence Against Women and Girls and Moray Women’s Aid, particular as Moray has
the highest proportion of domestic abuse incidents compared to the Scottish average
and moved that the Committee approve the recommendations as printed.  Councillor
Macrae seconded this. 
During further discussion in relation to the Draft Domestic Abuse Policy consultation,
Councillor Harris noted that Moray Women’s Aid did not feature amongst relevant
stakeholders who were being consulted and queried whether this organisation could
be included given the significant work they do alongside Moray Council in supporting
victims of domestic abuse. 
In response, the Service Manager Housing Strategy agreed to include Moray Women’s
Aid in the Draft Domestic Abuse Policy consultation.  
Thereafter, the Committee unanimously agreed:  
(i) to approve the draft Domestic Abuse Policy as set out in Appendix I of the
report;
(ii) that a consultation exercise on the draft Domestic Abuse Policy is undertaken,
as set out in Section 5 of the report which will also include Moray Women’s Aid
as a consultee; and
(iii) to note that an update report, detailing the consultation findings and providing
a final Domestic Abuse policy for approval, will be presented to this
Committee in March 2026.   
14         Common Repairs Policy Review 
Under reference to paragraph 6 of the Minute of the Community Services Committee
dated 23 November 2005, the meeting had before it a report by the Executive Director
Education, Housing and Communities asking the Committee to approve the revised
draft Common Repairs Policy and agree a consultation process with relevant
stakeholders. 
During discussion, Councillor Ross noted that a 6 week consultation period would
take place between 19 November 2025 and 9 January 2026 and queried whether this
could be extended to 8 weeks given it was over the festive period. 
In response, Ms Henly, Senior Housing Officer agreed to extend the consultation
period to 8 weeks.  
Following consideration, the Committee unanimously agreed:  
(i) to note the requirement to review the Common Repairs Policy;
(ii) to approve the revised draft Common Repairs Policy, as set out in Appendix I
and Section 6 of the report;
(iii) that a consultation on the revised draft Common Repairs Policy is undertaken
with key stakeholders, as set out in Section 6 of the report subject to the
consultation period being extended to 8 weeks; and
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(iv) to note that an update report, detailing the outcome of the consultation and
providing a final Common Repairs Policy for agreement, will be presented to
this Committee in March 2026.   
15         Building Services Budget 2025-26 - Budget Monitoring [Para 9] 
Ms B Davenport, Tenant Representative left the meeting at this juncture. 
Under reference to paragraph 7 of the Minute of the meeting of this Committee dated
6 May 2025, the meeting had before it a report by the Executive Director Education,
Housing and Communities presenting the budget monitoring information for the
period to 30 September 2025 for the Building Services Trading Operation.  
The Committee joined the Chair in congratulating the Voids Team in meeting the relet
target of thirty-two calendar days with an average relet timescale of thirty-one days
and thereafter unanimously agreed:  
(i) the financial information for the period to 30 September 2025, as detailed in
Section 6 and Appendix I of the report;
(ii) Building Services operating performance for the period to 30 September 2025,
as set out in Section 7 of the report; and
(iii) the revised projected outturn to 31 March 2026, as detailed in Section 8 and
Appendix I of the report.   
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Report to: Housing and Community
Safety Committee
Meeting Date: 12 March 2026  
Report by: Executive Director Education, Housing and Communities      
Author: Daska Murray Contact Email: housingstrategy@moray.gov.uk 
Subject: Local Housing Strategy 2025-2030 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to present the Committee with the results of the public
consultation on the consultative draft Local Housing Strategy 2025-2030.  
1.2  This report is submitted to Committee in terms of Section III (G) (11) of the Council’s
Scheme of Administration relating to the formulation and implementation of the Council’s
strategic Housing Plan.  
2.  SUMMARY  
2.1  This report presents the Committee with the revised draft Local Housing Strategy (2025-
2030) for approval following a recent public consultation.  
3.  RECOMMENDATIONS  
3.1  It is recommended that Committee:   
i)  considers the feedback received during the consultation period;   
ii)  approves the revised draft Local Housing Strategy 2025-2030 and action plan
for implementation as set out in section 7.8; and   
iii)  notes that there were no changes made to the Integrated Impact Assessment
(IIA) following the consultation as detailed in section 7.8.   
Daska Murray
Senior Housing Officer (Strategy) 
Item 6.
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4.  BACKGROUND AND CONTEXT  
4.1  The Housing (Scotland) Act 2001 requires local authorities to produce a Local Housing 
Strategy (LHS) supported by an assessment of housing need and demand.    
4.2  On 13 February 2024, this Committee was advised of the “robust and credible” status of
the Housing Need and Demand Assessment 2023 (HNDA) (paragraph 6 of the Minute
refers).  
4.3  On 24 June 2025, this Committee considered a report on the development of the LHS
2025-2030 (paragraph 9 of the Minute refers).    
4.4  This Committee were asked to approve a consultative draft LHS 2025-2030 for public
consultation (paragraph 7 of the Minute refers).  The consultative draft was developed in
accordance with Scottish Government guidance published in 2019.   
5.  LHS DEVELOPMENT AND CONSULTATION PROCESS  
5.1  The draft LHS set out how the Council and its partners intend to alleviate housing need,
address homelessness and improve the whole housing system across Moray.  It has been
developed using a collaborative co-production approach between partners, stakeholders
and public consultation.  It is underpinned by the findings of the HNDA 2023.    
5.2  Development of the LHS 2025-2030 was overseen by the multi-agency Housing Market
Partnership, supported by Arneil Johnston.  The Partnership includes representatives from
the relevant Council services and other agencies such as Planning, Health and Social
Care Moray, NHS Grampian, Registered Social Landlords, Scottish Government,
enterprise companies, private sector representative bodies and third sector
representatives.  Their contributions were central in shaping the draft, particularly in
identifying and refining the priorities and actions identified through early engagement.  
5.3  The draft LHS vision is “In Moray everyone has access to the right home, in the 
right place at the right time”.  To achieve this vision and tackle the main priorities for action 
identified by local residents, partners and stakeholders, the following four LHS priorities 
have been defined:
• Priority 1: Building more homes creates sustainable communities and enables
economic growth.
• Priority 2: Making better use of existing homes prevents homelessness and
improves housing options and choice.
• Priority 3: Partnership working maximises housing’s role in improving health and
wellbeing.
• Priority 4: Improving property condition and achieving affordable warmth is enabled
in all homes.  
5.4  A public consultation on the consultative draft LHS took place between 18 September to
14 November 2025.  This was published on the Council’s Moray Engage portal
accompanied by an online survey, with paper copies available on request.  The survey was
structured in a way to enable respondents to skip sections if these were less relevant to
them.  While earlier engagement focused on identifying key issues for inclusion in the LHS,
this final stage of consultation focused on assessing support for each priority and the
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actions associated with these, but with the facility to provide optional comments.  The
survey findings are presented in Section 6.  
5.5  The public consultation was promoted through a press release, social media activity and
internally on the Interchange.  Targeted emails were issued to an extensive list of
stakeholders, with a reminder sent two weeks before the consultation closed.    
6. LHS CONSULTATION RESPONSE  
6.1 The public consultation generated 70 responses, of which 9% represented views from
organisations and 91% from individuals.  This represents a significant increase compared
to the previous LHS review, which received 15 responses.  The results are summarised
below.  (Percentages may not tally exactly to 100% due to rounding).  
6.2 Overall, the feedback received was generally positive and only minor changes were
needed to the consultative draft LHS and action plan.  The results show significant support
for each of four priorities identified: 
Priority 1: Building more homes creates sustainable communities and enables
economic growth.
6.3 The majority of respondents supported this priority.  Of the 70 responses received, 46
(66%) either strongly agreed or agreed, 13 (19%) were neutral, and 11 (16%) disagreed or
strongly disagreed.    
6.4 Respondents could submit comments on any of the four priorities identified and 22
comments were received.  These were then analysed for themes relevant to each priority,
with some having relevance to multiple priorities.  The themes relevant to this priority
included:  
• support for increasing social housing supply, particularly to reduce homelessness
pressures;
• there being unmet need for certain types of properties across all housing tenures,
especially accessible homes for older people and smaller homes suited to single
households or couples;
0% 20% 40% 60% 80% 100%
Priority 4
Priority 3
Priority 2
Priority 1
LHS 2025-2030 : Do you agree with these priorities?
Don't know
Strongly disagree
Disagree
Neither agree nor disagree
Agree
Strongly agree
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• some of the comments were more relevant to other Council housing policy areas
not directly relevant to the scope of the LHS and therefore no changes have been
made; and
• mixed views on the wider impacts of increasing housing supply.  These comments
are more relevant for consideration within the Local Development Plan (LDP)
and/or the Council’s Economic Strategy.  
6.5 Respondents were then asked to give an approval rating for each item of the LHS action
plan associated with this priority.  A total of 54 responses were received to this part of the
survey, with high levels of support (ranging between 81%-91%) for each of the actions
suggested.    
6.6 The survey invited comments on the proposed actions for these priorities, and whether
there was anything else that could be done to achieve priority 1.  Comments returned on
the actions generally repeated the earlier themes noted, with some additional points:  
• a need to address under occupancy and make better use of the available housing
stock (considered under priority 2);
• the need for housing options for key workers;
• concerns that private sector new build often focuses on large family homes or
luxury housing, rather than accessible or smaller homes sought out by older people
or smaller households; and 
• a suggestion to incorporate the Cairngorms National Park Partnership Plan 2022-27
within Section 2.2 of the LHS (Strategic Context for Housing in Moray), which has
been actioned.   
Priority 2: Making better use of existing homes prevents homelessness and improves
housing options and choice.
6.7 There was strong support for priority 2.  Of the 70 responses, 67 (96%) strongly agreed or
agreed, 2 (3%) who gave a neutral ‘neither nor’ response, and 1 respondent (1%) who
disagreed.  The themes of the comments received relevant to this priority were
suggestions to review Council sheltered housing provision, and that facilities vary
significantly across areas.  This is an action within the proposed action plan.  There were
no comments regarding empty homes.  
6.8 Respondents rated the actions associated with priority 2.  There were 54 responses to this
part of the survey, with the majority (ranging between 79%-84%) supporting each of the
actions suggested for this priority.  Most of the comments returned for these actions
repeated the earlier themes, apart from the following:  
• the need to reduce underoccupancy in the affordable housing sector;
• several comments on short term lets and second homes impacting housing
availability; and
• the need to provide enhanced actions to support tenancy sustainment.   
Priority 3: Partnership working maximises housing’s role in improving health and
wellbeing.  
6.9 Most respondents supported this priority.  A total of 55 respondents (79%) either strongly
agreed or agreed, 13 respondents (19%) gave a neutral response of neither agree nor
disagree or don’t know, and 2 respondents (3%) disagreed or strongly disagreed. 
Comments mainly highlighted the importance of warmer homes and improved
soundproofing in flatted properties to support health and wellbeing.
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6.10 Respondents were asked to rate the proposed actions associated with this priority.  There
were 55 responses, with strong support for the actions proposed (84%-98%).   Comments
on the actions largely repeated themes noted earlier.  Additional points raised included:
• a need for housing suitable for specific needs or different life stages, such as young
people with disabilities and older people; and 
• comments relating to the lack of provision of specialist housing for people with
mental health support needs.  Text has been added to the revised draft LHS to
address this, and provision has been included in the SHIP approved on 18
November 2025 (paragraph 11 of the draft Minute refers).   
Priority 4: Improving property condition and achieving affordable warmth is enabled
in all homes.
6.11 The majority of responses were supportive of this priority.  There were 64 respondents
(91%) who strongly agreed or agreed, 2 respondents (3%) who gave a neutral (neither
agree nor disagree) response, and 4 respondents (6%) who either disagreed or strongly
disagreed.   Comments for this priority were mainly specific to social housing, or the
Council’s housing stock maintenance in particular:
• the need to prioritise energy efficiency and fabric improvements to Council stock;
and
• concerns about the affordability of energy efficiency standards for the social rented
sector.  
6.12 There were 54 responses to the approval ratings for the actions associated with priority 4.
Most actions received strong support (ranging between 67%–91%).  The survey invited
comments on these actions, and whether there was anything else that could be done to
achieve priority 4.  Only a few comments were received, some repeating the earlier
themes noted apart from the following:  
• the value of encouraging sustainable development through construction incentives
and prioritising local labour;
• less support for an action relating to carbon credits, which was removed from the
action plan as a result; and
• a view that apprenticeship programmes could be strengthened and should be
promoted better to young people.  The development of the apprenticeship
programmes will be led by the Community Wealth Building Team.  
7. LHS PUBLICATION  
7.1 The consultative draft LHS was submitted to the Scottish Government on 2 October 2025. 
The Scottish Government make arrangements for a peer review to be carried out by a
panel of officers from the Scottish Government and other local authorities.  The findings of
the panel are intended to be learning opportunities.  The Council is not required to make
further changes to its final LHS following the peer review process.  
7.2 Since the consultative draft was issued, a further amendment has been necessary to
reflect a new two-year partnership between Aberdeenshire Council and Moray Council to
deliver an empty homes service.  This fulfils the aims of the Strategic Empty Homes
Partnership acting for the Scottish Government, who have partly funded the project. 
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7.3 A revised draft strategy and action plan incorporating the amendments detailed in this
report have been uploaded to the Council’s website for consideration at
www.moray.gov.uk/housingstrategies.  No additional changes to the draft Integrated
Impact Assessment (IIA) were required following the public consultation.  It is proposed
that the Committee consider and approve these for publication, and implementation
begins with immediate effect.    
8. SUMMARY OF IMPLICATIONS  
8.1 The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X 
Policy and Legal  X
Financial  X
Risk  X
Staffing  X
Best Value and Transformation  X
Property  X
Information Communications Technology/Digital  X
Equalities. Social Inclusion and Economic Impact  X 
Climate Change and Biodiversity Impact  X 
8.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☒ Tackle Poverty and Inequality.
☒ Build Stronger Greener Vibrant Economy.
☒ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☒ Developing a diverse, inclusive, and sustainable economy
☒ Building a better future for our children and young people in   Moray.
☒ Empowering and connecting communities.
☒ Improving wellbeing of our population 
8.3 Policy and Legal 
It is a requirement of the 2001 Housing (Scotland) Act that local authorities have a Local 
Housing Strategy.  Detailed guidance has been produced by the Scottish Government.   
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8.4 Financial 
There are no implications arising directly from this report. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments       
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments       
8.5 Risk 
There are no implications arising directly from this report.  
8.6 Staffing 
There are no implications arising directly from this report.  
8.7 Best Value and Transformation 
There are no implications arising directly from this report.  
8.8 Property 
There are no implications arising directly from this report.  
8.9 Information Communications/Technology/Digital 
There are no implications arising directly from this report.  
8.10 Equalities, Social Inclusion and Economic Impact 
It is a statutory requirement that equality issues should be addressed in the LHS.  The LHS
includes strong themes on economic disadvantage and inequality.  Data and evidence
about the specialist housing and support needs of equalities groups have been gathered
as part of the Council’s Housing Need and Demand Assessment 2023.  The revised draft
LHS sets out how the Council intends to address these needs.  There have been no
changes to the draft Integrated Impact Assessment following the public consultation.  
8.11 Climate Change and Biodiversity Impacts 
The aims of the Local Housing Strategy are closely aligned to the Council’s Climate
Change Strategy, and Local Heat and Energy Efficiency Strategy (LHEES). 
9. CONSULTATION  
9.1 This report has been prepared in consultation with the Executive Director Education,
Housing and Communities, the Head of Housing, Property and Communities, the Head of
Growth, Planning and Climate, G. Anderson (Legal Services Senior Solicitor), the Chief
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Social Work Officer, Chief Officer MIJB, the Service Manager Housing Strategy, the Service
Manager Property, Estates and Assets, the Service Manager Housing Operations, the
Service Manager Housing Need, the Equal Opportunities Officer and L. Rowan
(Committee Services Officer).   
10. BACKGROUND PAPERS  
10.1 Held by author. 
Consultative Draft Local Housing Strategy 2025-2030 
Strategic Housing Investment Plan (SHIP) 2026/27 to 2030/31 
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Report to: Housing and Community
Safety Committee 
Meeting Date: 12 March 2026  
Report by: Executive Director Education, Housing and Communities  
Author: Fiona Geddes Contact
Email:
housingstrategy@moray.gov.uk 
Subject: Moray Affordable Housing Investment Programme 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to inform the Committee of progress on the Affordable
Housing Investment Programme in Moray.  
1.2  This report is submitted to Committee in terms of Section III (G) (10) of the Council's
Scheme of Administration relating to the preparation and implementation of strategic
housing plans. 
2.  SUMMARY  
2.1  The report provides details of an update on the current and future affordable housing
investment programme, including the recently received Resource Planning Assumption for
2025/26.  The report also provides an update on the Council’s own new build and
acquisition programme, including an update on development of Bilbohall, Elgin. 
3.  RECOMMENDATIONS 
3.1  It is recommended that Committee scrutinise and note progress on:   
i)  the Moray Affordable Housing Investment Programme; 
i)  delivery of housing intended to meet the workforce housing needs of SSEN
Transmission and their sub-contractors; and 
ii)  delivery of housing at Bilbohall, Elgin; and 
iii)  the delivery of the Council’s new build and acquisition programme.   
Fiona Geddes
Item 7.
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Housing Strategy and Development Manager 
4.  BACKGROUND AND CONTEXT  
4.1  The Council receives an annual resource allocation from the Scottish Government to fund
the supply of new affordable housing in Moray.  The Council’s Strategic Housing Investment
Plan (SHIP) determines how this funding will be used to plan and deliver the affordable
housing priorities of the Local Housing Strategy.  The investment and project priorities set
out in the SHIP form the basis of an annual Strategic Local Programme Agreement (SLP)
between the Council and the Scottish Government.  The SLP details the projects that will be
funded during the year, the affordable housing developers who will deliver them, the targets
for grant expenditure and the milestones by which progress on delivery will be measured. 
The Council and Registered Social Landlords (RSLs) are the principal developers of
affordable housing in Moray.  
4.2  On 13 February 2024, this Committee approved a rationale for prioritisation of projects
anticipated to start during 2024/25/26 (paragraph 9 of the Minute refers).  The agreed
priorities are: 
• corporate and strategically important projects, i.e. Bilbohall; Speyview, Aberlour;
• supported housing for people with learning disabilities i.e. Woodview2, Lhanbryde;
Western Village, Elgin South;
• Growth Deal Housing Mix Project developments i.e. South Street/High Street, Elgin;
Dallas Dhu, Forres;
• NHS key worker housing, to be agreed following the publication of NHS Housing Need
Assessment currently in development; and
• Open market acquisition of long-term empty homes.  
4.3  On 18 November 2025, this Committee approved the Council’s SHIP 2026/27 – 2030/31
(paragraph 10 of the draft Minute refers).  
4.4  The last update on the Affordable Housing Investment programme was presented to this
Committee on 24 June 2025 (paragraph 8 of the Minute refers). 
5.  MORAY STRATEGIC LOCAL PROGRAMME (SLP) 
5.1  On 1 May 2025, Moray Council received notification of the RPA for 2025/26 of £8.902m plus
£0.093m for acquisitions specifically to help address temporary accommodation
pressures, totalling £8.995m.  This is similar to pre-2024/25 allocations.  The Scottish
Government and the Council have agreed a SLP for 2025/26 based on this funding
allocation.  No indication of RPA for subsequent years has been provided.  
5.2  As in previous years, the Moray programme will be delivered by a combination of the
Council and the RSLs, Grampian Housing Association, Cairn Housing Association, Osprey
Housing. 
5.3  In recent years, the amount of More Homes Division grant has been over-committed against
RPA, and this has the support of the Scottish Government as an opportunity to take
advantage of programme slippage in other local authority areas and to contribute to the
aims of Housing to 2040.  
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5.4  The following tables illustrate the affordable housing programme for 2025/26 where
Scottish Government funding has been secured, or where the project fits with the
prioritisation described at Para 4.2 above: 
Currently under construction
Site Town No of
units Landlord Completion
date (est)
Speyview Phase 1 Aberlour 39 Moray Council Jan-Mar 2026
Kinneddar Meadows Lossiemouth 8 Osprey Housing Feb 2026
Western Village, Elgin South Elgin 42 Grampian HA May 2026
High St/South St Regen Elgin 38 Cairn HA Oct 2026
Firth Rise, Hopeman R1 Hopeman 12 Osprey Housing Jul-Nov 2026
Speyview Phase 2 Aberlour 31 Moray Council Dec 2026
Total 170   
Site start expected during 2025/26
Site Town No of
units Landlord Site start (est)
Bilbohall Phase 1 (R2) Elgin 28 Moray Council Jan 2025
Total 28   
Site start expected during 2026/27
Site Town No of
units Landlord Site start (est)
Bilbohall Phase 2 
(R3 Care Village) Elgin 22 Grampian HA TBC
Garmouth Road (Woodview2) Lhanbryde 34 Grampian HA Aug 2026
Hill Street (Ph2) Dufftown 5 Moray Council TBC
Elgin South, The
Campus/Birnie Wood East Elgin 51 Grampian HA TBC
Total 112   
5.5  Officers will continue to maintain a substantial shadow programme of developments. 
Should additional grant funding become available, officers will be able to bring a project(s)
forward from the shadow programme, in accordance with the priorities set out at Para 4.2
and in the SHIP.  
5.6  Progress on programme delivery will be reported to this Committee on a biannual basis. 
6.  MORAY STRATEGIC LOCAL PROGRAMME (SLP) 2025/26   
SSENT
6.1 SSENT have plans to complete a £20 billion investment programme.  Full details are
available on the SSENT website at Projects - SSEN Transmission.  SSENT need to bring their
workforce into the north of Scotland to deliver this programme.  This impacts on Highland,
Moray, Aberdeenshire and Angus local authority areas.  Workforce accommodation will be
required during 2025 – 2030. 
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6.2 Officers have provided options for SSENT, drawn from the SHIP Shadow Programme, with
the aim of enabling delivery of affordable housing stalled due to lack of funding.  Given that
delivery and occupation within required timescales are fundamental to SSENTs
programme, options where planning consent has already been granted have been
prioritised.  At the time of writing social landlords, including Moray Council, were actively
considering participation.    
6.3 Proposals for the Council’s participation in delivery on sites at Banff Road, Keith; Bain
Avenue, Elgin; and R1 Lhanbryde are being actively considered.  SSENTs intended exit
strategy is disposal of properties to Moray Council as affordable housing for rent when their
investment works programme and workforce housing need ends in approximately 4-5 years. 
The Scottish Government have been clear that no grant subsidy is available for these
developments, but they welcome the opportunity for a legacy of affordable housing to
result from SSENTs activity.   
Bilbohall, Elgin 
6.4 Following a competitive tender process, Ogilvie Construction have been appointed to
deliver a first phase of development (28 units), with construction beginning in spring 2026.    
6.5 Scottish Government funding has been secured via exchange of signatures.    
6.6 The first phase includes provision of shared infrastructure and advance planting
requirements.  This has necessitated a significant amount of Scottish Government grant
funding, taking up a large proportion of RPA.  This has impacted the site starts possible
during 2025/26 and is reflected in Para 5.4 above.  
7. COUNCIL ACQUISITION PROGRAMME 
7.1 The SHIP provides facility to purchase properties from the open market for provision of
affordable housing, where strategic and value for money criteria have been met.  
7.2 On 20 November 2025, the Scottish Government provided details of the distribution of the
Housing First Capital Funding 2025/26.  Moray Council has access to £0.041m.  
7.3 The projected outturn for 2025/26 is presented in the table below.     
2025/26
Funding Source Budget outturn
spend * completions pending
completions Total
Affordable Housing
Supply Programme
RPA £0.303m 1 3 5
Rural Affordable
Homes for Key
Workers Fund
Additional to RPA
but national
budget
£0.149m 2 0 2
Temporary
Accommodation
Pressures
£0.369m
ringfenced within
RPA
£0.369m 6 0 6
Housing First Capital
Fund
£0.041m
ringfenced
£0.041m 0 1 1 
* Projected
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8. SUMMARY OF IMPLICATIONS  
8.1 The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X 
Policy and Legal X 
Financial  X
Risk X 
Staffing  X
Best Value and Transformation  X
Property X 
Information Communications Technology/Digital             X
Equalities. Social Inclusion and Economic Impact             X 
Climate Change and Biodiversity Impact            X 
8.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☒ Tackle Poverty and Inequality.
☒ Build Stronger Greener Vibrant Economy.
☒ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☒ Developing a diverse, inclusive, and sustainable economy
☒ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☒ Improving wellbeing of our population   
8.3 Policy and Legal 
The affordable housing supply programme contributes to meeting the Council’s statutory
duties to address homelessness and meet housing need in Moray.  Assisting SSEN in their
objectives will contribute to delivery of the Council’s Economic Strategy, to delivery of new
build housing, and to achieving energy security in the longer term.  
8.4 Financial 
The report provides details of the resources being made available by the Scottish
Government to part-fund affordable housing in Moray.  The Council has agreed that 50 new
council houses will be built per annum. The current HRA Business Plan has made
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provision for the level of borrowing required to part-fund the Council’s housebuilding
programme. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments       
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments       
8.5 Risk 
The lack of RPA beyond 2025/26 is a significant risk to larger developments where
construction costs may extend beyond one financial year.  Moray Council and RSL Boards
may be unable to commit to a project if the Scottish Government funding commitment is
unconfirmed. 
There is a risk that slippage or reduction in the programme will result in loss of Scottish
Government More Homes Division grant funding to Moray, with the funds diverted to other
LAs. 
The programme may be impacted by economic and market conditions and site-specific
issues as developments proceed.  In particular, interest rates and potential front funding
will impact on the cost of development.  There are processes in place to manage these
risks and mitigations considered.  
8.6 Staffing 
There are no implications arising from this report  
8.7 Best Value and Transformation 
There are no implications arising from this report  
8.8 Property 
The report details the ongoing programme for development of additional affordable
housing in Moray in response to strategic needs and specifically the Council new build
programme to increase the Council’s own supply of affordable housing.  
8.9 Information Communications/Technology/Digital 
There are no implications arising from this report.  
8.10 Equalities, Social Inclusion and Economic Impact 
The housing needs of equalities groups are identified in the Local Housing Strategy (LHS). 
The Moray Affordable Housing Programme seeks to deliver the housing priorities identified
in the LHS.
