Property Consents Policy
Policy Control
Policy Owner: Chief Property Officer
Accountable Lead: Director of Asset Management & Procurement
Policy Level: Operational
Policy Reference: AS/008/2025
Link to Strategy: Asset Management Strategy
Version Control:
V1 first draft
Effective from: February 2025 to January 2028
Approved by: Chief Property Officer at Property Services Leadership Team meeting 10 February 2025
Consultation: Voicebox – July 2024, Property Services Leadership team
Equality analysis: Completed January 2025
Next review date: January 2028
Contents
- Policy Statement and Aims - 3
- Scope, Roles and Responsibilities - 3
- Principles - 4
- Application - 5
- Associated documents - 5
- Measurement of Success - 6
1. Policy Statement and Aims
1.1 This policy sets out Curo’s approach to managing customer requests to make alterations to their home and how we will deliver these while acting in line with the tenancy agreement, appropriate legislation and best practice.
1.2 We know customers want to make their home their own which sometimes means making changes to its appearance, layout, facilities and services. When managing such requests, our aims are to:
- 1.2.1 make sure any changes to Curo homes are completed with our knowledge and approval
- 1.2.2 make it easy to request consent for changes
- 1.2.3 make it quicker and simpler to assess consent requests
- 1.2.4 make it clear how and why Curo make decisions on consents
- 1.2.5 make it clear what customer and Curo’s responsibilities are with consents
- 1.2.6 make sure changes to Curo’s homes are safe and completed in line with Curo’s quality standards
- 1.2.7 make sure changes to Curo’s homes are affordable and practical for the current customer, future customers, the lifetime of the home and Curo’s stewardship
- 1.2.8 place a focus on customer experience when developing procedures to underpin this policy
2. Scope, roles and responsibilities
2.1 This Policy applies to customers where their tenancy agreement allows them to request consent or complete alterations and improvements in their home.
2.2 This Policy applies to customers and stakeholders who may want to take on service such as cleaning or grounds maintenance services.
2.3 The Policy does not apply to Aids, Adaptations or DFG (Disabled Facility Grant) works, although consent is required, this is covered by our Aids, Adaptations and DFG policy.
2.4 This Policy does not cover modular homes constructed utilising advanced or modern methods of construction. In all such properties, customers who have the right to alter or improve their home must first request Curo’s consent in writing for all alterations and improvements.
2.5 The Director of Asset Management & Procurement has overall responsibility for the policy and its implementation
2.6 The Strategic Asset Manager, Technical Manager and Contract Business Partner – Assets & Estates are responsible for delivering procedures which ensure the delivery of the policy and its objectives, and for ensuring that these are implemented consistently by the Asset Management team. They will make decisions in response to requests, subject to agreed procedures.
2.7 The Home Improvements and Estates team(s) will implement the procedures and make decisions in response to requests, subject to the Consents Framework detail set out in the Annex and Appendices 1-3.
2.8 The Board and Executive, through the Policy Owner, ensure that the policy delivers Curo’s strategic objectives and reflects corporate values.
2.9 The Accountable Lead is accountable to the Executive for the effective implementation of the policy in Curo, so that the principles are achieved through appropriate team plans and objectives, and procedures which translate the policy objectives into practice.
3. Principles
3.1 Our principles in providing a Property Consent policy are that we should:
3.2 Ensure that the service is easily accessible through a range of communication channels by customers at all appropriate times.
3.3 Meet our legal and contractual obligations.
3.4 Keep our homes safe, healthy, affordable and warm.
3.5 Keep our communal spaces a welcoming place for all who use them.
3.6 Consent will not be unreasonably withheld.
3.7 Where our discretion to approve is referred to in a tenancy or lease then we will give approval, unless we can demonstrate that to do so:
- 3.7.1 Be unsafe for current or future customers and cannot be practically mitigated
- 3.7.2 Be detrimental to the property, the neighbourhood or our ability to manage it.
- 3.7.3 Fail to meet best practice and/or professional standards.
