Climate and sustainability

The UK has set in law a target to bring all greenhouse gas emissions to net zero by 2050. To achieve this, housing associations need to work in partnership with the government to insulate many of their homes and replace all fossil fuel heating systems with 'clean heat' technologies such as heat pumps and heat networks.

Decarbonising Britain’s homes is not only an essential part of tackling the climate emergency but it also combats fuel poverty, supercharges the economy, creates jobs and cleaner air.

Housing associations want to be at the forefront of decarbonisation, but the sector is facing a huge challenge: how to cut carbon emissions while delivering a major programme of investment to improve the safety and quality of our homes, and build tens of thousands of new ones.

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Latest

Housing associations and heat network regulation

Warm Homes: Social Housing Fund

Net zero under a new government. During this webinar we hear from a range of speakers about the future of net zero under the new government and the implications for housing associations.

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English Housing Survey highlights warm homes challenge. This month, MHCLG published the Energy Report from the most recent English Housing Survey (EHS) of 2023 and gives us a detailed insight into the condition of the nation’s homes and our progress on fuel poverty and decarbonisation.

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How are barriers to retrofitting heritage homes being addressed? An estimated 25% of UK homes have heritage features that may restrict retrofit. This has serious implications for decarbonisation - essential if we’re to achieve the national net zero target.

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The road to net zero for smaller housing associations. The latest updates on the support and funding available for smaller housing associations to reduce their carbon emissions.

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How Abri is using the Social Housing Decarbonisation Fund to improve residents’ homes and reduce their energy bills. Every home in the programme saw its Energy Performance Certificate (EPC) rating increase from EPC D to EPC A or B, the highest ratings for energy efficiency.

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Smart meters can save money for both social residents and landlords. Paying energy bills is a struggle for millions of people in the UK but knowing how much everything costs gives us greater control and oversight of our energy costs. One easy way to do this is to use a smart meter.

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In conversation with the Building Safety Regulator webinar. This webinar is an opportunity to meet key figures from the Building Safety Regulator and learn more about key issues facing the sector.

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Widening the availability of section 71 registered social landlord relief. HMRC has updated its guidance to cover a number of scenarios around section 71.

