Understanding the Housing Ombudsman’s “Special Investigations” Process

On 30th October 2025, the Housing Ombudsman unveiled an important update to the way it tackles recurring service failures among landlords. The new Special Investigations process is designed to identify and resolve issues earlier, a clear step forward in building greater accountability, transparency, and trust across the housing sector. 

So, what's actually changing? 

The Ombudsman is introducing a tiered system that allows it to step in sooner when patterns of poor performance start to appear.

• Tier 1 is all about collaboration; the Ombudsman works with the landlord, asking for a response plan that sets out how the issues will be fixed.
• If things don’t improve, Tier 2 comes into play, with the Ombudsman taking a more hands-on role and keeping a close eye on progress.
• If problems persist, Tier 3 triggers a full investigation to get to the root cause and produce formal findings and recommendations. 

The biggest shift here is timing. The Ombudsman will no longer wait until problems become serious before acting. Instead, interventions will be based on real-time data and early warning signs. The process will also involve closer collaboration with other regulators including the Regulator of Social Housing and the Building Safety Regulator to make sure oversight is joined up and consistent. Some landlords have already gone through the first stage of this new process, helping to shape how it will work in practice. 

For residents, this is a really positive step. It means recurring problems like damp and mould, slow repairs, or poor complaint-handling are more likely to be recognised and dealt with earlier. The Ombudsman has been clear that complaints shouldn’t be seen as a nuisance; they’re opportunities to learn, improve, and build better services. 

For landlords and housing providers, the message is just as strong. This new approach calls for greater self-awareness, transparency, and proactive management. Providers will need to keep a close eye on their own performance data, spot emerging trends, and act before being prompted to do so. When the Ombudsman raises concerns, organisations will be expected to respond quickly and confidently with robust improvement plans, clear governance, and evidence of learning. Those that don’t risk escalation through the tiers, and ultimately, greater public scrutiny. 

This change isn’t just procedural, it’s cultural. It signals a move away from reactive complaint-handling towards prevention, insight, and continuous improvement. Complaints can no longer be treated as one-off incidents. Instead, they should be seen as signs of deeper issues that deserve real attention. 

Now is the perfect time for landlords to take stock. Reviewing performance data, strengthening complaint-handling processes, and putting clear response plans in place are all smart moves. Leadership and governance also need to be part of the solution embedding oversight and accountability at the very top. And above all, keeping open and honest communication with residents will be key to rebuilding and maintaining trust. 

The new Special Investigations process is much more than a technical update. It’s a signal of where the sector is heading, towards a culture that values openness, accountability, and genuine improvement. For organisations already striving to deliver great outcomes for residents, this is an opportunity to demonstrate leadership. For others, it’s a timely reminder to act before problems grow. 

At Pennington Choices, our consultancy team works with housing providers every day to help them prepare for regulatory change, strengthen complaint-handling, and embed a culture of learning and accountability. We can help you review your current approach, identify areas for improvement, and create practical, evidence-based action plans that align with the Ombudsman’s expectations. 

If you’d like to talk about how we can support your organisation in getting ready for these changes, we’d love to help. Reach out to get in touch with our team of experts.