MD3396 Delivery Plan – Improving London’s Housing Stock

Background

1.1.    The Greater London Authority (GLA) has been establishing refreshed delivery and governance arrangements over the last few months. 

1.2.    In undertaking these changes, we have:

•    defined a set of London-level, long-term outcomes which reflect Londoners’ aspirations for the city and to which the GLA and the GLA Group, in partnership with others, is working towards
•    agreed a small set of strategic, high-level, programmes which the Mayor will commission the GLA Group to deliver in order that the GLA and the GLA Group make the appropriate contributions towards the London-level outcomes.

1.3.    MD3274 ‘Updates to GLA Governance Documents’, published on 13 June 2024, marked the first formal step in implementing new portfolio and governance arrangements and set out approved revisions to the arrangements through which the Mayor exercises and, where appropriate, delegates his powers. It also laid out some changes to the way the GLA’s senior leadership works to ensure that the GLA is successful in exercising its strategic role and in securing delivery.

1.4.    The GLA is now bringing forward for approval delivery plans for the 14 strategic, high-level, programmes which are led by the GLA and involve functional bodies as appropriate. These are numbered 1-14 and set out below, along with delivery plans 15-21, where the relevant GLA Group organisation is taking a leadership role: 

1.    Building more homes
2.    Making best use of land
3.    Improving London’s housing stock
4.    Reducing inequalities
5.    Accommodation and wider support for those who need it most
6.    Reducing non-residential emissions
7.    Delivering a greener, more climate-resilient London
8.    Cleaning London’s air
9.    Supporting Londoners to benefit from growth
10.    Supporting and inspiring young London
11.    Boosting London’s growth sectors
12.    Helping local economies to thrive
13.    Upgrading London’s infrastructure
14.    Celebrating London
15.    Reducing violence and exploitation
16.    Building safer, more confident communities
17.    Supporting and overseeing reform of the Metropolitan Police Service (MPS)
18.    Improving the Criminal Justice System and supporting victims
19.    Healthy streets
20.    Decarbonising transport
21.    Providing more effective, accessible and affordable public transport.

1.5.    The Mayor has been issuing mandates for these proposed programmes to prospective Senior Responsible Owners (SROs). Mayoral mandates define what the Mayor wants to see from each of the programmes, including their scope, objectives, and cross-cutting priorities. Programmes and their associated delivery plans have been developed by the proposed programme SROs, working with the relevant Deputy Mayors, Mayoral Directors and others in response to the Mayor’s mandates. They have been developed to strike the right balance between setting out plans and retaining flexibility to respond to events and learning, as delivery progresses, recognising that agility is important in the context of a changing landscape.

1.6.    Delivery plans lay out the London-level outcomes to which each programme contributes. In considering the GLA’s specific role in contributing to the London-level outcomes, programme SROs have focused on the role of the GLA as London’s strategic regional authority. This has meant looking carefully at where activities most effectively sit within the London system and how the GLA can work with partners to unlock and drive progress. In some cases that will be through direct delivery or through funding. In others it will be through more indirect mechanisms such as system reconfiguration, coalition formation, technical support or capacity building.

1.7.    Resource allocations to each programme are based on the allocations contained in the GLA: Mayor Budget 2025-26. Changes required to delivery plans over time will be agreed by the Mayoral Delivery Board (MDB), or the Mayor, in line with our governance arrangements.

1.8.    Delivery plans lay out how each programme makes a positive difference to the relevant London-level outcomes. Key programme outputs are also detailed and will be reported quarterly to MDB, which is responsible for monitoring the performance and delivery of each programme’s delivery plans. 

Overview of the Improving London’s Housing Stock delivery plan

1.9.    The Mayoral mandate for the Improving London’s Housing Stock programme is appended to this Decision form at Appendix 1. The proposed delivery plan is appended at Appendix 2 and presented by the Executive Director for Good Growth, as the proposed SRO, for the Mayor’s approval.

1.10.    By approving the plan, and the resources allocated to it, the Mayor is enabling the GLA, working with partners, to contribute to the core London-level outcomes:

•    Londoners’ homes are safe and decent
•    London is a net-zero carbon city.

1.11.    The Mayor is committed to ensuring that Londoners can live in affordable, safe and green homes, and in doing so reducing energy bills and ending fuel poverty in London. But the challenges are stark. Eight years after the Grenfell Tower tragedy more than a third of high-rise buildings with unsafe cladding are yet to start remediation works; fourteen per cent of privately rented homes in London fail to meet the Decent Homes Standard, along with eight per cent of homes in the social rented sector; and 210,000 homes a year need to be made more energy efficient to help London reach net-zero by 2030. 

1.12.    The Improving London’s Housing Stock delivery plan aims to ensure Londoners can live in safe, decent and green homes, by reducing carbon emissions and improving energy efficiency, addressing critical safety risks and tackling under-performance in the private rental sector. It has three key strands:

•    Addressing systemic building safety issues: This encompasses the GLA’s work in partnership with the government to deliver a local remediation action plan for London and the administration of key funding streams for cladding remediation.
•    Providing safe and decent homes for renters: The GLA will support boroughs and other partners to drive up standards in the rental sector, while also working to increase security for renters, so that they are increasingly empowered to challenge failing landlords directly.
•    Accelerating the pace of domestic decarbonisation: This focuses on establishing Warmer Homes London and building its capacity, alongside both administering current funds and seeking to secure greater funding devolution and flexibility in future.

