Six steps to preparing for the ‘Publication Phase’

Social housing providers are already aware that the first phase of the Social Tenant Access to Information Requirements (STAIRs), is set to be introduced on 1 October. But will they be ready for Chapter 1 and what can they do to prepare for Chapter 2?

Based on a new Policy Statement, Chapter 1 is sometimes described as the “Publication Phase’, due to the requirement for private registered providers (PRPs) to publish specific classes of information for their tenants. The overall aim of the legislation is to improve transparency for tenants about how social homes are managed and give them access to relevant information.

Many PRPs will find that their existing practices are compliant with Chapter 1, partly due to the existence of the Regulator of Social Housing’s Transparency, Influence and Accountability (TI&A) Standard. However, with Chapter Two (due April 2027) calling for the introduction of clearer rights for tenants, with enforceable timelines, this is likely to be more challenging from an operational perspective, so it’s best to get ahead. 

Getting ready for the Publication Phase

In order to make preparation for the Publication Phase as streamlined as possible, PRPs should start by assessing the information they hold about how social homes are managed and services provided. They should also be working closely with tenants to ensure their priorities are fully considered and understood. It’s expected that as much as 90% of their day-to-day operations could be linked to the provision of social housing, so is likely to fall within the scope of STAIRs. 

In partnership with policy specialists at the National Housing Federation, our experts have produced new operational guidance to support PRPs in preparing for Chapters 1 and 2 of STAIRs.

This guidance provides everything from new decision-making models to templates to assist in the design of new request handling processes. To support PRPs in deciding which information falls in or out of scope of STAIRs, we have provided a comprehensive list of various types of information, which can be updated and extended as appropriate, including areas such as governance and decision making; finance and spending; housing services and tenant liaison and social housing management.

Six steps to prepare

Drawing on our new operational guidance, here are six steps to guide PRPs in preparing for Chapter 1 of STAIRs:

1. Know your data 

It will be crucial for providers to audit their existing documentation so that they can assess how the information currently held aligns with the classes of information listed in the Policy Statement.  Your Information Asset Register and Records Retention Schedule are key documents which should be of assistance here and should be referred to at an early stage. 

2. Make tenants aware

Through tenant liaison teams, providers should introduce their new STAIRs publication scheme from October 2026 and explain how tenants will be able to submit information requests from April 2027. In some cases, it may be possible to involve tenants in the design of the publication scheme and process for making requests. Tenants should also be made aware that they can request reviews under Chapters 1 and 2 of STAIRs and escalate complaints to the Housing Ombudsman Service (HOS) if they are not satisfied with the review response.  

3. Organise web content 

It may be helpful to revise webpages so that relevant content is clearly set out according to STAIRs classes of information – for example, by using a separate STAIRs “portal” or “one stop shop” for STAIRs-related information. 

4. Appoint a STAIRs champion

As it is intended that STAIRs will be aligned with freedom of information and data protection laws, providers will need to identify and appoint a key person to review documents and make recommendations as to whether in-scope documents can be published in full, or whether information needs to be redacted. This could be a Data Protection Officer or another information governance professional. 

5. Create a process for assessing information before publication

PRPs will need to put in place new standard operating procedures for identifying relevant information for publication with clear timelines. Teams across the organisation will need to ensure that relevant information is provided to the STAIRs team routinely and on a timely basis and published information is periodically reviewed to ensure the publication scheme is kept up to date. Key individuals within teams across the organisation should receive training on STAIRs and be able to identify relevant information that is within scope and make decisions with regard to its publication. Providers should consider recording these decisions within their Information Asset Register or a similar document. 

6. Ensure tenants can request a review 

Under the Policy Statement, tenants will be able to seek a review if they believe that information that falls within the scope of STAIRs has not been published or otherwise made available. Providers will need to ensure that their process for seeking a review is up and running in line with the introduction of the publication scheme from 1 October 2026.   

In readiness for Chapter 2, PRPs will have to design and implement a new process for handling and responding to tenant information requests. The Policy Statement states that tenant information requests must be made in writing, and PRPs must respond in writing within 30 days of receipt. Someone with the right training and skills will have to take a view on whether the information request should be treated as a STAIRs request or a ‘business as usual’ request. It’s important to get things right from the start, as complaints could be made to the Housing Ombudsman Service if timelines aren’t met, and matters could be referred to the Regulator.

In summary, given the scope and reach of STAIRs, organisations will need to ensure that boards are prioritising early preparation to ensure that internal processes will be effective by 1 October. Key to operationalising STAIRs is making sure that new publication schemes and request handling processes are grounded in tenant understanding and geared to meet their needs. Putting transparency and tenant understanding at the centre of decision-making processes will mitigate data governance risks and protect providers from regulatory sanctions.

NHF members can download a free copy of the new operational guidance for STAIRs here. Non-NHF members can obtain a copy of the guidance from Anthony Collins here.

Key takeaways

• STAIRs Chapter 1 is due to come into force on 1 October 2026, with Chapter 2 commencing from April 2027. The main purpose of STAIRs is to provide transparency for tenants about how social homes are managed and give them access to relevant information.
• Follow the six steps to readiness for Chapter 1, as outlined above. Start by knowing your information: what falls in scope and what doesn’t?
• Ensure someone in the organisation is responsible for controlling and managing the information. This must be periodically reviewed and kept up to date.
• Make sure tenants can seek a review. This must be up and running by 1 October 2026.
• Being ready for Chapter 1 is important, because Chapter 2 will be altogether more challenging from an operational perspective.