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The new Chancellor, Jeremy Hunt, announced that the off payroll working (IR35) rules introduced from April 2021 (6 April 2017 for the public sector) are to continue unchanged in a reversal of the proposed repeal announced by the previous Chancellor, Kwasi Kwarteng. On the basis that the rules won’t change, now is a good time to check the level of your compliance with IR35 obligations. Particularly as the HMRC ‘light touch’ approach to penalties for inaccuracies that were not deliberate ended on 5 April 2022, and HMRC is stepping up its compliance activity. Recap on IR35 obligations Under the rules introduced from 6 April 2021, medium or large-sized organisations in the private and third sectors (excluding those that are “wholly overseas”) have the responsibility for deciding whether arrangements with third party intermediaries such as Personal Service Companies (PSC) do in fact represent a disguised employment. Where an arrangement is deemed to be ‘inside IR35’ on the basis that it is a disguised employment, then the fee payer is responsible for operating PAYE/NIC on payments, including employer NIC, and where applicable the apprenticeship levy. The client using the services of the worker operating via an intermediary such as a PSC is also required to meet other obligations. For example, once the client has applied reasonable care and has determined whether the off payroll working rules apply to an engagement, it is required to communicate that decision in the form of a Status Determination Statement (SDS). It is also necessary for the client using the services to offer a status disagreement process to deal with any disputes regarding the SDS and respond within 45 days. Where the client is defined as a small business by the Companies Act 2006, responsibility for assessing the arrangements, and applying IR35 where necessary, will remain with the workers intermediary such as the PSC. Common issues and misunderstandings on off payroll working within the social housing sector Now that the IR35 intermediaries rules have been in place for over 18 months, our tax advisers, RSM, are seeing some recurring issues and misunderstandings within the sector around the rules, including: Obligations with regard to PSC versus obligations with regard to self-employed individuals Whilst employment status tests for workers providing services to a client via their own intermediary such as a PSC are the same as status tests for self-employed workers who are not operating via a PSC, the obligations that you have in relation to each differ and we often see confusion around this. As above, obligations, and risk, in relation to the use of PSCs by a medium or large client apply from 6 April 2021 only, whereas your obligation to determine whether a self-employed worker is genuinely self-employed for tax purposes have been in place for many years under separate rules. Where you are using the services of a PSC, then you are required to confirm your status assessment in a formal SDS and offer a status disagreement process. A formal SDS does not need to be issued when a self-employed individual is working for you, although ou must still assess whether or not they are genuinely self-employed, and you should keep a record of this. If the status of a self-employed worker who is not operating via a PSC is assessed and it is determined that they have the features of employment, then they must be treated as an actual employee for both PAYE/NIC and employment rights purposes. Where a PSC worker is determined as ‘inside IR35’ then they are treated as a ‘deemed employee’ for PAYE/NIC purposes only and do not automatically have employee status for rights such as pension auto-enrolment. Employment status and the Construction Industry Scheme (CIS) Many housing associations engage with off payroll sub-contractors who are paid via the CIS. It is important to emphasise that obligations in relation to assessing employment status and IR35 must be undertaken for sub-contractors as they are for any off-payroll worker. It is only once you have determined that the off-payroll worker is outside IR35/genuinely self employed that you can make payments to them under the CIS. In this respect it is often overlooked that each monthly CIS contractor return requires a declaration to be completed confirming that the employment status of each individual included on the CIS return has been considered and it has been confirmed that they are not in fact an employee or deemed employee. Obligations where workers are sourced via a recruitment agency Much like many other organisations, housing associations often source temporary workers via third parties such as recruitment agencies. In this situation payments are made to the recruitment agency, but it is important to obtain confirmation from the agency on a worker-by-worker basis as to whether or not the worker is subject to PAYE/NIC by the agency. If the recruitment agency is contracting with a worker operating via an intermediary such as a PSC and onwardly providing them, then the housing association as the client (i.e the end user of the worker’s services) has IR35 obligations, unless it is a small business as defined by the Companies Act 2006. Importantly, the housing association must consider the status of the worker and issue a SDS to both the agency that it contracted with and the worker. Failure to meet this obligation can result in the housing association becoming liable for any PAYE/NIC due. Due diligence on the labour supply chain is also important because, outside of IR35, there can be other tax and/or reputational risks if the worker is engaged by a party in the labour supply chain who is not correctly operating PAYE. For example, where the worker is working for a client in the UK, but is engaged by a party in the labour supply chain based outside of the UK who is not operating In summary, for now at least, the off payroll working rules are here to stay and HMRC are stepping up their compliance activity following the end of the ‘light touch’ year for penalties. All housing associations should periodically review their compliance in the high-profile area of employment status. Our tax advisors RSM work with many housing associations and other organisations with regard to their obligations under the off payroll working rules and would be pleased to help with any queries. For an initial discussion please get in touch with David Williams-Richardson. The Chancellor announced that the off payroll working rules introduced from April 2021 are to continue. Now is a good time to check the level of your compliance with IR35 obligations.

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Our guide for housing associations

In this guide, we set out how we can retrofit existing social homes so they are more comfortable, cheaper to live in and emit no carbon. It also sets out the support we’d need from the government to deliver this, and highlights the uncertainties we face.

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Decarbonisation: a guide for housing associations

Our guide for housing associations

Policy and funding

Everything you need to know about the current policy and funding environment updated regularly.

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Practical tools and resources

Here you'll find links to tools and resources to help housing associations with decarbonisation.

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Upcoming events

6 Feb 2025

Online

National Asset Management Network

15 Jul 2025

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National Asset Management Network 15 July 2025

18 Nov 2025

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National Asset Management Network 18 November 2025

24 Feb 2026

Online

National Asset Management Network 24 February 2026

The net zero and decarbonisation newsletter will keep you abreast of the latest and most important developments in decarbonisation and sustainability.

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Help shape this work

The National Asset Management Network is a space for the sector to share practice, insights and policy updates and hear from guest speakers on the issues that matter most to you and is free and open for all NHF members to join.

The Sustainability and Quality Homes Group provides a strategic steer at a national level for our work on decarbonising and managing the quality of housing association homes.