Registered social landlords (RSL) sector risk: update

1.1 This paper provides a six-month update to the Sector Risk Overview published in April 2026. It summarises the main developments since publication that may affect the risk profile of the Registered Social Landlord sector. Risks not covered in this update remain as described in the April 2026 Sector Risk Overview. A full update will be published in April 2027.

2.1 Political change (updates paragraph 2.1 of the April 2026 SRO)

Following the Senedd elections in May 2026, a new Welsh Government was formed. Its First 100 Days plan and Programme for Government included the following actions relevant to RSLs:

a. Establish Unnos – a new national development body and social housing enabler that will work closely with local authorities and housing associations to assemble land and secure finance for social housing

b. Begin the work of legislating for a Right to Adequate Housing

c. Outline proposals on making renting in Wales fairer

d. Review the existing Warm Homes Programme, and work to introduce changes so that we can go further and faster on improving home energy efficiency – raising living standards, tackling fuel poverty, and reducing carbon emissions for more households, more quickly

e. Examine options for reducing the complexity and bureaucracy of planning processes and extending permitted development rights, including for community-led housing and household renewables

f. Work with local authorities and other regional partners to develop a new National Development Framework that meets Wales’s needs, empowers local government and reduces costs, bureaucracy and duplication.

g. Work with local authorities to review the effectiveness of existing measures on second homes and holiday lets and assess what further action is needed to help young people remain in their communities and to promote the Welsh language and culture.

RSL boards should monitor these developments and consider their potential implications for corporate strategies, development programmes, financial plans and operational capacity.

3.1 Sources of funding (addendum to section 6.3 of the April 2026 SRO)

RSLs may have the option of entering into sustainability-linked loans, in which the lender will offer a discount on the cost of the loan provided that the borrower achieves specific social and/or environmental goals to be agreed between the two parties. In deciding whether to pursue this option, boards should take into account the cost of verifying that the agreed goals have been achieved and the potential reputational damage if they are not, as well as the cost savings from a lower interest rate.

4.1 The planning system (addendum to section 11.3 of the April 2026 SRO)

A consultation is under way on changes to the National Development Framework, whose remit includes the amount, types and location of new housing, as well as the integration of housing with regeneration, transport, economic growth and infrastructure. The consultation runs until 20^th November.

4.2 Nutrient neutrality requirements (addendum to section 11.3 of the April 2026 SRO)

The Welsh Government has published guidance and case studies to assist councils to progress Local Development Plans and to determine planning applications in areas affected by these issues. A mitigation handbook for developers has also been developed by the affected local authorities.

4.3 Strategy (addendum to section 11.5 of the April 2026 SRO)

In setting their development strategies, RSLs should take into account that the government has amended the basis of its target of 20,000 affordable homes by 2030 so that this includes only homes for social rent and intermediate rent where affordability is secured in perpetuity.

5.1 Landlord health and safety (addendum to section 12.1 of the April 2026 SRO)

The Building Safety (Wales) Act has now passed into law. It establishes a new building safety regime in Wales, regulating the assessment and ongoing management of building safety risks during the occupation phase of multi-occupied residential buildings. An overview of the Building Safety (Wales) Act 2026 can be found here. A phased timetable has been set out for compliance, with registration for buildings over 18m in height or at least 7 storeys opening in December 2027.

5.2 Lettings (addendum to Section 13.4 of the April 2026 SRO)

The Homelessness and Social Housing Allocation (Wales) Act has now passed into law. Unless a statutory exception applies, RSLs may only make an offer of their accommodation in line with Part 6 of the Housing Act 1996 (an offer of social housing) to people on the common housing register maintained by the local authority. Councils will also be able to request that an RSL makes an offer of suitable accommodation to a named applicant owed the final homelessness duty. Local authorities will also be required to prepare and maintain Prevention, Support and Accommodation Plans for all applicants the authority considers it owes a duty to under Part 2 of the Housing (Wales) Act 2014, and the measures taken by RSLs to support these tenants and maintain the tenancy should be aligned with these. RSLs should prepare for the implementation of these requirements.