Summary: Mrs B complained about the Council closing her housing applications. We find that the Council failed to clearly explain which documents she needed to provide with her applications. This caused Mrs B avoidable frustration and inconvenience and delayed her ability to join the housing register. The Council has since changed its procedures, assessed Mrs B’s application and offered her compensation. We do not consider any further remedy is necessary.

The complaint

1. Mrs B complains that the Council keeps closing her housing applications as incomplete, despite her providing all the required information. She says the Council’s failings have caused her unnecessary frustration and distress and have prevented her from joining the Council’s housing register.

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The Ombudsman’s role and powers

2. We investigate complaints about ‘maladministration’ and ‘service failure’. In this statement, I have used the word fault to refer to these. We must also consider whether any fault has had an adverse impact on the person making the complaint. I refer to this as ‘injustice’. If there has been fault which has caused significant injustice, or that could cause injustice to others in the future we may suggest a remedy. (Local Government Act 1974, sections 26(1) and 26A(1), as amended)
3. If we are satisfied with an organisation’s actions or proposed actions, we can complete our investigation and issue a decision statement. (Local Government Act 1974, section 30(1B) and 34H(1), as amended)

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What I have and have not investigated

4. I have investigated how the Council handled the housing applications Mrs B submitted between October 2024 and January 2025. I have not investigated how the Council handled any applications she submitted after she complained to us in March 2025.

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How I considered this complaint

5. I considered evidence provided by Mrs B and the Council as well as relevant law, policy and guidance.
6. Mrs B and the Council have had the opportunity to comment on my draft decision. I considered any comments before making a final decision.

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What I found

Housing allocations

7. Every local housing authority must publish an allocation scheme that sets out how it prioritises applicants, and its procedures for allocating housing. All allocations must be made in strict accordance with the published scheme. (Housing Act 1996, section 166A(1) & (14))
8. Every application made to a local housing authority for an allocation of housing accommodation shall (if made in accordance with the procedural requirements of the authority’s allocation scheme) be considered by the authority. In considering applications, authorities must ascertain:
• if an applicant is eligible for an allocation of accommodation, and
• if he or she qualifies for an allocation of accommodation. (Allocation of accommodation: guidance for local housing authorities in England, paragraph 3.2 and Housing Act 1996, section 166(3))
9. Applicants have the right to request a review of a decision that they are ineligible for an allocation, or that they are not a qualifying person. (Housing Act 1996, section 160ZA(9) and section 166A(9))
10. Paragraph 2.2.3 of the Council’s housing allocation scheme says:

“In addition to the application, the following documents (where available) must be submitted as evidence, via the Scheme website to verify the information provided by the main applicant, plus any other person who might reside with the applicant who might wish to become a joint tenant:

1. Passport, to help determine eligibility to rent social housing in England.
2. A utility or Council Tax bill from the past three months, to help determine eligibility to rent social housing in England.
3. Birth certificate, to help determine qualification to join the Scheme.
4. Details of any relevant unspent convictions, to help determine qualification to join the Scheme.
5. All financial records from the past three months relating to income and savings, to help determine qualification to join the Scheme.
6. All legal records relating to property ownership to help determine qualification to join the Scheme.
7. Any other information that helps to determine eligibility to rent social housing in England, qualification to join the Scheme or making a community contribution.”
1. The scheme places applicants in a priority band from Band A (highest priority) to Band D (lowest priority). Applicants whose circumstances do not warrant inclusion in any of the bands are considered to have no housing need and do not qualify to join the housing register.

Key events

12. Mrs B applied to join the housing register in October 2024 because she wanted to move out of her husband’s home, with her children. The application form outlined the required supporting documents, such as proof of identity, address, and financial records. Mrs B submitted several documents to support her application.
13. At around the same time, Mrs B moved, with her children, to a privately rented property. She says that she is struggling to afford the accommodation and would like to move into social housing.
14. In December 2024, the Council wrote to Mrs B to tell her that it had closed her housing application because it was incomplete. The letter stated that she needed to provide the documents listed on the application form and then reapply. It did not specify which of those documents she had not provided.
15. In December 2024, Mrs B submitted another application with additional documents from her new address. The form requires applicants to select from a list to indicate why they need housing. Mrs B selected “none of the above”.
16. When the Council assessed Mrs B’s application in January 2025, it decided that she did not qualify for inclusion in any of the housing priority bands and her application was closed.
17. Mrs B applied to join the register again in January 2025. This time she selected “hardship”, “exceptional circumstances” and “mobility” as her housing needs. She submitted various documents to support her application.
18. In March 2025, the Council decided that Mrs B’s application was incomplete. It again listed all the required supporting documents, highlighting the required financial records in bold type.
19. Mrs B considered she had already provided all the required documents. As the Council’s letter stated that she had no right to request a review of the Council’s decision, she brought her complaint to our office.
20. After we contacted the Council, it offered to reassess Mrs B’s application and backdate her award date if she qualified to join the housing register. It wrote to Mrs B asking her to provide evidence of her exceptional circumstances and to complete a mobility referral form. When Mrs B did not respond, it closed her application.
21. Mrs B applied again in August 2025. The Council commenced its assessment in October and wrote to Mrs B requesting evidence again regarding her need for housing. It also wrote to Mrs B offering £250 as compensation for her inconvenience.

Analysis

22. The Council accepts that, before June 2025, it did not adequately warn applicants that their housing application would be closed if they did not provide all the required documents. It also acknowledges that it did not provide clear information about the financial records it required, or what documents it would accept as proof of address when applicants were unable to supply a utility or council tax bill. For some time, the Council was not providing applicants with clear information about why their applications were considered incomplete, leaving them uncertain about what further evidence they needed to provide.
23. In June 2025, the Council changed its procedures. It no longer closes applications as incomplete when supporting documents are missing. Instead, it writes to applicants specifying which documents are outstanding and asks for them to be provided within ten days.
24. In Mrs B’s case, the Council closed her first application because she had not provided all the required documents, but it did not specify which documents she had not provided. This was fault.
25. When Mrs B next applied, she provided all required documents. But she did not include any housing needs in her application, and so the Council decided that she did not qualify to join the register. The Council properly informed Mrs B of her right to request a review of this decision. I have found no evidence of fault in the way the Council reached its decision to close Mrs B’s application.
26. When the Council assessed the application Mrs B submitted in January 2025, it decided that her application was incomplete because she had not provided three months of financial records. Mrs B had provided three months of records, but they contained her previous address. The Council should have clearly explained why it could not accept the bank statements she submitted. It did not do so; this was fault. If there had been no fault by the Council here, Mrs B would not have been put to the time and trouble of complaining to us and her application would have been properly assessed sooner.
27. The Council has since assessed Mrs B’s application and it has offered to make a payment of £250 for her inconvenience. I do not consider any further remedy is necessary.

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Decision

28. I have completed my investigation and uphold Mrs B’s complaint. There was fault by the Council which caused injustice to Mrs B. The action the Council has already taken is sufficient to remedy that injustice.

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Investigator's decision on behalf of the Ombudsman