EPCs – Historic England Report

Energy performance Certificates are a requirement for all let forms of accommodation. Although the legislation is not specific to almshouses the Association advises that it is best practice for EPCs to be obtained for them as they may well be requested by residents irrespective of whether the charity’s buildings are listed or not. EPCs are valid for 10 years & are required on the appointment of a new resident.

Further guidance can be found in our Standards of Almshouse Management guidance manual, chapter 16 Buildings, Section 16.8 EPCs.

Energy Performance Certificates (EPCs) are the Government’s legislated rating scheme to summarise and report energy performance of buildings. The domestic and non-domestic sectors use different methods in order to assess the energy efficiency of buildings. These case studies in the Historic England report focus on the domestic rented sector.

In 2020 the Government consulted on increasing the Minimum Energy Efficiency Standards (MEES) for privately rented domestic properties from EPC Band E to EPC Band C for new tenancies from 2025 and all tenancies from 2028.

Historic England in conjunction with the MEES working group (National Trust (chair), Historic England, Country Land and Business Association, The Central Association for Agricultural Valuers, The Landmark Trust and other stakeholders) undertook case studies to provide evidence of the issues surrounding EPC assessments for traditionally constructed buildings and identify the barriers to successful improvements to energy efficiency.

The key issues identified were:

  • EPC assessment procedure
  • Fuel types
  • Overall costs
  • Impact on traditional construction

The guidance is intended for architects, surveyors, conservators, other conservation professionals and anyone who is interested in or responsible for the care of buildings.

Please click here to download the report.

posted 20 May 2024


Awaab’s Law update

For those of our members who are Registered Housing Providers you will be aware that the Awaab’s Law consultation closed on 5 March 2024.

Once the outcome of the consultation is announced, any changes will be introduced through secondary legislation. With the Social Housing (Regulation) Bill due to be law by the summer and Awaab’s Law expected to be introduced within six months of that, the changes could be in place by the end of the year.

The Almshouse Association responded to the consultation, with our ‘latest news’ item of 1 March 2024 setting out our key concerns which related to timescales. We are also aware that other organisations such as the National Housing Federation and the Chartered Institute of Housing responded to the consultation with similar concerns.

The inclusion of Awaab’s Law within the Act places a spotlight on the severity of damp and mould as a hazard in social housing. This reinforces the obligations placed on all landlords in the Housing Act 2004 to ensure properties are free from serious hazards, as assessed through the Housing Health and Safety Rating System (HHSRS) – see link.

The Government is proposing that Awaab’s Law will introduce timescales across all 29 HHSRS hazards. The HHSRS, which operates by evaluating the potential risk of harm to an actual or potential occupier, is based on the risk to any particular age group and is a means of rating the danger posed by a health and safety hazard.

To recap, the secondary legislation, once introduced, will require social landlords to fix health hazards, including damp and mould, within what the government has said will be “strict new time limits.” The proposed legal requirements for social landlords, if implemented unchanged following the consultation, will mean that hazards must be investigated within 14 days, fixing the hazard should start within a further seven days, and any emergency repairs should be actioned in 24 hours.

Two of our member charities have recently received support from The Almshouse Association in the form of a loan to help support work to rectify damp and mould issues within their almshouses. Both charities, The Frances Geering Almshouse Charity and The William Holmes Almshouses have kindly provided a case study of the issues that they have encountered and their plans to resolve the issues. They will also provide a further update once the works have been completed. It is good to see that this is already a focus for our members.

Whilst awaiting the outcome of the consultation we would recommend that you start assessing:

  • your capacity to meet the timescales proposed
  • whether your record keeping is adequate
  • whether you have access to contractors or for larger charities skilled team members that can appropriately deal with repairs where required
  • your out of hours (weekend) repairs capacity, as the timescales proposed are calendar days, not working days.

