Tenant Satisfaction Measures: small landlord data submission pilot
Source: gov.uk (2025-09-18)

Summary of evidence, September 2025

Contents
- Executive summary (#exec)
- Background to the pilot (#background)
- Overview of pilot (#overview)
- Use of TSMs by small landlords (#use)
- TSM data of small landlords (#smalldata)
- TSM data submission (#submission)
- Equality (#equality)
- Conclusions (#conclusions)
- Annex A: Small landlords who submitted data as part of the pilot (#annexa)
Executive summary

The Regulator of Social Housing (RSH) regulates for a viable, efficient, and well governed social housing sector able to deliver quality homes and services for current and future tenants.

Tenant Satisfaction Measures are part of an enhanced consumer regulation regime described in the Social Housing White Paper (2020). All registered landlords of every size must publish TSMs. Large landlords which own 1,000 or more homes are required to submit a TSM data return and supporting information to the regulator. No similar requirement for submission to the regulator exists for small landlords which own fewer than 1,000 homes.

The regulator has undertaken a voluntary pilot to improve its understanding and evidence base in relation to the comparability of small landlords’ Tenant Satisfaction Measures results, any extent to which their annual submission could effectively support our regulation, and the level of burden that requiring such submission would place on small landlords.

We have considered the evidence drawn from the pilot. On balance we consider that it would be appropriate to continue with our existing approach. This means we will not require small landlords to annually submit their TSM information to us.

This approach does not change the existing TSM requirements for small landlords. They must still collect, process and publish TSM results in line with the Transparency, Influence and Accountability Standard.

We would like to thank the volunteer small landlords for taking part in this pilot.

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Background to pilot

1 - The Tenant Satisfaction Measures (TSMs) are a set of performance measures that all registered providers of social housing in England (‘landlords’) are required to collect and publish. They cover keeping properties in good repair, maintaining building safety, effective handling of complaints, respectful and helpful engagement and responsible neighbourhood management.

2 - There are two main types of TSM. The first type (‘tenant perception TSMs’) are calculated based on surveys undertaken by landlords. The survey questions, response scales and key methodological requirements are set by the regulator. The second type of TSMs (‘management information TSMs’) are drawn from landlords’ management information, calculated in a manner set by the regulator.

3 - ‘Small’ landlords are those which own fewer than 1,000 homesfootnote 1 (#ftn1), and ‘large’ or ‘larger’ landlords are those which own 1,000 homes or more. In order to reflect our risk-based approach and in line with our duty to exercise our functions in a way that minimises interference and is proportionate, the TSM requirements were made to be more flexible for small landlords in certain respects. This included:
- Permitting small landlords to report annual TSMs to a reporting year other than 1 April to 31 March.
- Allowing small landlords who use a census approach to generate perception TSMs to be considered to meet sample size requirements, recognising it would be practically difficult for many small landlords to collect enough surveys to achieve the minimum levels of statistical accuracy required for larger landlords.
- Requiring small landlords to undertake a high-level assessment of representativeness of their achieved sample, compared to the more detailed assessment required of larger landlords.
- A requirement to survey tenants every two years at a minimum, compared to every year for large landlords.
- Permitting small landlords to use a proportionate approach to defining their tenant population for certain TSMs where they have a mixture of low cost rental accommodation (‘LRCA’) and low cost home ownership accommodation (‘LCHO’).
- A requirement for small landlords to collect and publish TSM results, but no requirement to annually submit TSM data to the regulator.
4 - Our rationale for tailoring TSM requirements for small landlords included that:
- TSM results from small landlords would not be as comparable as those of larger landlords. Small landlords would have to survey a much higher proportion of their tenants compared to larger landlords in order to achieve comparable levels of statistical accuracy. Reflecting this, small landlords would not be required to collect survey data as frequently and to the same level of statistical accuracy as larger landlords.
- Our proposals would reduce the regulatory burden on small landlords, while ensuring that their tenants can hold their landlord to account by maintaining a requirement for small landlords to collect and publish TSM results.
5 - The approach to tailoring requirements was considered as part of our consultation on the introduction of TSMs, with respondents asked if they agreed with our approach to tailoring requirements. 71% of total respondents agreed with the approach, which included 68% of the respondents who were social housing tenants in rental accommodation and 61% of respondents who were shared owners.

6 - We received comments from the minority who disagreed with our proposals calling for more alignment of requirements for landlords regardless of size. The main area where alignment was called for was that small landlords should be required to submit their TSM data to us, with some respondents commenting that this would aid regulatory oversight of these landlords. Some respondents commented that requiring small landlords to submit their TSM data to us would support sector benchmarking and learning from good practice, as well as transparency for tenants.