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The property mix for the new build project has been influenced by Housing Need and
Demand Assessment findings which includes consideration of specialist housing needs. 
The detailed proposals include provision for amenity accommodation for older people,
and larger family sized housing intended to alleviate overcrowding, when the properties
revert to use as affordable housing. 
8.11 Climate Change and Biodiversity Impacts   
The aims of the affordable housing programme are closely aligned to the Council’s Climate
Change Strategy, and Local Heat and Energy Efficiency Strategy (LHEES).   
Assisting SSENT in the delivery of their investment programme will facilitate energy
security and contribute to electricity supply sufficient for the transition to zero carbon.  
9. CONSULTATION  
9.1 This report has been prepared in consultation with the Executive Director Education,
Housing and Communities, the Head of Housing, Property and Communities, the Head of
Economic Growth and Development, Service Manager Legal Services, the Service
Manager Property, Estates and Assets, the Service Manager Housing Need, the Service
Manager Housing Operations, the Service Manager Strategic Planning and Development,
the Integrated Service Manager Community Learning Disability Team, and L. Rowan,
Committee Services Officer. 
10. BACKGROUND PAPERS  
10.1 Strategic Housing Investment Plan (SHIP) - Moray Council
Moray Affordable Housing Investment Programme June 25.ashx 
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Report to: Housing and Community Safety
Committee
Meeting
Date:
12 March 2026  
Report by: Executive Director Education, Housing and Communities  
Author: Neil Strachan Contact
Email:
Neil.strachan@moray.gov.uk 
Subject: Housing Investment Plan Update to 31 December 2025 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to inform the Committee of the progress on the Housing
Investment Plan to 31 December 2025 and provide an update on the Housing and Property
Scottish Housing Quality Standards (SHQS) Compliance Improvement Plan.  
1.2  This report is submitted to Committee in terms of Section III G (3) of the Council’s Scheme
of Administration relating to the maintenance of the Council’s housing stock.
APPENDICES I – VI provides detailed spend in accordance with the unaudited draft
figures for the investment programme.    
2.  SUMMARY  
2.1  The report provides details of the progress of the housing investment programme during
this financial year where overall spend to date is £13,699k representing 38% of the budget. 
It is anticipated that at year end there will be an underspend of circa £2.031k.  The report
further updates on the progress of the Scottish Housing Quality Standard (SHQS) and
EESSH compliance improvement plan.  
3.  RECOMMENDATIONS 
3.1  It is recommended that Committee considers and :   
i) notes the planned works which will improve the Council’s housing stock;   
ii) notes the current progress of the improvement plan;   
iii) notes the plans to ensure compliance continues to improve;   
iv)  declares surplus to requirements 11 Sutherland Street, Buckie; and
Item 8.
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v) Recommends to Moray Council that  delegation is given to  the Head of
Housing, Property and Communities to declare surplus to requirements
single residential properties at the next review of the Scheme of Delegation.   
Neil Strachan
Service Manager Property, Estates and Assets 
4.  BACKGROUND AND CONTEXT  
4.1 The Council meeting of 26 February 2025 approved the Housing Revenue Account Annual
Budget for 2025-26 (para 4 of the minute refers).   APPENDIX I shows the approved budget
for 2025/6, which is £36,443k.  This report provides an update on the investment plan to 31
December 2025.    
4.2 The Housing Investment Plan reflects the investment priorities which tenants identified
within the most recent tenant survey and regulatory requirements. As of 31 December
2025, 55% of our stock met SHQS, compared with 80% of our peer group.  Database
compliance checks and uploads are currently ongoing, and it is anticipated that the
overall compliance rate will improve as these updates are completed. APPENDICES I-VI
and the below provide an outline of annual budget, commitment and variance to 31
December 2025.    
4.3 APPENDIX I shows the total income and expenditure for financial year 2025/26.  The figure
shows that as at 31 December, end of Quarter 3, expenditure of £20,954k was achieved,
which represents a spend of 57.5% against the £36,443k annual budget allocation.  This
represents an underspend attributed generally due to reduced tenant uptake in
improvement works and mobilisation of contracts. It is anticipated that there will be an
overall year end underspend of circa £2,031k. 
Annual Budget 
(£000’s)
Spend to 31 December
2025
(£000’s)
Variance to 31
December 2025
(£000’s)
£36,443 £20,954 £15,489 
4.4  APPENDIX II shows expenditure on Response and Void repairs.  Spend is £3,946k to 31
December 2025.  Overall expenditure to date is at 66% which is slightly underspent at
quarter 3.  The gas repairs are showing a significant underspend at 43% although this is
not unsurprising as the period does not include the traditionally colder winter months and
there has been significant investment in heating upgrades over the last few years. Void
house repairs are placing a pressure on this budget with a requirement being placed on
the DLO to keep this on budget.   
Annual Budget 
(£000’s)
Spend to 31 December
2025
(£000’s)
Variance to 31
December 2025
(£00’s)
£6,000 £3,947 £2,053 
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4.5 APPENDIX III shows expenditure on Estate Works which has an annual budget of 
£740k.   Current spend represents 71% of the budget is committed as at 31 
December 2025.   The largest spend was on the Estate Upgrade budget, which is already 
overspent by 23%. It is anticipated to have a yearend overspend of circa £500k.  This
additional spend is attributable to an increase in works via a combination of Estate
Walkabouts and the clearing of a backlog of maintenance. Works in this area include car
park repairs, external wall reinstatements, tree removals and fencing. The decision has
been made to underspend on the asbestos budget to be used to ensure the overall Estate
Works budget does not overspend and will project an underspend of £65,000. 
Annual Budget 
(£000’s)
Spend to 31 December
2025
(£000’s)
Variance to 31
December 2025
(£000’s)
£740 £526 £214 
4.6 APPENDIX IV shows the expenditure on Cyclical maintenance.  Spend to 31 December
2025 is £1,176k which represents 67% committed with a remaining budget of £580k.   The
external decoration and fabric repair budget has 84% committed and will be controlled to
ensure no overspend in this area. Overall, this budget is expected to be underspent by
£60k. 
Annual Budget 
(£000’s)
Spend to 31 December
2025
(£000’s)
Variance to 31
December 2025
(£00’s)
£1,756 £1,176 £580 
4.7 APPENDIX V shows the planned maintenance and other investment split between Capital
and Revenue spend.  Overall, the capital spend was £13,647k to 31 December 2025,
which represents 51% of the budget.   The revenue spend is £1,159k representing and
overspend of £185K of the budget. It is expected that this overall budget will underspend
by year end of £2,241k. 
Annual Budget 
(£000’s)
Spend to 31 December
2025
(£000’s)
Variance to 31
December 2025
(£00’s)
£27,947 £14,806 £13,141 
This budget covers the main areas of improvement investment. Recognising that window
replacement is a key tenant priority, the budget for this work was increased to £3m for the
2025/26 financial year.  As of 31 December 2025, a total of 79 properties has received
window upgrades, and 217 doors have been replaced.  Windows and doors remain a high
priority, and the Housing Asset Team is actively progressing procurement planning for the
2026/2027 programme to ensure continued delivery which aligns with tenant
expectations. Insulation continues to be a priority and the budget allocation for 2025/26 is
£750k. Spend within this planned budget is lower than expected, however this is balanced
with the overspend on the EESSH insulation budget line which has delivered a total of 885
insulation measures. It should be noted that there is spend of £606k in the capital section
against Electrical Upgrades. These are works directly connected with the improved
certification of the stock required for SHQS compliance and had not been budgeted
separately however will be covered by underspends within the capital budgets. In respect
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of revenue spend Electrical Upgrades has a significant overspend which again is in relation
to the additional certification that will be required for SHQS compliance. The expected
overspend of circa £450k will be partly met by underspends in other revenue budgets
stated above however there is expected to be an overall revenue overspend of circa £250k.  
4.8 APPENDIX VI shows the income and expenditure for Private Sector Housing Grants to 31
December 2025.   
Income and Expenditure for Private Sector Housing
APPENDIX VII shows the position with regard to grant expenditure for Private Sector
Housing Grant to 31 December 2025. 
The legally committed figure in Category C of £43k represents 100% of the allocated
budget. Spend to 31 December 2025 was £22k which represents 51% of the allocated
budget. 
Annual Budget 
(£000’s) 
Spend to 31 December
2025
(£000’s) 
Variance to 31
December 2025
(£00’s) 
43 22 21 
5.  HOUSING AND PROPERTY IMPROVEMENT PLAN UPDATE  
5.1  A programme of electrical inspection and certification to meet the enhanced
requirements of Scottish Housing Quality Standard (SHQS) has continued to be
undertaken in the course of 2025/26.  Over 90% of properties have now been visited with
full electrical SHQS compliance recorded in 74% of the housing stock.  The electrical
upgrade budget is £150k, however, as stated above to meet EICR remedial work and
additional electrical upgrades has resulted in an overspend in revenue and capital.  
5.2  The second key component of SHQS, is the Energy Efficiency Standard for
Social Housing (EESSH) compliance.  As of 31 December 2025, 73% of the
Council’s housing stock meets the EESSH standards. However, it is important to note that
changes to the EPC calculation methodology (RDSAP 10) introduced in mid-June 2025 may
affect future compliance.  These changes require some additional energy efficiency 
measures to ensure properties achieve the revised EPC ratings.  The Housing 
Asset Team is working with current contractors to ensure compliance can be achieved as
soon as possible.  
5.3  The improvement action plan as reported to this Committee on 7 May 2024 has continued
to deliver programmed works to a number of properties (para 9 of the Minute refers).  The
delivery model identified improvements across three management areas:
1) Moray East
2) Moray Central
3) Moray West  
5.4 The programme has continued in 2025/2026, with a budget of £17,950k allocated with
£7,957k committed to date, however, in appendix V it should be noted for financial
reporting purposes some of the spend has been split between the budget headings of
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Kitchens and Bathrooms, Bathroom Replacements, Central Heating and Doors and
Windows.  The budget will ensure that the programme continues to deliver until the end of
the financial year in 2025/26, delivering further on kitchen, bathrooms, heating upgrades
and insulation upgrades across the housing stock.  This programme from its start has
delivered the following improvements so far: 
384 Heating installations 
290 Kitchen upgrades 
319 Bathroom upgrades 
935 Insulation improvements (loft, cavity, internal & external wall) 
145 Solar /PV 
5.5 In addition to this, a separate programme of works in relation to properties in the Pinegrove
area of Elgin has recently commenced. A programme of improvements including cavity
wall insulation, heating and kitchen upgrades will be undertaken.  Spend on this project to
date is £414k.  
5.6 As the range of retrofit measures continues to be implemented across all areas of the
accelerated programme,  it has been noted that, gaining access to properties and tenant
refusal for upgrade works has become increasingly challenging. This has impacted the
pace of delivery.  As a result, contract durations are being extended to accommodate
these access issues and provide time for officers and contractors to work with tenants to
help ensure all properties can receive these improvements.  
6 Surplus Property  
6.1 Following a review of long-term void properties, it was identified that the property at 11
Sutherland Street, Buckie required extensive work to bring up to a lettable standard and
meet all regulatory requirements. An appraisal of the property was undertaken with costs
of upgrading the property to meet required regulatory standards would be in excess of
£72,000. Considering the cost, value and housing demand it was established that the best
value outcome for the Housing Revenue Account would be to dispose of the property.  
6.2 A review of the Council governance process highlighted that the declaring of surplus
Housing Assets was not delegated to the Head of Housing, Property and Communities it is
therefore requested that Committee approve the declaring of this property surplus to
requirements and recommends to Moray Council that future delegation is granted  to the
Head of Housing, Property and Communities when the Scheme of Delegation is reviewed.  
7. SUMMARY OF IMPLICATIONS  
7.1 The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) √ 
Policy and Legal √ 
Financial √ 
Risk √ 
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Staffing  √
Best Value and Transformation  √
Property √ 
Information Communications Technology/Digital              √
Equalities. Social Inclusion and Economic Impact   √
Climate Change and Biodiversity Impact  √ 
7.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☒ Tackle Poverty and Inequality.
☒ Build Stronger Greener Vibrant Economy.
☒ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☒ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☒ Improving wellbeing of our population 
7.3 Policy and Legal 
The Council undertakes maintenance and improvement works to ensure compliance with
statutory legal obligations and in alignment with current policies and best practices.  
7.4 Financial 
The financial implications associated with this report are detailed in paragraphs 4.1 to
5.7.  The planned level of spend achieved in 2025/26 is as set out in APPENDIX I. 
7.5 Risk 
Failure to expend agreed budgets have affected the Council’s ability to maintain stock at
the SHQS, replace life expired elements and attain the EESSH. Budget Managers are
aware of responsibilities for managing budget allocations and approval for variance will be
sought from Committee in line with the Financial Regulations. There is a risk of not
delivering the scale of improvement sought in 2025/26, notwithstanding the additional
resourcing of the accelerated programme. There is a corresponding risk of increased
regulatory scrutiny if the Council does not meet the SHQS requirements.  
7.6 Staffing 
There are no specific implications with this report  
7.7 Best Value and Transformation 
There are no specific implications with this report
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7.8 Property 
The improvement and maintenance of the housing stock will ensure that it remains
sustainable in the longer term both physically and environmentally.  
7.9 Information Communications/Technology/Digital 
There are no specific implications with this report.  
7.10 Equalities, Social Inclusion and Economic Impact 
There are no equalities issues associated with this report, as it is to 
inform the Committee on budget monitoring.  
7.11 Climate Change and Biodiversity Impacts 
The continued investment in the Council Owned Housing Stock identified in this report
has contributed to Moray Council achieving  its climate change targets by utilising a range
of energy saving measures that incorporate zero or low carbon into design, construction
materials and systems that support the Council in achieving The Energy Efficiency
Standard for Social Housing (EESSH). 
8. CONSULTATION  
8.1 This report has been prepared in consultation with the Head of Housing, Property and
Community Services, Service Manager Building Services, Chief Financial Officer, G.
Anderson, Senior Solicitor Legal Services, the Equal Opportunities Officer and Service
Manager Democratic Services and any comments made have been incorporated into the
report.   
9. BACKGROUND PAPERS  
9.1 None.  
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APPENDIX I 
INVESTMENT PROGRAMME INCOME AND EXPENDITURE 2025/26
31 December 2025
(All amount in £0’000) 
Annual 
budget 
2025/26
Expenditure
to date
%
budget
balance
Budget
balance
Projected
outturn to 31
March 
2026
Expenditure  
Response, Gas
and Void
Repairs
6,000 3,946 66% 2,054 5,934
Estate Works 740 526 71% 214 625
Cyclic
Maintenance
1,756 1,176 67% 580 1696
Planned
Maintenance
(Revenue)
974 1,159 119% -185 1434
Planned
Maintenance
(Capital)
26,522 13,647 51% 12,875 24,272
Other
Investment
451 500 111% -49 451
Sub total 36,443 20,954 57% 15,489 34,412 
Other Capital expenditure 
New build –
capital costs
14,117 8,088 
Total 14,117 8,088   
Funded by
HRA revenue 9,921 7,307   
Government
grant
9,285 5,241   
Use of Council
tax discount
650 0   
Prudential
borrowing
27,505 16,314   
Other Grants 0 180   
Capital
receipts
0 0   
C.F.C.R 3,199 0   
Total  50,560 29,042   
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APPENDIX II 
INVESTMENT PROGRAMME EXPENDITURE 2025/26 
31 December 2025
(All amounts in £0,000) 
RESPONSE AND VOIDS REPAIRS 
Annual budget
2025/26
Expenditure
plus
commitment to
date
%expenditure
plus committed
to date
Budget balance 
Projected
outturn to 31
March 2026
West area 969 694 72% 275 969
East area 1,521 753 50% 768 1521
Central area 874 650 74% 224 874
Void house
repairs
1,934 1,576 81% 358 1934
Voids
Decoration
voucher
66 1 2% 65 66
Gas heating
repairs
636 273 43% 363 636 
6,000 3,947 66% 2,053 6,000 
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APPENDIX III
INVESTMENT PROGRAMME EPENDITURE 2025/26
31 December 2025
(all amounts in £’000) 
ESTATE WORKS 
Annual budget
2025/26
Expenditure
plus
commitment to
date
%expenditure
plus committed
to date
Budget balance 
Projected
outturn to 31
March 2026
Garage
Upgrades
28 9 32% 19 10
Asbestos 383 95 25% 288 150
Landscape
Maintenance
92 114 124% -22 120
Estates/forum
upgrades 
237 308 130% -71 395 
740 526 71% 214 675 
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APPENDIX IV
INVESTMENT PROGRAMME EPENDITURE 2025/26
31 December 2025
(all amounts in £’000) 
CYCLIC MAINTENANCE 
Annual budget
2025/26
Expenditure
plus
commitment to
date
%expenditure
plus committed
to date
Budget balance 
Projected
outturn to 31
March 2026
Gas Servicing 432 328 76% 104 432
Solid fuel servicing 16 13 81% 3 16
Air source heat
pump servicing
67 43 64% 24 67
Smoke detector
servicing 
116 38 33% 78 116
External decoration
and Fabric Repairs
860 724 84% 136 860
Servicing fans,
windows etc
30 26 87% 4 30
PIV 50 0 0 50 50
Solar and battery 25 0 0 25 25
Fire Risk
Assessments and
Associated works
160 4 2.5% 156 100 
1,756 1,176 67% 580 1,696 
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APPENDIX V
Investment Programme expenditure 2025/26
31 December 2025
(all amounts in £’000) 
PLANNED MAINTENANCE and OTHER INVESTMENT 
Annual Budget
2025/26
Expenditure plus
commitments to
date
%
expenditure plus
committed to date
Budget Balance
Projected outturn
to 31 March 2026     
Kitchens and Bathrooms 1,300 1,131 87% 169 1,300
Bathroom Replacements 620 502 81% 118 620
Central Heating 1,900 1,837 97% 63 1,900
Doors and Windows 3,000 1,355 45% 1,645 3,000
EESSH - Insulation 750 89 12% 661 750
EESSH and Solar batteries 350 50 14% 300 150
EESSH - Social Housing Net
Zero Fund
150 914 609% -764 850
EESSH / EESSH 2/ Insulation 16,700 6,906 41% 9,794 14,500
Electrical upgrade 0 606 100% -606 600
Major works 700 1 0.001% 699 300
Roof replacements 1,052 257 24% 795 1,052
Sub Total (Capital) 26,522 13,648 51% 12,874 24,272        
Rainwatergoods 299 122 41% 177 299
Rainwatergoods - Roof Moss
Cleaning
239 334 140% -95 239
Plumbing Upgrades 62 23 37% 39 62
Electrical Upgrades 150 407 271% -257 600
Roof and Fabric 0 133 100% -133 0
Safety and Security 26 14 54% 12 26
Sheltered Housing 12 10 83% 2 12
Decoration Vouchers 124 97 78% 30 124
Shower Installations 62 18 29% 44 62
Sub Total (Revenue) 974 1,158 119% -181 1,434        
Disabled Adaptations 400 330 83% 70 400
Enabling Projects 51 170 333% -119 51
Sub Total (Other Investment) 451 500 111% -49 451      
Total 27,947 15,306 55% 12,641 25,706
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APPENDIX VI 
PRIVATE SECTOR HOUSING GRANT
SCHEME OF ASSISTANCE – 2025/26 
Annual budget
2025/26
Expenditure to
date
Balance
Legally
committed 
Anticipated year
end spend
CATEGORY
Independent Living 
Category C 43,000 22,000 21,000 43,000 43,000 
CATEGORY DESCRIPTIONS
Category C                                    Grant Assistance to aid independent living – House 
condition works 
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Report to: Housing and Community
Safety Committee
Meeting Date: 12 March 2026  
Report by: Executive Director Education, Housing and Communities      
Author: Gillian Henly Contact Email: Housingpolicy@moray.gov.uk 
Subject: Common Repairs Policy Review Update 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to inform the Committee of the Common Repairs Policy
consultation and request approval of the Common Repairs Policy for implementation.  
1.2  This report is submitted to Housing and Community Safety Committee in terms of Section
III G (3) of the Council’s Scheme of Administration relating to carrying out the management
and maintenance of the Council's Housing Stock including housing for the homeless and
sites for Gypsies/Travellers.  
2.  SUMMARY  
2.1  This report presents the results of the Common Repairs Policy consultation and the final
Common Repairs Policy for approval and implementation.    
3.  RECOMMENDATIONS 
3.1  It is recommended that Committee (delete as appropriate):   
i)  considers the results of the consultation feedback in Section 5 and
APPENDIX I; and 
ii)  approves the final Common Repairs Policy for implementation as set out at
APPENDIX II.   
Gillian Henly
Senior Housing Officer (Policy)
Item 9.
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4.  BACKGROUND AND CONTEXT  
4.1  Owner occupiers are primarily responsible for repairs and maintenance to their homes.
Most properties are governed by title deeds, which typically:
• define ownership responsibilities, 
• outline maintenance of common areas, and 
• set out how costs are shared. 
However, some deeds do not address decision-making for common repairs. Where deeds
are silent or incomplete, the Tenement Management Scheme provides a statutory
framework for decision-making and cost allocation.  
4.2  In blocks of flats, the Council, as a landlord and property owner, has the same rights and
responsibilities as other owners in relation to common elements.  However, to ensure
tenant safety and support investment programmes, the Council may propose works and
offer to undertake them on behalf of other owners.  In such cases, owners are required to
pay the Council their proportionate share of the costs.  Most owners agree to pay when
approached about common repairs.  However, refusal to contribute can delay essential
works, risking further deterioration and significantly higher costs if repairs are postponed.  
4.3  On 23 November 2005, the Common Repairs Policy, which sets out how the Council
manages the repairs of buildings where it shares ownership and responsibility with others,
was approved by the Community Services Committee (Para 6 of the Minute refers).    
4.4  On 18 November 2025, Housing and Community Safety Committee approved the draft
revised Common Repairs Policy for an eight-week consultation, (Para 14 of the Minute
refers).  It also agreed that an update report detailing the outcome of the consultation and 
a final Common Repairs Policy would be provided to this Committee for agreement. 
5.  CONSULTATION FEEDBACK AND ANALYSIS  
5.1  The eight-week consultation commenced on 19 November 2025 and was further extended
by one week to end on 21 January 2026.  The consultation included:
• Publication of the revised Common Repairs Policy, along with an easy-to-read version
of the policy;
• An online survey on the Housing Hub section of the Moray Engage portal, with paper
copies available upon request.  This was open to anyone who wanted to submit a
response;
• Targeted communication with housing tenants, along with property owners of buildings
where the Council shares ownership and responsibility, via email to inform them of the
consultation; 
• Promotion of the consultation via the Council’s website, news and social media
platforms;
• Requests for stakeholders’ feedback, including the Register of Interested Tenants and
Moray Tenant’s Forum.  
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5.2  The online consultation was open to any person to participate and provide feedback.  As
part of the consultation process more than 4000 emails and 3300 letters were issued to
stakeholders (tenants and property owners who share responsibility for a building with the
Council).  They were:
• invited to answer generic questions on the revised policy; and
• given the opportunity to provide any further general comments for consideration. 
Additionally, more than 4200 reminder emails were issued to stakeholders in advance of
the consultation end date to request their input. 
5.3  A total of 90 stakeholders completed the consultation survey.  The relatively low response
rate to the consultation is likely linked to the specialist and technical nature of the
Common Repairs Policy.  Unlike broader housing topics that affect all tenants and owners,
common repairs apply only to those living in mixed-tenure properties, and even within that
group, many residents may not regularly engage with common repairs or the underlying
legislation.  
5.4  Of the surveys completed, 69 (76.67%) stated that they were tenants/tenant
representatives and 21 (23.33%) stated they were owner occupiers.  34 (37.7%) of
respondents stated that they live in a block of flats where both owners and the Council
shares responsibility for repairs and maintenance.  An overview of the survey feedback
returned is set out below. 
Yes (%) No (%) Responses
received* 
Do you live in a block of flats where both
owners and the Council shares responsibility
for repairs and maintenance?
34 56 90
Do you support the Common Repairs Policy? 79 (87.77%)  11 (12.23%)  90
Did you find the revised Common Repairs
Policy easy to read and understand?
81 (90%)  9 (10%)  90
Is there a section of the revised Common
Repairs Policy that you think should be
reworded?
4 (4.49%)  85 (95.51%)  89
Is there anything missing from the revised
Common Repairs Policy that you think should
be included?
11 (12.22%)  79 (87.78%)  90
Is there anything in the revised Common
Repairs Policy that you think should be
removed?
3 (3.33%)  87 (96.67%)  90
*Variance due to a consultee skipping a question.  
5.5 The consultation generated a wide range of feedback which centred on several key
themes relating to understanding, responsibilities, fairness, communication and
confidence in service delivery.  An overview of the comments received, is available at
APPENDIX I.  The comments returned have been amended to correct grammatical and
typing errors.   Any comments relating to personal circumstances have been removed.    
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5.6 Most respondents supported the draft policy and found it easy to read and understand. 
There were a small number who responded that there should be some rewording or that
something had been missed.  In summary, the comments returned related to:
• detail, which is not directly relevant to the Common Repairs Policy.  However, the
information is included either in other Housing Service policies or supporting
procedures and information resources.
• individual circumstances which are outwith the remit of the policy review.  Where
relevant, these have been referred on to the relevant team to action.
• detail which is a legal requirement and is already detailed in the policy.  
• understanding of the policy with some respondents stating it was difficult to
understand, particularly for those who may be unfamiliar with technical or legal
terminology.  A plain language, easy to read version of the policy is available.  The
Housing Service will expand on plain language resources and develop additional
information to explain the policy and processes.  
5.7 Following analysis and consideration of the consultation feedback, there have been no
changes made to the draft policy.  Where appropriate, the feedback will be used to inform
the development of the operational procedures and supporting information resources
which will assist to strengthen communication and improve public understanding of the
policy.    
5.8 The revised Common Repairs Policy is provided at APPENDIX II for this Committee’s
approval.    The policy:
• complies with legislative and good practice requirements; 
• clarifies and explains the rights and responsibilities of the council and homeowners
in mixed-tenure properties;
• provides clear information to tenants and owners on how the Council will manage and
charge for common repairs in mixed-tenure properties;
• sets out the assistance available to owners to attain their agreement to complete and
pay their share of the common repair; and
• includes provisions to mitigate against financial risk, through robust debt monitoring
and where appropriate the use of Notice of Potential Liability for Costs.  