Whilst Awaab’s Law will only apply to Registered Housing Providers, one of the objects of The Almshouse Association is to promote the provision, improvement, upkeep and maintenance of almshouses and associated services and facilities. We would therefore encourage all almshouse charities to take an interest in the provisions of Awaab’s Law whether or not you are a Registered Housing Provider.

We will provide you with a further update once the outcome of the consultation is known.


What is Condensation?

Condensation is the liquification of invisible water vapours present in the air in contact with cold surfaces.

Condensation is often associated with the growth of mould as the tiny liquid droplets (condensation droplets) on the surface provide bacteria the necessary “fuel” to thrive, resulting in mould growth. Condensation and mould growth is a common seasonal problem in Britain, primarily affecting old buildings during the colder winter months between October to April. Condensation is generally not a problem during the warmer summer months.

Condensation occurs when warm humid air comes in contact with cold surfaces, mostly external walls. Water vapours in the air are slowed down near cold surfaces then attracted to them, making vapours to accumulate and liquefy on cold surfaces.

The 2 key variables determining the extent of condensation are:

  1. The surface temperature of the wall fabric: colder walls trap more of the available moisture, causing more condensation.
  2. The indoor humidity: higher internal humidity means more available moisture to liquefy or condense.

Of these two variables, low surface temperatures or cold wall surfaces – usually attributed to insufficient heating – are considered the main cause of condensation. However, this is only half of the story – there is more to it.

In our experience, especially in old buildings with solid walls, the other variable, high indoor humidity, tends to be a more important factor in the formation of condensation – something that is frequently overlooked or misdiagnosed.

To better understand the relation of these two variables and how they impact old buildings, let’s look at them in a bit more detail.

1. Cold Wall Surfaces

External walls can be cooled down by the external environment, leading to condensation problems driven by low temperatures

Condensation and mould in a 1940s building

But which part of the walls is the coldest and thus most susceptible to condensation? Long-term measurements done with embedded micro-sensors, however, revealed an interesting fact: the core of old walls was warmer in wintertime than the surface. Although this might sound counter-intuitive at first sight, it does make sense as old walls also accumulate and store some heat (thermal mass) keeping the core of the walls warmer than the environment. What cools down wall surfaces is the ongoing evaporation, making evaporative wall surfaces susceptible to condensation.

This condensation is common in newer buildings, typically built from the 1930s onward, often with external cement render, internally decorated with modern cement plaster, modern emulsion paint or wallpaper.   

And this leads us to the second variable… high indoor humidity.

2. High Indoor Humidity

What can cause high indoor humidity? In addition to man-made moisture, evaporating damp walls and floors are one of the largest sources of indoor humidity in old buildings. How much water can old walls absorb from the ground, store and evaporate out? Lots! These calculations from a British scientific research paper will give you an idea.

Those solid walls standing on the damp soil connected to the water table are constantly absorbing moisture from the ground (rising damp), then evaporating it out into the internal space. This results in constant high indoor humidity in the building, which condenses on colder wall surfaces. Hence condensation can also occur as a consequence and accompanying phenomenon of rising damp. The lack of a damp proof course makes old buildings susceptible to rising damp, resulting in (secondary) condensation as a result of high indoor humidity.

Condensation in an old listed building due to excess indoor humidity

This condensation can often present in several hundred year-old buildings, which despite being built with lime (breathable) and being “leaky” (not airtight by design), can have very high indoor humidity as a result of rising damp. This effect of rising damp – high vapour content indoors leading to condensation – are often overlooked or misdiagnosed.  

The two leading causes of condensation – cold walls and high indoor humidity – can overlap and be present at the same time and both contribute to condensation problems – so good diagnosis is essential for the full resolution of the problem.

Diagnosing Condensation Problems

When diagnosing condensation and mould problems it is important to do both temperature and humidity measurements on the property to establish whether the condensation is primarily caused by cold walls, high indoor humidity or both. High indoor humidity can indicate the presence of some underlying hidden moisture source in the building, this can be rising damp, complete lack of ventilation or something else – there is always a cause behind it that needs to be found.

