Social Tenant Access to Information (STAIRs): What Housing Associations Need to Know
Introduction
From October 2026, new Social Tenant Access to Information Requirements (STAIRs) will require housing associations in England to proactively publish key housing management data, enhancing transparency and accountability across the sector. By April 2027, tenants will also have a legal right to request a broad range of information, including details on repairs and maintenance, service charges, anti-social behaviour records, and energy efficiency metrics. These requirements, confirmed in a written Parliamentary statement on July 2, 2025, are set to transform how social landlords manage, protect, and share resident data.
For housing associations, these changes have significant data protection and compliance implications. Organisations will need robust data governance, privacy measures, and GDPR-compliant processes to ensure they handle tenant information lawfully and securely. This marks a critical shift for data protection in social housing, demanding enhanced procedures to safeguard sensitive data while providing tenants with greater access and oversight.
What changes, when:
Two phases, two sets of duties:
- Phase 1: Publication Scheme (from 1 October 2026). PRPs must identify what they already hold within specific classes of information, publish it proactively, make tenants aware of where to find it, and review and update the published set on a regular basis. Providers are not required to create new records and can redact where appropriate and reasonable.
- Phase 2: Tenant Information Requests (from 1 April 2027). Tenants or their designated representatives can make written requests for relevant information about the management of social housing. PRPs must acknowledge promptly and respond within 30 calendar days, with limited scope to extend in exceptional circumstances.
The Housing Ombudsman will handle individual disputes about both publication‑scheme issues and information requests; the Regulator of Social Housing will set and oversee standards, including STAIRs compliance.
Empowering Tenants and Enhancing Accountability
These reforms mark a turning point. Tenants will now see beyond their front doors, they’ll access stock condition, health and safety records, budgets, and policy frameworks. This transparency empowers them to query decisions, track response times, and challenge service failings. For the sector, it means a move from discretion to openness, building stronger landlord-tenant trust.
What you must publish (Phase 1)
Under the publication scheme, PRPs publish information they hold across the following classes (examples taken from the Government’s Table 1):
- Governance & decision‑making (e.g., senior staff names/roles; organisational structure; decision‑making processes/policies; how tenant consultation is carried out, plus agendas and minutes).
- Spending (e.g., spending, grants, use of service charge revenue).
- Housing stock management (e.g., plans, maintenance work, progress towards net zero, stock transfers).
- Performance (e.g., inspection outcomes, ratings, Tenant Satisfaction Measures, complaint metrics, health and safety performance/assessments, maintenance activity, number of evictions, media releases, request‑handling data).
- Housing services (descriptions of services, tenant guidance).
- Lists & registers (required by law or related to management of social housing).
- Social housing management policies & strategies.
If a tenant thinks something within scope has not been published, they can complain through your STAIRs review process (you should normally complete reviews within 30 days). If they remain dissatisfied, they can escalate to the Housing Ombudsman.
What tenants can request (Phase 2)
From 1 April 2027, tenants (or a designated representative they nominate in writing) can request relevant information connected to the management of social housing by the PRP, including information held by managing agents acting for the PRP (the PRP must use “all reasonable endeavours” to obtain it). The policy gives examples such as: repairs and condition, estate management and communal areas, rent collection/rates, service charges for shared owners, occupancy rights, anti‑social behaviour, complaints handling and redress, customer communications, health and safety, data handling and privacy, security, stock transfers/mergers/profile, and environmental/energy efficiency information.
Out of scope: matters decided by local councils (e.g., allocations, homelessness) and information on management of property not related to the PRP’s social housing functions. Also out of scope where a separate statutory access route already applies, or if the information was created after the date of the request.
Timelines and format: acknowledge promptly; respond within 30 calendar days; you may extend in exceptional cases (e.g., to consider if withholding is reasonable, or to secure information held by an agent), but you must notify the tenant and explain the reason and the expected response date. Make reasonable efforts to provide information in an accessible format.
Refusing or withholding: the rules and the “reasonableness” test
You can refuse a request only on specific grounds, including where it is reasonable to withhold the information; where you cannot establish the applicant’s identity; where the meaning of the request is unclear; where the information is not relevant information; where responding would exceed 18 hours of staff time; where the request is repeated (including coordinated repeats); or where the request is offensive/abusive.
