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For housing providers, transparency is about to become an even more important part of the relationship between landlords and tenants.
From 1 October 2026, private registered providers of social housing in England will begin to face new requirements under the Social Tenant Access to Information Requirements, or STAIRs.
The new requirements are intended to give housing association tenants broadly similar access to information about the management of their homes as local authority tenants already have through the Freedom of Information Act.
But for housing providers, STAIRs isn’t simply another regulatory requirement to add to the list. It raises important questions about how organisations create, store, manage, retrieve and disclose information – and how STAIRs will operate alongside existing data protection responsibilities.
What is changing?
STAIRs is being introduced in two stages.
From 1 October 2026, private registered providers will be required to proactively publish certain information relating to the management of their social housing.
This includes information across areas such as governance and decision-making, spending and finances, housing stock management, repairs and maintenance, and services provided to tenants.
The second stage comes into effect from 1 April 2027, when tenants – or a representative they have designated – will be able to request relevant information relating to the management of their housing.
Importantly, tenants will not need to specifically state that they are making a request under STAIRs for it to qualify. Providers will therefore need processes that enable staff to recognise when a communication should be treated as an information request.
STAIRs, SARs and information rights
For organisations already accustomed to dealing with Subject Access Requests (SARs), some aspects of STAIRs may feel familiar.
Both require organisations to understand what information they hold, locate it efficiently and make informed decisions about what can appropriately be disclosed.
But they are not the same.
A SAR gives an individual rights over their personal data under data protection legislation. STAIRs provides tenants with access to certain information about the management of their social housing.
A request could potentially engage both regimes, depending on what information is being sought.
This is where preparation becomes particularly important.
Housing providers will need to ensure that staff can identify what type of request they have received, understand which rules apply and recognise where data protection considerations affect what can be disclosed.
STAIRs does not override existing statutory responsibilities, including those under data protection legislation.
Data protection still matters when information is being disclosed
Greater transparency does not mean that every piece of information an organisation holds should automatically be released.
Information requested under STAIRs could contain personal information relating to other tenants, employees, contractors or other individuals.
Providers will therefore need robust processes for reviewing information before disclosure, identifying personal data and considering whether information should be redacted or withheld.
This creates an important balancing act.
Organisations need to embrace the greater transparency STAIRs is designed to achieve while continuing to protect the privacy rights of individuals whose information they hold.
Getting that balance right requires more than simply creating a new policy.
Your suppliers matter too
One particularly important aspect of STAIRs is that relevant information may not always sit within the housing provider itself.
Where information is held by another person or organisation responsible for managing social housing on the provider’s behalf, providers will be expected to use all reasonable endeavours to obtain that information so they can fulfil a valid request.
That makes supplier and information governance increasingly interconnected.
Housing providers should understand what information their contractors and service providers hold, where it is stored and how quickly it can be retrieved.
Waiting until the first request arrives to discover that essential information is sitting in a supplier’s system – and is difficult to extract – could create unnecessary pressure.
Why CEOs should be asking questions now
STAIRs should not be viewed solely as a task for data protection, governance or housing management teams. It is fundamentally about organisational transparency and accountability.
For leaders, now is the time to seek assurance that their organisation understands the new requirements and is preparing appropriately.
That means asking questions such as:
- Do we understand what information will need to be proactively published?
- Do we know where relevant information is held across the organisation?
- Do our staff understand the difference between a STAIRs request, a Subject Access Request and other types of information request?
- Can we retrieve relevant information held by contractors and other third parties?
- Do we have appropriate review and redaction processes to protect personal information before disclosure?
- Are responsibilities for receiving, escalating and responding to requests clear?
The first deadline is no longer somewhere in the distant future.
The proactive publication requirements take effect from 1 October 2026, with individual information request requirements following on 1 April 2027.
For housing providers, the coming months provide an opportunity to make sure policies, systems, supplier arrangements and – crucially – people are ready.
Because good information governance isn’t simply about being able to respond when somebody asks a question.
It is about understanding the information your organisation holds, why you hold it, where it sits and how it can be used and shared responsibly.
For organisations that get those foundations right, STAIRs should not simply be another compliance exercise. It can form part of a wider culture of transparency, accountability and trust between housing providers and the people they serve.
Have questions about STAIRs?
If your organisation is preparing for STAIRs and you have questions about how the new requirements interact with data protection, information requests or your existing processes, Hope & May can help.
We work with organisations to make data protection and information governance practical and manageable. If you would like to discuss what STAIRs could mean for your organisation, or how you can prepare for the new requirements, please get in touch with the Hope & May team.