The Social Tenant Access to Information Requirements (STAIRs) is a significant development in the regulatory and risk landscape for social housing in England.
While often discussed as a transparency or tenant rights initiative, STAIRs has much wider implications for governance, assurance, insurance and risk management. For ALARM members, the relevance is immediate. STAIRs exposes how well risk, governance and operational controls stand up to external examination.
At its core, STAIRs is not simply about providing information. STAIRs is about how well organisations can evidence decision-making, service delivery and control. For risk professionals, it introduces a new lens through which organisational resilience, maturity and culture will be tested.
STAIRs impact
STAIRs gives tenants of registered providers new rights to access specific information about how their homes are managed. It is being implemented in two phases under direction of the Regulator of Social Housing.
From October 2026, providers must operate a publication scheme, proactively making certain categories of information available to tenants. These categories are:
- Housing stock management
- Performance
- Spending
- Governance and how decisions are made
- Lists and registers
- Social housing management.
From April 2027, tenants (or their representatives) can submit formal information requests about the management of their homes, which landlords must handle within defined timescales. However, there is no provision for members of the public to make a request under STAIRs.
For local authorities, this mirrors longstanding obligations under the Freedom of Information Act 2000. For many housing associations, however, STAIRs introduces a level of scrutiny and formality that goes well beyond existing engagement or complaints processes.
Transparency as a test of the control environment
From a risk and audit perspective, STAIRs effectively creates a new ‘stress test’ for the control environment. Information disclosed under a publication scheme or in response to a tenant request must be accurate, consistent and defensible. Gaps, inconsistencies or delays are unlikely to be viewed in isolation.
Risk and internal audit teams will recognise the warning signs:
- Policies that exist on paper but are inconsistently applied.
- Performance data that cannot be readily reconciled.
- Decisions that are poorly documented or inadequately governed.
- Complaints or repairs data that exposes systemic weaknesses.
Once information is disclosed it becomes part of an organisation’s evidential trail. Poor transparency can quickly escalate into reputational damage, regulatory concern or increased complaints. These all have downstream impacts on claims experience, insurance discussions and assurance reporting.
The complaints, ombudsman and claims interface
The Housing Ombudsman has explicitly linked information transparency to complaint escalation, noting that many disputes could have been avoided had tenants had earlier access to clear, reliable information. Under STAIRs, disputes about information handling can be taken directly to the Ombudsman.
For insurers and risk managers, this matters. Complaint trends are often leading indicators of:
- Emerging liability risk
- Service failure
- Governance weaknesses
- Cultural issues around openness and accountability.
Where information requests expose delays in repairs, unclear responsibilities or inconsistent service standards, the potential for liability claims, particularly disrepair or health and safety, becomes more visible. STAIRs strengthens the connection between transparency, complaints handling and the organisation’s overall risk profile.
Governance, assurance and board oversight
STAIRs also raises important questions for boards, audit committees and senior leadership teams. Transparency is no longer discretionary; it is a regulated expectation.
Risk and internal audit functions can play a critical role by providing assurance that:
- Information governance arrangements are clearly defined and owned.
- Published information is reviewed, updated and quality assured.
- Decision-making processes are consistently documented.
- Staff are trained to handle information requests lawfully and confidently.
From an assurance perspective, STAIRs is an opportunity to test how effectively governance frameworks operate in practice. Organisations that struggle to evidence decisions or controls may find STAIRs acts as an early signal of deeper resilience issues.
England only – but with a useful comparator
It is important to note that STAIRs applies only in England. In Scotland, housing associations have been subject to the Freedom of Information (Scotland) Act for several years, meaning tenants already have wide access to information.
This provides a helpful comparator for risk professionals. The Scottish experience demonstrates that transparency requirements, when supported by strong governance and assurance arrangements, can become part of normal business practice rather than a regulatory burden.
Action
Although STAIRs does not formally take effect until October 2026, the direction of travel is clear. Tenants, regulators and ombudsmen increasingly expect openness supported by evidence.
For ALARM members, STAIRs reinforces a familiar principle: transparency exposes risk, but it also strengthens resilience. Organisations that understand their data, document their decisions and own their risks are better placed to respond – not just to STAIRs, but to the wider assurance and accountability demands facing social housing.