5.9 Subject to this Committee’s approval, a delivery plan will be developed to support an
implementation date of 1 April 2026.  This will include, publicising any changes via the
Council’s social media platform and on the Council website, review of the supporting
operational procedures, staff training and awareness of the revisions and updating public
information resources.  
6.  SUMMARY OF IMPLICATIONS  
6.1  The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) ✓ 
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Policy and Legal ✓ 
Financial ✓ 
Risk ✓ 
Staffing  X
Best Value and Transformation  X
Property  X
Information Communications Technology/Digital    X
Equalities. Social Inclusion and Economic Impact       ✓ 
Climate Change and Biodiversity Impact      ✓ 
6.2  Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☒ Tackle Poverty and Inequality.
☒ Build Stronger Greener Vibrant Economy.
☒ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☒ Developing a diverse, inclusive, and sustainable economy
☐ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☐ Improving wellbeing of our population   
6.3  Policy and Legal 
Legislation and associated statutory powers often differentiate between repairs required
to repair damage, ongoing maintenance to prevent deterioration, and improvements that
enhance an aspect of a home beyond its original state. 
The organisation of common repairs, and general property maintenance matters, within any
multi-owned property is shared between all owners and based on their shared legal
obligations.   These are generally set out in the owner’s title deeds.   Where the title deeds
are silent or have gaps, the Tenements (Scotland) Act 2004 will apply.  This legislation sets
out processes for decision-making in blocks of flats by majority, so that repair and
maintenance work can be carried out without requiring the full consent of every owner in a
block.  The scope of this legislation does not extend to improvements and to proceed
improvement works will require the consent of all owners.  
6.4  Financial 
The Housing Revenue Account (HRA) is funded from tenants’ rents, fees and service
changes for services provided to tenants, and assets held on the HRA accounts.  The HRA
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is self-contained and has no direct impact on the Council’s general services budget. 
Where the Council undertakes a common repair on behalf of an owner, it will initially be
funded from the HRA, and the relevant costs will be recharged to owners.  Any risk to the
HRA will be mitigated by ensuring processes for agreement of the works are legally
compliant and evidence is available to owners in relation to the scope and costs of works. 
In addition, the Council will maintain good debt monitoring and where necessary will take
action to secure the debt against the homeowner’s property. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments       
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments       
6.5  Risk 
Investment in mixed tenure blocks is essential to alleviate and prevent any risk to homes
and areas from deterioration and resulting in a need for greater investment at a later date. 
The delivery of mixed tenure common repairs relies on the agreement and financial
contribution from relevant responsible property owners.  
6.6  Staffing 
There are no staffing implications arising directly from this report.  
6.7  Best Value and Transformation 
There are no implications arising directly from this report.  
6.8  Property 
There are no property implications arising directly from this report.  
6.9  Information Communications/Technology/Digital 
There are none arising from this report. 
6.10  Equalities, Social Inclusion and Economic Impact 
The Integrated Impact Assessment (IIA) attached at APPENDIX III has been revised to
include the consultation outcome which has informed the final policy development.  No
new impacts have been identified because of the consultation feedback.  The IIA
determines that the mitigations are realistic and reasonable in terms of the policy
revisions and will address any potential inequality and / or disadvantage.
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6.11  Climate Change and Biodiversity Impacts 
The operation of common repairs in multi tenure properties will assist to deliver the
Housing Investment Programme and contribute to meeting EESSH standards within the
Council’s stock, thereby reducing energy ratings and carbon emissions in both council and
owner occupier properties.  
7.  CONSULTATION  
7.1  This report has been prepared in consultation with the Head of Housing, Property and
Communities, Chief Financial Officer, G. Anderson (Senior Solicitor, Legal Services), the
Service Manager Housing Strategy, the Service Manager Property Estates and Assets, the
Housing Asset Manager, the Equal Opportunities Officer, and L. Rowan, Committee
Services Officer and any comments made have been incorporated into the report.    
8.  BACKGROUND PAPERS  
8.1  Housing and Community Safety Committee – 18 November 2025 – Common Repairs
Policy Review 
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APPENDIX I
Common Repairs Policy Consultation Feedback
The profile of stakeholders who completed the survey is as follows:
Are you:  Number  %
• An owner 21 23.33
• A tenant  68 75.56
• A tenant representative  1 1.11
Total responses  90 100% 
Do you live in a block of flats where both owners
and the Council share responsibility for repairs and
maintenance?
Number %
Yes No Yes  No
• An owner 19 2 90.48 9.52
• A tenant  15 53 22.06 77.94
• A tenant representative  0 1 0 100
Total by response 34 56 37.77 62.23
Total responses 90 100 
Do you support the revised Common Repairs
Policy?
Number %
Yes No Yes  No
• An owner 19 2 90.48 9.52
• A tenant  60 8 88.24 11.76
• A tenant representative  0 1 0 100
Total by response 79 11 87.77 12.23
Total responses 90 100 
Did you find the revised Common Repairs Policy
easy to read and understand?
Number %
Yes No Yes  No
• An owner 19 2 90.48 9.52
• A tenant  61 7 89.71 10.29
• A tenant representative  1 0 100 0
Total by response 81 9 90.00 10.00
Total responses 90 100 
Is there a section of the revised Common Repairs
Policy that you think should be reworded?  
Number %
Yes No Yes  No
• An owner 1 20 4.76 95.24
• A tenant  3 64 4.48 95.52
• A tenant representative  0 1 0 100
Total by response 4 85 4.45 94.44
Total responses 89* 100
*Variance due to a consultee skipping a question.
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Please tell us what you would like reworded.
Comments received Housing Service Response/Action
The part where we can do the repairs
ourselves small things like painting the
communal hall.
No change to the policy needed.
The Council must comply with the legal
framework for common repairs.  Painting
is included within the rules of the
Tenement Management Scheme and is
considered as maintenance.
Tenements (Scotland) Act 2004 Schedule
1 Rule 1.5
Where property title deeds are silent or
inconclusive, owners and the Council
must comply with the rules, which
includes decision making.    This means
that before painting can commence, the
majority of owners must agree to the
work. 
Although we appreciate that some
residents may be willing to carry out
some small tasks themselves, we hope
that this explanation clarifies why formal
agreement is needed.
The council haven’t done any repair work
to these flats in years.  It’s unfair as there
are 2 flats above my 2-bed flat.  In 25
years, the only thing I’ve seen them
change is doors and kitchens, no harling
or roof repairs.
No change to the policy needed.
The policy review cannot comment on
individual cases. 
There have been instances where an
owner’s refusal to agree to the common
repair works or pay their share of the
costs, has delayed or prevented repair
and maintenance works.  Unless
emergency work, we would require
majority agreement of all involved before
the work can proceed. 
The revised policy aims to provide clarity
on roles and responsibilities.   We hope
that the emphasis on early engagement,
financial planning and enforcement
provisions will support better cooperation
by owners and help to ensure that the
common repairs can be completed
timeously.
Reword it for easier understanding to the
general public.  As sometimes it's a
No change to the policy needed.
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Is there anything missing from the revised Common
Repairs Policy that you think should be included?
Number %
Yes No Yes  No
• An owner 1 20 4.76 95.24
• A tenant  10 58 14.70 85.30
• A tenant representative  0 1 0 100
Total by response 11 79 12.22 87.78
Total responses 90 100 
Please tell us what you would like reworded.
Comments received Housing Service Response/Action
difficult read, and it’s hard to understand
the words used if they are uncommon.  In
relation the whole thing needs a bit of
work.
We recognise that the common repairs
process can be complex.  The policy aims
to explain the process as clearly as
possible, outlining the correct legal
process and explaining the key
terminology used.  To make the
information accessible, the policy is
supported by an easy-to-read version. 
We will also develop a leaflet and
webpage that using plain language to
help make the information easier to
understand.
Tenants / owners can also contact the
Housing Service if they have any
questions or need further clarification.  
Please tell us what you think should be included.
Comments received Housing Service Response/Action
For example, insulation, I know that are
blocks of flats have no / or little left.  I am
a ground floor flat and have already been
told that if I was to get new insulation
upstairs (owner) would have to agree to
pay for theirs, I have mentioned it to my
neighbour and already know they would
be happy to pay.
No change to the policy needed.
This is outwith the scope of the policy
review and the policy review cannot
comment on individual cases.
As part of its housing investment
programme, the Council undertakes
energy efficiency improvement works,
including the installation of insulation. 
Where multi-tenure ownership exists, this
would be progressed as common repairs
and the process set out in the policy
would apply.  
The policy also explains that any
responsible owner can propose and
initiate works accordance with their title
deeds and the Tenement (Scotland) Act
2004. 
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Please tell us what you think should be included.
Comments received Housing Service Response/Action
We appreciate the importance of
energy-efficiency improvements and
hope this clarification helps explain how
such work is managed.
I have had a number of common repairs
done but never been charged so I don't
fully understand terminology.
No change to the policy needed.
The policy review cannot comment on
individual cases.
The terminology is explained in
APPENDIX I of the policy and in the easy-
to-read version.  The Housing Service will
aim to ensure that staff explain any
terminology when in contact with
owners/tenants so that the process is
easier to follow. 
A rough guide of prices for repairs council
tenants have to pay for if it was
accidental/deliberate damage.
No change to the policy needed.
This is outwith the scope of the policy
review.
The Rechargeable Repairs Policy details
the process where a repair is the
responsibility of a tenant due to
accidental or deliberate damage. 
Charges for rechargeable repairs are
based on current repair costs, including
materials and labour from the agreed
Moray Council Schedule of Rates which
is reviewed annually.  We appreciate the
importance of energy-efficiency
improvements and hope this clarification
helps explain how such work is managed.
Tenants are advised of the cost of
rechargeable repairs when the work is
undertaken. 
We understand that having clearer cost
expectations can be helpful, and we will
explore opportunities to provide simpler
information where appropriate.
If you are a council tenant your rights will
be undermined and your council tax will
be lowered.
No change to the policy needed.
This is not factually correct and is outwith
the scope of the policy review. 
We would like to reassure tenants that
their rights are protected under housing
legislation and are not affected by the
Common Repairs Policy.
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Please tell us what you think should be included.
Comments received Housing Service Response/Action
Priority for disabled tenants such as a
similar approach to PSR.
No change to the policy needed.
It is important to distinguish between
general common repairs and adaptations
to common parts for disability needs:
• Common repairs: are for the general
maintenance of shared areas like the
roof, stairs, or drains.
• Adaptations for disability are specific
alterations to a home or common parts
to meet the needs of a disabled person
(e.g. installing a ramp or stairlift).
Disabled homeowners or tenants have a
right to adapt common parts with the
consent of the majority of owners, which
cannot be unreasonably refused (please
refer to the Scottish Government’s How
to Guide – Adapting Common Parts).  
This is a separate process from the
Common Repairs Policy. 
We understand that accessibility is
important, and we hope this explanation
clarifies how adaptations are progressed.
Why does it not state to Moray Council
tenants how long the council have got to
fix or replace any work that needs done
before the tenant has to right to get the
work done at the council’s expense?
No change to the policy needed.
This would not be detailed in the
Common Repairs Policy.  This is detailed
in the Response Repairs Policy and Right
to Repair Procedure which comply with
the Housing (Scotland) Act 2001 and
the Scottish Secure Tenants (Right to
Repair) Regulations 2002. 
We recognise that timescales are
important for tenants, and the separate
Response Repairs Policy provides clear
guidance on this.
Let people know they have to have
contents insurance for when you come in
our home to complete work and destroy
our belongings because if anything gets
destroyed nobody takes responsibility for
it.
No change to the policy needed.
This is outwith the scope of the policy
review.
Owners and tenants are responsible for
ensuring that they have contents
insurance.  Depending on the
circumstances, they should claim on
their own household insurance.  If they
don’t have insurance or have any
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Is there anything that you think should be removed
from the revised Common Repairs Policy?  
Number %
Yes No Yes  No
• An owner 1 20 4.76 95.24
• A tenant  2 66 2.94 97.06
• A tenant representative  0 1 0 100
Total by response 3 87 3.33 96.67
Total responses 90 100 
Please tell us what you think should be included.
Comments received Housing Service Response/Action
difficulties, they should contact the
Housing Service.   
We will consider including a reminder
about contents insurance in future
information resources to help raise
awareness.
Renew toilet seats and tube lights for the
kitchen.
No change to the policy needed.
This is outwith the scope of the policy
review.
Quicker repair times, been waiting since
October for a gate divider, between mine
and neighbour back garden!!!!
No change to the policy needed.
This is outwith the scope of the policy
review.  The respondent should contact
the Service directly and provide contact
details so that the matter can be
investigated. 
We appreciate how frustrating delays can
be and encourage reporting such issues
so they can be addressed as quickly as
possible.
Please tell us what you think should be removed.
Comments received Housing Service Response/Action
It is unfair to charge owners of ground
flats for roofs that aren’t theirs, ground
flat owners have no loft or roof.
No change to the policy needed.
While acknowledge the respondent’s
views of unfairness, this requirement is
not set by Moray Council.   The Council
will comply with relevant legislation.  
Unless the liability is stated in the title
deeds for the properties, the Tenement
(Scotland) Act 2004 (which sets out
the   Tenement Management Scheme) will
apply.  This set of rules states which part
of the building every owner is liable to
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Do you have any other comments on the revised
Common Repairs Policy?  
Number %
Yes No Yes  No
• An owner 7 14 33.33 66.67
• A tenant  21 47 30.89 69.11
• A tenant representative  0 1 0 100
Total by response 29 61 32.22 67.78
Total responses 90 100 
maintain, called “scheme property” and
those parts which only some owners
must maintain.  Scheme property
includes the roof, rafters and any
structure supporting the roof.  Liability for
scheme costs are generally shared in
proportion to the floor area of each flat
unless the title deeds specify other
arrangements. 
We understand that this can feel unfair
for ground-floor owners, and we hope this
explanation helps clarify how
responsibilities are legally determined.
Do you have any other comments on the revised Common Repairs Policy?
Comments received Housing Service Response/Action
My concern would be that many owners
and tenants, particularly owners are likely
to be unaware of the policy - it needs to
be promoted in some way, perhaps
simply through social media or when
people become owners of a relevant
property.
No change to the policy needed.
The policy will be promoted e.g. website
updates, leaflets and where the Council
wants to undertake work in relation to
common repairs, targeted and early
engagement with owners will be
undertaken.
Unfortunately, the Council cannot notify
incoming owners of this requirement at
the point of purchase.  However, owners
should be made aware of the
requirements set out in their title deeds
and the Tenement Management Scheme
when they purchase a property.
We appreciate the importance of clear
communication and will continue to
promote the policy in accessible ways.
I am the only council tenant in my
building and one time me and my
neighbour decided to repaint the
No change to the policy needed. 
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Do you have any other comments on the revised Common Repairs Policy?
Comments received Housing Service Response/Action
communal hall white as it was the colour
that was there.  When we started the
gentleman who comes round to keep eye
on the area said to stop that the council
will be doing it soon 3 months later still
not done so we painted the top part as we
are on the first floor that was a few years
ago and it still not been done by the
council and I will be freshing it up in the
summer time of 26 again. It would be
good if I could get the white paint from
the council instead of me having to pay
for it. 
This issue has been forwarded on to
relevant team to consider. 
Painting is included with the rules of the
Tenement Management Scheme and is
considered to be maintenance
(Tenements (Scotland) Act 2004
Schedule 1 Rule 1.5).
Owners and the Council must comply
with the rules, which will include decision
making, before the painting can begin. 
We recognise the frustration caused by
delays and hope the team’s review will
help address this situation.
Looks ok.  The points well explained  Noted.   Thank you for your feedback.
It’s council house, all repairs should be
paid by council.  There is no right to buy
house, it’s enough that we waste money
by paying rent.
No change to the policy needed.
The policy details the process the
Council must legally follow where
common repair works are need to
buildings where we share ownership with
other owners.
Repairs to council tenant homes are paid
for by the Housing Service unless they are
rechargeable repairs (where a tenant is
liable and recharged for the cost of the
repair).  For common repairs, the Housing
Service will pay for its share (properties
which tenants live in, while owners are
legally responsible for their share.   
We appreciate the concern raised and
hope this explanation clarifies how
responsibilities are divided.
Please attend all repairs with the prior
knowledge of what needs repairing.  As
clients shouldn't have to tell people over
and over again what needs fixed.
Noted.    No change to the policy needed.
This is outwith the scope of the policy
review. 
As set out in the policy, unless an
emergency repair, the Council can only
proceed with repairs which have been
agreed in advance with the majority of
owners, which may not include the
additional repairs referred to.   
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Do you have any other comments on the revised Common Repairs Policy?
Comments received Housing Service Response/Action
We understand how repeating
information can be frustrating and will
ensure the comment is shared with
relevant teams.
I am forever thankful for the readiness
and efficiency which the common repairs
have brought for my comfort in living well.
Noted.   Thank you for your positive
feedback.
What happens if my property is damaged
by the upstairs flat being flooded.  I own
my flat and have at least on 2 occasions
had to cover the costs to my home being
repaired after the council property was
flooded.
No change to the policy needed.
The policy review cannot comment on
individual cases.   Owners should claim
on their own household insurance policy. 
If they don’t have insurance or have any
difficulties, they should contact the
Housing Service.   
We understand that such situations can
be stressful, and we encourage owners to
get in touch for support where needed.
If no upgraded work is to be done the
council tenant rent and council tax will be
lowered
No change to the policy needed.
Outwith scope of the policy review.  Rent
and any discount that a tenant may be
eligible for in relation to the attributes of a
property is addressed by the Rent Setting
Policy.  Council Tax is determined
separately. 
We hope this helps clarify how rent and
council tax decisions are made.
I hope that the council tenants don't just
ask for anything that may not really be
necessary needed as they won't be
paying 
and 
does the flat entrance roofs come under
everyone in the block.
No change to the policy needed.
When a tenant reports a repair, an
assessment will be undertaken to ensure
that the work is necessary. Costs for
tenant-caused damage are recharged to
the tenant. 
Unless the liability is stated in the title
deeds for the properties, the Tenement
(Scotland) Act 2004 which sets out
the   Tenement Management Scheme will
apply.   
This set of rules states which part of the
building every owner is liable to maintain,
called “scheme property” and those parts
which only some owners must maintain. 
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Do you have any other comments on the revised Common Repairs Policy?
Comments received Housing Service Response/Action
Scheme property includes the roof,
rafters and any structure supporting the
roof.  Unless the title deeds state
otherwise, liability for scheme costs is
generally shared in proportion to the floor
area of each flat. 
We appreciate the concerns and hope
this explanation reassures owners that
unnecessary costs will not be passed on
to them.
It may be there and I didn't spot it, but as
a landlord a contact number / email
within the doc would be useful if
clarification is needed, or if I need to
progress a repair to the roof etc.
No change to the policy needed.
Contact details are not included in policy
documents.  However, they will be
included in direct correspondence and
any supporting information such as the
website / leaflets etc. 
We understand the desire for quick
access to contact information and will
ensure it is easily available through
supporting resources.
I agree that everyone should pay their
share for common shared areas, but if for
example you have a block of 4 flats with
three council owned, and one bought
outwrite, the three council owned tenants
are not worried about keeping things to
an acceptable standard, (say if they are
getting rent free accommodation), they
know the council will pick up the bill).  So,
I don't think it’s fair to ask a bought flat
owner to pay for something that they have
no control over.
No change to the policy needed.
Tenants have a responsibility for keeping
the property to agreed acceptable
standards.  This is set out in the Scottish
Secure Tenancy agreement and is
explained at the start and during each
tenancy.  If it is determined that a repair is
needed due to tenant neglect or damage,
the tenant may be recharged for the cost. 
Such costs are not passed on to others. 
Owners have a responsibility to maintain
their property.  If you own a flat, you are
usual responsible for repairing and
maintaining the shared areas.  this is
normally set out in your title deeds.   If
your title deeds do not say or are not
clear,  the  Tenement Management
Scheme will apply. 
We appreciate the perspective shared
and hope this provides reassurance
about how responsibility is determined.
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Do you have any other comments on the revised Common Repairs Policy?
Comments received Housing Service Response/Action
Repairs need to be done quickly, not
months after being reported so that the
item requiring repair does not become
worse and therefore likely to cost more to
fix. “A stitch in time saves nine” comes to
mind.
No change to the policy needed.
Generally, repairs reported will be
assessed to identify if they are an
emergency.  Thereafter we must follow
the correct process, complying with title
deeds and the Tenement Management
Scheme to request the agreement of
other owners involved.  The Scheme sets
out timescales which might be adhered
to.  This can result in a delay in
completing works.  If 50% or more of
owners don’t agree with the proposed
works, then we will not be able to
complete the work. 
Some work may be progressed as
planned maintenance or improvement
work driven by the Housing Investment
Programme and will be subject to
different timescales. 
We understand the frustration caused by
delays and aim to progress works as
efficiently as the legal framework allows.
Like I said been in the flat around 25 years
and can count the number of repairs that
have been done to the flats.  They have a
temp flat just a few doors up from this
that they repair after the tenant’s damage
the flat before new ones come in.  
I don’t understand why things have
changed, we have a shared drain, if the
neighbours block it, is it our fault? 
Our flat - there is 2 separate flats above it
as we are single storey, and they are
double on top.
No change to the policy needed.
The policy review cannot comment on
individual situations. 
When a tenancy ends, a property
inspection is completed to assess the
property condition and identify any repair
works need to ensure that it meets the
agreed minimum standards before it is
relet.  If the repair is the tenant’s
responsibility or deliberate damage is
identified, the tenant may be recharged in
line with the Rechargeable Repairs Policy. 
The responsibility for the repair of shared
block drains will depend on who the drain
serves, where it is located and what the
title deeds stipulate or if they are silent,
the Tenement Management Scheme will
apply.   
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Do you have any other comments on the revised Common Repairs Policy?
Comments received Housing Service Response/Action
We appreciate the concerns raised and
hope this clarification helps explain how
decisions are made.
Council not interested in fixing or making
houses more efficient
No change to the policy needed.
The Housing Service is committed to
ensuring that housing meets acceptable
standards, including energy efficiency. 
Common repairs support the delivery of
the Housing Investment Programme and
help to meet EESSH standards, thereby
reducing energy ratings and carbon
emissions in both council and owner
occupier properties. 
We understand the importance of energy
efficiency and remain committed to
continued improvement.
I live in a 3-bedroom council owned
bungalow; I don’t live in a block of flats
No change to the policy needed.
Noted.   
All council tenants were invited to
participate in the consultation, as
common repairs are funded through the
Housing Revenue Account. 
Thank you for taking the time to
participate.
This is all sounds good on paper the big
question is will it be implemented or is it
just trying to look good.
No change to the policy needed.
Common repairs support the Housing
Service to deliver the Housing Investment
Programme and contribute to meeting
EESSH standards which are monitored
and reported by the Scottish Housing
Regulator. 
It will assist the Council to meet the aims
and priorities of the Local Housing
Strategy.  Priority 4 – “Improving property
condition and achieving affordable
warmth is enabled in all homes.” 
We understand the concern and hope
this explanation provides reassurance
about the policy’s purpose and oversight.
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Do you have any other comments on the revised Common Repairs Policy?
Comments received Housing Service Response/Action
No everything seemed to be just fine. Noted.  Thank you for your feedback.
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APPENDIX II 
Common Repairs Policy
Date of Creation September 2025
Owner (Service) Housing, Property and Communities
Reviewer Head of Service Head of Housing, Property and Communities 
Approver Executive
Director
Executive Director Education, Housing and
Communities
Date Approved XXXX 2025, for implementation on 1 April 2026 
Approver (Committee) Housing and Community Safety Committee
Date Approved TBC
Next Review Date  2029 or earlier if required by legislative or guidance
changes
Version History
Version Date Author Changes Made Approved By
1.0 25.09.25 Housing Policy  Initial document Housing and Community
Safety Committee 18.11.25
1.1 21.01.26 Housing Policy Final draft  Housing and Community
Safety Committee TBC
Index
Section 1 Scope of the Policy
Section 2 Strategic Framework
Section 3 Objectives and principles of the policy
Section 4 Legislation and regulatory requirements
Section 5 Equality and diversity
Section 6 Confidentiality and data protection
Section 7 Common repairs
Section 8 Owners’ responsibilities
Section 9 Engagement with owners
Section 10 The Tenement Management Scheme
Section 11 Maintenance, repair or improvement
Section 12 Planned maintenance
Section 13 Repairs
Section 14 Emergency repairs
Section 15 Improvements
Section 16 Assistance for owners
Section 17 Recharging owners
Section 18 Appeals
Section 19 Monitoring 
Section 20 Policy review
APPENDIX A Definitions
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1. Scope of the Policy
1.1 This policy outlines the framework Moray Council will follow in managing
common repairs.  It aims to ensure that there is a clear and consistent approach
to engaging with and recharging responsible owners when such repairs are
undertaken by the Council. 
1.2 A common repair refers to maintenance or repair work in mixed-tenure blocks
where homeowners and the Council share responsibility for the costs
associated with common areas or parts of the building. 
1.3 The Common Repairs Policy applies to flats in mixed-tenure blocks where the
Council still has a vested interest.  The Council has the same legal obligation as
other owners concerning the management of common repairs. 
1.4 For ease of reference, a summary of definitions used within the Policy is
provided at APPENDIX A. 
2. Strategic Framework
2.1 The Common Repairs Policy will assist the Council to meet the aims and
priorities of the Local Housing Strategy.  Priority 4 – “Improving property condition
and achieving affordable warmth is enabled in all homes.” 
2.2 The Scheme of Assistance aims to support private owners and landlords invest
in housing repair and maintenance and includes the provision of advice on
common repairs. 
3. Objectives and principles of the policy
3.1 The specific objectives underlying the Common Repairs Policy are to:
• explain the rights and responsibilities of the Council and owners; 
• give clear guidance on how the Council will manage and charge for common
repairs;
• outline the process of recharging owners for common repairs;
• inform owners of payment arrangements;
• inform owners of the action the Council will take if payment is not made; and
• comply with legislation, relevant guidance and good practice. 
3.2 The specific principles of the Common Repairs Policy are that:
• tenants and stakeholders are consulted on the policy;
• through monitoring and feedback from customers and staff, the management
of common repairs is continuously improved;
• communication with tenants and owners is always clear, appropriate, easily
understood and easily accessible; 
• the common repairs service is supported by appropriate training for
operational staff; and
• policy will be supported by detailed procedures and agreed practices applied
uniformly across the service. 
