STAIRs & Housing Ombudsman changes — what housing associations must do to prepare

Transparency and tenant empowerment remain central to ongoing reform in the social housing sector. The introduction of the Social Tenant Access to Information Requirements (STAIRs) — alongside proposed changes to the Housing Ombudsman Scheme — marks a significant step towards greater accountability for private sector housing associations and/or providers. 

With implementation beginning in October 2026, providers should now be actively preparing for the shift in tenant information access obligations and complaints handling. 

Here, Paddy Fearnon and Eleanore Beard from our data protection team explain the key STAIRs compliance requirements for housing associations, explore how the Housing Ombudsman’s role is changing and outline the practical steps that providers must take to remain compliant and avoid scrutiny. 

What is STAIRs & how will it affect housing associations? 

The STAIRs framework gives tenants of housing associations clearer rights to access information about how their homes and services are managed. 

In practice, housing associations must: 

• publish key information about their services 
• respond to tenant information requests 
• withhold information only where reasonable to do so. 

Unlike local authorities, housing associations aren’t subject to the Freedom of Information Act 2000 (FOIA), meaning that STAIRs introduces a new, tailored transparency regime for the sector.  

How is the Housing Ombudsman’s role changing under STAIRs? 

One of the most significant changes made within the Housing Ombudsman as a result of the STAIRs consultation is the expansion of its jurisdiction to cover information access complaints. 

The Ombudsman will now: 

1. investigate how housing associations handle tenant information requests 
2. consider failures relating to publication schemes 
3. assess whether there has been maladministration, including delay, unfairness or failure to follow policy.  
    

Importantly, STAIRs complaints will sit outside the existing Complaint Handling Code, creating a separate process that providers must manage in parallel.  

The emphasis will be on whether decision-making is reasonable, consistent and well evidenced — not simply whether information was provided. 

Understanding the STAIRs process & tenant escalation routes 

STAIRs introduces a clear and structured process for private housing associations, ensuring standards of transparency that will include:  

1. Publication schemes — housing associations must proactively publish information on management, governance, spending and maintenance. 
2. Information requests — tenants can request certain information. For example, information relating to antisocial behaviour, complaints handling, health and safety, rent rates, stock profiles, energy information and estate management. 
    

Information requests can be made by a social housing tenant of the registered provider or a representative nominated by the tenant to communicate with the provider on their behalf. Similar to FOIA, for a request to be valid, the applicant must be identifiable and the request itself must be made in writing. 

It’s therefore important that as a provider of social housing you’re able to identify these requests, as tenants don’t need to expressly mention STAIRs for the request to fall within the regime.  

As a provider of social housing, you’ll also need to fulfil a request for information as quickly as you can within 30 calendar days. A provider of social housing can take longer but only in exceptional cases, such as where they need more time to decide if some information should be withheld or get information from a contractor or another organisation. 

If the response will be late, you must tell the requester why and when they should expect a reply. If you refuse the request, you must explain why. 

There will be instances where you can remove or hide information where needed. Where you do provide information, you should also try to provide it in a format that the requester can use. 

If the request is unclear, you should help them to explain what information they want. 

If a requester is dissatisfied: 

1. The housing association must conduct a single-stage internal review. 
2. A decision must be provided within 30 days (although there are some circumstances where this can be extended). 
3. The tenant can then escalate to the Housing Ombudsman (it’s important to note that the Housing Ombudsman won’t be able to consider a complaint where the tenant has an alternative source of redress in relation to data protection legislation).  
    

You should consider whether you’re ready to respond to an initial information request and deal with any complaint about how you’ve complied with STAIRs. 

What remedies will STAIRs complaints lead to? 

Unlike traditional complaints, STAIRs is expected to focus less on compensation and more on improving transparency and decision-making. 

The Ombudsman is more likely to: 

• require providers to review decisions and provide clearer reasons 
• identify and address process failings 
• in some cases, require the disclosure of information.  

 This signals a shift towards systemic accountability rather than one-off financial remedies. 

When do STAIRs obligations & deadlines apply? 

The STAIRs framework will be introduced in phases: 

• Summer 2026 — updated Housing Ombudsman Scheme expected. 
• 1 October 2026 — publication scheme requirements come into force. 
• 1 April 2027 — information request requirements take effect.  

Alongside this, the Regulator of Social Housing is introducing a separate standard, creating a dual framework of regulatory oversight and complaints enforcement.  

Information governance & data readiness 

Could your current record-keeping withstand Ombudsman scrutiny?  

Providers will need: 

1. consistent document management systems 
2. clear audit trails for decisions 
3. accessible and accurate historical data. 
    

Historic data gaps may present challenges, particularly where information hasn’t been centrally stored. 

Aligning STAIRs with existing obligations 

STAIRs will sit alongside existing legal regimes, including: 

• data protection legislation (e.g. handling personal data) 
• wider consumer regulation reforms 
• Tenant Satisfaction Measures. 

Housing associations must ensure that responses to information requests are consistent across these frameworks, particularly where disclosure may engage confidentiality or data protection considerations. 

Increased scrutiny & reputational risk 

STAIRs is designed to empower tenants to challenge their landlord.  

Non-compliance could lead to: 

• adverse Ombudsman findings 
• regulatory attention 
• reputational damage. 

Looking ahead 

The introduction of STAIRs represents a fundamental shift towards greater transparency and tenant accountability in the social housing sector. 

The direction of travel is clear: housing associations will be expected to disclose more, respond faster and justify decisions more robustly. 

Providers that begin preparing now by strengthening information governance, reviewing processes and training staff will be best placed to meet these expectations. Those that delay risk falling behind and facing increased scrutiny once the framework takes effect. 

As the regime beds in, early Ombudsman decisions are likely to shape best practice. Staying ahead of these developments will be key to managing risk effectively. 

Talk to us 

Don’t leave STAIRs compliance to the last minute. 

If you’d like support with your STAIRs readiness — including reviewing your publication scheme, stress-testing your processes or aligning your approach with wider regulatory obligations — our housing and data protection teams can help. 

To discuss how this applies to your organisation, talk to us by giving us a call on 0333 004 4488, sending us an email at hello@brabners.com or completing our contact form.