- 3.7.4 Make it harder or limit Curo’s ability to re-let in the future, devalue the property or compromise Curo’s ability to borrow against the asset.
- 3.7.5 Breach Planning constraints or Building Regulations.
- 3.7.6 Invalidate a new build structural warranty, the building insurance or other guarantees, warranties or insurances; OR
- 3.7.7 Where insufficient detail or information (such as quotes, drawings, specifications, etc) is provided to make an informed decision on the safety, professionalism or suitability of the change.
3.8 If a customer has breached their tenancy agreement or lease, we will refuse the consent request until the breach is rectified (i.e. rent arrears has been paid, anti-social behaviour stops, customer allows reasonable access request, etc.) at which point the customer can resubmit their application.
3.9 Provide an inspection service for those areas of work that may require technical input/guidance prior to approval
3.10 Always have a customer focus in our procedures.
3.11 Have regard to the environmental impact of what we do.
3.12 Involve customers in deciding how the service is delivered
4. Application
4.1 Planned improvements that customers would like to complete and that do not require consent from us are set out in Appendix 1.
4.2 Improvements that require consent from us in all cases without exception are set out in Appendix 2.
4.3 Improvements that will not be allowed are set out in Appendix 3.
4.4 For full details on how this Policy is applied, please refer to the Annex.
5. Associated documents
5.1 This policy operates in context of the following key legislation, policies and procedures:
- Relevant Tenancy Agreements.
- Housing Act 1985 Section 97-100
- Regulator of Social Housing, Home and Tenancy Standard
- Relative terms of the Housing Act 1988
- Aids, Adaptations and DFG Policy
- Homes (Fitness for Human Habitation) Act 2018
- Responsive Repairs Policy
- Regulatory Reform (Fire Safety) Order 2005
- Housing Health and Safety Rating System (HHSRS)
- Health and Safety at Work Act etc. 1974 (HASWA)
- Landlord and Tenant Act 1985 (LTA) Housing Act 2004 (HA)
- Building Regulations 2010 (BR)
- Shared Spaces Policy
6. Measurement of Success
6.1 We aim to respond to Consent requests with a decision within 30 working days upon receipt of all necessary documents and subject to requiring access to a customer’s home to undertake a surveyor inspection.
7. Reasonable adjustments
7.1 Colleagues are empowered to make reasonable adjustments based on individual customer needs ensuring equal access to services.
7.2 Colleagues are encouraged to assess each situation thoughtfully and make adjustments where appropriate, considering factors such as accessibility, medical or specific requirements. These adjustments should be made in a way that meets statutory and regulatory requirements, maintains a high standard of service, and supports customers in a fair and respectful manner.
Annex to Property Consents Policy
Curo’s Property Consents policy and guidance
Definition
1.1 The definition of an improvement made by a customer to their home is noted in legislation as:
“…any alteration in, or addition to, a dwelling-house, and includes:
- Any addition to or alteration in landlord’s fixtures and fittings.
- Any addition or alteration connected with the provision of services to the dwelling-house.
- The erection of a wireless or television aerial.
- The carrying out of external decoration.
2.2 The Tenancy Standard of the Regulator of Social Housing (RSH) states that registered providers:
“1.2.2: shall meet all applicable statutory and legal requirements in relation to the form and use of tenancy agreements or terms of occupation.”
2.3 The Home Standard of the RSH states that:
1.1 Quality of accommodation Registered Providers shall:
- Ensure that customers’ homes meet the standard set out in section 5 of the Government’s Decent Homes Guidance one and continue to maintain their homes to at least this standard.
- Meet the standards of design and quality that applied when a home was built, and where required as a condition of the publicly funded financial assistance, if these standards are higher than the Decent Homes Standard.
2.4 Consent will not be unreasonably withheld and will be given in accordance with gas, fire and building regulations where appropriate, that will include reference to:
- Fire Safety Regulations (England) 2022 which requires us to responsibly manage our buildings/assets and to carry out fire risk assessments to develop safe systems of working and is specific to flatted accommodation.