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4. Legislation and regulatory requirements
4.1 Section 27 and Schedule 4 of the Housing (Scotland) Act 2001 and the Scottish
Secure Tenants (Right to Repair) Regulations 2002 require the Council to include
basic repairing obligations in their Scottish Secure Tenancy Agreements. 
4.2 The organisation of common repairs, and general property maintenance matters,
within any multi-owned property is shared between all owners and based on their
shared legal obligations.   
4.3 In line with the Title Conditions (Scotland) Act 2003, rules detailing owners’
specific responsibilities for the upkeep, management and maintenance of the
common elements are normally found within the title deeds, which set out
ownership rights, responsibilities and boundaries for properties.  For communal
buildings, they define the various ownership shares, common areas and
maintenance obligations of each owner within the tenement. 
4.4 Although title deeds granted by the Council specify liabilities and the Council can
carry out common repairs and recharge in line with the title deeds, the title deeds
do not provide a decision-making process for all owners.   
4.5 The Tenements (Scotland) Act 2004, sets out the Tenement Management
Scheme (TMS) and shows the steps that owners need to take when making
decisions which affect all owners about maintaining and repairing common
parts.  These rules can be used if title deeds don’t specify how decisions should
be made, or if different owners’ title deeds are conflicting (see Section 10). 
4.6 The title deeds are generally silent on improvements.  This policy seeks to make
provisions for the procedure to be followed for improvement works.   
Scottish Social Housing Charter
4.7 The Scottish Social Housing Charter sets the standards and outcomes that all
social landlords should aim to achieve in performing their housing activities. The
relevant Charter Standards/Outcomes for Common Repairs are: 
Equalities 
Social landlords perform all aspects of their housing services so that: they
support the right to adequate housing every tenant and other customer has their
individual needs and rights recognised, is treated fairly and with respect, and
receives fair access to housing and housing services. 
Communication
Social landlords manage their businesses so that: tenants and other customers
find it easy to communicate with their landlord and get the information they need
about their landlord, how and why it makes decisions and the services it
provides. 
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Repairs, maintenance and improvements
Social landlords manage their businesses so that: tenants’ homes are well
maintained, with repairs and improvements carried out when required, and
tenants are given reasonable choices about when work is done 
Value for money
Social landlords manage all aspects of their businesses so that: tenants, owners
and other customers receive services that provide continually improving value for
the rent and other charges they pay. 
5. Equality and diversity
5.1 Moray Council will comply with the Equality Act 2010, Human Rights Act 1998,
Fairer Scotland Duty (socio-economic inequality) and the United Nations
Convention on the Rights of the Child (UNCRC) by:
• making reasonable adjustments for disabled persons;
• understanding and addressing barriers faced by marginalised groups;
• ensuring that common repairs are managed in a non-discriminatory and
inclusive manner; and
• monitoring actions to avoid disproportionate impacts on protected groups. 
5.2 The Council is committed to preventing discrimination and promoting equality
of opportunity for every person.   In accordance with the Equality Act 2010, the
Council seeks to ensure that the Common Repairs Policy does not discriminate
between individuals with one or more of the following protected
characteristics: age, disability, gender reassignment, marital status/civil
partnership, pregnancy and maternity, race, religion or belief and sexual
orientation. 
5.3 In delivering the Common Repairs Policy, full consideration will be given to the
Council’s Public Sector Equality Duty (PSED).  This requires public authorities
to eliminate discrimination, harassment and victimisation, advance equality of
opportunity and to foster good relations between those who share a relevant
protected characteristic and those who do not. 
5.4 The Council will develop and provide information and advice in alternative
formats.   The Council will provide interpretation and translation services free of
charge where these are required. 
6. Confidentiality and data protection
6.1 The Council will ensure that any information given to it as part of the common
repairs  process will be used in accordance with the General Data Protection
Regulations (GDPR) and the Data Protection Act 2018.   Relevant Privacy
Notices, available on the Moray Council website, advise customers how
personal information may be collected, used, stored, shared and securely
disposed of and the legal basis for doing so and what their Data Subject Rights
are. 
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7. Common repairs
7.1 Owners are responsible for repairs and improvements to their individual
property.  Homeowners who live in mixed-tenure blocks are also responsible for
a share of the cost of the maintenance and repair of the common areas or parts
of the building.  If the common areas of the building need to be repaired, every
owner who is entitled to use that common area must pay their share of the cost
of the repairs.   
7.2 Section 26 of the Tenement (Scotland) Act 2004 sets out the meaning of
“tenement” as a building comprising two or more related flats which are owned
or designed to be owned separately and which are divided horizontally.  This
includes:
• high-rise blocks;
• modern apartment blocks;
• four-in-a-block or cottage flats;
• blocks of flats with ground floor shops;
• large houses converted into flats; and 
• traditional sandstone or granite buildings, usually of three or four storeys. 
8.    Owners’ responsibilities
8.1  When a flat is sold, a right of common ownership is usually granted along with
any other flats sharing common parts of the building.  Title deeds normally set
out an owner's duty to pay a share towards the cost of common repair and
maintenance.  In the event of title deeds for a flat being silent or have defects or
are unclear, the TMS, introduced by the Tenement (Scotland) Act 2004, will
prevail (refer to Section 10).  For example, the title deeds may not say how
decisions should be taken, or may not describe all the common parts, or they
may allocate shares of costs that do not add up to 100%.   
8.2 In any block of flats, Moray Council, in its role as a landlord and owner of flatted
properties, holds the same rights or responsibilities as all other owners
regarding the organisation or undertaking of work to the common elements of
the block. 
8.3 In practice however, to ensure Council tenants remain safe and secure in their
homes, or to support its housing investment programmes, Moray Council may
approach other responsible owners regarding potential works, offering to
undertake them on their behalf.  In such circumstances, the owners would pay
Moray Council for their proportion of the share of the costs of the works in
accordance with the burdens stated within their title deeds or if these are
silent, in accordance with the TMS (refer to Section 10). 
8.4 This role by the Council of proposing and/or organising works on behalf of other
responsible owners does not extend to closes/blocks in which the Council no
longer retains any properties. 
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8.5 Where the property has been purchased through the now abolished “Right to
Buy” scheme, the Council has the right to appoint a manager for 30 years.  This
manager will be the Council’s Housing Service.  This right remains for 30 years
or until two-thirds of the properties in a management scheme have been sold
by the Council, when the owners can dismiss the management appointed by
the Council. 
8.6 The title deeds granted by the Council state that not only can owners be
recharged, but also that the choice of materials and contractors used will be
determined by the Council.   
9. Engagement with owners
9.1  The Council is committed to working with tenants and homeowners, in all of its
repair and maintenance programmes.  The Council must work with owners
regarding any common repairs it is proposing and will always try to get their
agreement.  In mixed-tenure blocks, it is likely that the Council will take the
initiative in organising and managing repairs, although any owner can do this. 
9.2 When engaging with owners regarding a common repair, the Council will ensure
all communication, including phone, letter, email and personal contact from
staff, is clear and transparent and owners are provided with every opportunity
to ask questions and receive clear answers. 
10. The Tenement Management Scheme
10.1 The Tenement Management Scheme is the default scheme used where title
deeds have gaps (such as them not saying how decisions should be taken, or not
describing all the common parts) or defects (such as allocating shares of costs
that do not add up to 100%).  It:
• explains what is considered as maintenance; 
• defines scheme property (the parts that everyone is required to maintain);
• sets out how owners will make decisions about repairs and maintenance
(called scheme decisions); and 
• sets out how costs will be shared. 
Scheme property
10.2 Owners are responsible for repairs and improvements to their own property.  If
they live in a mixed tenure block, they are also responsible for a share of the cost
of the maintenance and repair of the common areas or parts of the building,
known as “scheme property”.   Scheme property is the parts of the tenement that
every flat owner should maintain.  It is:
• any part the title deeds say is common property of two or more owners;
• any part that all flats use and the title deeds say two or more owners must
maintain;
• the ground on which the tenement is built;
• the external walls and foundations;
• the roof, rafters and any structure supporting the roof;
• the part of the gable wall that is part of the tenement building; and
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• any load bearing wall, beam or column. 
Parts that only some owners maintain: 
There are some parts of a tenement that are not scheme property.  This means
only some owners are responsible.  An individual owner is responsible for the
following, if they only serve their flat:
• doors, windows, skylights, vents or other openings;
• a chimney stack or flue; and
• an extension. 
Only the owners who have use of the following are responsible for them:
• drainpipes serving one side of the flat; and
• any part that only some flats use, that the title deeds say two or more owners
must maintain. 
Scheme decisions
10.3 The TMS sets out the process owners must follow when making decisions on
maintaining and repairing common parts where the title deeds are silent of have
gaps.  Any decisions made under the TMS are known as “scheme decisions” and
may be used to make decisions about:
• carrying out maintenance;
• arranging maintenance inspections;
• hiring or dismissing a property manager;
• giving a property manager authority to carry out inspections and
maintenance;
• arranging common insurance;
• deciding that an owner doesn't have to pay their share (or part of a share) of
scheme costs;
• authorising any maintenance of scheme property already carried out; and
• changing or cancelling any other decision made in the past.
In addition to carrying out repairs and maintenance to common elements,
scheme decisions can be undertaken for: 
•  first time door entry systems installations; and
•  certain energy efficiency works such as cavity/external wall insulation. 
10.4 Owners will be advised that if they request a formal meeting, an opportunity will
be provided to discuss the repair at an open meeting between the Council and
the owners, particularly for larger repairs. 
10.5 The Council will provide each owner with the opportunity to obtain two
competitive quotes from tradesmen.  Owners will be required to obtain quotes
within two weeks. The Council will evaluate all quotes in accordance with Best
Value and will ensure that they comply with Council standards, for example,
health and safety. 
10.6 Where the Council accepts a quotation obtained by an owner which offers Best
Value, the Council will:
• write and authorise the owner to accept the quotation, confirming that the
Council will contribute to the cost of the work once it has been completed
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to the Council standard. 
• write and advise each owner of the contractor chosen prior to work
commencing. 
• advise owners that if the common repair does not meet with Council
standards upon completion, the Council will rectify the repair, and owners
will be recharged for the cost involved. 
Voting process
10.7 In line with provisions set out by the TMS, scheme decisions are made using a
voting system, with each responsible property representing one vote.  For the
work to proceed, the majority of the owners in the block, which includes the
Council, must be in agreement.  Where the Council is proposing to carry out
common repairs and maintenance to a block of flats, it will:
• check the relevant title deeds and confirm responsibility for costs;
• write to owners and advise of the scope of works, their legal obligations,
estimated costs, a designated officer to contact and signpost owners to
information on the TMS; and
• follow the TMS voting process and timescales, allowing 28 days for voting slips
to be returned.  For more complex/larger common repairs, the Council may
seek to arrange a public meeting as part of the consultation process and will
provide owners with a minimum of 48 hours’ notice. 
10.8 The Council will: 
• contact and / or visit any owner who has not returned their voting slip by the
closing date and endeavour to obtain their decision.
• confirm the result of the vote in writing to all the owners within five working
days of the closing date, informing them about the scheme decision. 
10.9 The Council will adhere to the voting outcomes as follows: 
10.9.1 Full agreement
Where there is 100% agreement each owner will be informed about:
• the decision outcome;
• their legal obligation in line with the TMS;
• details regarding repairs that need to be carried out;
• the owner’s share of the cost; and
• the contractor's name and contact number, and a designated Council
contact. 
10.9.2 Majority agreement
Where a majority vote in favour of the repair is returned, the Council will
write and update each owner with the scheme decision and advise of the
right to appeal.  Any owner who is not in favour of a scheme decision or a
new owner who was not the owner at the time the decision was made can
appeal to the Sheriff Court within 28 days from the date of notification of
the decision.  The work will not start until after the 28-day period has
passed and there have been no appeal applications.  If there are no
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appeals submitted within the 28-day period, then the work will proceed,
and owners will be updated as at 10.6.1.  If an appeal is submitted, the
Council will act in accordance with the decision of the Sheriff Court. 
10.9.3 50% of owners or more disagree 
Where 50% or more of the owners disagree with the proposed works, then
no works can be completed at this time.  The Council will write to all
owners confirming the outcome.  The Council will regularly review the
scheme decisions and will act in accordance with the voting outcome.   
Access for repairs and maintenance
10.10 Owners, and those authorised by owners, have a right of access to each other’s
flats, if access is necessary to: 
• carry out maintenance that was decided by a scheme decision; 
• carry out repairs to a part owned by an individual; 
• carry out inspections to decide if maintenance is needed;
• lead through a service pipe, cable or other equipment, as long as it is not
wholly within another owner’s flat; 
• make sure that any part of the building that provides support and shelter is
being maintained; 
• make sure that none of the owners is doing anything that might damage the
parts of the building that provide support and shelter or doing anything to
reduce the natural light to the building; and calculate the floor area to decide
how costs should be allocated. 
10.11 The owner or the occupier must be given reasonable notice that access is
required and, within reason, can refuse access at inconvenient or inappropriate
times. 
Sharing the cost of works
10.12 Once a scheme decision is made, owners become responsible for the cost of
carrying out any maintenance or repairs needed (“scheme costs”).  Under the
TMS, all owners pay an equal share of the costs of maintenance and repairs,
except:
• when the work involves a part of the tenement that isn't used by everyone (in
which case only the owners of the flats involved should pay); or
• when the floor area of the biggest flat is more than one-and-a-half times the
floor area of the smaller flat (in which case repair costs should be split so the
owner of the larger flat pays more). 
10.13  In line with Section 11 of the Tenements (Scotland) Act 2004, an owner becomes
liable to pay for relevant costs as soon as a decision has been made that such
work should go ahead. 
10.14 Section 10 of the Tenements (Scotland) Act 2004 provides that where repairs
have been completed so as to provide support or shelter, the Council will be able
to claim back a share of expenses from other property owners, even if the owners
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were not aware that the work was being carried out.  For example, emergency
repairs. 
11. Maintenance, repair or improvement 
11.1 Maintenance is preventative, while repairs are reactive.  Replacing something
obsolete with a modern equivalent may still count as a repair, but adding
something new is usually an improvement. 
11.2 Many of the legal rights and responsibilities for owners apply only when
‘maintenance’ is being carried out.   Maintenance is legally defined as: 
• repairs and replacement;
• the installation of insulation;
• cleaning; 
• painting and other routine works; 
• gardening; 
• the day-to-day running of the tenement; 
• the reinstatement of part (but not most) of the tenement building. 
It does not include alteration, demolition or improvement, unless the
improvement is inherently part of maintenance work.  For example, if a main
door needs to be replaced, choosing one with a more suitable specification or
adding an improved modern lock would be counted as maintenance, rather than
improvement.  Maintenance also excludes internal decorative repair of areas
that are not owned in common, unless they are incidental to the repair of
common parts. 
11.3 A summary of the different elements to maintain, repair or improve a common
part, is detailed below: 
Definition  Example Legal basis Consent
needed
Maintain Routine upkeep
to keep
buildings in
good condition
and prevent
deterioration,
cleaning,
repairs,
replacements
• Clearing gutters
• Repainting
communal
areas
• Servicing lifts or
door entry
systems 
• Tenements
(Scotland) Act
2004, Schedule
2, 1.5
• TMS allows
owners to make
decisions
about
maintenance
when title
deeds are
silent
• Majority (under
TMS)
Repair Fixing damage
or restoring
original
condition
• Fixing a leaking
roof
• Replacing
broken guttering
• Repairing
damaged
• Housing
Scotland Act
2001 
• Housing
(Scotland) Act
2006, Section
• Majority (under
TMS)
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11.4 Title deeds to properties sold by the Council reserve a right of access to the
Council at all reasonable times for inspecting, maintaining, repairing and
renewing any adjoining Council property and the common parts, for all
necessary purposes.  Where the Council requires access to an adjoining
property it will always provide owners reasonable notice when requesting access
to their properties. 
12. Planned maintenance
12.1 Planned maintenance is repairs and replacement which the Council is aware of
and has planned for.  Examples of common areas planned maintenance that can
be carried out to communal areas include:
• painting closes;
• external harling repairs and maintenance;
• repairs and paint work to fencing. 
12.2 Where the Council intends to carry out such planned maintenance, it will write
and engage with the owner of properties included in the maintenance
programme at the earliest opportunity and inform them of the proposed works
and how much it will cost them.  The cost provided to owners will include a ten
per cent tolerance.  If this is exceeded the Council will contact the owner and
advise of updated costings. 
12.3 The Council will apply the TMS, using the voting process set out at sections 10.7
– 10.9, to obtain the agreement from owners in the block before carrying out
planned maintenance works. 
12.4 Before repair and improvement works can proceed, the majority of owners within
the block must agree with the works going ahead and to pay their equal share of
costs. 
12.5 Improvement works will only proceed, if all owners within the block agree with
the works going ahead and to pay their equal share of costs. 
Definition  Example Legal basis Consent
needed
stonework or
windows
13
• Tenement
(Scotland) Act
2004
Improve  Enhancements
or upgrades
beyond original
condition or
standard.
• Installing double
glazing where
none existed 
• Title deeds
• Mutual
agreement
• Usually
unanimous.
• Not enforceable
unless all
owners agree.
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13. Repairs 
13.1 Where essential repair work is required, for example repairing a roof to prevent
rainwater leaking, the Council will:
• write to all responsible property owners of properties inform them of:
o their legal obligation;
o details the proposed works; 
o the estimated cost; 
o an estimate of their share of the cost; and
o a designated officer to contact.
• apply the TMS, using the voting process set out at sections 10.7 – 10.9, to
obtain the agreement from owners in the block before carrying out the repair
work.
• Complete the repair where the majority of owners agree to the works. 
14. Emergency repairs
14.1 Emergency repairs are defined as those that:
• cannot wait for a scheme decision to be made; 
• are required to prevent damage to the building; or  
• are in the interests of health and safety. 
14.2 Examples of an emergency repair include:  
• a hole in the roof that is letting in a significant amount of water (could cause
further damage to the building) 
• loose stonework that might fall on a passer-by (a risk to health and safety) 
• internal lights not working and leaving the stairwell in darkness 
14.3 In the case of an emergency common repair, the Council has a duty to make the
property safe where there is a safety risk to a tenant or member of the public or if
there is a potential for further damage. The Council will deliver notification of the
emergency repair to the owner and proceed to make the repair safe.   
14.4 The Council will write to the owner informing them of the value of the common
repair for which they are liable. 
14.5  Certain emergency common repairs will also fall under the Right to Repair
category.  In this case the work will be carried out within the set timescales,
however, the tenants and owners will be informed of their rights under the Right
to Repair legislation and an appropriate repairs receipt included within the letter. 
14.6  The Council will ensure that a robust and accountable audit trail of its actions is
maintained to demonstrate that it has acted reasonably and that the emergency
repair is justified to the owner(s) involved.   
15. Improvements 
15.1 In delivering its Housing Investment Plan, the Council may undertake renewal
works that may not be immediately necessary but are considered beneficial in
the long term due to the age or condition of the building components.  The
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approach to property maintenance, aims to minimise future repair costs for both
the Council and individual owners.  For example, the full re-roofing of a block or
flats where no current issues are identified beyond age. 
15.2 Title deeds do not normally impose conditions concerning the improvement of
properties.  Where common improvements may be required or proposed, the
mutual consent of all responsible owners is required.  The Council cannot
enforce that an owner agrees to or meets the costs of an improvement.   
15.3 If homeowners agree to the Council carrying out the improvement work, they will
be recharged for their share by the Council.  Homeowners may benefit from a
reduction in cost (when compared to what they would pay had they arranged for
the improvement), due to the economy of scale offered by the Housing
Investment Plan delivered by the Council. 
15.4 Prior to any planned improvement project that will involve owners, the Council
will consult fully with owners providing them with an overview of the project,
including estimated costs, tendering arrangements and proposed timescales. 
15.5 Where an improvement project is proposed, a consultation meeting will be
arranged between owners and the Council, irrespective of the anticipated cost. 
Where only a small number of owners are to be involved, this consultation will be
completed by means of a visit.  Every owner will be provided with the opportunity
to discuss the proposals and design materials, etc. 
15.6 The Council will only proceed with the improvement where it has obtained the
written consent of every owner to proceed with the project and their agreement
to pay their appropriate share of the cost of the improvement and any future
maintenance of it.   
15.7 The Council will advise owners of the decision outcome.  Where an owner
informs that they would agree to the improvement but that it will cause them
financial hardship, the Council will provide them with information and advice
regarding options available to them (see Section 17). 
15.8 Where agreement is reached to proceed with the improvement work, the Council
will ensure that it diligently updates owners with progress and notifies them of
any changes that may occur. 
16. Assistance for owners 
Scheme of Assistance
16.1 Homeowners have responsibility for ensuring their homes are properly
maintained.  It is recognised that the main source of finance for common repairs
must be a property owner’s own savings or loans.  The Housing (Scotland) Act
2006 provides broad discretionary powers for local authorities to provide
assistance to owners who have difficulties in carrying out work required to
ensure properties are kept in a reasonable state of repair.  Assistance can
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include practical help, advice and guidance.  The role of the Council is to provide
advice and assistance to help homeowners repair and maintain their properties. 
16.2 Independent advice and further information is also available from the Under One
Roof website. 
17. Recharging owners
17.1 Following the completion of the common repair, the owner shall be invoiced for
their share of the costs.  For repairs or maintenance works, this will be in
accordance with the criteria stated in their title deeds or the share agreed in
accordance with the TMS.  In the instance of an improvement, owners will be
informed of the amount prior to the commencement of any work.  All costs will
be subject to any relevant additional costs for VAT, admin on costs and legal
costs. 
17.2 In instances of smaller repair work, it is uneconomic to process individual
payments under £100.  For such minor repair work, owners will be invoiced either
within 6 months from the repair being completed or when the cost of the repair
amounts to £100.  When the value of repair work is £100 or over, the owner will
be recharged at the time the works are invoiced to the Moray Council. 
17.3 The Council has standard terms for settlement of invoices.  However, it
recognises that, in some circumstances, owners may experience financial
hardship if the full share of the costs of the repair/improvement must be paid
immediately following completion of the works.  Where owners advise that they
will experience financial hardship, should the full cost of common repairs be
paid immediately, the Council will discuss and may agree a reasonable and
affordable repayment period with the owner.  Where a repayment plan is agreed,
owners will be required to sign the agreement confirming that they will comply
with payments. 
17.4  Where a repayment plan is agreed, the Council will register a Notice of Potential
Liability for Costs against the title of the property owner.  Although this will not
prevent the property from being sold before the debt to the Council has been
repaid, it is likely that a purchaser will insist on settlement of the outstanding
amount to discharge the Notice, before proceeding with the purchase. 
17.5 Legislative provisions apply should a property be put up for sale at the point that
repair and maintenance work has been carried out but not yet paid for.  A new
owner will be jointly liable with the seller for the share of the costs allocated to
the property but only where a notice of potential liability for costs has been
registered in the property registers.  Registration of the notice must occur at least
14 days before the new owner became owner.  Where the Council is aware of
such a situation, it will register a Notice of Potential Liability for Costs. 
17.6 If an owner fails to settle an invoice or defaults on any agreed repayment
instalment arrangement, recovery will be sought in accordance with the Moray
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Council’s Debt Management Policy and using relevant legal remedies available
to the Council, for example an inhibition order.   
18. Appeals
18.1 The Council’s title deed style does not make any provision for arbitration. The
Council shall adopt the policy that, where there is disagreement between the
Council and an owner about repairs or maintenance of common parts and in
particular the choice or cost of materials, contractors or the timing of works the
matter shall be referred in the first instance to the Housing Asset Manager.   
Thereafter if the person is still not satisfied, they can write to the Service
Manager Property, Estates and Assets stating the reason for their request.   
18.2 When an owner is not satisfied with a decision that is taken in accordance with
the TMS, for example if they did not vote for a decision or it was taken before they
purchased a property, they can apply to the Sheriff Court to have it cancelled.
The sheriff will only cancel a decision made by the majority of owners if it is not in
the best interests of the owners as a group, or if it is unfair to one or more of
them.  Owners must apply to the court within 28 days of being informed of the
decision. During that time, the decision cannot be implemented. 
19. Monitoring
19.1 The Council will monitor the following:
• number of occasions on which the TMS scheme is used;
• cost of common repairs;
• repayment agreements reached with owners;
• any actions such as Notice of Potential Liability for Costs or inhibition orders;
and
• the number of applications to the Sheriff Court to have scheme decisions set
aside. 
20. Policy review
20.1 The Common Repairs Policy will be reviewed in 2029, or earlier if required by
legislative or statutory guidance changes.
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APPENDIX A
Definitions
Balustrades The railing system that encloses one or both sides of a
staircase.
Capital Investment
Programme
The programme through which the Council funds and
organises major improvements and investment in its
housing stock.
Common areas or
parts
Parts of the tenement or block of flats that are not within
the boundaries of individual flats but are owned jointly by
two or more owners in the tenement or block.
Common repairs Repairs to the common parts or areas of a building for
which all the owners of the relevant common parts or areas
are responsible
Missing shares Term used to describe an amount which represents an
owner’s share for repair costs where that owner is unable
or unwilling to pay their share or where that owner cannot
be found. The amount paid will be recovered from the
‘missing’ owner by means of a payment plan or Repayment
Charge
Repayment charge If a local authority pays for common repairs when some
owners fail to contribute, they can recover these costs
through a repayment charge on the property. The local
authority will then register the charge in the appropriate
Land Register.  The repayment charge has priority over all
future burdens and debts secured on the house and, with
some exceptions, existing burdens and debts. If the
property is sold with the charge still in place, the new
owner will become responsible for the debt.
Scheme Decision A decision taken by the owners of a majority of the flats
in a tenement or block of flats relating to repairs to the
common parts.
Solum The area of ground that lies inside the walls or foundations
of a building.
Tenement A tenement is a building comprising two or more related
flats that are divided from one another horizontally. Large
houses that have been converted into flats, high-rise
blocks, four-in-a-block and modern apartment blocks are
tenements.
Tenement
Management
Scheme
The Tenement Management Scheme is set out in the
Tenement (Scotland) Act 2004 which the Council uses to
manage common repairs in mixed-tenure flatted properties
where property title deeds are silent or contain gaps.