Dehumidifier in an old farm building extracting a lot of moisture on a daily basis

Just installing robotically some extra ventilation in the building to lower the high humidity won’t necessarily solve the problem and without understanding hat’s going on it’s poor practice.  

Here is a simple test one can do to diagnose the problem. Run a dehumidifier in the building or in the affected room(s). If the dehumidifier consistently extracts large amounts of water from the air – typically half litre or more per day – that’s a strong indication that there is a hidden moisture source present somewhere in the building that keeps generating the excess humidity the dehumidifier collects.

Professional humidity measurement showing very high indoor absolute humidity – 11.21 g/m3 

Additional tests can be done by taking absolute humidity readings:, this usually require specialist instrumentation. One often finds that when a hidden moisture source is present in the building, the absolute moisture inside the building is higher than outside. This, in plain English means that there is higher humidity inside the building than outside; or the air inside the building is more saturated than outside. This is not a good thing.

The differences between the absolute and relative humidity is explained in detail here

Solving Condensation Problems

Although the theory behind why condensation occurs is simple, solving it or eradicating it can sometimes be more complicated. One is generally recommended to start with simpler actions and gradually progresses towards more complex interventions until the problem is eliminated. Some of these simpler actions one can take can be:

  • Improving the ventilation of local areas by pulling the furniture awa from the walls.
  • Improving the general ventilation of the building by opening the trickle vents
  • Improving the heating in the building

If these do not resolve the problem, more complex actions are required that need professional help. Some of these can include:


Flooding and extreme weather

With warmer and wetter winters expected together with more extreme events such as heavy rainfall, the UK is seeing more flooding events like the recent Storm Henk in January.

We would, therefore, urge members to review and update their Disaster Recovery Plan which includes an Emergency Plan, Evacuation Procedure and Recovery Plan. 

A template is available on The Almshouse Association website in Model Policies and Templates here.

To assist this, we have outlined below some recommended information websites for identifying flood risk areas, actions to take before, during and after flooding, together with measures that could be taken to mitigate the impact of future floods.

If you are in a flood risk area, you need to establish the Lead Local Authority (usually Unitary or County Council) to contact. 

  • The Environment Agency is responsible for main rivers, reservoirs, estuaries and the sea. 
  • The Canal & River Trust owns our canals and navigable rivers.

Making contact with local businesses, landowners and community groups in affected areas is also sensible. Many local communities at risk of flooding are advised to prepare a resilience plan, which could include vulnerable and older residents. Often the resilience plan has two settings – stand by and activation – as not all flood alerts lead to flooding but it allows residents to be prepared.

Local authorities advise those at risk of flooding to take proactive steps to protect their property, such as flood protection measures or retaining a stock of sand/sandbags. It is also worth noting that if sandbags have been used in a flooded area, they may be contaminated by sewage so should not be retained after use.

In addition to natural flood risks from rivers and the sea, members should also consider what to do in the event of flooding, even outside a flood risk area as the result of a “flash flood” or burst mains water pipe.  Even small water pipes can cause serious damage and require evacuation of residents if left unattended.  Please do review and update your Disaster Recovery Plan to consider Flooding.


Bed bugs

Since the surge of infestations in Paris, concerns of bed bugs have been on the rise. Thankfully, there are steps you can take to stop them being introduced to your home as well as methods to keep the numbers contained should they find their way in.

Note that, in the case of the latter, it can be difficult to get rid of bed bugs yourself and you should you discover them in a resident’s almshouse, you should contact your local council or pest control service.

Preventative measures

1. Mattress cover: But bear in mind that bed bugs can live in all sorts of spaces around your bed, not just your mattress. They can be found in cracks in the walls, in the joints of your furniture and around the carpet’s edge, so more preventive measures are a good idea.

