From today, housing associations in England will have to publish more information about how they manage social housing. From April 2027, their tenants will also be able to request information under the new Social Tenant Access to Information Requirements, known as STAIRs.

It is a significant change, but Scotland offers a useful point of comparison. Registered social landlords here have been subject to freedom of information law since November 2019. The two systems are different, but they raise much the same practical question: when someone asks how a home has been managed, can the landlord find a clear and reliable answer?

What happened in Scotland

Scotland extended FOI to registered social landlords and many of their subsidiaries on 11 November 2019. It covers information relating to specified activities, including the management of social housing, the prevention or alleviation of homelessness, and the management of sites for Gypsies and Travellers.

There was a straightforward fairness argument for that change. A council tenant could use FOI to ask about the management of their housing. A housing association tenant could not make the equivalent request to their landlord.

One concern was that landlords would be inundated with requests. A projection based on local authority experience suggested an association might receive 60 to 90 requests a year. The Scottish Information Commissioner’s survey of the first full year found a different picture, 60% of responding landlords received six or fewer requests in 2020, and 95% received 24 or fewer. Most dealt with FOI using their existing staff.

That first year included the COVID pandemic, so those figures are no forecast for England. They do show that the feared flood of requests did not materialise for most of the Scottish respondents.

The harder part is finding the record

The number of requests is only part of the challenge. What matters more is whether the information is complete, accurate and easy to find.

Take a question about damp in one home. The answer might involve the tenant’s original report, photographs, an inspection, the decision about what work was needed, a contractor’s job sheet, correspondence with the tenant and confirmation that the work was completed. Those records may sit in several disparate systems and with more than one organisation.

England’s STAIRs policy covers relevant information held by someone managing social housing on a landlord’s behalf. The landlord must make all reasonable efforts to obtain it when responding to a tenant’s request. Where a contractor manages housing on the landlord’s behalf, the records it holds may therefore be needed to answer a tenant’s request.

And scope matters. Scottish RSLs are subject to FOI for specific activities, but their private factoring services and management of private or mid-market rented accommodation do not fall within that FOI designation. Landlords need to know what they hold, where it is and which access rules apply.

Damp and mould will put the records to the test

This is becoming more immediate in Scotland. From 6 October 2026, new rules require social and private landlords to investigate reports of damp or mould within ten working days, and provide the tenant with a written summary within three working days of completing the investigation.

Where the investigation finds substantial damp or mould, repair work must generally begin within five working days of the investigation concluding. Social landlords must then complete the repair within a maximum of 20 working days from its commencement. The rules also address circumstances beyond a landlord’s control that prevent a deadline being met.

Each stage needs a clear record of when the landlord became aware of the problem, who investigated, what they found, what the tenant was told, and when repairs began and ended. If a tenant complains, the landlord may need to show that it complied or explain, with evidence, why it could not meet a deadline.

A missing record does not prove that the work was not done. It does make it much harder to show what has happened. I have seen how easily that difficulty arises when the landlord holds one part of a job, the contractor holds another, and neither record tells the full story.

The lesson for both sides of the border

Scotland’s experience suggests three sensible steps. Prepare, train, and educate staff to recognise and handle requests. Publish the information tenants are likely to need or request. Above all, record inspections, decisions, communications, and completed work at the time, with a clear link to the home concerned.

England’s new requirements will give tenants a stronger route to ask how their homes are managed. The biggest test may not be how many requests arrive; it will be whether a landlord can give a trustworthy and accurately documented account of what they did.

Transparency isn’t a new burden if your records are sound. It only becomes one when they’re not.