Title Deed A legal document, registered in the Register of Sasines
or the Land Register, which states who owns a property
and sets out the rights and obligations attaching to the
property.
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APPENDIX III 
INTEGRATED IMPACT ASSESSMENT (IIA) COVERING
• EQUALITIES & SOCIO ECONOMIC DUTIES
• HUMAN RIGHTS AND RIGHTS OF THE CHILD 
DATE UPDATES/EXECUTIVE SUMMARY VERSION DETAILS
Insert Date
(e.g.
03/10/2023)
Add brief notes/highlight which section amended (e.g.
first draft of IIA completed and submitted to SFC
25/10/2023 for consideration; noting that further work
on Stage 2 will be required). 
Insert (ShP) Version
Info (when details
have been agreed)
(e.g. 5.0
03/10/2023 11:21
AMcL)
29/08/2025 1st Draft IIA submitted to Housing and Community
Safety Committee on 18/11/25 
21/1/2026 Second Draft IIA to be submitted to Housing and
Community Safety Committee on 12 March 2026. 
STAGE 1 - DO I NEED AN INTEGRATED IMPACT ASSESSMENT? 
Name of policy or proposal:                Common Repairs Policy
Is this a  Please ✓ below
New activity, programme or policy? 
Change to an existing activity, programme or policy? ✓
Budget proposal? 
Duties: tick the boxes you think apply No Maybe                                                                                                                                             Yes
Equalities: Will your proposal have an impact on groups with
protected characteristics?
Consider the impact of your proposal on people and how they
access your services and information without barriers.  
✓
Socio-economic 
Not every person/family has access to regular income or savings.
Will your proposal have an adverse impact on them  
✓
Does your proposal impact on the human rights of people?    ✓
Does your proposal impact on the rights of children and young
people  
✓
Reasoning - Briefly describe your reasoning for the responses given above: 
Individuals within certain protected groups:
• can be affected by more socio-economic issues in relation to lower income / poverty
issues and ability to access resources needed to finance their share of a common
repair.
• may experience issues with communication / accessing information.
If you have answered “maybe” or “yes” to any of the Stage 1 questions above, then
proceed to complete the Stage 2 Integrated Impact Assessment questions below.
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If you have answered “no” to the Stage 1 questions above, then provide the details
below and submit to [email]
Lead Officer for developing the contract 
Other people involved in the screening (this
may be council staff, partners 
or others i.e. contractor or community) 
Date 
STAGE 2: INTEGRATED IMPACT ASSESSMENT
Brief description of the affected service
1. Describe what the service does: 
The revised draft Common Repairs Policy complies with relevant legislation and regulatory
requirements.  It sets out the framework for managing and delivering repairs to communal
areas in mixed-tenure buildings where both Moray Council and private owners have repairing
obligations.  It aims to ensure that common repairs are carried out efficiently, fairly, and in a
way that supports the sustainability of housing stock and communities.  
The policy sets out: 
• How Moray Council will manage common repairs in mixed-tenure blocks.
• Responsibilities of owners and the Council.
• When the Council will lead on common repairs and the process that it will apply to
emergency repairs / planned maintenance / improvements.
• How repair costs are recharged to owners.
2. Who are your main stakeholders? 
• Owner-occupiers, landlords and private tenants, who own or live in mixed tenure
blocks in Moray 
• Moray Council tenants
• Moray Council staff
3. What changes as a result of the proposals? Is the service reduced or removed?
The revised Common Repairs Policy aims to:
• ensure the Council has policy which complies with current legislative and regulatory
requirements and reflects current operational practice;
• provide clarity on the process the Council will follow in its management of a common
repair; and
• remove reference to grant funding which is no longer available.  This change has not
been enacted through this policy review.  
4. How will this affect your customers?
It provides clarity on rights and responsibilities and the process that will be used for carrying
out a common repair, ensuring a transparent, accountable and consistent process is
delivered.  This includes:
• setting out owner occupier and Council responsibilities; 
• assistance that the Council will provide; 
• measures to protect the Housing Revenue Account; and 
• ensuring that the housing investment programme is effectively delivered and that
tenant properties are maintained in accordance with relevant standards.
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The policy will support improvements to Moray Council and owner-occupied properties and
enhance the visual appeal of communities across Moray. 
5. Impact on staff providing the service
Minimal impact.  Training and awareness raising and guidance on the policy and procedure
changes will be provided. 
6. Please indicate if these apply to any of the protected characteristics
Protected groups Potential impacts and considerations
Race  Potential Impact – 
Language barriers may affect engagement in the
process or impair the understanding of legal
implications/actions.
Disability  Potential Impact – 
Those with physical, visual, hearing, learning
disabilities or mental health conditions may
struggle to access and understand the common
repairs service.
Some people with a disability may be impacted due
to their ability to make financial contributions.
Carers (for elderly, disabled or
minors)
None identified
Sex Potential Impact – 
• Single women and men with children may be at
higher risk of poverty, depending on their
circumstances.  
• Victims of domestic abuse (male/female) may
have restricted access to finance.  
These groups may be disproportionally affected in
their ability to make financial contributions.
Pregnancy and maternity (including
breastfeeding)
No direct impact
Sexual orientation No direct impact 
Age (include children, young people,
midlife and older people)
Potential Impact – 
• Some older owners may not have the financial
capability to raise/borrow the finances needed
to fund their share of common repairs. 
• Some older residents may face barriers in
understanding or contributing to decisions on
repairs.
• Not undertaking the common repair may risk the
quality of the building/area.  This may mean that
children in poorly maintained communal areas
may suffer health issues and educational
setbacks.
Religion, and or belief None identified, but faith-sensitive practices should
be respected
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Gender reassignment None identified
Inequalities arising from socio-
economic differences
Potential Impact – 
• Low income homeowners may not have the
financial capability to raise/borrow finances
needed to fund their share of common repairs.
• Investing in the common repair may incur
increased debt and / or reduce a household’s
ability to pay for essentials. 
Investing in homes and neighbourhoods and
improving quality of life will have a positive impact
on people’s physical and mental health. 
Repair/maintenance and upgrading existing homes
helps to alleviate risks such as fuel poverty
concerning poverty. 
Human rights
List of convention rights Describe, where applicable, if and how specific
rights are engaged
Article 5: Right to liberty and security 
Article 6: Right to a fair trial Policy review ensures compliance with due legal
processes and requirements 
Article 8: Right to respect for private
and family life, correspondence and
the home
The policy supports the right to live in safe, secure,
and habitable housing.
Article 10: Freedom of expression 
Article 11: Freedom of assembly and
association 
Article 12: Right to marry 
Article 14: Prohibition of
discrimination (in relation to the
convention rights)
Policy review and IIA to identify and reduce any
impacts through relevant mitigations to support
this right.
Article 1 of Protocol 1: Protection of
property
The policy supports the right to live in safe, secure,
and habitable housing.
Article 2 of Protocol 1: Right to
education 
Article 3 of Protocol 1: Right to free
elections by secret ballot 
Children’s Rights and Wellbeing 
Relevant articles – UNCRC 
Article 2 – Non discrimination Policy review incorporates UNCRC considerations. 
IIA to identify and reduce any impacts through
relevant mitigations to support this right.
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Article 3.1 – Best interest of the child Policy supports this right by incorporating UNCRC
considerations.
Article 6.2 – Right to survival and
development
The policy seeks to improve housing quality.  Poor
housing quality has a direct effect on children’s
health, development and educational outcomes.
Article 12 – Respect of the views of
the child
Policy supports this right by incorporating UNCRC
considerations.  
Article 19(1) – The right to be
protected from violence and abuse
while in the care of parents 
Article 23 – Children with a disability Policy supports this right by incorporating UNCRC
considerations.  
Article 27 – Adequate standard of
living - for the child's physical,
mental, spiritual, moral and social
development
Policy supports this right by incorporating UNCRC
considerations.   
7. Evidence. What information have you used to make your assessment?
Performance data 
Internal
consultation
Head of Housing, Property and Communities
Service Manager Housing Strategy
Service Manager Property, Estates and Assets
Housing Asset Manager
Senior Housing Officer (Policy)
Equal Opportunities Officer
Consultation with
affected groups
A consultation was undertaken between 19 November 2025 and 21
January 2026.  This included:
• publication of the revised Common Repairs Policy on the Council
website along with an easy read version of the policy and summary
of the changes;
• an electronic survey, available via the Council’s Moray Engage
portal site, which was promoted across social media platforms;
and
• contacting relevant stakeholders for feedback (email issued to
tenants with an up-to-date email address and letter / email issued
to property owners with whom the Council shares ownership and
responsibility for common repairs), including Register of
Interested Tenants and Moray Tenant’s Forum.
Consultation summary:
• 79 respondents (87.77%) support the draft policy. 
• 81 respondents (90%) find it easy to read and understand.  
• respondents (4.45%) thought there should be some re-wording.  
• 11 respondents (12.22%) thought something was missed and
should be included.   
• respondents (3.33%) thought that something should be removed
from the policy.
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Following consideration of the feedback received, there have been no
changes made to the Common Repairs Policy.  The comments
received will, where relevant, be used to inform the development of
operational procedures and information resources that support the
policy.
Local statistics Tenant Satisfaction Survey 2024 
National statistics 
Other Good practice from other local authorities, CIH, Scottish Government
Scottish Government – Housing to 2040: equalities position
statement 
8. Evidence gaps 
Do you need additional information in order to complete the information in the
previous questions?
Feedback from tenant and stakeholder consultation has been considered and no further
information is needed. 
9. Mitigating action 
Can the impact of the proposed policy/activity be mitigated?  Please explain 
• Information resources on the Common Repairs Policy and process will be made
available in accessible formats and using plain language.  For example, website
updates, leaflets/FAQs and signposting to reliable sources of guidance and good
practice.
• Non-digital formats will be considered when communicating with owners/tenants. 
For example, issuing of notices and letters, with contact details provided.
• Where appropriate translation and interpretation services will be available, in line
with Moray Council policy.
• Communication will be maintained with owners/tenants throughout the process.
• Staff will offer advice and will signpost owners to sources of independent and / or
legal advice.
• Where appropriate, repayment plans may be agreed with owners to mitigate against
any disproportionate financial impact of the cost of the common repair.
• Where appropriate, staff will signpost owners to financial inclusion services and
provide information on other available options that an owner may want to consider
such as the Open Market Purchase Scheme.  Staff will endeavour to provide owners
with information and guidance so that they can make an informed decision.
• Human Rights – The policy supports the right to live in safe, secure, and habitable
housing.
• Rights of the Child (UNCRC) – The commitments made within the policy seeks to
improve housing quality.  Poor housing quality has a direct effect on children’s
health, development and educational outcomes. 
10. Justification
If nothing can be done to reduce the negative impact(s) but the proposed
policy/activity must go ahead, what justification is there to continue with the change?  
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All impacts fully mitigated as per Q9 above. 
SECTION 3 CONCLUDING THE IIA
1. No potential negative impacts found for any protected groups. 
2. Some potential positive impacts have been identified.
The impacts relate to:
✓
Reducing discrimination, harassment, victimisation or other conduct
prohibited under the Equality Act 2010
✓
Promoting equality of opportunity ✓
Fostering good relations ✓
3. The proposals interfere with human rights and/or the rights of the child ✓
4. Negative impacts can be mitigated as outlined in Q9. ✓
5. The negative impacts cannot be fully mitigated but are justified as Q10. 
6. Further consultation with affected groups is needed. ✓
7. It is advised not to go ahead with the proposals. 
Decision - Set out the rationale for deciding whether or not to proceed with the
proposed actions: 
To be presented to the Housing and Community Safety Committee on 12 March 2026. 
Date of Decision: 
Sign off and authorisation: 
Service Housing, Property and Communities Service
Department Housing 
Policy/activity subject to IIA Common Repairs Policy 
We have completed the integrated impact
assessment for this policy/activity. 
Name: Gillian Henly
Position: Senior Housing Officer (Policy)
Date:  
Authorisation by head of service  Name: Edward Thomas
Position: Head of Housing, Property and
Communities
Date:
Permission to publish on website - 
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1 
Report to: Housing and Community
Safety Committee
Meeting Date: 12 March 2026  
Report by: Executive Director Education, Housing and Communities      
Author: Emma Armit Contact Email: Housingpolicy@moray.gov.uk 
Subject: Domestic Abuse Policy – Consultation Results 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to inform the Committee of the Housing Service’s draft
Domestic Abuse Policy consultation results and approve the final policy for
implementation.    
1.2  This report is submitted to Housing and Community Safety Committee in terms of Section
III (G) of the Council’s Scheme of Administration relating to:
• (4) the allocation and letting of houses and homelessness; and
• (12) implementing the Council’s strategy and policies in relation to, Community
Safety and Anti-Social behaviour, in partnership with other public sector partners,
voluntary sector and private sectors as appropriate.   
2.  SUMMARY  
2.1  This report presents a summary of the recent Domestic Abuse Policy consultation results,
explains the rationale for amendments made as a result of the consultation feedback and
presents the final Domestic Abuse Policy for approval and implementation.     
3.  RECOMMENDATIONS 
3.1  It is recommended that Committee:   
i)  notes the recent consultation feedback results at Section 5 and APPENDIX I;
and 
ii)  approves the final revised Domestic Abuse Policy for implementation at
APPENDIX II.
Item 10.
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Emma Armit
Senior Housing Officer (Policy) 
4.  BACKGROUND AND CONTEXT  
4.1  On 21 September 2022, the Community Planning Board endorsed the Moray Community
Safety Strategy 2022-2026 focusing on reducing harm and safeguarding our Community. 
In partnership with Police Scotland and Violence Against Women and Girls Partnership
(VAWGP) this involved reducing incidents of domestic abuse, involvement of substance
misuse in incidents of violence and domestic abuse and rates of domestic abuse where
children are present.  
4.2  On 13 February 2024, this  Committee approved the revised Allocations Policy (Paragraph
8 of the Minute refers) to introduce domestic abuse points for applicants who experience
domestic abuse and urgently need rehousing, strengthening the Council’s commitment to
ensuring those experiencing domestic abuse are empowered and supported to escape
abuse or harm, while making informed housing choices.   
4.3  The Housing (Scotland) Act 2025 requires social landlords to develop and implement a
domestic abuse policy, setting out a support framework for tenants at risk of losing, or
having to change their home due to domestic abuse, without resorting to homelessness. 
Although there is no commencement date, the Council understand the importance of
committing to a domestic abuse policy and having regard for it when exercising Council
functions.    
4.4  The Scottish Government has committed to a national ‘Fund to Leave’ as part of the
Housing Emergency Action Plan.  The fund aims to help victims cover the costs of moving
to a new home, new clothes, transport and all the other essential costs that victims
absorb when rehousing.  This expansion from earlier pilot schemes shows the Scottish
Government’s intent to embed this support into its housing / emergency support
framework.  Full details on rollout, eligibility, and application mechanisms are due to be
released through 2026.  
4.5  On 18 November 2025, this  Committee approved the draft Housing Domestic Abuse
Policy for a public and stakeholder consultation period to inform the final policy
development (para 13 of the Minute refers).   
5.  CONSULTATION ANALYSIS AND FEEDBACK  
5.1  An eight-week consultation took place between 19 November 2025 and 14 January 2026. 
The consultation asked about how communication could be improved, what the Council
could do differently to support survivors, what the main barriers are and what type of
housing options and / or support is most important.  The consultation included:
• An online survey, accessed via the Housing Hub section of Moray Engage;
• Publication of the draft Housing Domestic Abuse Policy along with an easy read version
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of the policy;
• Targeted distribution to all tenants / joint tenants and housing list applicants via email       
or letter depending on their preferred method of contact;
• Promotion via the Council’s website, news and social media platforms; and
• Requests for stakeholder feedback including:
o Violence Against Women and Girls Partners (including Moray Women’s Aid,
Moray Rape Crisis, Health and Social Care Moray, Education and Police
Scotland),
o Community Safety Partners,
o Registered Social Landlords who operate in Moray,
o Moray Tenant’s Forum and Register of Interested Tenants.  
5.2  9690 Council tenants, joint tenants and housing list applicants were contacted as part of
the consultation and:
• invited to answer generic questions on the revised policy;
• given the opportunity to provide any further general comments for consideration; and 
• asked if they needed additional support with their tenancy and / or rent.  
5.3  A total of 139 responses were received.  This equates to a low response rate of (1.4%)
given the overall context of the sample size, despite reminders being issued directly via
text and /or email, as well as across both Council and Housing’s social media platforms. 
Officers believe the relatively low response rate reflects the specialist nature of the policy. 
While domestic abuse is a serious and important issue, it is one that primarily affects a
specific proportion of service users and certain partner organisations, therefore
responses are largely received from individuals and organisations with direct experience
of, or professional involvement in, this area.   
5.4  Of the 139 responses received:
• 135 (97%) were from individuals broken down to:
o Moray Council tenant – 87 (64%)
o Moray Council tenant representative – 1 (1%)
o Housing Association tenant – 17 (13%)
o Member of public in private rented / owned property – 29 (22%)
• 4 (3%) were from organisations (Moray Council Housing Service, Health or Social
Care, Education, Other- Gypsy Traveller Community). 
5.5  Of particular significance is that the majority of responses (74%) were submitted by those
with direct lived experience of domestic abuse.  Survivors accounted for 66% (90) of all
responses, with a further 8% (11) provided by family members or friends supporting
someone experiencing domestic abuse.  The feedback is grounded in real, local
experiences, providing authentic insight into the realities of abuse and reinforces the
effectiveness of current service provision while strengthening the feedback relevance and
credibility in terms of conclusions drawn.    
5.6  On the whole, the draft policy was well received and welcomed with approximately 60% of
respondents feeling the draft policy recognises trauma, prioritises safety, choice and
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4 
dignity and considers survivors needs, affirming that good work is already taking place
locally in relation to domestic abuse.   
5.7 Due to the sensitive nature of domestic abuse, the feedback has been anonymised to
remove any identifying information or personal circumstances. A high-level summary of
the responses, collated into overarching key themes, is provided in APPENDIX I. 
5.8 126 (91%) of respondents supported the draft policy, finding it easy to read and
understand.  Of the remaining respondents:
• 18 (15%) thought something was missed and should be included.  Analysis of
these comments identified that either the suggestion made is already included in
the draft policy or is more relevant and beneficial to inform the development of the
supporting operational procedures and staff training.
• 10 (8%) thought there should be some re-wording which has been considered and
actioned with minor revisions for clarity.
• 6 (5%) answered to say something should be removed but comments related to
practice(s) that could be considered for removal.  
5.9 The top priorities respondents identified in terms of housing options and support were:
•  ‘Transfer to a different, safe Council property’ 75% (104), ‘Temporary emergency
accommodation’ (67%) 93, and ‘Support to maintain a tenancy safely’.  
• This was closely followed by ‘Respite accommodation in MWA’ 64% (89) and
‘Safety measures in current home’ 64% (89).
• Others included advice on joint tenancies and tenancy rights and access to
independent advocacy.  
5.10 The following overall summary of the consultation feedback highlights the main themes
and practical implications that have been identified:
• Language / inclusivity – Consider language, expand emphasis on perpetrator
accountability, explicitly reference all groups. 
• Communication / joint working - Named case workers, proactive updates, safe and
accessible contact, reduce repetition, clearer guidance.  APPENDIX I (Q.10)
provides a summary. 
• Staff training - Mandatory trauma-informed, inclusive training to ensure service
users are listened to, believed, and respond to all forms of abuse.
• Housing / safety - Prioritise safe, flexible housing.  Implement physical security
measures.  Consider pets, family and survivor circumstances.
• Support services - Holistic, survivor-led support with counselling, advocacy, and
practical guidance that continues once re-housed.  APPENDIX I (Q.11) provides a
summary. 
• Policy implementation - Clear procedures, timely action, strong inter-agency
coordination, recognition of systemic barriers.  A summary of perceived current
barriers by service users have been identified and is available at APPENDIX I (Q.12)
but includes lack of available housing, waiting times, safety / risk concerns, issues
with staff, systems, bureaucracy and evidence requirements, support limitations,
financial / personal / practical constraints.
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5.11 Although only 54% of respondents felt the Council deals effectively with the abuse, this
opinion is reflective of the legal and justice system as a whole.  The Policy commits to
taking action within the legal provisions available to it as a social landlord.  
5.12 Following analysis and consideration of the feedback at APPENDIX I, there has been no
material change to the scope, commitments, objectives or substance of the policy.  Some
minor revisions to the policy are:
• Marginal revisions to wording / terminology
• Revision to Section 5 - Legal Provisions updated with new information on
legislation enactment and royal assent where the provisions strengthen a
landlord’s statutory powers in relation to removing perpetrators from the home.
The minor revisions to the Policy are highlighted in italics at APPENDIX II . 
5.13 Despite no major changes, the feedback from service users with lived experience has
provided valuable insight into the practical challenges and needs faced when accessing
Housing and related services. This evidence will be used to inform and refine supporting
operational procedures, to ensure they are responsive, trauma-informed and grounded in
real experience. By embedding these insights into daily practice, the Housing service and
VAWG partners will be better equipped to deliver consistent, effective and compassionate
support to those affected by domestic abuse.     
5.14
POLICY IMPLEMENTATION 
A Domestic Abuse Review Group has been established, comprising officers and managers
from the Housing Service to oversee the implementation of the revised policy.  The group
will meet periodically throughout 2026 to:
• review operational procedures that support the Housing Domestic Abuse Policy in
practice to ensure:
o improved practice(s) on first approach including consistency, continuity
and robust recording;
o quicker responses;
o more considered allocations around areas and lets based on
circumstances;
o use of legal provisions with progression to enforcement and legal action
where appropriate;
o those who need support are identified and supported. 
• develop a training programme, incorporating periodic refresher training for staff
across the Housing Service;
• develop a network of domestic abuse champions in teams across the Housing
Service; 
• review all domestic abuse information, webpages and communications to tenants
to enable clear understanding of the process, what support that is available and
signposting information.  
5.15 Subject to this Committee’s approval, officers will work towards an implementation date
of 1 April 2026.  This will include, informing tenants of any changes, arrangements for
implementing the revised policy and operational procedures, any necessary changes and /
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or testing to the NEC housing system to facilitate the implementation, staff training and
awareness of the revisions.  
6.  SUMMARY OF IMPLICATIONS  
6.1  The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) ✓ 
Policy and Legal ✓ 
Financial ✓ 
Risk ✓ 
Staffing  X
Best Value and Transformation  X
Property  X
Information Communications Technology/Digital            X
Equalities, Social Inclusion and Economic Impact            ✓ 
Climate Change and Biodiversity Impact  X 
6.2  Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☒ Tackle Poverty and Inequality.
☐ Build Stronger Greener Vibrant Economy.
☒ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☒ Building a better future for our children and young people in Moray.
☒ Empowering and connecting communities.
☒ Improving wellbeing of our population 
6.3  Policy and Legal 
The proposed policy is in line with current legislation as detailed in Section 4, APPENDIX A
of the policy at APPENDIX II.  
6.4  Financial
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Commitment to staff training and security measures will incur some financial costs which
will be absorbed into existing budgets. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments       
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments       
6.5  Risk 
The policy provides a framework to address risk and reduce future risk to victims /
survivors.    
6.6  Staffing 
There are no staffing implications arising directly from this report.  
6.7  Best Value and Transformation 
There are none arising from this report.  
6.8  Property 
There are none arising from this report.  
6.9  Information Communications/Technology/Digital 
There are none arising from this report.  
6.10  Equalities, Social Inclusion and Economic Impact 
An IIA was developed as part of the initial draft policy development. The IIA has been
further revised following the consultation period to reflect the feedback received and is
attached at APPENDIX III.  The potential negative impacts identified can be mitigated. 
6.11  Climate Change and Biodiversity Impacts 
There are none arising from this report. 
7.  CONSULTATION  
7.1  This report has been prepared in consultation with the Head of Housing, Property and
Communities, the Service Manager Housing Operations, the Service Manager Housing
Need, G. Anderson, Legal Services Senior Solicitor, the, the Equal Opportunities Officer
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and L. Rowan, Committee Services Officer and any comments made have been
incorporated into the report.   
8.  BACKGROUND PAPERS  
8.1  Housing and Community Safety Committee – 18 November 2025 – Draft Housing
Domestic Abuse Policy
Consultation feedback held by author.   
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Housing Domestic Abuse Policy Feedback               APPENDIX I
Q1-4. 
Individual responses                                                                                                   TOTAL 135 97%
MC tenant 87 65%
MC tenant rep  1 1%
HA tenant 17 13%
Member of public in private rented or owned property 29 22% 
Organisation responses                                                                                             TOTAL 4 3%
Moray Council Housing Service Staff  1 25%
Housing Association / Registered Social Landlord (RSL)   
Domestic Abuse or Specialist Support Service Staff  
Police / Community Safety / Safeguarding Partner  
Health or Social Care Professional 1 25%
Education 1 25%
Other – Gypsy and Traveller Community 1 25% 
Q5. Individual respondents above are:
Victim/survivor of domestic abuse - please note this is purely optional and
confidential.  
90 66%
Family member / friend supporting someone through domestic abuse 11 8%
Prefer not to say 34 25% 
Yes % No %
Q.6 Do you support the draft Housing Domestic Abuse Policy? 126 (91%) 12 (9%)
Q.7 Did you find the draft Housing Domestic Abuse Policy
easy to read and understand?
126 (91%) 12 (9%) 
Yes % No %
Q8 Is there a section of the draft Housing Domestic Abuse
Policy that you think should be reworded?
10 (8%) 122 (92%) 
Q.9 If yes, please tell us what you would like reworded.
Comments received summarised into key
themes:
Housing Service Response/Action
Policy – a concern that Moray Council doesn't
follow own policy nor act on repeated reports of
abuse by neighbour (different policy area)
No policy change required but
information used to inform supporting
operational procedure and staff training.
Lived experience feedback - prolonged
homelessness, unmet support needs, need for
dignity and integrity for survivors of both physical
and emotional abuse.
Policy commits to addressing these
concerns.  No policy change required but
information used to inform supporting
operational procedure and staff training.
Inclusion - Emphasis that domestic abuse affects
all people (genders/ages/communities – including
gypsy travellers but this is different policy area) 
Policy commits to supporting those from
all protected groups under the Equalities
Act 2010. No policy change.