2. Reduce clutter: If your bedroom is full of clutter, you’re providing more places for bugs to hide. Bed bugs prefer to stay out of sight while we’re active, so if there’s boxes or clothes permanently strewn across the floor, you’re supplying additional shelter as well as spaces to lay eggs. Even if your room doesn’t appear obviously cluttered, always check under your bed. If you’ve got cardboard boxes stored here, you’re giving the bed bugs a prime position to hide close to where you sleep.

3. Vacuum, steam and wash: A clean house is just as likely to suffer from a bed bug infestation as a dirty one, but certain chores will reduce their numbers. For instance, regularly vacuuming your floors, furniture and mattress will pick up rogue bed bugs. This won’t kill them though, so you need to empty the canister between each run, carefully, into a sealed plastic bag in the outside bin.

Heat is a well-known method for killing bed bugs, and so a steam cleaner can be a handy investment that can be used on carpets and upholstery around the home, killing any immediate bed bugs in your path. The temperature needs to reach 130°F with a gentle air flow — otherwise you will just blow the bed bugs away.

Washing your bed linens, the bedding itself (pillows included) and any other fabrics on the highest temperature allowed in your washing machines can also kill bed bugs. The wash temperature needs to be at least 140°F for 90 minutes to be effective, followed by drying on the highest temperature allowed for 30 minutes. Keep any infested items sealed in plastic bags until you’re ready to wash them. If the items can’t tolerate a hot wash, steaming them is another option.

4. Take care with textiles: If you know you’ve got bed bugs in your home, you’re going to want to limit their spreading as much as possible while you work on eliminating them. There are several ways bed bugs can travel, but they tend to cling to inanimate fabrics, which is why our suitcases are often hotspots. They won’t usually hang onto the clothes you’re physically wearing because the movement is too aggressive and they’re not a fan of such intense heat. But any inanimate fabrics or those you carry alongside are certainly at risk.  

6. Be vigilant when you travel: It’s all too common to bring bed bugs home with you when you travel, so it’s a worth knowing what to look for when you check into a hotel room. There are several signs of bed bugs including eggshells, shed skins, ink-like spots of faeces and, of course, the bugs themselves. A musty smell may also be present. Inspect the mattress thoroughly, checking cracks, crevices and seams. Check around the headboard as well as any surrounding fabrics too, such as cushions and curtains.  Wash all your clothes when you return from holiday.

7. Seal any cracks and gaps in your walls: If you share a wall with neighbours, bed bugs may well be able to travel between the properties too. This is because they can fit through tiny cracks and gaps and come out the other side, making their way in through light switches as well as power outlets. With this in mind, you may wish to consider caulking and sealing any unnecessary cracks in the walls.

Make sure you don’t bring the bed bugs in with you if you share a communal space too, such as a hallway. Don’t leave items on the floor, and check your shoes and clothes as you enter.


Charity Commission Accounts

Problems encountered with Charity Commission Accounts

We are aware that a number of our members have encountered problems when trying to log onto the Charity Commission website and we have, therefore, been in communication with the Charity Commission in order to ascertain the current position.

We understand that the Charity Commission has recently undertaken an update of their systems which, unfortunately, has led to extensive, temporary problems for charities needing to gain access to file returns, lodge accounts etc.  

We are informed that as matters stand the ‘My Charity Commission Account’ as a service is working and functional, however access to the area for filing for Annual Return 2023 is still under development. This will be launched within the next few weeks, and communications will be sent out when this happens.

It is now necessary for every charity in England and Wales to register for a ‘My Charity Commission Account’ and we understand that charities can contact the Commission in one of the following ways to request access, although there are likely to be considerable waiting times if telephoning which could be as much as 45 minutes:

In the event of a change of email address, it is necessary to request a new link and set up a new account.

It has been confirmed that when contacting the Commission, it is the main listed contact who should get in touch and, if this is not known, a trustee of the charity should telephone who will then be taken through a verification process.  