7 - We took those issues raised by respondents into account. However, our concern remained about the risks around statistical accuracy, comparability and the burden on small landlords of annual submission. We concluded at that time to not make it a mandatory requirement for small landlords to annually submit their TSM data to us. However, as the decision by necessity came before the collection of any TSM data we were aware that future evidence could be used to understand the position in more detail. We announced our intention to run a voluntary pilot with small landlords to gather data and consider further this issue in the light of the results of the pilot.

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Overview of pilot

8 - All small landlords - including both private registered providers and local authority registered providers - were invited to volunteer to take part in the pilot. In total we received 124 volunteers. Of these landlords, 98 submitted their first years’ TSM data.

9 - Pilot participants were very broadly representative of the more than 1,000 small landlords. The volunteers included private registered providers and local authority registered providers, supported housing specialist landlords, almshouses and for-profit landlords. Collectively the pilot participants who submitted results collected over 13,000 surveys and owned over 30,000 homes.

10 - There were however some limitations to the representativeness of the sample:
- As shown in Table 1 (#table1), just under half of pilot landlords owned 250+ homes, compared to 14% of the small landlord sector.
- In the case of 59% of the small landlords who submitted TSM information to us in the pilot, supported housing (which includes housing for older people) represented more than 30% of their total homes, whereas this is the case in relation to only 41% of all small landlords. We therefore have a reasonable degree of confidence in our understanding of the relevant needs of both supported housing focused small landlords and those which hold higher amounts of general needs accommodation.
- We recognise that volunteer landlords were a self-selected cohort which means they are likely to have a greater focus on the TSMs and would be more willing to submit their TSM results compared to the population.
Table 1: Breakdown of small landlord volunteers by size (number of units). Source: Small landlord TSM submissions, Registered providers stock and rent publication.

11 - We asked volunteer landlords to submit TSM data and supporting documents covering their first year of collection. The data we requested was more limited than the information we require large landlords to submit but allowed us to collect sufficient information to both calculate the small landlords’ TSMs and understand relevant contextual factors behind them. For example, we collected information on the survey collection methods used as this is important context for the results.

12 - Alongside the data submission we undertook two surveys of landlords to understand their experiences of preparing for submission and submission itself. We followed the first survey with 21 individual conversations with landlords, that helped us to understand submission from the landlord’s perspective.

13 - Three information sessions were held with volunteer landlords to explain the process, ensure that they had information available to submit and confirm the emerging analytical evidence.

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Use of TSMs by small landlords

14 - Feedback from the two surveys of landlords and the individual conversations conducted as part of the pilot told us landlords value the way the TSMs can highlight areas they need to focus on, give tenants an opportunity to understand the landlord’s performance and help inform future decision making. In particular the individual conversations confirmed:
- The vast majority of interviewees recognised the value of introducing TSMs.
- Over half of interviewees had already used TSM data to inform policy reviews and support improvements to service provision.
15 - Landlords also told us that they have added qualitative questions to the TSM survey, as they are permitted to do in the requirements. Many small landlords find this to be a useful source of information as direct responses from tenants allow them to understand their performance and how to improve this.

16 - Our use of the TSMs for both small and large landlords has confirmed there is value in looking at results across a single landlord. A landlord can look at their own perception survey results and see which service areas have high and low results. This is a key piece of information that the landlord can interrogate in order to decide where service improvements may be required. They are also required to share these results with tenants, which will support effective tenant scrutiny by allowing them to undertake similar analysis.

17 - Similarly, the collection and publication of a common set of measures for management information supports landlords to understand their own position and show areas to focus resources upon. Publication of management information results by the individual landlord can also support effective tenant scrutiny. This is particularly clear in relation to areas such as building safety, homes not meeting the Decent Home Standard, repairs and complaints.

18 - These valuable uses of the TSMs do not require collection or publication of collated landlord results by the regulator.

19 - Landlords interviewed also confirmed that they had used creative approaches to encourage a higher level of responses. This included pre-survey engagement where they tell tenants the surveys will be coming out shortly and telling tenants in advance that surveys will be coming on a particular colour of paper. This means tenants will not be hesitant or concerned when they receive a letter out of the blue from their landlord. Landlords also told us that the use of specific coloured paper can also support accessibility amongst certain groups, including older tenants. These approaches may be of interest to other landlords who are seeking to ensure sufficient response rates either generally or from specific groups

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TSM data of small landlords

Comparability of tenant perception TSMs

20 - Comparability of tenant perception TSMs is affected by survey collection methods, which we know from our analysis has a significant impact on satisfaction scores. As shown in Figure 1 (#figure1), small landlords undertake surveys with more variation in survey collection method than large landlords. Whilst 65% of large landlords used telephone as their predominant survey collection method there is no similar trend amongst small landlords. This is consistent with a tenant focused approach - small landlords may use different methods to larger landlords in view of the geographical concentration of their homes.