Terminology- Word victim can trigger  Recognised legal terminology that
acknowledges harm and accountability
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Q.10 How can the council and housing providers improve communication and/or joint working
sensitivity when dealing with domestic abuse?
providing clarity for risk assessing,
safeguarding and protection.  After
careful consideration and only 1
respondent raising this, no change has
been made to the policy.
Perpetrator Focus – too brief and lacking
emphasis.
The policy has been revised to include
new legal provisions.  These will inform
operational procedures and legal
remedies available to staff. 
Minor drafting issue - Spelling mistake  Corrected
Comments received summarised into key
themes:
Housing Service Response/Action
Positive feedback received - Some respondents
reported good work already being done in their
cases with good practices are evident such as
empathy, lock changes with sensitive support
given.
Noted and fed-back to operational staff. 
No policy change required.
Clear information and transparency - Better
explanation of Housing Options, processes,
timescales and waiting lists.
No policy change required but
information used to inform supporting
operational procedure and staff training.
Reduce need to re-tell what happened - Better
joint working and shared case information so
survivors do not have to repeatedly retell their story.
Policy commits to this in S.7. No policy
change required but information used to
inform supporting operational procedure
and staff training.
Improved contact:
• A consistent point of contact - Allocate a
named case worker for continuity and trust.
• Accessibility of contact - Improve
responsiveness to calls/emails, offer safer
contact methods (e.g. text/email) and out-of-
hours support.
• Confidentiality and safety - Ensuring discreet
contact, private interview spaces, and safe
engagement when abusers may be present.
No policy change required but
information used to inform supporting
operational procedure and staff training:
• Keeping survivors informed, regular
check-ins, ongoing support.
• Proactively contact those disclosing
abuse, including via housing
applications.
• Clear information on options,
timescales and available support.
Timely action - Faster responses, quicker
rehousing, lock changes, and practical safety
measures.
Policy commits to this at Executive
Summary, S.14 and 16. No policy change
required but information used to inform
supporting operational procedure and
staff training:
• Rehousing considerations as a
priority – areas, sensitive lets, etc. 
• Flexibility in housing options.
• Provide or support physical safety
measures for safe/ secure housing.
Staff training:  Policy commits to this at S.15.  No policy
change required but information used to
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Q.11 What could the Council do differently to make survivors feel believed, supported, and safe?
• Listen, believe, and respond - Survivors want
to be taken seriously, believed, and not ignored
or judged.
• Trauma-informed communication and
understanding - Use sensitive, non-
judgemental language, recognising all forms of
abuse, not just physical.
• More specialist training on domestic abuse,
mental health, and professionalism.
inform supporting operational procedure
and staff training:
• Taking reports seriously
• Mandatory, consistent training on all
forms of domestic abuse (emotional,
coercive, financial, psychological, as
well as physical).
• Trauma-informed practice, language.
• Better understanding that risk can
escalate quickly. Evidence not always
available.
Stronger partnership working - Improved
coordination between Housing, Police, Women’s
Aid, health, and other agencies.
Policy commits to this at S.8. No policy
change required but information used to
inform supporting operational procedure
and staff training around clear, timely
signposting and collaboration.
Person-centred approach - Put survivors’ needs,
circumstances, and support networks at the centre
of decision-making.
Policy commits to this at S.1 Scope and
S.4 objectives. No policy change required
but information used to inform
supporting operational procedure and
staff training around:
• Asking survivors what they feel they
need once immediate safety is
addressed.
• Consider individual circumstances:
children, pets, support networks,
transport.
• Support even when survivors return
to an abuser due to trauma bonding.
Gender neutral language Policy commits to supporting anyone
affected by abuse regardless of gender
and equalities considerations at S.6.  No
policy change.
Comments received summarised into key
themes:
Housing Service Response/Action
Positive feedback - Some respondents reported
compassionate, effective support and
improvements in recent practice.
Noted and fed-back to operational staff. 
No policy change required.
Communication:
• Proactive communication - Make contact,
provide reassurance, regular updates and clear
information on options and timescales.
• Information
• Continuity and trust - Offer a single point of
contact and safe spaces to talk without
repeatedly retelling experiences.
No policy change required but
information used to inform supporting
operational procedure and staff training.
Support: 
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Q. 12 What are the main barriers when trying to access safe housing?
• Access to emotional support - One-to-one
counselling and ongoing wellbeing support.
• Person-centred support - Ask survivors what
they need, consider their full circumstances,
support networks, children, pets, and
transport.
Private counselling is out with scope of
this review. Policy commits to support.
No policy change required but
information used to inform supporting
operational procedure and staff training.
Staff Training and professionalism:
• Consistent, high-quality training on domestic
abuse, trauma, and empathy, unacceptable
behaviour (e.g. dismissive or inappropriate
responses) highlighted.
• Use trauma-informed, sensitive, non
judgemental language and practice
• recognise all forms of abuse, not just physical.
• Listen and believe survivors - Take all
disclosures seriously 
Policy commits to this at S.15.  No policy
change required but information used to
inform supporting operational procedure
and staff training.
Focus on action:
• Safe and secure housing - Provide
accommodation that is physically secure and
located away from abusers, antisocial
behaviour, or known offenders.
• Timely rehousing and action - Faster moves,
early intervention, and not waiting for extreme
evidence or escalation.
• Safety measures - Practical security support
such as lock changes, cameras, lighting, and
neighbourhood safety.
• Consistent, transparent decision-making
Policy already commits to timely action
and safety measures at S.10.  The
Council’s Allocations Policy covers
sensitive lets/areas. 
No policy change required but
information used to inform supporting
operational procedure and staff training.
Stronger partnership working - Stronger
coordination with Women’s Aid, police, health, and
support services with clear signposting.
Policy commits to this at S.8. No policy
change required but information used to
inform supporting operational procedure
and staff training around clear, timely
signposting and collaboration.
Comments received summarised into key
themes:
Housing Service Response/Action
Lack of available housing / long waiting lists:
• Insufficient properties, limited safe options,
difficulty finding housing quickly.
• Delays in allocation.
• Placement issues / unsuitable housing
• Being placed near unsafe tenants, drug users,
or abusers
• Poor property conditions
• Lack of security measures / Insecure
properties
• Unsafe areas,
The Council are continually working
towards increasing their housing stock
through Strategic Housing Investment
Plan (SHIP), Housing Needs and Demand
Assessment (HNDA) and Open Market
Purchase Scheme where funding allows. 
Policy already commits to safety
measures at S.10.  
The Council’s Allocations Policy covers
sensitive lets/areas. 
No policy change required but
information used to inform supporting
operational procedure and staff training  
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Q. 13 Do you think the Policy makes sure the Council’s Housing Service: 
Yes 
Recognises the impact of trauma and avoids causing further harm 81
Prioritises safety, choice and dignity 86
Puts the victims’/survivor’s needs and rights at the centre of all decisions 80
Deals effectively with the abuser 54 
Yes % No %
Q.14 Is there something we’ve missed from the draft Housing
Domestic Abuse Policy that you think should be included?
18 (15%) 101 (85%)
Safety concerns / risk from abuser:
• Fear of being found, followed, threatened by
abuser
• Risk from neighbours or unsafe areas.
• Housing near abuser
Policy commits to safety measures at
S.10 and areas/sensitive lets through
application of the Allocations Policy.
No policy change required but
information used to inform supporting
operational procedure and staff training.  
Staff and system issues:
• Dismissive or untrained staff,
• Complex processes
• Difficulty proving abuse.
• Staff attitudes and processes
• Rude, dismissive, or unsupportive staff
• Lack of trauma-informed practice
• Poor inter-department communication.
Bureaucratic and evidential barriers
• Needing to provide proof of abuse (especially
non-physical)
• Complex applications
• Delays in processing.
Policy commits to staff training at S.15. 
No policy change required but
information used to inform supporting
operational procedure and staff training. 
Will be covered in procedural review and
staff training.
Support limitations:
• Lack of support services for men
• Limited guidance for navigating housing
• Poor communication or follow-up
• Emotional / trauma-related challenges
• Stress of moving
• Feeling unsafe
• Trauma making decision-making harder. 
Financial and personal constraints:
• Costs of deposit, rent, moving, lack of
affordable housing
• Impact on family and children
• Moving away from schools, family, or support
networks
• Needing family-friendly accommodation.
• Restrictions on pets which can prevent
accepting housing. 
Policy commits to helping overcome
financial barriers to enable re-housing at
S.13. 
Personal considerations are dealt with
through Allocations Policy.
No policy change required but
information used to inform supporting
operational procedure and staff training.
Other practical issues - Transport, privacy, and
neighbourhood suitability.
As above.
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Q.15 If yes, please tell us what you think should be included.
Comments received summarised into key
themes:
Housing Service Response/Action
Safety and security measures – Ensuring survivors
are not housed near abusers, ability to use
cameras, lock as, alarms, and other safety features.
Policy commits to safety measures at
S.10 and areas/sensitive lets through
application of the Allocations Policy.
No policy change required but
information used to inform supporting
operational procedure and staff training.  
Support for victims and abusers – Counselling,
therapy, and emotional support for both parties
Private counselling is out-with the scope
of this review. The policy commits to
support through Housing Support, MWA,
AMIS and Victim Support. 
No policy change required but
information used to inform supporting
operational procedure and staff training.  
Staff training and sensitivity – Front-line staff need
training to respond appropriately and
empathetically
Policy commits to this at S.15.  No policy
change required but information used to
inform supporting operational procedure
and staff training.
Holistic and timely response – Clear procedures,
prioritising victim needs, and timely action against
abusers (e.g., evictions).
Policy already commits to timely action
and safety measures at S.10.  No policy
change required but information used to
inform supporting operational procedure
and staff training.
Mental health support – Recognising and
supporting mental health impacts of abuse.
Policy commits to this at S.8.  No policy
change required but information used to
inform supporting operational procedure
and staff training.
Recognition of vulnerable groups – Men, ethnic
minorities (e.g., Gypsy/Traveller community), and
other underserved groups.
Policy commits to considering all groups
protected by the Equalities Act 2010 at
S.6.  No policy change required but
information used to inform supporting
operational procedure and staff training.
Privacy and personal space – Survivors having their
own safe and private living environment
Allocations Policy should address this. 
No policy change required but
information used to inform supporting
operational procedure and staff training. 
Pets and household considerations – Support for
victims with animals when relocating or accessing
housing.
The Housing Service are currently
considered its policy around pets in
Council houses which will help inform
and address this barrier.  
No policy change required but
information used to inform supporting
operational procedure and staff training.
Awareness of non-physical abuse – Recognising
emotional, psychological, and neighbour-to-
neighbour abuse as valid.
Policy commits to staff training at S.15. 
No policy change required but
information used to inform supporting
operational procedure and staff training.
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Q.16 What types of housing options and/or support are most helpful for people affected by
domestic abuse? 
Other
Acknowledging systemic barriers – Survivors feeling
unsupported, ignored, or retraumatised by current
council procedures.
Policy commits to staff training at S.15.   
The policy has been developed to reduce
all barriers.  No policy change required
but information used to inform
supporting operational procedure and
staff training.
Temporary Moray Council emergency accommodation 93 67%
Respite accommodation in Moray Women’s Aid or property 89 64%
Transfer to a different, safe Council property 104 75%
Safety measures in the current home, such as locks / Ring doorbell 89 64%
Support to maintain a tenancy safely 91 65%
Advice on joint tenancies and tenancy rights 70 50%
Access to independent advocacy 74 53%
Other 11 8%
Comments received summarised into key
themes
Housing Service Response/Action
Counselling and emotional support - Access to
trauma-informed counselling to help survivors
process abuse.
Private counselling is out-with the scope of
this review. The policy commits to support
through Housing Support, MWA, AMIS and
Victim Support. 
No policy change required but information
used to inform supporting operational
procedure and staff training.  
Financial support and advice - Assistance to
reduce financial stress while dealing with
abuse and recovery.
Policy commits to helping overcome
financial barriers to enable re-housing at
S.13 and signposting to relevant agencies
such as Money Advice.
No policy change required but information
used to inform supporting operational
procedure and staff training.
Recognition of all types of abuse - Domestic
abuse should be taken seriously regardless of
the survivor’s age, gender, or relationship to the
abuser.
Policy commits to considering all groups
protected by the Equalities Act 2010 at S.6
and future legal provisions within the
Housing (S) Act 2025 will widen the definition
to include other relationships with abuser. 
Policy has been revised at S.5 ‘Legal
Provisions’. 
Tailored support - Services should respond to
the individual survivor’s needs and wishes.
Current Housing Support and MWA Support
is person-centred.  No Policy change. 
Support for children - Clear signposting to
children’s services where relevant.
Policy commits to this at S.8.  No policy
change required but information used to
inform supporting operational procedure and
staff training.
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16 
Yes % No %
Q.17 Is there something that you think should be removed from
the draft Housing Domestic Abuse Policy?
6 (5%) 124 (95%) 
Q.19 Please tell us if you have any other comments on the draft Housing Domestic Abuse Policy.
Housing flexibility - Options to access safe
housing, including considerations for pets
As above.
Survivor-led approach - Ask survivors what they
need and address both immediate and long-
term needs.
As above.
Q.18 If yes, please tell us what should be removed.
Comments received Housing Service Response/Action
Financial burden on survivors - Debts and costs
should not fall on survivors, responsibility
should lie with the abuser.
Policy already commits to this specifically at
S13. No policy change required but
information used to inform supporting
operational procedure and staff training.
Overly complex or restrictive policy - Some
aspects of the policy may be impractical given
housing limitations.
The Housing Service do work within funding
and resource limitations similar to other
services and local authorities. The policy is
intended to improve service delivery.  No
policy change.
Barriers to accessing help - Requirements like
police involvement can prevent survivors from
getting support.
Policy and partnership working means MWA
can provide support. 
Gender bias - Services and policies perceived
as focused on women; need to better include
men and other survivors.
Policy commits to helping anyone
experiencing domestic abuse in line with the
current definition.   No policy change.
Lack of practical support options - Need for
more actionable, supportive measures rather
than just policy statements.
The policy commits to support throughout. 
No policy change. 
The abuser Reference necessary to explain policy
commitments.  No policy change.
Comments received Housing Service Response/Action
Belief and responsiveness - Survivors feel they
are not always believed or adequately helped
need for staff to take abuse seriously.
Policy commits to staff training at S.15.  No
policy change required but information used
to inform supporting operational procedure
and staff training.
Inclusive support - Policy should support all
victims, including men, gypsy/traveller
communities, and those experiencing non-
physical or silent abuse.
Policy commits to considering all groups
protected by the Equalities Act 2010 at S.6. 
No policy change required but information
used to inform supporting operational
procedure and staff training.
Staff training - Importance of well-trained,
trauma-informed, inclusive staff;
understanding diverse needs and situations.
Policy commits to staff training at S.15.    The
policy has been developed to reduce all
barriers.  No policy change required but
information used to inform
Safety and housing options: As covered above.
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17 
• Safe temporary accommodation or shelters
are crucial, especially for children.
• Concerns about abusers being housed
nearby.
• Repairs and financial responsibility for
damage caused by abusers.
• Visits by housing officers should consider
gender balance to avoid assumptions
Holistic, long-term support - Psychological
services, counselling, and tailored support to
address internal trauma; ongoing support
beyond housing placement.
Policy already commits to support within the
Council’s funding and resources allow as
well as through partner agencies.  Any private
counselling would be out-with the scope of
this review. 
Policy accessibility and clarity - Policy should
be easy to read, understandable, and widely
publicised (leaflets, drop-in days).
Easy Read Version is available.  Consultation
was widely published.
No action required.
Practical implementation concerns - Risk that
policy won’t be fully implemented due to
funding or lack of resources.
Need for coordination with other services.
Funding and resources are currently in place
to support the policy at this current time.
Privacy and discreet access to support -
Survivors need ways to access help safely
without alerting abuser.
Policy commits to support throughout.
No policy change.
Acknowledgment of broader impacts -
Decisions should consider impact on children,
schooling, family stability, and overall well-
being.
Policy commits to person-centred approach
which considers these issues. No policy
change.
Appreciation and encouragement - Positive
feedback for the policy as a step forward.
Strong desire for actions to match words.
Noted and feedback to staff. 
Implementation plan to support delivery is in
place. 
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18 
APPENDIX II 
Housing Domestic Abuse Policy 
Date of Creation September 2025
Owner (Service) Housing, Property and Communities
Reviewer Head of Service Head of Housing, Property and Communities 
Approver Executive
Director
Executive Director Education, Housing and
Communities
Date Approved <TBC> 2025, for implementation on 1 April 2026 
Approver (Committee) Housing and Community Safety Committee
Date Approved TBC
Next Review Date  2029 or earlier if required by legislative or guidance
changes 
Version History
Version Date Author Changes Made Approved By
1.0 29.09.25 Housing Policy Initial draft document
Housing & Community
Safety Committee
18.11.25
2.0  12.03.26 Housing Policy Final document for approval
Housing & Community
Safety Committee
12.03.26 
1. Scope of policy
2. Definition(s)
3. Strategic context 
4. Objectives and principles of the policy
5. Legal provisions 
6. Equalities, rights and socio-economic requirements
7.        Confidentiality and data protection
8. Partnership, co-ordination and collaborative working
9. Prevention and early intervention
10. Remain in current home
11. Housing options
12. Homelessness
13. Financial considerations
14. Enforcement action against perpetrators
15. Training 
16. Risk management
17. Quality assurance
18. Review and complaints process
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19 
19. Performance monitoring and policy review
APPENDIX A - Other Relevant Legislation, Guidance and Regulatory
Requirements 
Executive Summary 
Moray Council fully recognises the critical role it plays as a social landlord in preventing and
responding to domestic abuse across our Moray communities. This Domestic Abuse Policy
firmly embeds Scotland’s national Equally Safe strategy and framework to prevent and
eradicate domestic violence.  While the policy supports anyone experiencing domestic abuse,
it also recognises that domestic abuse is a form of gender-based violence that
disproportionately affects women and girls. As a result, the policy takes a gender-informed,
trauma-sensitive approach, ensuring all responses reflect an understanding of the gendered
nature and power dynamics of abuse.   
Moray Council is committed to helping the person experiencing abuse make informed housing
choices based on their individual circumstances, enabling them to remain in their home and
community should this be their preferred option, where it is safe and appropriate to do so.  Our
framework will focus on person-centred tenancy solutions, including the removal of the
perpetrator from joint tenancies and exclusion from the property where appropriate, timely
rehousing options when remaining in the home is not safe or desirable while minimising any
disruption, particularly for survivors with caring responsibilities or those at risk of
homelessness. 
The complexity of domestic abuse demands a co-ordinated multi-agency response. Moray
Council works collaboratively with key statutory and third-sector partners to ensure survivors
receive comprehensive, tailored support.   This approach ensures that housing responses are
embedded within a wider risk framework of assessment, safeguarding, and support planning. 
Moray Council’s Housing Service is fully committed to:
• a zero-tolerance, trauma-informed and victim-centred response in a drive to help
eliminate domestic abuse and gender-based violence in Moray
• the Scottish Government’s Equally Safe vision of a Scotland where everyone,
regardless of gender, can live free from violence, abuse, and fear. 
This housing policy will play a key part in achieving this, by ensuring that those experiencing
abuse / survivors are believed, supported, safe and protected while perpetrators are held
accountable.   
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1. Scope of policy
1.1     This policy details the framework Moray Council’s Housing Service, in its key role
as a social landlord, will follow to ensure the safeguarding, support and housing
security of any individual experiencing domestic abuse.  The Housing service will
take a zero tolerance, person-centred approach while working collaboratively
across the Council and partners to provide a co-ordinated response, enabling
victims / survivors to access what they need to live free from violence and abuse.   
1.2 The Housing service is committed to delivering services with empathy, dignity
and respect, that are responsive to the needs of individuals who may have
experienced trauma, while understanding the lasting impact on wellbeing,
behaviours and the ability to engage with services. 
1.3 In recognition of the key role housing has in enabling individuals to escape
domestic abuse, this policy: 
• presents a safe, sensitive and trauma-informed housing response,
recognising when a person may be affected by trauma, making
adjustments with them in a collaborative way to take this into account and
responding in a way that supports their recovery while avoiding adding to
that trauma in our response. 
• aligns with national strategy, legal obligations, and partnership
commitments, while supporting victims / survivors’ right to safety and
recovery; and
• sets out the Housing Service’s commitment to a gendered and rights-
based approach to supporting women, children and any individuals
experiencing domestic abuse regardless of their sex, gender or
relationship.
• ensures that any risks identified that could jeopardise a positive outcome
will be escalated to the Head of Housing, Property and Communities who
may exercise urgent discretion and authorise any actions necessary to
safeguard individuals and ensure an appropriate and timeous response. 
1.4 The policy applies to:
• all Moray Council tenants currently living in a property owned by the Housing
Service; and
• any individual seeking housing options, homeless or housing information and
advice as a result of domestic abuse.   
2. Definition(s)
2.1 This policy adopts the following Scottish Government’s definition of domestic
abuse (as gender-based abuse) ‘which can be perpetrated by partners or ex-
partners and can include physical abuse (assault and physical attack involving a
range of behaviour), sexual abuse (acts which degrade and humiliate women
and are perpetrated against their will, including rape) and mental and emotional
abuse (such as threats, verbal abuse, racial abuse withholding money and other
types of controlling behaviour such as isolation from family or friends).’ 
The term gender-based abuse is used because women and girls are
disproportionately affected by certain types of abuse.
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This definition will apply to anyone experiencing domestic abuse including men,
lesbian, gay, bisexual, transgender people and gender non-binary people
(LGBT+) 
The Domestic Abuse (Scotland) Act 2018 as amended by the Domestic Abuse
(Protection) (Scotland) Act 2021 further expands the legal definition to include a
pattern of controlling, coercive, threatening, degrading and/or violent behaviour
by a partner or ex-partner.  This includes various forms of abuse such as
physical, sexual, psychological and financial abuse. A pattern of abusive
behaviours is 2 or more incidents of abuse that a reasonable person would think
would cause the victim / survivor to suffer physical or psychological harm,
including fear, alarm and distress. 
3.      Strategic context
3.1  This policy aligns with the following national and local strategies and plans that
collectively support the prevention of domestic abuse and the provision of
effective, trauma-informed housing responses:
• Equally Safe Strategy (Scottish Government and COSLA):  recognises
domestic abuse as a form of gender-based abuse that violates human rights. 
The national strategy aims to eradicate abuse against women and girls
through early and effective intervention, maximising the safety and
well-being of women, children, and young people, while embedding a
trauma-informed approach to prevention and recovery. 
• Moray Council Corporate Plan 2024-2029: prioritises tackling poverty and
inequality and building thriving, resilient, empowered communities, which
are key foundations for preventing and responding to domestic abuse. 
• Local Strategic Frameworks: including the Local Housing Strategy, Rapid
Rehousing Transition Plan, Moray 2027, the Council’s Corporate Plan,
priorities from the Moray 10 Year Plan and the Health and Social Care Moray
Strategic Plan.  These collectively support sustainable housing solutions and
integrated support for those affected by domestic abuse.
• The Council’s Local Outcomes Improvement Plan (LOIP):  supports strategic
objectives such as building a better future for children and young people,
empowering and connecting communities and improving overall wellbeing. 
These objective are particularly relevant to supporting children and
vulnerable individuals affected by domestic abuse.
• The Council’s Community Safety Strategy 2022 – 26:  enhances partnership
work via the Community Safety Hub, dynamic case reporting and proactive
identification and tackling of emerging safety needs, including domestic
abuse. 
4.      Objectives and principles of the policy
4.1     The overall aim of the Domestic Abuse Policy is to prevent and alleviate all forms
of domestic abuse through a sensitive, effective and person-centred approach. 
Where abuse does occur, the policy seeks to provide reasonable, considered,
responsive and sustainable solutions that minimise its impact on affected
households and support recovery in a dignified and empowering manner. 
4.2     The specific objectives of the Housing Domestic Abuse Policy are to: 
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• increase the awareness and understanding of domestic abuse amongst
residents, employees and stakeholders;
• facilitate early identification of domestic abuse and respond effectively and
consistently to all reports;
• acknowledge that those who experience domestic abuse often have
additional vulnerabilities which increase the risk and nature of abuse;
• provide an effective and trauma informed service to those who have
experience/are experiencing domestic abuse; 
• empower victims /survivors to make informed choices by providing
information on the options available to them;
• ensure that in responding to domestic abuse, barriers are removed and
procedures followed so as not to exacerbate any risk.  For example, staff
trained to recognise domestic abuse and not confuse it with antisocial
behaviour;
• offer flexible safe, supportive and effective interventions which reduce the
risk of harm;
• ensure that housing solutions are sustainable through the provision of
housing support and other relevant services; and
• promote and engage in joint working arrangements with other Council
services and external partners and agencies. 
4.3     The panel principles of the Domestic Abuse Policy are:
• Participation – ensure the voices of those affected by domestic abuse voices
are heard when they engage with us ensuring trauma-informed
communication and support to empower them to express their information
and views safely.
• Accountability – through monitoring data, actions and outcomes of
domestic abuse cases, provide clear information to tenants about their
rights, and ensuring staff are trained to deal sensitively with such cases for
consistent service provision through enhancing current procedures.
• Non-Discrimination and Equality – provide Housing services that adhere to
equality, human rights and the rights of the child to meet the needs of
diverse survivors.
• Empowerment – to help victims /survivors make informed choices about
their housing need while ensuring they have access to the correct support
• Legality – are comply with legislation and guidance while promoting best
practice; 
5.       Legal provisions
5.1     This policy has been developed in line with the following legislation:
• Housing (Scotland) Act 2025 requires staff are trained to support victims /
survivors, while including them in the decision about where they want to live.
• Domestic Abuse Protection (Scotland) Act 2021 – Part 2 comes into force on
1 August 2026 giving power to apply to court to end a perpetrator’s sole
tenancy or their interest in a joint tenancy.  
• Domestic Abuse (Scotland) Act 2018 - criminalised controlling, coercive and
psychological behaviour as a course of conduct offence, where ongoing
harmful and abusive actions in a relationship, which in isolation might not
seem as serious, are examined together, focusing on behaviour over time.
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• Domestic Abuse (Scotland) Act 2011
• Housing (Scotland) Act 1987 as amended by the Housing (Scotland) Act
2001, 
• the Housing (Scotland) Act 2010 which provides housing support to
homeless households, with triggers for housing support including risk from
domestic abuse. 