- Housing Health and Safety Rating System (HHSRS) requires us to ensure we manage risk relating to health and safety identified in our homes.
- The Homes (Fitness for Human Habitation) Act 2018 requires us to ensure our homes are provided and maintained in a state of fitness for human habitation and connected purposes.
Requesting Consent
3.1 Customers who have the right to alter or improve their home must request Curo’s consent in writing, stating and/or providing evidence that:
- Planning consent is obtained where needed and evidenced.
- The tradesperson has, and provides, relevant certificates, qualifications and warranty, including adequate public liability certificates, in line with building regulations and British Standards.
- Access must be given for inspection on request.
- A copy of the specification for work, stating materials to be used
3.2 Depending on the proposed works, Curo may require customers to also provide additional information or evidence. This may include things such as structural engineers reports, architects reports or may require Party Wall Notice etc.
3.3 Customers will be signposted to the following portal in order that they can identify if planning permission will be required:
https://www.planningportal.co.uk/
3.4 We will not unreasonably withhold consent and we will ensure the customer has every opportunity to provide the relevant documents and/or meet the requirements to get consent.
3.5 All customer requests for consent will be considered as required. Agreement or refusal of requests will be communicated to the customer following consideration.
3.6 A copy of the Consent Application Form can be found at Appendix 4.
3.7 Where Consent is sought for works that are high in value, Curo may require evidence that the finance or money is available to complete the works in full.
3.8 Where Curo consider that a consent for an alteration requires an asbestos survey, Curo will carry out the survey at no cost to the applicant.
3.9 If the proposed work requires asbestos be removed, Curo will carry out the removal work using their licensed contractors. Curo will also replace any ceilings containing asbestos or boxing around pipes that are removed but will not carry out other work to make good where asbestos containing materials have been removed (e.g. where vinyl floor tiles are taken up).
3.10 If the occupants are required to move out whilst asbestos is removed the applicant will be responsible for all costs associated with moving out. Curo will not be responsible for any delay in work as a result of undertaking a survey or removal of asbestos containing materials.
3.11 The customer will be responsible for the servicing, repairs and maintenance to any improvements made. However, the customer must allow Curo access where we deem it appropriate to adopt the servicing and maintenance of particular equipment e.g. stairlifts installed privately.
Refusal Reasons
4.1 The reasons we will refuse consent include but are not limited to:
- The alteration or improvement is one where we will refuse consent –see Appendix 3.
- The improvement will make the property or any other premises less safe for occupiers to live in.
- The improvement may cause unnecessary increase in costs for us.
- The improvement may affect the price of sale or rent in the future.
- The relevant information has not been provided i.e. building regulations, planning permission noted in section 3.1 above.
- The improvement may affect defects liability on new build properties.
- The proposed tradesperson is insufficiently qualified to complete the work.
- The materials are inferior to the existing fixtures and fittings and they inhibit sound transference to neighbouring properties, especially in flatted accommodation.
- There may be objections from neighbours for the proposed works.
- Maintenance costs for us increase.
- Communal space is no longer accessible for all to use
- Any other requirement that is necessary for the health and safety of our customers, visitors, colleagues or contractors who occupy the property and that maintains the standard of our asset.
4.2 We will confirm the reason for refusing consent in writing, stating what is needed to get consent, unless the alteration or improvement is one where consent will not be given – see Appendix 3.
Retrospective Consent
5.1 We will give retrospective consent where we discover improvements that have been completed without consent and that meet the requirements of the Policy.
5.2 Where consent is not given, the customer will be informed of remedial work that is required to achieve consent and a timescale in which to complete it.
5.3 If the customer is unable or refuses to complete the work, we will complete the work to our operating standard and recharge the customer for the costs.
Leaving the home
6.1 Before a customer leaves the home, and it is found that there are improvements or alterations that have been made without consent, we will inspect the property and may decide to:
- Require the customer to return the property to its former state before leaving; or
- Consider completing the work to return the property to its former state and recharge the full costs and expenses to the outgoing customer
Compensation for Improvements
7.1 We may consider offering customers compensation for the costs of improvements made during the occupancy of their home, after the tenancy ends, only where they have had consent to carry out an improvement or alteration.
