Tenancy fraud policy

Version 1.0 Last reviewed: July 2026

1. Scope

2. Purpose and objectives

3. Policy statement

4. Definitions

5. Policy

6. Contacting SNG

7. Complaints

8. Compliance

9. Sustainability

10. Responsibilities

11. Equality, diversity and inclusion

12. Related documents

13. Legislation and regulation

14. Review

1 - Scope

This policy applies to all tenants and any other person who occupies, controls, seeks to obtain or derives a benefit from living in homes managed by Sovereign Network Group (SNG). It outlines the steps we take to prevent, identify, investigate and take action against tenancy fraud, including situations where customers are not occupying their home as their main residence or provided false information during the application process.

All SNG employees, contractors, and stakeholders share responsibility for identifying and reporting suspected fraud.

2 - Purpose and objectives

We are committed to ensuring our homes are allocated fairly and used appropriately by those in genuine housing need. This policy aims to:

Take a consistent and proportionate approach to preventing, identifying and addressing tenancy fraud
Prevent fraudulent activity through the use of robust identification checks and verification tools
Ensure that allegations of tenancy fraud are investigated
Ensure that homes are occupied as a principal residence and used in line with tenancy conditions, except where otherwise agreed
Raise awareness among staff, customers, partners, and the public to report suspected fraud through our website
Work collaboratively with partners and relevant agencies to share information, work together to identify and respond to fraudulent activity
Support appropriate enforcement action, including legal remedies and financial recovery where required
Protect availability of social housing by recovering homes where fraud has occurred.

3 - Policy statement

Tenancy fraud has a significant impact on individuals, communities and the effective use of social housing. It reduces access to affordable housing, increases demand on limited resources and can create safeguarding, financial and community risks.

All actions taken under this policy will be:

Evidence based
Proportionate to the risk and severity of the behaviour
Compliant with relevant legislation and regulatory expectations
Informed by consideration of vulnerability and individual circumstances.

4 - Definitions

Tenancy fraud - Deliberate misrepresentation, concealment or misuse of a tenancy or housing application in order to gain or retain a social housing property to which the individual is not entitled.

This may include but is not limited to:

Using forged documents or false identities
Not using the home as the main/principal residence
Holding multiple tenancies
Unlawful subletting of all or part of the property, including short or long holiday lets
Obtaining a home by deception (e.g. by failing to disclose homeownership or withholding information, supplying false documents, misrepresenting homelessness or local connection)
Fraudulent succession or assignment
Key selling (receiving payment to pass on keys) or unlawful transfer of occupancy
Fraudulent Right to Buy/Right to Acquire applications or mutual exchange applications
Undisclosed lodgers
Failing to notify us of a tenant’s death and death certificate
Adding someone to the tenancy through deception.

National Anti-Fraud Network (NAFN) - National Anti-Fraud Network is a national not-for-profit local authority-run data and intelligence service, providing support to any organisation that has responsibility for managing public funds/assets.

Benefit fraud - Fraudulently claiming benefits or other welfare support (managed by the DWP/local authority).

Unlawful Profit Order (UPO) - A court order requiring repayment of profits gained from unlawful subletting, available under the Prevention of Social Housing Fraud Act 2013.

5 - Policy

SNG takes a structured approach to tenancy fraud, and is focused on:

1) Prevention

2) Identification, investigation and action

Our principles:

We operate a risk-based, proportionate and evidence-led approach to tenancy fraud.
Suspected fraud will be assessed based on both individual and any wider pattern across interactions or services, with risk determining the response.
We will consider vulnerability, disability and individual circumstances at all stages, including where these may impact behaviour or engagement.
Decisions will be clearly recorded, with appropriate audit trails to support actions taken.

5.1. Preventing tenancy fraud

We will take reasonable steps to prevent tenancy fraud through:

Operating robust lettings, mutual exchange, assignment and tenancy succession processes with strict eligibility checks
Verifying the identity of:
- all applicants and household members (for those over 18 years old) at lettings stage
- household members who are over 18 and want to be added to an existing tenancy
- customers, by completing identity checks when a customer rings our customer service centre, when we make a site visit or other key stages of the customer journey
Ensuring clear communication to our customers of their tenancy obligations and consequences of misuse
Working with partners and agencies to deter and reduce fraudulent activity
Maintaining accurate and up to date customer data
Raising awareness among staff, customers, partners, and the public to report suspected fraud through our website
Publicising successful tenancy fraud convictions to our customers in a bid to inform them and deter others.

5.2. Identification and investigation of tenancy fraud

5.2.1 Identification and investigation

SNG will identify and investigate tenancy fraud through:

Publicising how to report tenancy fraud via our website, phone and email
Investigating allegations in a timely, fair and proportionate manner
Utilising reports from customers, communities, colleagues and external partners, which will be investigated sensitively and confidentially
Undertaking unannounced tenancy visits
Data sharing and intelligence gathering in line with legal requirements
Risk-based monitoring and review of tenancy-related information
Proactive and reactive enquiries where concerns are identified. This includes:
- Checking rent accounts showing high arrears, high credits or payments from overseas
- Checking households with no recent contact or access for compliance checks
- Completing welfare checks
- Completing and using NAFN checks and the services of fraud investigators when required
Ensuring our systems are kept up to date with fraud actions taken.

5.2.2 Tackling tenancy fraud

When fraud is identified, SNG will:

Take action to address unauthorised occupation or misuse
Pursue legal remedies, including possession proceedings and recovery of unlawful financial gain, where appropriate
Work with relevant agencies where criminal or wider safeguarding concerns are identified
Ensure that any action taken is evidence based and legally compliant.