• the  Housing (Scotland) Act 2014 regarding a streamlined eviction where a
tenant is convicted of an offence.
• Homelessness etc.  (Scotland) Act 2003 as amended.
• Antisocial Behaviour (Scotland) Act 2004
• Matrimonial Homes (Family Protection) (Scotland) Act 1981 
5.2 Other relevant legislation, guidance and regulatory requirements is set out in
APPENDIX A. 
6. Equalities, rights and socio-economic requirements 
6.1 Moray Council, as a social landlord, will comply with the Equality Act 2010,
Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012, Human Rights
Act 1998, Fairer Scotland Duty (socio-economic inequality) and the United
Nations Convention on the Rights of the Child (UNCRC) by:
• Making reasonable adjustments for disabled individuals.
• Understanding and addressing barriers faced by marginalised groups.
• Assessing domestic abuse cases sympathetically, respectfully and
sensitively through a non-discriminatory, non-judgemental lens.
• Monitoring domestic abuse cases to ensure safety, housing security through
the right to adequate housing, avoiding disproportionate impacts on
protected groups.
• Taking a trauma informed, survivor-led approach that considers impact on all
victims / survivors within the household.
6.2 The Equality Act 2010 requires the Council to eliminate discrimination,
harassment and victimisation, advance equality of opportunity and to foster
good relations between those who share a relevant protected characteristic and
those who do not. Outcome 1 of the Scottish Social Housing Charter on
Equalities ensures social landlords perform all aspects of their housing services
to ensure individual needs are recognised and service users are treated fairly
with respect and receives fair access to adequate housing and housing services. 
6.3 In delivering the Domestic Abuse Policy, the Housing Service is committed to
ensuring that full consideration will be given to the Council’s Public Sector
Equality Duty (PSED) when assessing all domestic abuse approaches and
application to meet its duties under the Equalities Act 2010. It includes the
Housing Service’s responsibility to find ways to understand the rights and needs
of customers and or tenants who are victims / survivors of domestic abuse and
delivering services that recognise and meet these needs which may include
making reasonable adjustments.  Each stage of the decision-making process the
equality duty will be considered, focusing sharply on enhanced consideration for
a domestic abuse case. 
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6.4 Domestic abuse violates human rights.  This includes the right to respect for
private and family life enshrined under Article 8 of the European Convention of
Human Rights (ECHR) and Article 9 of the UN Convention on the Rights of the
Child (UNCRC).  It is also relevant to other rights including Article 2 (right to life)
and Article 3 (freedom from torture and inhuman or degrading treatment).  The
Domestic Abuse Policy will strive to ensure that when responding to domestic
abuse, the Council upholds the best interests of children, helps them to be safe
and secure at home, and recognises the impact of domestic abuse on other
rights.  By taking a victim centred approach to domestic abuse, the policy will
help to secure these rights. 
6.5 The Housing Service will:
• communicate with tenants and customers in clear, concise plain language to
help with the understanding of important information;
• develop and provide advice / information in alternative formats where
necessary; and
• provide free interpretation and translation services, where required. 
7.  Confidentiality and data protection
7.1 The Council will treat all service users with courtesy, sensitivity and complete
confidence and ensure that any information given to it will be used in
accordance with the General Data Protection Regulations (GDPR) and the Data
Protection Act 2018.  Relevant privacy notices advise how personal information
may be collected, used, stored, shared and securely disposed of, the legal basis
for doing so and what their Data Subject Rights are. 
7.2 The Council will ensure:
• victims /survivors are not required to disclose or discuss the reason for their
visit in public areas;
•  any interviews will take place in a private interview room; 
•  option of requesting a member of staff of a specific sex / gender is offered;
and
• a process which avoids victims /survivors having to repeat their case / history
with different members of staff. 
8. Partnership, co-ordination and collaborative working
8.1 The Housing service is committed to working collaboratively internally and
externally, at both strategic and operational levels with key statutory and third-
sector partners to ensure survivors receive comprehensive, tailored support. 
The main partners include: 
Violence Against Women and Girls Partnership (VAWGP) which supports
Moray’s multi-agency ‘Moray Protects’ framework and commits to delivering the
national Equally Safe Strategy.  The partnership work specifically to coordinate
multi-agency and multi-disciplinary responses across Moray, Aberdeenshire and
Aberdeen City to effectively tackle gender-based abuse.  Partnership priorities
reinforce the importance of early education, prevention, intervention and
resilient multi-agency / disciplinary support networks, risk assessment planning,
safeguarding and support and safety recommendations alongside perpetrator
accountability.
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Police Scotland – Including regular Multi-Agency Risk Assessment Conferences
(MARAC), which is a co-ordinated process used to manage the highest risk
domestic abuse cases alongside the Multi-Agency Tasking and Co-ordination
(MATAC) process of identifying and tackling serial perpetrators of domestic
abuse.   
Specialist domestic abuse services including Moray Women’s Aid, Moray Rape
Crisis, Abused Men in Scotland (AMIS), Victim Support to design responses that
suit local context and needs to ensure that victims / survivors receive the expert
help and support they need. 
NHS Grampian – Also have a vital role in responding to domestic abuse.  Staff
are empowered and trained to identify, assess, and respond to domestic abuse,
working confidently in a multi-agency environment to support individuals and
protect children at risk, providing direct care for physical injuries and / or offering
mental health support.   
Adult and Child Protection Services – for adults and children at risk of harm or
abuse. 
9. Prevention and early intervention 
9.1 The Housing Service commits to working in full collaboration with Moray
Violence Against Women and Girls Partnership, preventing incidences of
domestic abuse and wherever possible to assist in the delivery of the national
Equally Safe outcomes. 
9.2 To aid prevention and early intervention in instances of domestic abuse, the
Housing Service will:
• Ensure, where appropriate, that a joint tenancy is considered at initial sign-
up stage to help facilitate the easier transfer of the tenancy.  
• Review the Scottish secure tenancy agreement (SST), short SST and
homeless occupancy leases with a view to including a statement about
action that may be taken against perpetrators of domestic abuse, including
eviction.
• Develop a structure of domestic abuse champions, from various roles
across the service, adopting an ‘eyes and ears’ approach.  Clear referral
pathways will be established to ensure that any concerns from staff relating
to domestic abuse, including operational, maintenance and support staff,
are reported promptly and to the appropriate person to ensure prompt
action.
• Develop and regularly review information resources to continually promote
the zero-tolerance stance which will include details of where to access
practical, specialist and legal help and support.   
• Update the Tenants’ Handbook, Housing Options Guide, webpages and
information to include any helpful resources including Disclosure Scheme
for Domestic Abuse Scotland (DSDAS). 
10.  Remain in current home
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10.1 Where possible, if a victim /survivor of domestic abuse wants to remain in their
own home, the Housing Service will provide support for them to do so.  This may
include but is not limited to:
• Providing advice and information based on their circumstances, including
tenancy and occupancy rights, to ensure they understand their rights and
can make informed decisions;
• The option to temporarily move into an alternative safe space, such as a
sanctuary, to allow a period of respite to make informed decisions on the
action they want to take;
• Working in partnership with specialist agencies to prioritise the victim’s /
survivor’s safety.  This may include undertaking an assessment of the
property if required and making? recommendations on how to improve
safety at the property.  The recommendations may be shared with other
landlords, if relevant, for safety measures to be put in place;
• Supporting personal safety planning;
• Providing support to retain or regain tenancy rights;
• Liaising with Benefits to establish the victim’s / survivor’s entitlements; and 
• where appropriate, supporting the rehousing of the perpetrator ensuring any
alternative accommodation avoids any further risk to the victim(s) /
survivor(s). 
Moray Council tenants
10.2 The Housing Service will offer tenants who are victims / survivors of domestic
abuse advice, assistance and support based on their circumstances.  This
includes:
• supporting victims / survivors to recognise they are actually victims of
domestic abuse;
• stay in their home, should they want to.  This could include transferring the
tenancy to their own name where possible and ensuring the property has
relevant safety and security measures such as lock changes, smart
doorbells, etc. where appropriate;
• providing appropriate information and advice to ensure they understand
their rights and can make informed decisions;
• finding relevant assistance in terms of legal information and advice;
• making referrals to Moray Women’s Aid or Abused Men in Scotland for
specialist domestic abuse support;
• supporting them to move, should they want to.  Housing’s Allocations Policy
includes the award of domestic abuse points, enabling access to suitable
safe and secure alternative accommodation.  This approach prioritises
rehousing through the allocations process rather than the homeless
pathway, helping to avoid further unnecessary trauma at an already
traumatic time; and
• consideration of a management transfer, where domestic abuse points does
not give sufficient priority to secure alternative accommodation. 
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11. Housing options 
11.1 The Housing Service recognises that one of the most dangerous times for victims
/ survivors is when they try to leave their abuser.  Leaving does not necessarily
mean that victims / survivors are safe.  Abuse can continue after they leave their
abuser.  The early intervention approach will assist victims / survivors to avoid
the potential trauma of emergency accommodation, living in an unfamiliar area
(away from existing support networks), and reducing the likelihood of financial
hardship associated with homelessness. 
11.2 The Housing Service will endeavour to maximise choice and safety through a
housing options approach which will aim to provide a range of housing options
to meet the individual needs of victim / survivors and, where possible, avoid
them becoming homeless, if that is their choice.  However, the Housing Service
understands that for some victims /survivors, the trauma experienced in their
accommodation may mean that it is not an option for them to remain there. 
11.3 Individuals who approach the Housing Service for housing assistance due to
domestic abuse will receive a housing options interview.  This will adopt a
trauma informed approach and will explore a range of housing options and
provide advice tailored to their individual circumstances and assessed needs. 
Victim(s) / survivor(s) will be:
• given in-depth housing advice, to support them to make an informed choice
about their housing options, including options to remain at home or access
temporary accommodation;
• where appropriate, offered safe and secure temporary or supported
accommodation which meets their needs and that of their children;
• supported to access / referrals made to relevant specialist support agencies
and / or refuges, should a place be available;
• assisted to access legal advice; 
• offered guidance and support to make a homeless application, if this is their
preferred option; and
• Supported to apply for housing and given information the domestic abuse
points.  This priority can empower victims / survivors, giving choice while
preventing homelessness. 
11.4 The Housing Service recognises that children who witness domestic abuse are
victims / survivors in their own right.    It will ensure that appropriate
safeguarding referrals are made and so that the voice of the child can be heard. 
12. Homelessness
12.1 In line with the Homelessness Policy and Rapid Rehousing Transition Plan, the
Housing Service will seek to prevent homelessness where possible and when it
does occur, to reduce its impact and resolve homelessness as quickly as
possible. 
12.2 Where a victim / survivor of domestic abuse feels it is not safe for them or their
family to remain in their current home and decides to submit a homeless
application, the Housing Service will:
• Provide a suitable safe alternative accommodation, based on assessed
need and risk, as a sanctuary for respite.  Accommodation will be monitored
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to establish if a move to more suitable alternative accommodation is
required.  Where the temporary accommodation is required, it will be
affordable and of an acceptable standard;
• Signpost / make referrals to relevant support services; 
• Continue to provide a comprehensive and holistic housing options service.
o Explain the options available under Housing’s Allocations Policy, ensuring
the person has a current and up to date housing application.
o Explain and where appropriate support the victim / survivor to access
alternative and safe housing options.  For example, housing with another
social landlord or in the private rented sector.
• Support the person to move into a new home and where relevant signpost
them to appropriate sources of support. 
13. Financial considerations
13.1 The Housing Service recognises that financial limitations and / or pressures can
both exacerbate domestic abuse as well as being a barrier to reporting abuse or
receiving help.  Recognising that financial barriers should never prevent
someone from seeking safety or accessing housing assistance, Housing will
provide support and flexibility to victims / survivors, appropriate to their
individual circumstance.  Examples may include:
• Provide removal and / or storage facilities to enable victims / survivors and
their children to keep their possessions
• Consider any financial advice and assistance available to ensure victims /
survivors do not experience any further financial hardship due to their
housing situation.   
• Consider applicable benefit easements for individuals fleeing domestic
abuse, including support for overlapping tenancies (where entitlement to
housing benefit may be awarded in certain circumstances) and income-
assessed crisis assistance via the Scottish Welfare Fund.  
• In accordance with Section 20 of the Housing (Scotland) Act 1987, ensure
that victims / survivors of domestic abuse are not held financially liable for
property damage resulting from abuse, or required to pay rent in advance
as a condition a Council house tenancy.  This may constitute
discrimination based on income, disproportionately affecting women who
have experienced financial abuse and barriers to employment.
• Review housing policies and procedures, including those on rent arrears,
allocations and rechargeable repairs to ensure that victims / survivors are
not adversely affected by housing debt incurred because of the
perpetrator’s actions.  This includes withholding an offer of housing until
there are repayment arrangements in place, which may disproportionately
disadvantage victims / survivors, particularly those who have experienced
financial abuse. 
13.2 The Housing Service will also support individuals who may experience additional
and significant barriers when attempting to escape an abusive relationship,
including those arising from immigration status:
• The fear of approaching services for support or advice due to the real
potential of deportation; and / or
• No recourse to public funds (NRPF).   
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13.3 The principles of the Domestic Abuse Policy will apply regardless of such
circumstances, and the Housing Service will work with relevant partners,
including national organisations who have expertise in these areas to support
these individuals through such complex, challenging situations. 
14. Enforcement action against perpetrators
14.1 The Housing Service commits to taking appropriate enforcement action against
perpetrators of domestic abuse. This includes using legal powers afforded to
social landlords and supporting victims / survivors in accessing protective
measures. The actions will be taken with a trauma-informed approach, ensuring
the safety and housing stability of survivors. The Housing Service will maintain
robust and accountable records of incidents and actions to support
enforcement and legal proceedings. Actions may include: 
Tenancy enforcement
• Legal action, including eviction action, where the perpetrator breaches the
tenancy conditions.
• Section 14 of the Housing (Scotland) Act 2014 allows a streamlined eviction
process.  Where there has been a recent criminal conviction punishable by
imprisonment for tenancy related antisocial or criminal behaviour within the
previous 12 months, Housing can end the tenancy for the perpetrator and /
or convert their SST to a SSST.
• Transferring a tenancy from the perpetrator to the victim / survivors
• Ground 15, Schedule 2 of the Housing (Scotland) Act 2001 allows Housing to
seek repossession of the tenancy where a tenant's spouse, civil partner,
former spouse, civil partner or cohabitee (including a same-sex cohabitee)
asks to transfer the tenancy to them because they or the tenant no longer
wants to live together. The ground to recover possession from the tenant,
where it is reasonable to grant the order for repossession and suitable
alternative accommodation, will be provided for the existing tenant.
• Offering a perpetrator a short Scottish secure tenancy (SSST) instead of a
Scottish secure tenancy (SST).
• Ensure that the victim / survivor is not penalised or displaced as a result of
any action taken against the perpetrator.
• Supporting the victim / survivor to use legal remedies afforded to them. 
Part 2 of the Domestic Abuse (Protection) (Scotland) Act 2021 allows the
removal of perpetrators from the home and restrict contact, even if the
perpetrator is the sole tenant and apply for recovery of possession of the
tenancy from the perpetrator. The aim will be to transfer the tenancy solely to
the victim, should they want to stay in the property.  This will also apply to joint
tenancies. 
The Matrimonial Homes (Family Protection) (Scotland) Act 1981, S13 also offers
the following protection and provisions:
Married couples - the non-tenant spouse or joint tenant can apply to the court to
become the sole tenant.
Civil partners - the non-tenant or joint tenant can apply to the court to become
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the sole tenant of the home. At this stage the court considers factors before in
deciding to grant the transfer such as conduct of the partners and the needs of
any children. 
The Antisocial Behaviour (Scotland) Act 2004 sets out powers that can be used
in conjunction with the above Housing and Matrimonial Homes legislation to
assist with legally removing perpetrators of domestic abuse. 
Housing Needs of the Perpetrator
14.2 Perpetrators who are willing to move on a voluntary basis and / or end their
interest in the tenancy voluntarily will be offered alternative accommodation
located an appropriate distance from the victim(s) / survivor(s). 
14.3 Those found guilty of committing domestic abuse will be offered a short Secure
Scottish tenancy (SSST) which will be located an appropriate distance from the
victim(s) / survivor(s).  The Housing Service will:
• work closely with Community Safety and Public Protection Partners to
ensure perpetrators are dealt with as effectively as timely as possible;
• ensure MARAC recommendations are followed
• ensure any pathway referrals are made for support and / or any other
relevant signposting.   
15. Training
15.1 The Housing Service is committed to ensuring all relevant staff across the
Housing Service where appropriate:
• receive robust, accredited and relevant domestic abuse training, to
ensure staff recognise and understand the signs and dynamics of
domestic abuse and coercive behaviours, can respond appropriately and
are equipped to help victims / survivors to recognise their experience as
abuse. Training will be tailored to the responsibilities of each role, with
enhanced training provided to staff in key positions.
• are kept up to date with any legislative developments and/or national
guidance that may impact on the service response, actions available, and
the information and advice it provides in relation to domestic abuse
cases.
• maintain the privacy and confidentiality of victims / survivors and
perpetrators at all times, while taking responsibility to avoid service-
generated risks.  Developing protocols for safe disclosures and
information-sharing This ensures the service provides a safe, appropriate
and trauma-informed response to domestic abuse.
• maintain a training register to support the delivery cyclical refresher
training and staff knowledge is maintained to an acceptable level. 
15.2 Domestic Abuse champions have been appointed within Housing teams across
the service to support and provide guidance to staff dealing with domestic abuse
cases.  This will assist to:
• bridge gaps in knowledge, experience or direction; 
• ensure that staff feel confident and well supported when responding to
domestic abuse; and
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• facilitate vital pathways between victims, survivors and perpetrators and
the specialist support services available to them. 
16. Risk management  
16.1 Housing staff will follow appropriate risk assessment processes to identify the
level of risk in domestic abuse cases.  Responses will be tailored to the current
circumstances and the immediacy of the situation, ensuring that action take is
proportionate and timely and aligns with legislative and best practice. 
16.2 Housing have dedicated staff appointed to represent the service in relation to
MARAC and MATAC.  Highest risk cases will be referred on to the MARAC
meetings to ensure multi-agency risk management planning and subsequent co-
ordinated approach by partner agencies. 
16.3 The Housing Service will ensure that staff follow relevant Moray Protects adult
and child protection procedures where there are any identified risk(s) due to
domestic abuse. 
17. Quality assurance
17.1 A random sample of domestic abuse cases will be quality assured by the
appropriate senior staff to ensure appropriate and relevant advice given, actions
taken and/or referrals made.  Any identified outcomes from this assurance work
will be used for staff development purposes and where appropriate to inform
operational procedure reviews. 
18. Review and complaints process
18.1 Any individual who is not satisfied with the way Housing Staff have dealt with
any aspect of their case, should in the first instance contact the Housing
Operations Officer or the Senior Housing Needs Officer for an explanation.  If
the individual is a Moray Council tenant, they should contact their Area housing
Officer.   
18.2 If person is not satisfied with the explanation provided, they can ask for an
appointment with the Housing Needs Operations Manager or the Area Housing
Manager who will review the case and provide a further response.    
18.3 Where the person is still not satisfied with the way the Housing Service has
dealt with their case, the Council also has a corporate Complaints Policy. 
Explanatory information is available on the Council’s website. 
19. Performance monitoring and policy review
19.1 Ongoing internal monitoring will be used to inform the Housing service’s
response to domestic abuse.   Statistical monitoring on performance is used to
inform the Annual Return on the Charter (ARC) to the Scottish Housing Regulator
and Scottish Government statistical returns.   
19.2     The Housing Service will monitor the following Scottish Government Statutory
Returns in relation to domestic abuse cases.  These are the two most common
reasons for Housing Options approaches and Homelessness cases respectively:
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• Prevent 1 Return (Housing Options cases) - Reason for approach
‘Relationship breakdown (violent or abusive)’ with recorded ‘Outcome’
for these cases where the customer chose to ‘Remain in their current
accommodation’.  Highlights potential cases for concern and signposting
to relevant agencies.    
• HLI Return (Homelessness) - Cases Assessed – Household fleeing
domestic violence and outcome
• Number of current MC Housing Applications with domestic abuse points 
19.3 Performance will be reported to the Housing and Community Safety Committee
or any other relevant Committee which has the remit to consider Housing, anti-
social behaviour, public protection and/or safeguarding issues. 
19.4 The Housing Service will review the Domestic Abuse Policy in 2029, or earlier if
required by changes to legislation or guidance.  Any review will be carried out in
consultation with representative groups and partners agencies to ensure any
review is fully informed.
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APPENDIX A 
Other Relevant Legislation, Guidance and Regulatory Requirements 
Adult Support and Protection (Scotland) Act 2007
Children (Scotland) Act 1995 as amended 2020 
Children and Young People (Scotland) Act 2014
Children’s Hearing (Scotland) Act 2011
Forced Marriage etc.  (Protection and Jurisdiction) (Scotland) Act 2011
Protection from Abuse (Scotland) Act 2001  
Civil Partnership (Scotland) Act 2004, as amended 2020 
National Guidance
Scottish Government working group report – Improving housing outcomes for
women and children experiencing domestic abuse
Domestic Abuse: a good practice guide for social landlords (ALACHO, CIH,
SFHA, Shelter and Scottish Women’s Aid)
Prevention of Homelessness Guidance (2009) emphasises the need for local
multi-agency joint action to meet the needs of those affected by domestic abuse
and homelessness 
Regulatory framework 
The Council observes the Scottish Housing Regulator (SHR) requirements set
out in the ‘Regulation of social housing in Scotland’ Framework which regulates
Council provided housing and homelessness services.  The Council must also
meet the standards set by the Care Inspectorate for its temporary, residential
and support services. 
Section 31 of the Housing (Scotland) Act 2010 introduced the Scottish Social
Housing Charter, setting regulatory standards and outcomes that the Council as
a social landlord should aim to achieve when performing its housing activities. 
The relevant standards and outcomes are:   
Outcome 2 – Communication 
Social landlords manage their business so that:
• tenants and other customers find it easy to communicate with their landlord
and get the information they need about their landlord how and why it makes
decisions and the services it provides. 
Outcome 6 – Tenancy Disputes 
Social landlords, working in partnership with other agencies, help to ensure as
far as reasonably possible that:
• tenants and other customers live in well-maintained neighbourhoods where
they feel safe. 
Outcome 7, 8, and 9 – Housing Options 
Social landlords work together to ensure that:
• people looking for housing get information that helps them make informed
choices and decisions about the range of housing options available to them
• tenants and people on housing lists can review their housing options.
Social landlords have a role to prevent homelessness and should ensure that:
• people at risk of losing their homes get advice and information on preventing
homelessness.
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Outcome 10 - Access to Social Housing 
Social landlords will ensure that: 
•  people looking for housing find it easy to apply for the widest choice of social
housing available and get the information they need on how the landlord
allocates homes and their prospects of being housed. 
Outcome 11 – Tenancy Sustainment   
Social landlords ensure that:
• tenants get the information they need on how to obtain support to remain in
their home and ensure suitable support is available from the Council as well
as other organisations. 
This includes tenants in a domestic abuse situation. 
Outcome 12 – Homeless People 
Councils perform their duties on homelessness so that: 
• people who are homeless or at risk of homelessness get prompt and easy
access to help, advice and information; are provided with suitable, good-
quality temporary or emergency accommodation when this is needed; and
are offered continuing support to help them get and keep the home they are
entitled to. 
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APPENDIX III
INTEGRATED IMPACT ASSESSMENT (IIA) COVERING
• EQUALITIES & SOCIO ECONOMIC DUTIES
• HUMAN RIGHTS AND RIGHTS OF THE CHILD 
DATE UPDATES/EXECUTIVE SUMMARY VERSION DETAILS
Insert Date
(e.g.
03/10/2023)
Add brief notes/highlight which section amended (e.g. first
draft of IIA completed and submitted to SFC 25/10/2023
for consideration; noting that further work on Stage 2 will
be required). 
Insert (ShP) Version Info
(when details have been
agreed) (e.g. 5.0 03/10/2023
11:21 AMcL)
29/08/2025 1st Draft IIA to be submitted to H&CS Committee 18/11/25 
21/01/2026 IIA revised to include consultation feedback outcomes. To
be presented to Housing & Community Safety Committee
on 12/03/2026 
STAGE 1 - DO I NEED AN INTEGRATED IMPACT ASSESSMENT? 
Name of policy or proposal:                Housing Domestic Abuse Policy
Is this a  Please ✓ below
New activity, programme or policy? ✓
Change to an existing activity, programme or policy? 
Budget proposal? 
Duties: tick the boxes you think apply No Maybe                                                                                                                                             Yes
Equalities: Will your proposal have an impact on groups with
protected characteristics?
Consider the impact of your proposal on people and how they
access your services and information without barriers.  
✓
Socio-economic 
Not every person/family has access to regular income or savings.
Will your proposal have an impact on them  
✓
Does your proposal impact on the human rights of people?    ✓
Does your proposal impact on the rights of children and young
people  
✓
Reasoning - Briefly describe your reasoning for the responses given above: 
Domestic abuse affects individuals from every protected group and socio-economic status,
either as a victim or perpetrator with intersectional impacts requiring consideration. 
Domestic abuse can be caused by, and can also create socio-economic disadvantage. 
Women and girls are disproportionately affected by certain types of abuse. 
If you have answered “maybe” or “yes” to any of the Stage 1 questions above, then
proceed to complete the Stage 2 Integrated Impact Assessment questions below.
If you have answered “no” to the Stage 1 questions above, then provide the details
below and submit to [email]
Lead Officer for developing the contract 
Other people involved in the screening (this
may be council staff, partners 
or others i.e. contractor or community) 
Date 
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STAGE 2: INTEGRATED IMPACT ASSESSMENT
Brief description of the affected service
1. Describe what the service does: 
The Housing Service does not currently have a dedicated, stand-alone Domestic Abuse
Policy.  Domestic abuse cases are currently dealt with through other relevant policies and
frameworks such as:
• Allocations Policy – incorporates domestic abuse points and management transfers 
• Homelessness Policy – includes housing Options and Housing Support
• Partnership working with VAWGP
• Police Scotland’s MARAC and MATAC safeguarding and risk process for high risk
cases.