21 - The amount of variation in their survey collection method profiles complicates the comparison of tenant perception TSM results between small landlords. Comparisons between landlords are most insightful when the landlords share similar characteristics–(such as size, region and proportion of supported housing) and where similar survey collection method profiles have been used.footnote 2 (#ftn2) Comparisons between similar landlords who use different survey collection methods will be limited in relation to what conclusions can be drawn from them, and may lead to inaccurate or misleading conclusions.

Figure 1: Breakdown of responses by collection method for small (<1,000 homes) and larger (1,000 homes or more) landlords, based on submissions covering 2023-24. Sources: Small landlord TSM submissions, 2023-24 TSM Publication

22 - Even with the ability to use a census, innovative approaches to encourage a higher level of responses, and a variety of survey collection methods to collect tenant perception TSM information, 30% of respondents to the survey that we undertook during the pilot following submission told us that they experienced difficulties in achieving a sufficient response rate.

23 - The data submitted through the pilot has confirmed many small landlords have not been able to achieve the standard minimum level of statistical accuracy.footnote 3 (#ftn3) In the pilot, more than 90% of landlords used a census, indicating this is a widely used approach among small landlords. Some landlords did achieve the standard minimum level of statistical accuracy, including through utilising the methods shown above. However, based on all submissions, just over half (54%) did not meet that standard. This is broken down further in Table 2 (#table2). As landlords which own between 1 and 249 homes are underrepresented in the pilot submissions (see Table 1 (#table1)) the proportion of such landlords who do not meet the standard minimum level of statistical accuracy is likely to be even higher.

Table 2: Volunteer small landlords who did not meet the standard minimum level of statistical accuracy by number of homes owned. Sources: Small landlord TSM submissions, 2023-24 TSM Publication

*Small landlords are able to report Low Cost Rental Accommodation and Low Cost Home Ownership Accommodation separately. A small number of respondents used this approach, meaning the number of submissions differs marginally from the number of landlords shown in Table 1 (#table1).

24 - This issue of statistical accuracy requires side by side comparisons with other landlords to be much more nuanced and increases the likelihood of inaccurate or misleading conclusions being drawn from such comparisons. It is possible that a landlord with a higher reported result has a lower proportion of truly satisfied tenants than a peer with a lower score. This does not stop small landlords from usefully scrutinising their own results, for example looking to see which are higher and lower, but it does make comparisons with other landlords much more difficult.

25 - In comparison, almost all larger landlords (those which own 1,000 or more homes) were able to meet the standard minimum level of statistical accuracy in their submitted TSMs.

TSMs drawn from management information

26 - Evidence from the volunteer landlords confirmed that the management information TSMs reported can vary significantly for small landlords. For example, a landlord undertaking 100 repairs in a year means that each repair counts as 1% of their total. For complaint numbers (CH01) and anti-social behaviour (NM01) the TSMs are calculated per 1,000 homes, so a 1% difference would be represented in the results by 10 out of 1,000. This means a small number of complaints or ASB cases can make one landlord look very different to another, even though their actual level of service may be very similar. Our follow up conversations with landlords with outlier results confirmed that matters of interpretation or classification can also drive what appear to be large differences in performance. For example, whether an individual expression from a single tenant is assessed to be a complaint or a service request can significantly affect both CH01 and CH02. Small landlords are unlikely to have specialist teams who are applying the relevant definitions on a range of issues on a daily basis. Whilst seeking to accurately classify cases they may differ between each other in how they have assessed cases against the relevant definitions.

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TSM data submission

27 - Feedback from small landlords has confirmed our understanding that submission of TSMs would be an additional burden. The TSM Regulatory Impact Assessmentfootnote 4 (#ftn4) considered that overall approach to TSMs would have a larger impact on small landlords compared to larger landlords, but the additional cost as a proportion of turnover is low.

28 - The pilot has further substantiated this in relation to the submission of small landlord TSM results to the regulator. Small landlords have confirmed an additional burden of submission would be present but limited. A third of landlords responding to the post-submission survey confirmed that they found the data return difficult to understand and that necessary validationsfootnote 5 (#ftn5) in the return could be confusing.