To reiterate – Filing for Annual Return 2023 is not yet available, though we have been advised that Returns lodged in due course will be backdated.  Filing for Annual Return 2022 and years prior to this are available which must be completed within a Charity Commission account, here: Sign in (charitycommission.gov.uk)

We are conscious that the current situation is causing considerable frustration and can only advise our member almshouse charities that we are assured that the Charity Commission is doing all possible to rectify the position at the earliest opportunity.

posted 20 September 2023


Lithium batteries

Lithium batteries are generally safe and unlikely to fail, but only so long as there are no defects and the batteries are not damaged. When lithium batteries fail to operate safely or are damaged, they may present a fire and/or explosion hazard.

Lithium batteries have found themselves in the news recently – for both good and bad reasons. The increasing use of lithium-ion batteries is due to their ability to store and provide much more energy than other battery types, allowing for longer usage. This has led to a transport revolution, with many people using e-bikes and e-scooters as a greener and more economical form of transportation. Unfortunately, it has also resulted in a frightening increase in particularly dangerous fires.

If overheated – through damage, flawed design, or the use of substandard chargers – lithium-ion batteries can create fierce fires that are not only difficult to extinguish but also release toxic gas. These fires can occur when just one cell of the battery overheats, creating a domino effect or “thermal runaway”, with a fire developing within seconds that can reach a temperature exceeding 600 degrees Celsius.

Steve Sitch, Chief Executive of Exeter Homes Trust has kindly shared with members their Fire Safety Bulletin on the topic of Lithium batteries. Trustees and clerks may want to share similar advice with their residents.

posted 14 September 23


Government announces extra £50M home adaptation funding

On 7 September 2023, the Government announced an extra £50M home adaptation fund will be provided to local authorities in England so they can make quicker home adaptations for older people or those with disabilities, ensuring they can stay independent.

  • Additional funding to help older and disabled people live more independently in their own homes
  • £50 million to be provided this year to adapt people’s homes
  • Overall, adaptation grants support 50,000 people a year and help people to be discharged from hospital quicker, cutting waiting times.

In order to be able to apply for a grant:

  • Eligibility – Someone living in the house must be
    • (a) disabled
    • (b) intend to live there for the grant period (usually 5 years but can be shorter if, for example, they are terminally ill).
  • Application must be submitted by either
    • (a) owner
    • (b) tenant
    • (c) landlord
  • Council needs to be satisfied the work is
    • (a) necessary and appropriate to meet disabled person’s needs AND
    • (b) reasonable and can be done, depending on age and condition of the property (c) the work should be completed within 12 months of the grant being approved.
  • Planning and Building regulations approval is required separately and the Council may ask applicants to employ a qualified architect to plan and oversee the work.  If you get a grant, you can use it towards the cost of their fees.

posted 13 September 2023


Fire doors in almshouses

Fire Doors are crucial in preventing the spread of fire and smoke in buildings.  Responsible persons need to decide on suitable and sufficient measures for the specific types of premises they are responsible for.

For example, further information can be obtained from:

  • The Fire Safety in Specialised Housing Guidance
  • The suite of HM Government Fire Safety Risk Assessment Guidance
  • The Fire Safety Act 2021 clarified that flat entrance doors must be considered in the Fire Risk Assessment mandated by the Fire Safety Order
  • The Fire Safety (England) Regulations 2022 require regular checks to ensure that self-closing devices are working and the fire doors including flat entrance doors are in efficient working order and in good repair. These checks are to ensure that the existing door standard is maintained
  • Responsible Persons, including both building owners (for example freeholders) and other persons having control of the premises (for example managing agents) were required to comply with the regulations from 23 January 2023.

Residents have an important role to play in ensuring that, if there is a fire in their almshouse, the entrance door is an effective barrier to the spread of fire and smoke into the common parts.

Regulation 10 requires that residents are given information that:

  • fire doors should be kept shut when not in use
  • residents or their guests should not tamper with self-closing devices
  • residents should report any fault or damage immediately to the Responsible Person.