This draft Domestic Abuse Policy sets out the framework for how Moray Council’s Housing
Service commits to supporting domestic abuse victims through safe, equitable, trauma-
informed Housing security and response that aligns with national strategy, legal obligations,
and partnership expectations, while supporting survivors’ right to safety and recovery.
2. Who are your main stakeholders? 
Domestic abuse victims / survivors and their households – both Moray Council tenants and
other individuals.
Domestic abuse perpetrators
Public Protection Partners
Moray Council Staff
3. What changes as a result of the proposals? Is the service reduced or removed?
The new policy:
• Ensures the Housing Service has a current policy reflective of all updated legal and
regulatory requirements while taking into consideration the financial implications of
such cases;
• Enhanced equality, rights and socio-economic considerations and commitments
with the consideration of financial support for cases of real hardship;
• More emphasis on the victim/survivor remaining in the home if that is what they
choose;
• Perpetrators being removed from the home and supported to find alternative
accommodation; 
• Updated internal monitoring commitments; and
• A review of supporting internal operational procedures with reporting pathways.
4. How will this affect your customers?
The policy will:
• provide greater, more consistent support for victims of domestic abuse from various
affected groups but predominantly women and girls/children, receiving tailored
support based on their individual circumstances.  
• Have an impact on perpetrators who tend to be male through removing them from the
tenancy.
5. Impact on staff providing the service
Staff will be expected to undertake comprehensive domestic abuse training/awareness as
well as on policy and procedural revisions to support the implementation of the policy in
practice. 
6. Please indicate if these apply to any of the protected characteristics
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Protected groups Potential impacts and considerations
Race  Potential Impact - Language barriers or immigration
status may affect consultation / engagement, ability to
report or lack of understanding of legal implications /
actions.
Disability  Potential Impact - Tenants with disability, mental health
or learning difficulties may be more vulnerable to abuse
or it may be caused by the abuse.
Carers (for elderly, disabled or
minors)
Potential Impact – Caring responsibilities tend to fall to
females who may struggle to access support /
information 
Sex Potential Impact – females (adult and children) can be
disproportionately affected (as evidenced) and/or at
higher risk of impact depending on their circumstances. 
Females still affected by gender pay gap and lower
income to enable change, may have restricted access to
finance.
Men – a gender-blind approach repeats and re-enforces
inequalities experienced by females.  Men, as the more
common perpetrator, will be more negatively impacted
by the policy as a consequence of behaviours that may
require legal action /enforcement.
Pregnancy and maternity (including
breastfeeding)
Potential Impact – Increased vulnerability during this
time. Maternity leave can cause additional financial
pressures or time at home with less support.
Sexual orientation Potential impact – can cause vulnerability
Age (include children, young people,
midlife and older people)
Potential Impact – Can affect all age groups and children
as household members, victims or perpetrators.  
Religion, and or belief Potential impact – Different cultures can have different
impacts based on beliefs 
Gender reassignment Potential Impact – if policy is not inclusive 
Inequalities arising from socio-
economic differences
Potential Impact – More likely to impact on individuals
from this group due to low income.  Victims may have
restricted access to finance, be financially dependent on
perpetrator which is a barrier to initiating reporting or
change.  
Individuals with disabilities tend to fall into the lower
income category. 
Human rights
List of convention rights Describe, where applicable, if and how specific
rights are engaged
Article 2 Right to life Policy supports this right
Article 3 Prohibition of inhuman or
degrading treatment
Policy supports this right
Article 5: Right to liberty and security This right may be affected where perpetrators
experience legal consequences.
Article 6: Right to a fair trial Policy supports this right 
Article 8: Right to respect for private
and family life, correspondence and
the home
Potential impact – Removal of perpetrator from
home / tenancy.  Escalation to court action or
eviction proceedings to evict perpetrator may
interfere with Article 8 rights if not handled
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List of convention rights Describe, where applicable, if and how specific
rights are engaged
proportionately. Otherwise, Policy supports this
right.
Article 10: Freedom of expression Those affected have right to have their views heard
through public consultation taking place
November.
Article 11: Freedom of assembly and
association 
Article 12: Right to marry 
Article 14: Prohibition of
discrimination (in relation to the
convention rights)
Policy review and IIA to identify and reduce any
impacts through relevant mitigations to support
this right.
Article 1 of Protocol 1: Protection
against unlawful deprivation of
property
Policy supports this right.
Article 2 of Protocol 1: Right to
education 
Article 3 of Protocol 1: Right to free
elections by secret ballot 
Children’s Rights and Wellbeing 
Relevant articles – UNCRC 
Article 2 – Non discrimination Policy supports this right and incorporates UNCRC
considerations.  
Article 3.1 – Best interest of the child Policy supports this right. Homelessness due to
domestic abuse has the potential to impact a
child’s wellbeing and educational stability. 
Article 6.2 – Right to survival and
development
Policy supports this right by incorporating UNCRC
considerations.  
Article 12 – Respect of the views of
the child
Policy supports this right by incorporating UNCRC
considerations.  
Article 19(1) – The right to be
protected from violence and abuse
while in the care of parents
Policy fully supports this right by incorporating
UNCRC considerations.  
Article 23 – Children with a disability Policy supports this right by incorporating UNCRC
considerations.  
Article 27 – Adequate standard of
living - for the child's physical,
mental, spiritual, moral and social
development
Policy supports this right by incorporating UNCRC
considerations.   
7. Evidence. What information have you used to make your assessment?
Performance data Prevent 1 HO Cases reason for approach and those that returned
home as outcome, HL1 as above, HL3, any data re MWA? 
Internal
consultation
Head of Housing, Property & Communities
Housing Strategy & Development Manager
Housing Needs Manager
Senior Housing Officer (Policy)
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Equal Opportunities Officer
Housing Services Manager
Area Housing Managers
Consultation with
affected groups
Tenant consultation to be held November 2025 to January 2026 for 8
weeks to gain feedback.  This will include:
• publication of the draft Domestic Abuse Policy on the Council
website along with an easy read version of the policy;
• an electronic survey published via the Council’s Moray Engage
portal and social media platforms;
• contacting relevant stakeholders for feedback, including Moray
Council tenants and former tenants, Register of Interested
Tenants and Moray Tenant’s Forum.
Update 21.1.26 – 60% of respondents feel the draft policy recognises
trauma, prioritises safety, choice and dignity and considers survivors
needs, affirming that good work is already taking place locally in
relation to domestic abuse.  Feedback has been summarised into
main key themes and will be used to inform supporting operational
procedures particularly around who can be affected by abuse
(genders), support required, financial support, etc. 
Local statistics 
National statistics Scottish Housing Network Benchmarking 
Other Good practice from other Local Authorities, CIH, Scottish
Government 
8. Evidence gaps 
Do you need additional information in order to complete the information in the
previous questions?
Feedback from tenant and stakeholder consultation will be used to further inform the IIA
before a final decision is made.
Update 21.1.26 – Consultation feedback collated and considered. No further information
required. 
9. Mitigating action 
Can the impact of the proposed policy/activity be mitigated?  Please explain 
The above identified potential impacts can be mitigated as follows:
• Race – Moray Council provide translation/interpretation services
• Disability – Consideration of appropriate reasonable adjustments will to be
considered by staff such as accessible communication formats, etc. 
• Carers – Support and signposting given to find additional, specialist support for
those with caring responsibilities. 
• Sex – Specific signposting to specialist agencies - VAWGP or AMIS
• Pregnancy/Maternity – Signposting/referrals to support service and or Money
Advice/Income maximisation
• Age – Provide or signpost to age-appropriate advice and support
• Gender Reassignment – inclusive communications and procedures to ensure
LGBTQ+ victims / survivors feel heard, safe and respected.
• Socio-economic disadvantage – Considered holistically based on individual
circumstances.  Referral pathways for various financial support such as Money
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Advice, Income Maximisation, SWF, consideration of extra HB for 2 homes, as well as
for safety and security measures.  
• Human Rights – the Policy fully supports the human rights of the victims / survivors.  
While removing male perpetrators from the home cannot be fully mitigated, it is seen
as a proportionate action to achieve the legitimate aim in terms of the Council’s duty
of care under adult and child protection.  
• Rights of the Child (UNCRC) – As above, the Policy fully supports a child’s rights.
o The commitments made within the policy may prevent homelessness or
disruption of schooling / wellbeing in affected household.
o Fully embedded signposting and referrals mechanisms for victims within
household, ensuring joint working with social work or children’s services, VAWGP,
MWA or AMIS where appropriate to avoid homelessness whenever possible. 
Housing’s Service Plan 2025/56 and Moray Council’s Equality Outcomes for 2025-2029 also
commit to reducing the number of children in temporary accommodation, the duration of
homelessness for families and the impact of homelessness on children 
10. Justification
If nothing can be done to reduce the negative impact(s) but the proposed
policy/activity must go ahead, what justification is there to continue with the change?  
All impacts fully mitigated as per Q9 above. 
SECTION 3 CONCLUDING THE IIA
1. No potential negative impacts found for any protected groups. 
2. Some potential positive impacts have been identified.
The impacts relate to:
✓
Reducing discrimination, harassment, victimisation or other conduct
prohibited under the Equality Act 2010
✓
Promoting equality of opportunity ✓
Fostering good relations ✓
3. The proposals interfere with human rights and/or the rights of the child ✓
4. Negative impacts can be mitigated as outlined in Q9. ✓
5. The negative impacts cannot be fully mitigated but are justified as Q10. 
6. Further consultation with affected groups is needed. 
7. It is advised not to go ahead with the proposals. 
Decision - Set out the rationale for deciding whether or not to proceed with the
proposed actions: 
To be presented to Housing & Community Safety Committee on 14 March 2026 for final
approval. 
Date of Decision: 
Sign off and authorisation: 
Service Housing, Property & Communities Service
Department Housing
Policy/activity subject to IIA Domestic Abuse Policy 
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We have completed the integrated impact
assessment for this policy/activity. 
Name: Emma Armit
Position: Senior Housing Officer (Policy)
Date:  21/01/2026
Authorisation by head of service  Name: Edward Thomas
Position: Head of Housing, Property &
Communities
Date:
Permission to publish on website - 
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Report to: Housing and Community
Safety Committee 
Meeting Date: 12 March 2026  
Report by: Executive Director Education, Housing and Communities  
Author: Edward Thomas Contact
Email: 
edward.thomas@moray.gov.uk 
Subject: Housing and Property Services Budget Monitoring to 31 December 2025 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to note the budget position for the Housing Revenue Account
(HRA) and General Services Housing and Property Budget for the period up to 31
December 2025.  
1.2  This report is submitted to Committee in terms of Section III (G) (1) of the Council's
Scheme of Administration relating to the management of budgets. 
2.  SUMMARY  
2.1  This report sets out the position for the HRA and General Services Housing and Property
budgets to 31 December 2025, comments on the variances on these budgets and provides
a projected outturn for the financial year 2025/26. 
3.  RECOMMENDATIONS 
3.1 It is recommended that Committee:   
i) considers and notes the budgetary position for the period to 31 December
2025, consisting of an overspend of £818k for the HRA and an overspend of
£81k for General Services Housing and Property; and   
ii) approves the proposed service development detailed at para 6.15.   
Edward Thomas
Head of Housing, Property and Communities 
Item 11.
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4.  BACKGROUND AND CONTEXT  
4.1  Moray Council agreed the HRA Budget for 2025/26 at the meeting on 26 February 2025
(paragraph 4 of the Minute refers). Housing and Property budget monitoring reports are
presented quarterly. 
5.  HOUSING REVENUE ACCOUNT TO 31 DECEMBER 2025  
5.1  Appendix I details the HRA budget position to 31 December 2025.  
The HRA budget for the period to 31 December 2025 is as follows, including variances
arising:
Budget to 
31/12/2025
Actual to 
31/12/2025
Variance to
31/12/2025
£,000 £,000 £,000
10,299 9,481 (818) 
5.2  The HRA budgeted expenditure for the period to 31 December 2025 is as follows, including
variances arising:
Annual Budget Budget to
31/12/2025
Actual to
31/12/2025
Variance to
31/12/2025 
£,000 £,000 £,000
Supervision and
Management
3,955 3,703 252
Sheltered
Housing
51 34 17
Repairs and
Maintenance
6,791 7,536 (745)
Bad and Doubtful
Debts
75 81 (6)
Downsizing
Incentive
Scheme 
54 39 15
Service
Development
105 10 95 
5.3  The key expenditure variances to 31 December 2025 are summarised below.  
5.4 Supervision and management – there are a range of variations within this budget resulting
in a net underspend of £252k.  This includes underspends in staffing (£303k), arising from
vacancies being higher than budgeted provision, £34k for software due to revised project
timescale, £9k for training and £37k in other minor underspends.  This was partially offset
by overspends in voids (£70k) arising from increased costs of refurbishment, Council Tax
on void properties (£45k) and additional expenditure on the Local Housing Strategy (£16k). 
5.5 Sheltered Housing – there was an underspend of £17k in the sheltered housing budget,
arising from lower than budgeted energy costs (£18k), partially offset by £1k in minor
budgetary overspends. 
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5.6 Repairs and maintenance – there was an overspend of £745k in the repairs and
maintenance budget, arising from higher than anticipated expenditure on planned/cyclical
maintenance (£794k), predominantly external decoration/fabric repairs, electrical
upgrades and estate upgrades and higher than budgeted voids expenditure (£243k), which
were partially offset by lower than budgeted response repairs (£292k). It is anticipated that
a proportion of the overspends which have initially been posted to the revenue budget will
subsequently be recoded as capital expenditure. A detailed report of the Building Services
activity is provided on this agenda. 
5.7 Bad and doubtful debts – there was an overspend of £6k against provision for bad and
doubtful debts, based on write-offs.  
5.8 Downsizing Incentive Scheme – there was an underspend of £15k arising from slightly
lower activity. 
5.9 Service Developments – there is an underspend of £95k, partly arising from the lead-in
time to appointing to various posts approved in previous reporting cycles and the tenancy
sustainment fund being delivered towards the end of the budgetary year.  
5.10 HRA income for the period to 31 December 2025 is as follows:
HRA Income
2025/26
Budget to
31/12/2025
Actual to
31/12/2025
Variance to
31/12/2025 
£,000 £,000 £,000
Non-dwelling
rents
213 215 2
House Rents 20,983 20,428 (555)
Other Income 134 241 107
Total Income 21,330 20,884 (446) 
5.11 The income at 31 December 2025 was £446k lower than expected.  This is due mainly to
the continuation of rental discounts for properties with lower Energy Performance
Certificate (EPC) bandings, pending the stock improvement works. It is acknowledged that
the projections in this regard were overly ambitious with hindsight. 
6. HRA PROJECTED OUTTURNS 2025/26  
6.1 Appendix I also details projected outturns for 2025/26:
Annual Budget Variance to
31/12/2025
Projected
Outturn to
31/03/2026
Projected
Variance to
31/03/2026
£,000 £,000 £,000 £,000
28,838 (372) 28,090 748 
6.2 Supervision and management - An underspend of £234k is projected. This variance
arises from an underspend in staffing costs arising from vacancy levels (£318k), lower than
anticipated software costs (£46k) and other minor underspends (£20k). These are partially
offset by anticipated overspends in voids (£100k) and Council Tax on void properties
(£50k), based on cost of refurbishment and higher premiums respectively.    
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6.3 Sheltered Housing – An underspend of £5k is projected. This is based on anticipated
energy costs.  
6.4 Repairs and Maintenance - An overspend of £54k is projected.  This is comprised of £75k
in property fees attributable to the accelerated investment programme, partially offset by
an anticipated underspend in planned/cyclical works (£21k). 
6.5 Financing costs - An underspend of £286k is projected based on the cost of borrowing
being less than anticipated due to lower than budgeted capital expenditure. 
6.6 Bad and Doubtful debts – There is no variance currently projected.      
6.7 CFCR - The level of Capital from Current Revenue (CFCR) is projected to be £277k lower
than budgeted, in order to bring the year-end balance in line with the projected reserve
provision.  
6.8 Downsizing Incentive Scheme – There is no variance currently projected.  
6.9 Service Developments – There is no variance currently projected.    
6.10 Total expenditure on the HRA - Projected to be £748k lower than budgeted.  
6.11 The key projected variances to 31 March 2026 are summarised below.
Service
Description
Overspend
(£000)
Underspend
(£000)
Net Variance
(£000)
Supervision and
Management 
234 
Sheltered
Housing 
5 
Repairs and
Maintenance
(54)  
Financing Costs  286 
CFCR  277 
TOTAL   748 
6.12 Income
Total income to the HRA is projected to be £731k lower than originally budgeted for
2025/26, with £757k less in rental income arising from the continuation of EPC discounts
detailed in paragraph 5.11 and lower than anticipated interest on revenue balances (£74k),
which will partially be offset by £100k in other income.  
6.13 The key projected income variances to 31 March 2026 are summarised below.
Service
Description
Overspend
(£000)
Underspend
(£000)
Net Variance
(£000)
House Rents  (757)  
Income on
Revenue
Balances 
(74)  
Other Income  100 
TOTAL   (731) 
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6.14 Overall, a surplus balance of £17k is projected for the HRA budget in 2025/26, with
reserves of £2,250k at year end in line with policy.  
6.15 Following the delivery of the accelerated investment programme, the housing service
requires to enhance its asset management approach to meet tenant expectations for the
ongoing maintenance of the housing stock. A project officer is required to facilitate this
work and adjacent activities within Housing, Property and Communities – full year
equivalent funding of £65,178 is available within the service development provision.  
7. GENERAL SERVICES HOUSING and PROPERTY BUDGET  
7.1 Appendix II provides details of the budget position to 31 December 2025.  
7.2 The General Services Housing and Property budget for the period to 31 December 2025 as
follows:
Annual Budget Budget to
31/12/2025
Actual to
31/12/2025
Variance to
31/12/2025
4,147 3,167 3,248 (81) 
7.3 Planning and Development - consists of Improvement Grants and Affordable Housing
budgets, including disabled adaptations.  The position at 31 December 2025 shows an
underspend of £24k, arising from an underspend in discretionary grants. 
7.4 Housing Management – there has been an overspend of £1k, arising from £2k higher than
budgeted expenditure on the provision of toilets/site clearance, partially offset by £1k in
lower staff costs.  
7.5 Homelessness/Allocations - comprises of Homelessness and Housing Support services. 
There was an underspend of £22k in this budget, comprised of underspends in Temporary
Accommodation (£14k) arising from additional income from revised charges, and general
homelessness (£21k), partially offset by an overspend of £13k in Housing Support.    
7.6 Miscellaneous General Services Housing – comprises various small budgets for which
there is currently a £30k underspend.  
7.7 The Building Services Budget - is reported in detail separately on this Committee’s
agenda and any surplus achieved or deficit will be returned to the HRA, or by proportionate
spend to General Services. 
7.8 The Property Services Budget - includes the budgets for the Design Team and Property
Resources.  There is an overall underspend of £157k to date. Within the Design Team there
was an overspend of £212k, predominantly arising from lower than anticipated recharges
for professional fees. Following the recent restructure, there will be a review of the budget
allocations and fee projections in this area. Property Asset Management has a £55k
underspend, predominantly arising from higher than budgeted income for industrial
estates (£86k) and lower than expected repairs and maintenance (£111k), partially offset
by an overspend in school repairs and maintenance (£136k) and the additional cost of
managing surplus property (£43k). 
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7.9 The key expenditure variances to 31 December 2025 are summarised below.
Service Description Overspend
(£000)
Underspend
(£000)
Net Variance
(£000)
Planning and Development   24 
Housing Management (1)  
Homelessness/Allocations  22 
Misc. General Services
Housing 
31 
Property Services (157)   
TOTAL    (81) 
7.10 As at 31 December 2025, the General Services Housing and Property budget shows a net
overspend of £81k.    
8. GENERAL SERVICES HOUSING and PROPERTY SERVICES PROJECTED OUTTURNS
2025/26  
8.1 Appendix II also indicates the projected outturns for 2025/26:
Annual Budget Variance to
31/12/2025
Projected Outturn
to 31 March 2026
Projected
Variance to 31
March 2026
4,147 (81) 4,062 85 
8.2 Planning and Development – An underspend of £20k is projected, arising from lower
expenditure in discretionary grants. 
8.3 Housing Management – There is no variance currently projected.  
8.4 Homelessness/Allocations – There is no variance currently projected.  
8.5 Miscellaneous General Services Housing – An underspend of £25k is projected, arising
from lower than expected repairs and maintenance expenditure on certain properties.  
8.6 Building Services – There is no variance currently projected. 
8.7 Property Services - Projects an overspend of £138k.  This is comprised of anticipated
overspends in Design and Construction, largely due to lower than budgeted fee income.
The service is working on controlling costs and increasing revenue in order to mitigate this
position by year-end. 
8.8 Housing and Property Savings – Staffing savings are anticipated to be £178k more than
the budgeted provision. The service is also continuing to deliver savings to the general
services budget: 
Housing and Property Amount
25/26
£,000
Posted
25/26
£,000
Property - Take a more commercial approach to rent reviews (65) (65)
Property - Close two corporate offices (50) (50)
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Elgin Community Centre  (33) (33)
Milne’s ASG – Building Services Pilot (10) (10)
Building Services - Depot Rental (100) (112)
Housing Improvement Grants (70) (70)
Moray Women's Aid (26) (26)
SACRO Guildry House (17) (17)
LED & Solar (30) (30)
Temporary Accommodation savings (42) (42)
Depot & Stores (10) (10)
Out of Hours review (118) (118)   
(571) (583) 
8.9 The projected variances in delivery of savings to 31 March 2026 are summarised below. 
Service Description Overspend
(£000)
Underspend
(£000)
Net Variance
(£000)
Building Services – Depot
Rental 
12 
TOTAL   (12) 
8.10  The review of rental charge for the DLO depot has delivered an additional £12k towards the
savings target. Overall savings of £583k have been delivered in the course of the reporting
year.  
8.11 Overall, it is now projected that the General Services Housing Budget will underspend by
£85k on the agreed budget.  
9. SUMMARY OF IMPLICATIONS  
9.1 The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan)  X
Policy and Legal  X
Financial X 
Risk  X
Staffing  X
Best Value and Transformation  X
Property  X
Information Communications Technology/Digital             X
Equalities. Social Inclusion and Economic Impact   X
Climate Change and Biodiversity Impact  X
9.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
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One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments       
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments
Property,
Estates
and Assets
Service
Development
1 April
2026
£65,178   
9.5 Risk 
Budget Managers are aware of their responsibilities for managing budget allocations and
approval for variance will be sought from the Committee in line with Financial Regulations.  
9.6 Staffing 
Paragraph 6.15 details the proposed recruitment of one post at Grade 9. 
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☒ Tackle Poverty and Inequality.
☐ Build Stronger Greener Vibrant Economy.
☒ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
Local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☒ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☒ Improving wellbeing of our population 
9.3 Policy and Legal 
There are no policy or legal implications arising from this report.  
9.4 Financial 
The financial implications of this report are considered in Section 5 -8 and detailed in
Appendices I and II.
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9.7 Best Value and Transformation 
There are no best value or transformation implications arising from this report.  
9.8 Property 
There are no property implications directly arising from this report.  
9.9 Information Communications/Technology/Digital 
There are no information communications/technology/digital implications arising from
this report.  
9.10 Equalities, Social Inclusion and Economic Impact 
There are no equalities/socio economic impacts arising from this report.  
9.11 Climate Change and Biodiversity Impacts 
There are no climate change/biodiversity impacts arising from this report. 
10. CONSULTATION  
10.1 This report has been prepared in consultation with Finance staff, Chief Financial Officer,
G. Anderson (Senior Solicitor), Senior Managers within Housing, Property and
Communities and L. Rowan (Committee Services Officer) and any comments made have
been incorporated into the report.   
11. BACKGROUND PAPERS  
11.1 Housing Revenue Account Annual Budget 2025-26
Housing and Property Services Budget Monitoring Report to 30 June 2025 
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APPENDIX I 
Housing Revenue Account       
Budget Monitoring to 31 December 2025     
Service Description
Annual
Budget
2025-26
Budget to
31 Dec
2025
Actual to
31 Dec
2025
Variance
to 31 Dec
2025
Projected
Outturn to
31 Mar 2026
Projected
Variance
to 31 Mar
2026
Expenditure £,000 £,000 £,000 £,000 £,000 £,000
Supervision & Management 6,455 3,955 3,703 252 6,221 234
Sheltered Housing 66 51 34 17 61 5
Repairs and Maintenance 10,183 6,791 7,536 (745) 10,237 (54)
Financing Costs 8,413 0 0 0 8,127 286
Bad & Doubtful Debts 250 75 81 (6) 250 0
CFCR  3,089 0 0 0 2,812 277
Downsizing Incentive
Scheme 72 54 39 15 72 0
Service Development 310 105 10 95 310 0
Total Gross Expenditure 28,838 11,031 11,403 (372) 28,090 748              
Income £,000 £,000 £,000 £,000 £,000 £,000
Non-dwelling rents 275 213 215 2 275 0
House rents 28,034 20,983 20,428 (555) 27,277 (757)
IORB 350 0 0 0 276 (74)
Other income 179 134 241 107 279 100
Total Income 28,838 21,330 20,884 (446) 28,107 (731)              
Surplus / (Deficit) for the
year 0 10,299 9,481 (818) 17 17              
Accumulated Surplus
Balance brought forward         2,233                
Estimated Surplus Balance
at 31 March         2,250   
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APPENDIX II 
General Services Housing & Property               
Monitoring to 31 December 2025     
Annual Budget 
Actual &
committed Variance Projected  Projected 
Service Description Budget to to at  Outturn Variance   
2025-26 31 Dec
2025
31 Dec
2025
31 Dec
2025 2025-26 2025-26    
£'000 £'000 £'000 £'000 £'000 £'000
Planning & Development 186 272 248 24 166 20               
Housing Management 18 33 34 (1) 18 0               
Homelessness / Allocations 1683 1336 1314 22 1683 0               
Miscellaneous General
Services Housing 203 73 42 31 178 25                
Building Services 0 (100) (100) 0 0 0                
Property Services 2040 1553 1710 (157) 2178 (138)                
General Services Housing &
Property Savings 178 0 0 0 0 178                
General Services Housing &
Property Allocations (161) 0 0 0 (161) 0                
General Services Housing &
Property Total  4147 3167 3248 (81) 4062 85 
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