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Regulator will be ‘more prescriptive’ if landlords ‘game’ the TSMs, consumer director warns

The Regulator of Social Housing (RSH) will become more prescriptive with methods of collecting data on tenant satisfaction measures (TSMs) if landlords try to ‘game’ the surveys, its director of consumer regulation has warned.

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Kate Dodsworth, director of consumer regulation at the RSH, speaking at Inside Housing’s Tenant and Resident Engagement Conference
Kate Dodsworth, director of consumer regulation at the RSH, speaking at Inside Housing’s Tenant and Resident Engagement Conference
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The Regulator of Social Housing will become more prescriptive with methods of collecting data on tenant satisfaction measures if landlords try to ‘game’ the surveys #UKhousing

Speaking at Inside Housing’s Tenant and Resident Engagement Conference in London on Tuesday, Kate Dodsworth said that patterns will begin to emerge and if there is a “correlation with things clearly going wrong and people using a particular collection method”, the English regulator may “have to be more prescriptive”. 

The 22 TSMs, which were finalised and published in September last year, form a major part of the RSH’s new consumer-focused regime.

Data on TSMs started being collected on 1 April 2023 through tenant perception surveys and landlord data. These cover five main themes: repairs, building safety, effective complaint-handling, respectful and helpful tenant engagement, and responsible neighbourhood management.

The results must be submitted to the regulator, which will publish the data in 2024.


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As it stands housing associations and councils can use whatever methods they wish to survey people, such as via phone, online, or in person. 

The RSH decided to keep survey methods open as there are equality issues around some collection measures, for example for vulnerable tenants. 

But Ms Dodsworth said that if a pattern of ‘gaming’ – using particular survey methods to garner more positive results – begins to emerge, the regulator may become more prescriptive. 

She said: “If the landlords in the room are preparing for a blueprint of regulation and are chasing that in order to pass the test, don’t. 

“This is about a culture shift where everyone from the green paper onwards has said it’s time for the sector to shift and make improvements so that tenants live in good-quality, safe homes and have universally good landlord services.

“If you’re waiting just for regulation to do that, you’re following the wrong game.”

Ms Dodsworth added that gaming to get the TSMs right, probably means a landlord is not running a very good service.

“What we have said is that where there is a correlation with things clearly going wrong and people using a particular collection method, after a couple of years of TSM data, we can start to see patterns and themes. 

“In fact, I’m looking forward to two years in when we see patterns and themes on lots of things. 

“If we have to be more prescriptive, then we will,” she stated. 

Activist Kwajo Tweneboa and Charlotte Bates of Expert Citizens CIC spoke during a session on the importance of listening to tenants with lived experience.

Mr Tweneboa began campaigning after he and his family were forced to live in terrible disrepair on the Eastfields Estate in south London.

His landlord, Clarion, failed to help, despite his father being treated for an aggressive cancer in the conditions.  

Kwajo Tweneboa spoke about his horrific experience in social housing
Kwajo Tweneboa spoke about his horrific experience in social housing

Mr Tweneboa’s father died after contracting an infection, which meant he was unable to have his tumour removed in time.

On whether the regulatory changes will drive improvements, Mr Tweneboa, who has been working with the government on reforms, said he “hopes so”.

“It’s about getting it right and it’s about taking accountability,” he said, adding that the changes “have to be enforced”.

Ms Bates, who had a horrific experience when she was vulnerable and placed in emergency accommodation by her local council, said people need support to prosper. 

She added: “The money’s there – it’s costing £200 a week to keep people in exempt accommodation, and it’s unsafe.

Charlotte Bates spoke about her terrible experience in emergency accommodation
Charlotte Bates spoke about her terrible experience in emergency accommodation

“The money is not being used properly. It’s not being used the way it needs to be used and it’s not being used to keep people safe.”

On the regulatory changes, Ms Bates said: “I have faith that everybody wants to do a good job.

“The regulations, I hope, are not just reinventing the wheel. We all know what’s right and wrong. 

“We just need to be able to feel that we have the power as a tenant or as a person working in the sector to do what’s right… I just hope that that regulation becomes a thing that we live by.”

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