SHROA & regulation
SHROA: where we are, and what comes next.
The government responded to the Supported Housing (Regulatory Oversight) Act consultation in April 2026. In our view the framework is better than it was. But it moves risk onto licence holders, boards and named individuals, and much still depends on guidance, case law and local implementation.
Settled
What has been decided
- A Supported Housing Licence will be required for a Housing Benefit claim in England
- One licence per council area, held by the person managing or in control of the housing, with a schedule of schemes
- No new housing standards, but higher expectations: the National Supported Housing Standards underpin licensing
- A strengthened fit and proper person test covering licence holders, boards and, for vulnerable services, service managers
- Risk-based inspection and graduated enforcement, with exemptions for services regulated elsewhere
Still open
What has not been resolved
- Care, support or supervision has not been reviewed or redefined
- The long-term future of Housing Benefit, and what funds support if it goes
- How licence-holder decisions will interact with exempt accommodation and managed property status
- Detailed guidance on exempt council-run and commissioned services
- Whether there will be pilots, and time to learn from good practice elsewhere
Where the risk now sits
Questions every board should be asking
Our reading of the response suggests these are the decisions that will matter most to providers, landlords and councils over the coming years.
Who should hold the licence?
In agency-managed services the managing agent may hold it. That choice may affect whether schemes are treated as exempt accommodation or managed property, with real revenue consequences.
Would our board pass the fit and proper test?
Potential liability may extend to boards and named individuals. Integrity, competence and experience will all be tested.
Can we evidence management and control?
Councils, and revenues and benefits teams, will want to see who actually manages the housing, and how.
Are our exemptions safe?
“Low support” must not be allowed to become “low cost”. Residents’ needs change, and exemptions may need to be reviewed.
Read more
Our SHROA analysis
We have followed SHROA since before it became law. See everything we have written on it.
SHROA: Progress Made, But the Job Isn’t Finished
No new housing standards, but higher expectations. What the government response settles, and what it leaves open.
What difference did the coproduced SHROA consultation response make?
Mapping the sector’s shared template response, point by point, against the government’s reply.
The Supported Housing (Regulatory Oversight) Act 2023
The Act that set the sector on course for national standards and local licensing.
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