The above information must be provided by the Responsible Person to any new resident as soon as reasonably practicable after the resident moves into their flat. The Responsible Person must also remind all residents about this information at periods not exceeding 12 months.

Where a resident wants to alter or change their front door, this should be done with the knowledge and agreement of the Responsible Person to ensure that it does not negatively impact upon the overarching fire risk assessment for the premises.

It is good practice to inspect fire resisting door sets on a six-monthly basis as part of a programme of planned preventive maintenance. Communal fire doors should be inspected more frequently i.e., 3 monthly.  For example, check fire door sets from both sides:

  • Check the operation of the self-closer; door closes fully and tightly in to the rebate
  • Check the door and frame are not damaged
  • No warping of the door that affects its fit in its frame
  • Check intumescent fire and cold smoke seals are intact, serviceable and not overpainted
  • The cold smoke seal should bridge the gap between the door and frame
  • Doors needs to be a good fit within their frames with a maximum of 4mm gaps between the sides and tops of a door and the door frame
  • The gaps at the base of the door should normally be limited to 6mm
  • Check the door frame and leaf are OK, i.e., free of holes left from replacement locks and handles etc.
  • The condition of the fire-resisting glass and glazing system in the door panels, and any associated side or over panels forming part of the door set, retains their ability to resist the spread of fire and smoke
  • No obvious defects in the hinges (for example missing or loose screws), or any other element of the ironmongery (for example ventilation grilles)
  • Letterboxes are firmly closed and not jammed open. Where a letterbox has been fitted to a door that did not previously have one, the resident will need to confirm that the new letterbox is suitable for use in fire-resisting doors and has been fitted by a specialist contractor
  • If there has been any alterations or damage to a door’s glazing apertures or air transfer grille
  • Is there any newly fitted, but inappropriate, door furniture?
  • Have any relevant doors been replaced using non-fire-resisting types? Modern fire doors should display a visible fire resistance rating
  • Where needed, relevant fire door signage is in situ?
  • Although unusual, where a double door is installed, that requires one leaf to close before the other, a door selector may be fitted to ensure that the doors swing closed in the correct order. Where such a selector is fitted, this should be checked to ensure that it is operating correctly.

Where defects are reported, it is important that action is taken within an appropriate timescale and that they are not simply left until the next six/three-monthly inspection.

As mentioned above, the information is provided for guidance purposes only. Responsible persons need to decide on suitable and sufficient measures for the specific types of premises they are responsible for.

Written by Robert Grayson, Fire Risk Assessors & Workplace Safety Ltd, Email: fra.grayson@gmail.com, Company Registration Number 10279766 – England, dated 2 September 2023


MP Briefing

The Association has always encouraged our member almshouse charities, wherever possible, to hold meetings with their local MPs for them to gain an understanding of the issues affecting almshouse charities.

This is something we are especially encouraging at this time as there are a number of regulatory matters that have an adverse effect upon almshouse charities that we are keen to see addressed at both a local and national level.

The issues concerned are set out as follows below and as a download here. We we hope you will find it a helpful briefing note, but please do not hesitate to let us know should you have questions arising.


BRIEFING NOTE:  Regulatory Challenges to The Almshouse Charity Model

THE PURPOSE OF THIS PAPER: The Almshouse Association is seeking for almshouses:

  • to be recognised in the National Planning Policy Framework (NPPF) definition as “affordable housing”
  • to be recognised under the new Community Infrastructure Levy as “affordable housing”
  • to be exempt from new regulation that would challenge the charity structure and spirit of almshouses as embodied in the Social Housing Bill
  • a new appropriate form of regulation fit for small housing charities such as almshouses.

The history and background:  Almshouses, established as a charitable form of social housing in the 10th century, continue to operate as charities providing valuable social housing at a local level, with residents being offered a home based on the terms of the gift of the original benefactor as laid down in the charity’s governing documents.

