Strengthening Leaseholder Protections over Charges and Services

The consultation sets out proposals to improve transparency, accountability and fairness in leasehold management.

The consultation forms part of a wider programme of leasehold reform aimed at addressing long-standing concerns around service charges, building insurance, access to information, and the professional standards of managing agents.

The proposals include new requirements for landlords and managing agents to provide standardised service charge demand forms and annual reports, enhanced rights for leaseholders to request information, and mandatory qualifications for property managers.

The Government also seeks to simplify the major works consultation process and improve the handling of litigation costs.

Stonewater, as a landlord and freeholder of leasehold properties, supports the overall ambition to improve leaseholder confidence and ensure greater consistency across the sector.

However, our response highlights the need for flexibility, realistic implementation timelines, and recognition of the operational challenges faced by housing providers.

What did we call for?

Supporting transparency with practical safeguards

• We welcomed proposals to standardise service charge demand forms and annual reports, and agreed that leaseholders should have access to clear, consistent financial information. However, we cautioned that the volume of new data required - particularly in the first year - would be resource-intensive and require significant system changes.
• We supported the introduction of reserve funds and Asset Management Plans (AMPs) for new leases but called for flexibility in applying these requirements to existing leases and schemes where surveys are not yet in place.

Concerns around cost recovery and exemptions

• We raised concerns about proposals to cap cost recovery if works are delayed or exceed initial estimates. As a not-for-profit landlord, we emphasised that full cost recovery is essential to maintain financial viability and continue investing in homes and services.
• We also called for exemptions in cases where landlords are not the managing agent or have recently acquired stock and highlighted the need for flexibility in responding to leaseholder information requests, particularly where high volumes of requests could impact service delivery.

 Building insurance and conflict of interest

• Stonewater supported proposals to improve transparency around building insurance, including the declaration of conflicts of interest and commissions.
• We agreed that landlords should provide insurance information in a standardised format, with flexibility to add context where needed.
• We also supported the use of email for delivering insurance documents, with safeguards such as read receipts and follow-up communications to ensure delivery.

Qualifications and enforcement

• We backed proposals to introduce mandatory qualifications for managing agents, with Level 4 as the minimum standard for most roles.
• We also supported the idea of continuous professional development (CPD) and recognised the need to accommodate neurodiversity in qualification pathways.
• However, we expressed concern about relying on local authorities for enforcement, given well-documented resource constraints. We recommended a more consistent national approach to avoid a patchwork of outcomes across the country.

Holly Edwards, Customer Experience Director – Income, Lettings and Commercial Services at Stonewater, said: We fully support the ambition to improve transparency and empower leaseholders with better information.

“But the scale of change proposed in this consultation is significant. Providers of affordable homes like Stonewater operate across hundreds of schemes, and implementing these reforms will require new systems, staff training and careful planning.

“We want to work with Government to ensure these changes are introduced in a way that’s proportionate, achievable and doesn’t divert resources from other vital services.”