29 - 20% of respondents to the survey stated that they found submission time consuming. Any requirement to annually submit information would need to be put in the context of wider burdens affecting small landlords. Feedback through the surveys, information events and individual conversations confirmed that many small landlords have relatively few staff. Chief Executives or other staff often end up performing multiple roles that are undertaken by specialists in larger organisations. Preparing TSM information for submission would therefore be an additional specialist task that they would need to achieve within their work. It would also have an opportunity cost as they could not work on other areas which, particularly given the issues with the comparability of small landlords’ TSM results, may be more impactful that submitting their TSM results to the regulator.

30 - Submission of small landlord TSM results would also have an impact on the regulator. The regulator cleaning, preparing and analysing small landlord TSM information would require substantial resources. For the pilot, we applied only a high-level cleaning check to returns post-submission. Even with this high-level check we considered it necessary to contact around half of the submitting volunteer landlords to follow up on data cleaning checks and ensure required documents were submitted. The significant issues identified were often similar to the large landlord returns outlined in the 2023-24 TSM Publication.footnote 6 (#ftn6) Applying this approach across the more than 1,000 small landlords would mean a significant outlay of the regulator’s resources.

31 - 21% of landlords who originally volunteered did not submit TSM results. There were no penalties for landlords who withdrew from the pilot. Landlords gave multiple reasons for withdrawing. We sought to minimise our submission request as far as possible (while also ensuring that the submissions would give us useful results for the purposes of the pilot), but some landlords withdrew once the level of information we were requesting was clear. We anticipate that, as with other data returns, there would be some small landlords who would struggle to submit on time and who may need more technical support to provide the relevant information. This would have an impact on the regulator’s ability to undertake other tasks.

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Equality

32 - In developing and reaching our conclusions we have been mindful of our general public sector equality duty under section 149 of the Equality Act 2010. In summary, this duty says that public authorities must, in the exercise of their functions, have due regard to the need to:

eliminate behaviour that is prohibited by the Equality Act 2010, including discrimination, harassment and victimisation;

advance equality of opportunity between people who share a protected characteristic and those who do not; and

foster good relations between people who share a protected characteristic and those who do not.

33 - We have identified that, although the vast majority of older or disabled social housing tenants live in housing owned by large landlords, in general, a small landlord is likely to have a higher proportion of older or disabled tenants than a large landlord.

34 - With this in mind, we considered that if the TSM results of small landlords would generally meet minimum thresholds of comparability, or their annual submission to us would effectively support our regulation of small landlords, then requiring their annual submission could have some positive potential equality impacts (for example, through helping to drive improvements in how small landlords operate).

35 - However, the relevant evidence we have gathered indicates that the annual collection and publication of small landlords’ TSM information by the regulator could facilitate meaningful comparisons only in highly specific and limited instances. The landlords in the comparison would not only need to have met minimum levels of statistical accuracy but would also need to have shared similar contextual factors (such as survey collection method profiles). Even then, a small number of individual cases could make one small landlord’s TSM results look very different from another’s, even where their actual levels of service may be very similar. In relation to our regulation of small landlords, we have also kept in mind that any potential for the annual submission of small landlords’ TSM information to effectively support our regulation would be limited by the need for the regulator to take a proportionate and risk-based approach.

36 - We have also considered that the annual collection and publication of small landlords’ TSM information by the regulator could have an adverse impact on the need to advance equality of opportunity and the need to foster good relations, including in relation to tenants who are older and tenants with a disability. The pilot has highlighted how the publication of small landlords’ TSM results by the regulator would risk misleading conclusions being drawn from that information. The pilot has also improved our understanding of the burden that requiring annual submission would place on small landlords, potentially diverting resources that could otherwise be applied towards the needs of their tenants.

37 - Overall though, while we have identified some positive and negative potential impacts, we have assessed that continuing not to require small landlords to annually submit their TSM information to us is likely to have a broadly neutral impact on the needs referred to in the general public sector equality duty.

38 - The regulator is undertaking other activities in relation to the TSMs that look to support those needs, including using National Tenant Survey analysis to help us better understand different levels of satisfaction amongst different groups of tenants, and ensuring that important contextual information, such as survey collection method and landlord size, supported housing holdings and major region, are included in the regulator’s publication of large landlords’ TSM information.

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Conclusions

39 - The regulator carried out the pilot to improve its understanding and evidence base in relation to the comparability of small landlords’ TSM results, any extent to which their annual submission could effectively support our regulation, and the level of burden that requiring such submission would place on small landlords. Due to the efforts of the volunteer landlords we now have a much better understanding of the impact of submitting TSM data to ourselves. We would like to thank the volunteer small landlords for taking the time to undertake the submission, our surveys and individual conversations. We have published the list of submitting volunteer landlords in Annex A.

