Referral of the proposed subsidy to TBG Open Door Homes Ltd by the London Borough of Barnet
Source: gov.uk (2025-11-05)

The Subsidy Advice Unit (SAU) has published its report in response to a request from the London Borough of Barnet (LBB) concerning its proposed subsidy to TBG Open Door Homes Ltd (Open Door Homes).

Administrative timetable

Final report

5 November 2025: The SAU has published its report providing advice to LBB concerning its proposed subsidy to Open Door Homes. The report sets out the SAU’s evaluation of LBB’s Assessment of Compliance of its proposed subsidy with the requirements set out in the Subsidy Control Act 2022.
- Final report (https://www.gov.uk/government/publications/report-on-the-proposed-subsidy-to-tbg-open-door-homes-ltd-by-the-london-borough-of-barnet) (5.11.25)
Request from LBB

25 September 2025: The SAU has accepted a request for a report from LBB concerning its proposed subsidy to Open Door Homes. This request relates to a Subsidy of Particular Interest.

The SAU will prepare a report, which will provide an evaluation of LBB’s assessment of whether the subsidy complies with the subsidy control requirements (Assessment of Compliance). The SAU will complete its report within 30 working days.

Information about the subsidy provided by LBB

Barnet Council is proposing to give a combined subsidy of c.£25 million to TBG Open Door Ltd (known as ‘Open Door Homes’), which is a subsidiary to the Council’s own Arm’s Length Management Organisation and a registered provider of social housing. It will enable the delivery of a shared policy objective to increase the supply of affordable homes to be made available to meet the housing needs of households to which Barnet Council has a housing duty.

This subsidy forms part of a wider package of £57 million for the acquisition of 300 new affordable homes expected to be delivered between 1st October 2024 and 30th September 2026, with a long stop completion date of 31st March 2027. There are 150 homes of the proposed 300 that are being funded with grant funding from Barnet Council, and 150 homes that are being funded by the Greater London Authority (GLA).

The subsidy subject to this referral consists of:

a direct subsidy of £17.760 million from Barnet Council for the provision of a further 99 units at affordable rents

a below market lending rate for up to £70 million of borrowing that is required to help pay for the purchase cost of the 300 homes. Through this below market lending rate, ODH will be able to review the mix of homes that it purchases in order to deliver a broader range of unit sizes; such a discounted lending rate constitutes a subsidy of £8.164 million over the course of the proposed lending period

The desired outcome is the provision of an increase in affordable housing available to the Council, as without the subsidy this would not be supplied by the market in a manner affordable to the council and tenants.

Without delivering subsidy support to TBG Open Door Ltd, the Council itself would not be able to purchase and maintain such homes due to limitations around rental that would result in a viability gap, or it would be forced to place the same households into emergency ‘nightly-purchased’ temporary accommodation, leading to additional annual costs of at least £2.4 million for accommodation and a further £1.5 million in housing benefit subsidy loss (based on current average net additional costs to the council).

Barnet Council’s assessment has considered the potential impact of the subsidies on both the ability for the wider market of affordable housing providers, the market of private and institutional landlords, and the housing management services market, finding the relative scale of the programme and the extent of the impact to be limited.

The relative additional benefit of grant funding from the GLA for the remaining 150 properties within the portfolio has also been considered and accounted for, and still the proposed subsidies in relation to the programme are viewed by Barnet Council as proportionate to securing the necessary policy outcome of an increase in available affordable housing supply to meet growing homelessness needs.

Information for third parties

If you wish to comment on matters relevant to the SAU’s evaluation of the Assessment of Compliance concerning LBB’s proposed subsidy to Open Door Homes please send your comments on the date stipulated in the timetable above. For guidance on representations relevant to the Assessment of Compliance, see the section on reporting period and transparency in the Operation of the subsidy control functions of the Subsidy Advice Unit (https://www.gov.uk/government/publications/guidance-on-the-operation-of-the-subsidy-control-functions-of-the-subsidy-advice-unit/operation-of-the-subsidy-control-functions-of-the-subsidy-advice-unit).

Please send your submissions to the public authority xxx@xxx.xx (mailto:xxx@xxx.xx)

Please also provide a contact address and explain in what capacity you are making the submission (for example, as an individual or a representative of a business or organisation).

Notes to third parties wishing to make a submission

The SAU will only take your submission into account if it can be shared with LBB. The SAU will send a copy of your submission to LBB together with its report. This is to allow the public authority to take account of the submission in its decision as to whether to make or modify the subsidy or its assessment. We therefore ask that you provide express consent for your full and unredacted submission to be shared. We also encourage you to share your submission directly with LBB using the email address provided above

The SAU may use the information you provide in its published report. Therefore, you should indicate in your submission whether any specified parts of it are commercially confidential. If the SAU wishes to refer in its published report to material identified as confidential, it will contact you in advance

For further details on confidentiality of third party submissions, see identifying confidential information in the Operation of the subsidy control functions of the Subsidy Advice Unit (https://www.gov.uk/government/publications/guidance-on-the-operation-of-the-subsidy-control-functions-of-the-subsidy-advice-unit/operation-of-the-subsidy-control-functions-of-the-subsidy-advice-unit)

Contacts
- CMA press team: xx-xxxx-xxxx or xxx@xxx.xx (mailto:xxx@xxx.xx)