Where appropriate, we will also take steps to offer signposting to individuals affected by tenancy fraud in a SNG property.

5.3. Fraud by employees

Suspected tenancy fraud involving employees will be investigated in accordance with relevant internal policies, including our Code of Conduct and Disciplinary Policy.

Employees are required to declare any conflicts of interest in line with organisational requirements. To help prevent fraud, customers who are employees of SNG must include this in their annual declaration.

6 - Contacting SNG

Customers can contact us through the following channels:

Online via our website or customer portal
Email
Telephone
Social media

6.1 Support for customers

We offer a range of support options to meet customer needs:

Online support via our website, including the ability to:
- Adjust text size and page colours
- Summarise content
- Access audio support
- Translate content
Telephone support (weekdays, 8am–6pm):
- London and Herts: 0300 373 3000
- South and West: 0300 5000 926
- Customer Service Advisors can provide information in alternative formats (e.g. translation, audio, large print)

When customers contact us we will listen carefully to understand their needs and provide appropriate support in line with our Vulnerability and Reasonable Adjustments Policy.

Staff involved in tenancy fraud case management will receive appropriate training on vulnerability, reasonable adjustments and policy exceptions to ensure decisions are proportionate, evidence-based and compliant with SNG’s Equality Act duties.

7 - Complaints

Any customer who is dissatisfied with how we have managed their case is able to submit a complaint using our Complaints process. Once our Complaints process has been exhausted, and if the Customer remains dissatisfied, then they can contact the Housing Ombudsman Service, who can consider if we have acted appropriately.

8 - Compliance

Understanding of this policy will be confirmed during induction and reinforced through regular policy refreshers. Managers are responsible for monitoring compliance, including appropriate use of data sharing agreements and addressing any instances of non-adherence promptly and sensitively. Assurance on compliance and the effectiveness of this policy will be reported regularly to relevant governance groups, including the Customer and Neighbourhood Leadership Team (CNLT), Chief Customer Officer Leadership Team (CCOLT), Customer Influence Panel, and/or Executive Board.

We provide quarterly reports on tenancy fraud to the Audit and Risk Committee.

We will monitor the effectiveness of this policy through:

The number and type of tenancy fraud cases identified and investigated
Outcomes, including property recovery and legal action
Financial recovery, including Unlawful Profit Orders
The timeliness and consistency of decision making.

This information will be used to:

Inform service improvement
Identify risks and trends
Provide assurance to governance groups.

9 - Sustainability

At SNG, we recognise the critical importance of sustainability in our operations and services. We are committed to embracing sustainable practices that contribute to environmental protection, social equity, and economic viability.

Examples of sustainability specific to this policy may include community engagement, customer empowerment and risk mitigation. By integrating these practices into our operations, we aim to create lasting value for our business, our customers, and the broader community, aligning with our long-term commitment to sustainable development.

10 - Responsibilities

Customer and Neighbourhoods Director - Accountable for the delivery of this policy.

Regional Director of Localities - Responsible for the effective implementation and ongoing delivery of this policy.

Operational Development Groups - To ensure the development of processes that support this policy.

Locality Officers - Responsible for investigating suspected tenancy fraud, taking the necessary actions and for keeping our housing management systems up to date.

Accommodation/Property Managers - Responsible for investigating suspected tenancy fraud, taking the necessary actions and for keeping our housing management systems up to date.

All Staff - Responsible for identifying and reporting suspected tenancy fraud.

All contractors - Responsible for identifying and reporting suspected tenancy fraud.

11 - Equality, diversity and inclusion

Sovereign Network Group is committed to the fair, respectful and equal treatment of its customers, employees and applicants.

We will apply this policy consistently, fairly and will not discriminate against anyone based on the protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation, as defined in the Equality Act 2010.

We’ll make sure our services and workplaces are as inclusive and accessible as possible and take seriously any concerns that we’ve not acted in a fair way, dealing with them as quickly as we can.

We are committed to helping customers to access information about their homes and services in a way that suits individual needs. We will also consider any reasonable adjustment requests in line with our Vulnerability and Reasonable Adjustments Policy.

12 - Related documents

Tenancy Fraud and Subletting Procedure
Squatters and Unauthorised Occupiers Procedure
Succession Procedure
Lettings Policy and Appendices
Mutual Exchange Policy
Succession Policy
Vulnerability and Reasonable Adjustments Policy
Anti-Fraud, Bribery and Corruption Policy
Whistleblowing Policy
Code of Conduct
Data Protection Policy

13 - Legislation and regulation

The legislation listed in this policy is not intended to cover all legislation applicable to this policy. To comply with clause 1.1 of the Regulator of Social Housing’s Governance and Financial Viability Standard, which requires adherence to all relevant law, SNG will take reasonable measures to ensure compliance with all applicable legislation by reviewing policies and procedures and amending them as appropriate. Any queries relating to the applicable legislation should be directed to the policy owner.

Housing Act 1988
Housing Act 1985 as amended
Prevention of Social Housing Fraud Act 2013
UK General Data Protection Regulation (UK GDPR)
Data Protection Act 2018
Fraud Act 2006
Regulation of Investigatory Powers Act 2000
Equality Act 2010
Human Rights Act 1998

14 - Review

This document will be reviewed every two years, or sooner if significant changes occur in the relevant legal or operational landscape.