The Housing Ombudsman has published a revised Housing Ombudsman scheme and its response to the consultation on the Ombudsman's role in handling complaints under the new Social Tenant Access to Information Requirements (STAIRs). The changes represent a significant development in the social housing regulatory landscape and are intended to support greater transparency and accountability among private registered providers (PRPs) of social housing.

Background: the Ombudsman and STAIRs complaints

The Government has designated the Housing Ombudsman as the independent complaints body for STAIRs-related disputes. Consequently, the Ombudsman has amended its scheme to establish the framework for investigating complaints arising from information requests. The amended Scheme confirms that STAIRs complaints will be handled under a new Part 2B of the Scheme, and relates to complaints about:

• a failure to proactively publish information in accordance with Chapter 1 of the STAIRs policy statement;
• a failure to disclose information in response to a STAIRs information request; or
• the handling of a STAIRs information request or STAIRs review request. 

Overview of the consultation

The consultation on the revised Scheme ran between 20 January and 17 March 2026 and generated 296 responses from housing associations, tenants, sector bodies, charities and other stakeholders. Respondents were principally asked to comment on:

• who should be able to complain;
• the proposed time limits;
• the route for making complaints; and
• the Ombudsman's proposed investigative approach.

The Ombudsman's response confirms that while some refinements and clarifications have been made, the overall approach consulted upon has been largely retained. 

Key Changes to the Housing Ombudsman scheme

1. Creation of a dedicated STAIRs complaints process

The revised scheme establishes a separate process for STAIRs complaints, distinct from the Ombudsman's existing service complaint jurisdiction. Before approaching the Ombudsman, a tenant must first submit an information request to their landlord and allow the provider an opportunity to respond.

Where the tenant is dissatisfied with the response, or where no response is received within 30 calendar days, the complaint may be brought to the Ombudsman for review. 

2. Three-month time limit for Ombudsman referrals

One of the most discussed aspects of the consultation was the proposed limitation period. The Ombudsman has retained the requirement that STAIRs complaints be referred within three months of:

• receiving the landlord's response; or
• the point at which a response should have been received.

Importantly, the scheme preserves discretion to accept complaints outside this timeframe where appropriate. The Ombudsman considered this flexibility sufficient to address exceptional circumstances raised during the consultation. 

3. Eligibility of former tenants

The consultation proposed allowing former tenants to pursue STAIRs complaints where the underlying information request was made during their tenancy.

This approach was broadly supported by respondents and has been adopted in the final scheme. Former tenants who made requests while they remained tenants will therefore continue to have access to redress through the STAIRs process. 

4. Publication of decisions

The Ombudsman has confirmed that determinations arising from STAIRs complaints will be published. This mirrors the broader trend towards transparency and sector-wide learning within the sector.

Key themes from the consultation response

1. Demand for greater guidance and clarity

A recurring theme throughout the consultation was the need for practical guidance explaining how STAIRs will operate in practice and how it differs from the Ombudsman's traditional complaints jurisdiction.

Stakeholders expressed concern that tenants and landlords could struggle to distinguish between:

• service complaints;
• data protection requests;
• Freedom of Information-style requests; and
• STAIRs information requests.

The Ombudsman accepted this feedback and committed to publishing additional resources and learning materials before implementation, including their internal STAIRs guidance. The Ombudsman also referenced the good practice guidance published by Anthony Collins and the National Housing Federation.

2. Clarification of remedies

Respondents also sought greater information regarding the remedies that may be available following a successful STAIRs complaint.

The Ombudsman indicated that STAIRs cases are likely to focus primarily on non-financial remedies, such as:

• apologies;
• clearer explanations;
• disclosure of information; and
• improvements to information handling processes.

The consultation response stresses that compensation will not be punitive and that guidance on remedies will be developed as experience under the regime grows. 

3. Relationship with the Regulator of Social Housing

Some consultees raised questions regarding how STAIRs complaints might interact with the Regulator of Social Housing's oversight role.

The Ombudsman acknowledged these concerns and noted that referrals to the Regulator may be appropriate where complaints reveal broader systemic issues. This reflects the increasingly integrated approach being adopted across the social housing regulatory framework. 

Implications for housing providers

For housing associations, STAIRs represents more than a new complaints process. The regime will require organisations to strengthen records management, information governance, tenant communications and disclosure processes.

In announcing the revised Scheme, Housing Ombudsman Richard Blakeway emphasised that weaknesses in record-keeping are a recurring feature of Ombudsman investigations and suggested that STAIRs could help drive a stronger data culture throughout the sector. 

Providers should therefore use the period before October 2026 to review policies, establish procedures for handling information requests and ensure that staff understand the distinction between STAIRs requests and existing complaint or data protection processes. 

For further information or support for your organisation in implementing STAIRs please visit our dedicated STAIRs website hub or contact me.