Almshouse charities today: There are 1,600 almshouse charities operating throughout the UK today providing safe, comfortable homes to some 37,000 people in need. Most almshouses are small communities comprising less than 20 dwellings and while residents live independently, they are also part of a community where there is help and support in the background which may be called upon in times of need.

Almshouses are affordable housing for people in need and often operate within a specified geographical boundary. In some cases, the charities cater for a specified group of people, defined for example by age, sex and, in some instances, those who have been employed in certain industries and are now retired. While the majority of almshouse charities are for older people, the almshouse movement is progressive and there are increasing examples of new charities being established for younger people and families.    

 How almshouse charities operate: Almshouses operate under charity law, are regulated by the Charity Commission and abide by the guidance of The Almshouse Association in its manual, Standards of Almshouse Management (“SAM”)which was produced in conjunction with the Association’s legal advisors, Stone King and in consultation with the Regulator of Social Housing. SAM provides a robust set of standards, processes and procedures, policies and templates that set out legal and good practice examples which are subject to regular review by Stone King.

Almshouse charities also comply with legal obligations such as those required by the Health and Safety regulations, the Trustee Act, the Charities Act and overarching duties such as safeguarding within the Care Act. Almshouse charities are managed and led by voluntary trustees and do not operate under the Landlord and Tenant Act. As opposed to Assured Shorthold Tenancies, almshouse residents, who are beneficiaries of the charity, occupy by way of a licence commonly known as a ‘Letter of Appointment’. 

The Regulator of Social Housing: The 2008 Housing and Regeneration Act established the Regulator of Social Housing. The Act states that Government funding through Homes England (and other funding bodies such as the Greater London Authority) could only be used to support “affordable housing” defined as Regulated Housing such as Housing Associations.

Almshouses are a form of affordable housing and are often the most affordable form of housing available in the area. Residents do not pay rent but pay a Weekly Maintenance Contribution. The majority of almshouses (80%) are not regulated by the Regulator of Social Housing and therefore cannot access the funds made available to other forms of affordable housing unless they become regulated and, as a result, are subject to regulations not always fit for purpose.

Under the NPPF funding can be made available for affordable housing under Section 106. However, as almshouses are not recognised as affordable housing in the current guidance unless they are registered providers with the Regulator of Social Housing, they are not eligible to receive the funding concerned.  

Almshouses that become Regulated Housing Providers (RHPs): The Regulator of Social Housing is designed for organisations holding over 1,000 units but it is a significant fact that 80% of almshouse charities have less than 20 units. The obligations of being an RHP or Regulated Social Landlord can be extensive, time-consuming, and inappropriate. Out of our membership of 1,600 almshouse charities, 264 have opted to become RHPs in order to access Homes England funding.

Not only is regulation an additional burden on trustees but new policies and obligations for RHPs can challenge the charity status of almshouse charities leading to, we believe, a homogenisation of almshouses in order to fit into the social housing model. This can significantly restrict the ability of trustees to fulfil their objectives, can inadvertently widen the objectives of the charity to mirror small housing associations, and can dilute the model of charity which is locally led under defined objectives.  There is a significant risk that this centuries-old, workable, valuable, charity housing model could disappear.

Right to Buy: Almshouses as charities are exempt from the Right to Buy as trustees currently hold the asset on trust in perpetuity.  It is feared that if they fall under the increasing remit of the Regulator of Social Housing, their defence against Right to Buy would be weakened and could leave charities open to being sold.

What is needed: Almshouse charities to be recognised by local government planning departments as being affordable housing and qualified to access support or land under Section 106 (NPPF).

The same recognition is needed in the drafting of the Community Infrastructure Levy.

Almshouses are regulated by the Charity Commission and if a different measure of regulation is to be required in order to access Government funds it should be appropriate to both the scale and structure of these small almshouse charities. Trustees should be allowed to continue to operate under charity law and to fulfil their legal duties and obligations to act in the best interests of their charity and, by definition, their residents.


If you are successful in arranging a meeting with your MP, we would also welcome receiving any feedback.

posted 21 August 23