7.2 Compensation may be paid to the tenant, successors of a tenancy, or a joint tenant who was present during the improvement and has lived in the home at the end of the joint tenancy/tenancy.
7.3 If there was no consent requested or granted for the improvement, compensation will not be paid.
7.4 Any debts owed to us will be offset prior to final payment of compensation, which will be calculated using the depreciation formula/which will be calculated up to a limit of £3000, noted below.
7.5 The compensation is calculated using an approved formula, set out by The Secure Customers of Local Authorities (Compensation for Improvements) Regulations 1994
7.6 The cost of the improvement, multiplied by the number of years' notional life left, divided by the notional life.
7.7 The notional life is set out in the regulations referred to in 7.5. these are provided in the table at 7.14.
7.8 Example 1: a new kitchen costing the customer £5,000 fitted six years ago.
The notional life for a kitchen is 10 years, so there would be four years' notional life left. We would work out the compensation to be paid like this:
(£5,000 (cost) ÷ 10 (notional life for a kitchen) X 4 (notional life left) = £2,000
There is an upper limit of £3,000 compensation for any one improvement and a lower limit of £50.
7.9 Example 2: a new bathroom costing the customer £4,000 fitted 10 years ago.
The notional life for a bathroom is 12 years, so there would be two years' notional life left. We would work out the compensation to be paid like this:
(£4,000 (cost) ÷ 12 (notional life for a bathroom) X 2 (notional life left) = £667
Customers must submit a request for compensation no earlier than 28 days before the tenancy ends and no later than 14 days after their tenancy ends.
7.10 Notional Life:
Qualifying Improvements and Notional Life
| Qualifying improvement | Notional life (years) |
|---|---|
| Bath or shower | 12 |
| Wash-hand basin | 12 |
| Toilet | 12 |
| Kitchen sink | 10 |
| Storage cupboards in bathroom or kitchen | 10 |
Rechargeable Repairs
8.1 We may recharge the customer for carrying out alterations or improvements in the home where:
- The customer is leaving and did not have consent to carry out the work, and is unable to revert the property to its former state; and/or
- Retrospective permission has been refused for the improvement or alteration they wish to leave behind; and/or,
- The alteration or improvement is a risk to health and safety, where we are required to complete the work urgently; and,
- No access is given to complete inspection and/or works that were pre-arranged. This will be considered as a tenancy breach where no access occurs.
- Any alteration or improvement leads to the damage of neighbouring property
Breach of Tenancy Agreement
9.1 The following will be considered as wilful damage and a breach of tenancy, in accordance with the tenancy agreement:
- Consent has been reasonably refused, and the alteration or improvement has been completed; and/or
- The customer has not put the property back to it’s former state after retrospective permission has been refused, within given timescales; and/or
- Access has been refused for us to complete repairs where any consent was refused.
Tenancy Management - DIY, Willful Damage and No Access
10.1 Where there is evidence of wilful damage from do-it-yourself repairs without consent noted in Appendices 1-3, or there is a health and safety issue, we will consider legal remedies to gain access to the property to mitigate any risks, if the risk is to life and limb.
10.2 Where there is evidence of wilful damage and processes for not unreasonably withholding consent have been exhausted, we may consider legal remedies to repair the damage.
10.3 If there is no access given by the customer, we may consider legal proceedings to gain action to complete repairs for wilful damage, dependent on the nature and severity of the work required.