40 - We are now more advanced in our understanding of small landlord results. We have concluded that:
- Small landlords consider there to be value in their own collection and publication of TSM results. We agree with this assessment. Looking at an individual landlord’s TSM results can be a powerful tool for the landlord and its tenants to understand the quality of service and where improvements can be made. The desire of small landlords to innovate and find ways to improve the comparability of data, for example by increasing response rates, is recognised.
- Even with these efforts, comparability between small landlords’ TSM results is often low. Small landlords use a wider variety of survey collection methods than larger landlords and cannot in many cases reliably meet minimum levels of statistical accuracy. Small differences in the factual position behind small landlords’ TSM calculations, or in how relevant definitions have been applied for those calculations, can have an outsized impact on their TSM results. This makes undertaking comparisons much more nuanced and increases the chances of misleading conclusions being drawn.
- There is a burden on landlords in submitting their data, which will be proportionately larger for small landlords relative to large landlords due to their size, and the likelihood that their staff will already be covering multiple specialist areas. For the pilot, we minimised the submission as far as we considered achievable to understand the results, but this level of submission would still be a burden for landlords.
- There would also be significant resource implications for the regulator in cleaning, considering and preparing data for publication and internal use.
41 - On balance, we consider that it would be appropriate to continue not to require small landlords to annually submit their TSM information to us. We have reached this conclusion in view of:
- the low comparability of small landlords’ TSM data;
- the risk of misleading conclusions being drawn from the regulator’s publication of that data;
- the limited potential for its annual submission to us to effectively support our regulation;
- our assessment that continuing not to require such submission would be likely to have a broadly neutral impact on the needs referred to in the general public sector equality duty;
- the further regulatory burden for small landlords, and the resource implications for the regulator, that requiring such submission would create;
- our co-regulatory, risk based, and assurance based regulatory approach, which is underpinned by our overarching statutory duty to exercise our functions in a way that minimises interference, and (so far as is possible) is proportionate, consistent, transparent and accountable.
42 - This approach has no impact on the requirement for small landlords to collect, process and annually publish information about their performance against the TSMs in accordance with the regulator’s requirements.

43 - Maintenance of our current approach includes the requirement for small landlords to tell us of any material issues that has affected or may affect their ability to deliver the outcome of our standards. It also includes our approach to responsive engagement, which we may carry out with a landlord where we assess an issue or a potential issue to be material to the landlord’s delivery of the outcomes of our standards. This includes any such issues we become aware of as a result of referrals (including self-referrals) about the landlord’s delivery of the outcomes of the Transparency, Influence and Accountability Standard that relate to TSMs.

44 - During the pilot exercise we were provided with information from small landlords that was outside of the pilot’s scope, but which may help inform a wider review of our TSM requirements in the future. We plan to review our TSM requirements, including around the submission of TSM information to the regulator, at an appropriate time in light of further relevant intelligence received through regulatory activity or other sources, and as landlords become more used to delivering the TSM requirements.

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Annex A: Small landlords who submitted data as part of the pilot

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1: In this document, ‘homes’ refers to dwelling units of low cost rental accommodation and low cost home ownership accommodation, as defined in sections 69 and 70 of the Housing and Regeneration Act 2008. ⬆️ return (#ft1)

2: In general results from surveys are seen as meeting a minimum level of statistical accuracy if there is a margin of error of less than ±5%, which we have referred to in this document as the standard minimum level of statistical accuracy. This means we can be 95% confident that the reported result may be 5% higher or 5% lower, so a result of 65% would mean we are 95% confident the result of a survey of all tenants would be between 60% and 70% (as long as the sample is representative). ⬆️ return (#ft2)

3: A breakdown of results by these factors is included in the large landlord TSM publication for this purpose.⬆️ return (#ft3)

4: Tenant Satisfaction Measures: Regulatory impact assessment (https://www.gov.uk/government/consultations/consultation-on-the-introduction-of-tenant-satisfaction-measures/outcome/annex-7-tenant-satisfaction-measures-regulatory-impact-assessment-accessible) ⬆️ return (#ft4)

5: Validations ensure that data conforms to the expected format. These controls prevent users from entering text where numbers are required, putting in too many digits after the decimal point, or incorrect use of positive/ negative values. ⬆️ return (#ft5)

6: Tenant Satisfaction Measures 2023-24 (https://www.gov.uk/government/statistics/tenant-satisfaction-measures-202324) ⬆️ return (#ft6)