When applying the reasonableness test, you must have due regard to protections in the Freedom of Information Act 2000, the Data Protection Act, and other relevant statutes, balancing factors for disclosure against the likelihood of harm. Consider third‑party views where relevant. You cannot refuse because of the applicant’s identity, their reasons, or how they might use the data, and it is not reasonable to refuse because disclosure may cause reputational risk to the provider. You are not required to create new records, you must not destroy or manipulate requested information to prevent disclosure, and you may redact where appropriate and reasonable.
If you refuse or delay, you must tell the applicant why and when to expect a response. If they’re unhappy, they can use your review route (normally 30 days), then go to the Housing Ombudsman.
Unpacking the Practical Challenges
STAIRs bring a significant operational impact:
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- Financial Strain: Initial costs are estimated at around £1.8 million in year one. This includes staffing, systems, data processing, and technology upgrades.
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- Overlapping Regulations – Providers already juggle standards ranging from Awaab’s Law to net-zero pledges. The G15 collective stresses the need for clear guidance and proportionate timelines to avoid duplication G15.
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- System Readiness – Publishing data in accessible formats, responding in 30 days, and proactive content management call for a robust digital infrastructure and tenant portals.
Turning Requirement into Opportunity
This isn’t just red tape, it’s a moment for transformation. Here’s how providers can pivot from compliance to advantage:
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- Tenant portals and apps: Allow easy access to maintenance logs, inspection outcomes and service performance, boosting engagement and reducing repetitive data requests.
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- Publish once, use often: Build a publication scheme; regularly publish approved content to reduce repetitive information requests and staff burden.
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- Smart automation: Use workflows that flag tenant requests, assign case handlers, and track deadlines—reducing admin effort.
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- Training and culture: Staff need clear standard operating procedures and training to manage expectations and data quality.
Balancing Transparency and Affordability
Concerns are real with 40% of tenants expecting cost recovery via rent increases. Pathways to balance this include: phased investment plans, seeking government funding, shared tech development across housing groups, and using operational gains to justify investment.
Our take & expectations moving forward
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Scope extends to Wales. The policy statement and consultation outcome are framed around PRPs in England; whilst there’s is currently no indication in these documents of extension to Wales, we believe that this will change to ensure consistency and a level playing field across the sector (except for Arms Length Management Organisations and Scottish Housing associations) who themselves are subject to Freedom of Information Requests.
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“Regular updates” will need a pragmatic cadence. The policy requires providers to review and update publication content “on a regular basis” but does not set a fixed frequency. Expect sector practice to converge on pragmatic cycles (e.g., quarterly for performance packs; ad hoc for policies when changed), potentially informed by future good‑practice notes from the Housing Ombudsman or Regulator.
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Templates will matter more than tools. The policy doesn’t mandate a portal or format: only accessible disclosure and reasonable assistance to applicants. In our experience, clear templates (acknowledgements, clarifications, refusal notices, redaction rationales) reduce friction and keep responses inside 30 days.
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The 18‑hour limit demands early scoping. Because requests that would exceed 18 hours can be refused, early clarification (helping applicants make “a clear and valid request”) is essential. Expect to see pre‑response scoping steps become normalised to keep requests within workable bounds.
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Evidence discipline will be key for Ombudsman escalation. The Ombudsman will take STAIRs cases directly. Providers that keep decision logs, reference the reasonableness test correctly, and signpost the review/Ombudsman routes in their letters will be better placed in any dispute.
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FOIA/Data Protection balancing needs repeatable patterns. The policy anchors withholding/redaction in FOIA and Data Protection protections. We expect sector patterns (e.g., typical redactions for third‑party personal data, security‑sensitive material) to settle as internal precedents so decisions are consistent and defensible.
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Further guidance is likely but plan to the letter of the policy now. Government has directed the Regulator to introduce the STAIRs standard, with rollout dates fixed. While additional guidance may come, the safest path is to align delivery precisely to the policy statement’s requirements and dates.
Final Take
STAIRs mark a pivot-point for social housing governance: tenants gain a right to information and providers face a mandate for transparency. The core challenge is operational: balancing trust-building and tenant empowerment with financial and technical readiness.
Yet, this is more than compliance, it’s an opportunity. When providers lean into STAIRs, invest in digital systems, and build a culture of openness, they can enhance tenant trust and efficiency. Done right, STAIRs could become the foundation for a more sustainable and accountable social housing sector.
If you would like to learn more about how GRC Hub can ensure you are ready for the STAIRs requirements or would like help or guidance with Data Protection for the Social Tenant Access to Information Requirements, contact GRC Hub on 0113 532 7830, or view our Governance Risk & Compliance Services and information on GRC Hubs STAIRs readiness assessment and recent case study