Appendix 1 – Improvements that do not require consent from us (except where the property is new build and in defects liability period – they are not allowed)
| Internal | External |
|---|---|
| Dishwasher or washing machine installation where space exists and no alterations are needed to plumb one in | Cable TV, telephone or internet – underground installation only or using existing cable |
| Internal non-glass door | Ground anchor (for securing a bike, caravan or similar) |
| Kitchen door in a house (not a flat) – should be a fire door but this is not mandatory | Key safe for care reasons |
| Smart meters | Outside tap |
| Mixer taps | Garden works – non-destructive only (decoration, planting, minor paving) |
| Water meters | Satellite dishes (if not in conservation areas, not currently installed on the building, and compliant with planning requirements) |
| Window restrictors to the ground floor | Hot tub or jacuzzi – 13 amp plug-and-play only (not for indoor use) |
| Internal decoration and repairs due to natural settlement | Hand or grab rails |
| Picture, shelf or mirror hanging | Temporary access ramps |
| Fitted wardrobes | |
| Curtain rails | |
| Fixed mobility aids such as bathroom grab rails | |
| Kitchen door set (including frame) for a house or bungalow | |
| Laminate flooring in any room within a dwelling (house or bungalow only). Must be slip resistant to at least R10 rating |
**may require planning permission - see https://www.planningportal.co.uk/ for all planning permission requirements
Improvements that require permission
The table below lists internal and external improvements that may require permission before work is carried out.
| Internal | External |
|---|---|
| Bathroom upgrades, including electrical fittings | Canopies |
| Dishwasher installation where space exists but alterations are needed to plumb it in | Driveways |
| Electric fire | Electrical fittings (for example: lights, CCTV, car charging points) |
| Electrical fittings (lights, sockets, burglar alarms, wired smoke alarms, CCTV or similar) | Additional lock to front or back door |
| Insulation (excluding loft insulation), subject to review | Garden works involving excavation or major landscaping |
| Kitchen unit adjustments where removing units is necessary to fit a fridge or freezer | Mobility scooter storage |
| Kitchen upgrades, including electrical fittings | New fencing (where none currently exists or replacing what used to exist) |
| Extensions to heating systems (radiators only), subject to agreement | Patio doors where they already exist |
| Showers, including electrical fittings | Cat flaps |
| Motorised accessibility aids (for example bath lifts or stair lifts) | Replacing existing fencing with a different type or height (not like-for-like) |
| Loft conversions | External decoration (house and bungalow only) |
| Sheds – wooden or other non-permanent structures | |
| Sheds – brick-built (demolition only) | |
| Decking | |
| Hot tubs or jacuzzis – 32 amp with electrical supply | |
| Permanent access ramps | |
| Mobility scooter or buggy storage units | |
| Garage alterations (power, lighting, doors or access) | |
| Replacement uPVC windows or doors for houses and bungalows | |
| Electric vehicle charging points | |
| Changes to communal green infrastructure | |
| Communal play equipment |
**may require planning permission - see https://www.planningportal.co.uk/ for all planning permission requirements
Improvements requiring permission (additional items)
The table below lists additional internal and external improvements that may require permission before work is carried out.
| Internal | External |
|---|---|
| Hearth installation or modification | Conservatories |
| Gas central heating installation | Extensions |
| Gas cooker installation where no gas pipe exists in the kitchen | New external doors where none currently exist |
| Glazed internal door set | Front door lock replacement (for example replacing a thumb-turn with an internal key lock where there is a medical requirement) |
| Wood burners or solid fuel fires requiring chimney or flue cleaning, or installation of a new flue | Metal security gates or grills |
| Structural changes to walls, floors, ceilings or joists | Ponds |
| Knocking down or erecting internal walls | Satellite dish for a flat in a building containing four or more flats (planning portal rules apply) |
| Laminate flooring in flats on the first floor or above | Shed – construction of a permanent structure such as brick (or similar) |
| Upgrades to central heating systems | Structural works |
| Loft conversions in flats | Porches |
| Alterations or replacement of flat entrance doors | |
| Conversion of single-skin external store rooms | |
| Lean-to or similar structures attached to the external fabric of the building | |
| Solar photovoltaic (PV) panels or thermal panels | |
| Land acquisition or enclosure (“land grab”) | |
| Paddling or swimming pools in communal spaces |
**may require planning permission - see https://www.planningportal.co.uk/ for all planning permission requirements