Tenant Satisfaction Measures (TSM) 2025/26: Key Data Return Tips

As another financial year draws to a close, the sector’s collective focus shifts to end of year reporting, with a spotlight on compiling and validating annual regulatory returns, including the Tenant Satisfaction Measures (TSMs).

To offer an additional layer of scrutiny and assurance, in this article we will share five top tips and common pitfalls registered providers should guard against, to ensure their submissions are accurate and their data stands up to regulatory validation.

Following the golden thread

As anyone who has followed the recent regulatory C-gradings will have observed, building safety compliance is clearly a central tenet in determining the Regulator’s perspective.

Within the building safety TSMs, providers are asked to specify the number of homes or building spaces which require compliance certification, and the proportion of these which had an up-to-date check at year end.

While on the surface BS01 to BS05 should be the simplest metrics to compile, leaders should also assure themselves of the processes which sit behind this calculation, which can be significantly less straightforward. They should be asking questions such as – how is the organisation ensuring all relevant properties and communal spaces are included in compliance cycles? What is excluded? And on what basis?

The simplest way to ensure all properties are captured, and an approach endorsed by the Regulator, is implementing and embedding a golden thread of record keeping for each individual home and asset. Starting with the Asset Register, registered providers should document which homes or assets are excluded from each compliance cycle and on what basis. Paired with a robust approach to maintaining an up-to-date Asset Register, this “all in” baselining approach ensures nothing is missed in relation to building safety compliance.

TSMs must = Data returns

The TSMs do not exist in a silo. Alongside the TSM submission, registered providers will also be preparing and submitting their annual Statistical Data Return (SDR) / Local Authority Data Return (LADR) to the Regulator at the end of June.

In many organisations, the SDR/LADR and TSM submissions will be led by different data owners, reflecting the largely corporate and finance focused data requirements of the SDR and operationally focused data requirements of the TSMs.

While there is minimal crossover between the two, there are key points the Regulator will cross-validate and expect to be consistent. This includes reporting of Decent Homes Standard failures and exclusions, and the base number of LCHO and LCRA homes the provider owns.

Where multiple data teams are working on compiling the SDR/LADR and TSM returns, collaborating early, cross-scrutinising and agreeing the base figures for these points of commonality can save significant time (or an embarrassing query from the Regulator) later.

KPIs ≠ TSMs

For most registered providers many of the TSM performance metrics will also be reported as part of their ongoing operational Key Performance Indicators (KPIs).

While this demonstrates best practice in relation to ensuring ongoing oversight and facilitating continuous improvement, registered providers must also be mindful that internal KPI definitions may well vary from the regulatory TSM calculation requirements, even for what on the surface may appear to be the same measure.

Take, for example, stage 1 and stage 2 complaint volumes. When reported as a KPI to the Board or Member Responsible for Complaints, to most effectively monitor the total volume of complaints raised, this KPI will likely include complaints raised by all tenure groups, non-customers and external stakeholders. This gives an accurate reflection of the total complaints being received. However, the TSM technical guidance explicitly asks for complaints raised by customers in Low-Cost Home Ownership and Low-Cost Rental Accommodation only, so in this case the TSM volume is a sub-set of the KPI score. The same is true for building safety measures in complex organisations with multiple tenure types owned or managed. While KPIs will likely report compliance across all owned buildings, the TSMs should report LCHO and LCRA compliance only.

When reviewing TSM scores, organisations need to be alive to intentional discrepancies between internal KPIs and TSM technical guidance, and explain these variations when figures are reported for approval to their governing body.

These variations also offer an opportunity to highlight findings of more granular sub-group analysis to leadership; if complaint volumes drop markedly when non-LCRA customer segments are removed, this should raise further assurance questions in relation to the volume of non-LCRA complaints.

You vs You

Much has been written in the sector press already about variations in TSM methodology and the impact this has on the reliability and validity of TSM benchmarking. Whether strategically you pay any credence to benchmarking or not, two things are important to take from it from a scrutiny and assurance standpoint:

Firstly, comparing your organisation’s performance to others, particularly in relation to volume metrics, offers a basic sense check that you are calculating performance accurately. If your volume of completed repairs, ASB cases or complaints are a significant positive or negative outlier, it would be prudent to reflect both on whether you are calculating the metric correctly, and operationally what may be driving this variation so you can offer this explanation to the Board and the Regulator.

Secondly, the Regulator has been clear that while sector comparative performance is interesting, the most salient measure is your own performance trends over time. For this reason, registered providers should expect and prepare for any significant variations in performance (or perception) to be queried on validation or inspection.

Registered providers who have altered aspects of their approach should also fully articulate the rationale for any changes in relation to the gathering and analysis of the perception TSMs in their supporting methodology statement. Wherever possible, methodology, including choices on whether to address representation skew by weighting perception data should be kept as consistent year on year as possible to facilitate accurate tracking of performance shift over time.

The benefit of a different perspective

Building on the point above, while process owners and performance analysts will naturally be the first line of assurance in reviewing and validating TSM data, their operational closeness to the data and agreed operating procedures also makes them most susceptible to not spotting where agreed process varies from technical calculation guidance.

For this reason, where possible we would recommend having an independent individual review the data compilation and calculation process for each of the TSMs. This could involve housing management leads reviewing asset management metrics and vice versa.  It is often in the asking of a seemingly naïve question, that the greatest issues come to light.

At Altair, we have technical experts who can assess our clients’ TSM data prior to submission to provide that added level of external assurance. If your organisation would benefit from support to review and validate your TSM submission, please feel free to get in touch, and Altair would be happy to support and provide advice and assurance.

 

Katy Wilburn, Principal Consultant

Katy.Wilburn@altairltd.co.uk

07308769448