1.13.    The proposed delivery plan sets out the budget for each project within the programme. 

1.14.    Projects detailed in the delivery plan fall into one of three categories:

•    projects which are already set out in detail in an existing Mayoral Decision or Director Decision 
•    projects for which this Mayoral Decision seeks Mayoral delegation to the SRO to take expenditure decisions
•    projects which will require separate Mayoral Decisions.

1.15.    The projects with Mayoral Decisions and other relevant approvals already in place are:

•    delivering high-rise cladding remediation projects – approved under Mayoral Decisions MD2346, MD2490, MD2630, MD2774, and MD3363. It should be noted that MD2630 provides approval to receive and administer the Building Safety Fund, with an initial estimate of £700m funding to be spent primarily in 2021-22, which could be extended (and has been extended since, with the funding provided increasing commensurately)
•    delivering the Warm Homes Local Grant programme in London – approved under MD3366.

1.16.    The projects for which this Mayoral Decision seeks Mayoral delegation to the SRO to take expenditure decisions are:

•    taking action on wider building safety issues, including convening partners to deliver a Local Remediation Acceleration Plan for London – all elements of this project other than the delegation of funding to Homes England (covered by MD3363). The government has recently confirmed that it will make £2.5m available to the GLA in 2025-26 for the development and delivery of the Local Remediation Acceleration Plan for London, and therefore this MD also seeks approval for the receipt of this funding (which has been included in the budget set out in the delivery plan)
•    enabling effective licensing and enforcement in the private and social rented sectors
•    improving security and stability for private renters.

1.17.    Two projects will require separate Mayoral Decisions because they are expected to require significant GLA funding or involve entering into new contracts or commercial relationships, and because further more detailed work is required before Mayoral approval is sought. They are:

•    establishing (with London Councils) and clienting Warmer Homes London
•    providing fair-priced green energy and enabling decarbonisation through London Power (should the GLA seek to enter into any new contractual arrangements with Octopus Power Co Ltd or any other commercial partner).

1.18.    The Executive Director for Good Growth will ensure compliance with the obligations set out in The Openness of Local Government Bodies Regulations 2014 which describe when written records of decisions and their content need to be published. Director Decisions and Assistant Director Decisions will be required, where appropriate, to meet these transparency requirements, including in instances where GLA funds are paid to external organisations.

Transfers to/from other programmes and receipt of external funding

1.19.    Development of this delivery plan has prompted refinements to the published budget. As a consequence, Mayoral approval is sought for budget transfers between Improving London’s Housing Stock and other programmes, in accordance with GLA governance processes. 

1.20.    Funding for the work of creating and financing a pipeline of climate projects, making use of the Mayor’s London Climate Finance Facility, specifically for decarbonisation programmes, was included within the Improving London’s Housing Stock programme when the GLA 2025-26 budget was approved in March 2025. It has since been decided that it is more appropriate for this project to be included within the Reducing Non-Residential Emissions programme. This MD seeks Mayoral approval to transfer this funding accordingly. 

1.21.    The budget will also be updated to reflect receipt of government funding via the Warm Homes Local Grant Scheme (approved by MD3366) and of additional government funding (as set out in paragraph 1.16) for the development and delivery of a Local Remediation Acceleration Plan for London.

1.22.    This MD also seeks approval for the receipt of this latter, totalling £2.5m in 2025-26, which responds to a new requirement on Strategic Authorities to work with government and national and local partners to develop a shared plan to increase the pace of remediation. This forms a key part of the Improving London’s Housing Stock delivery plan and will be overseen in London by a board co-chaired by the Building Safety minister and the Deputy Mayor for Housing and Residential Development.  

Securing additional funding for projects in the delivery plan

1.23.    Key to meeting the objectives and expected outcomes of the Improving London’s Housing Stock delivery plan is securing funding to support the delivery of both new and existing projects.

1.24.    Where additional funding from government (or other sources) is secured in the future to expand or extend existing approved schemes contained in the Improving London’s Housing Stock delivery plan (as has previously been the case for the cladding remediation funding approved under MD2630) and the parameters remain the same or similar as originally agreed with government (or the relevant body), this Decision form seeks approval to delegate to the Executive Director for Good Growth to agree the receipt of such funding after consulting with legal advisors and the GLA’s Chief Finance Officer and subsequently having secured agreement from the MDB. For the purposes of considering whether the parameters are similar as originally agreed with government (or the relevant body), the Executive Director for Good Growth will have regard to whether the outcomes to be delivered have changed significantly or there is a significant change in attendant risks of the original scheme. If the outcomes to be delivered have changed significantly or there is a significant change in attendant risks, or the decision is viewed as novel, contentious or repercussive, a Mayoral Decision will be required.

1.25.    Any decisions to accept additional funding will need to comply with the obligations set out in The Openness of Local Government Bodies Regulations 2014 as highlighted in paragraph 1.18 above. Any decisions to accept additional funding that do not require a formal decision form must be documented via a Record in Writing, as defined in MD3274 ‘Updates to GLA Governance Documents’, signed in June 2024, and will be reported publicly quarterly. 
 

2.1.    The delivery plan for the Improving London’s Housing Stock programme describes how the GLA will work across the housing sector and in close collaboration with London local authorities and central government to ensure Londoners’ homes are safe, decent and green, and in doing so reduce energy bills and end fuel poverty. It includes activity towards the Mayor’s commitments around the remediation of unsafe cladding in London, around improved licensing and enforcement of the private rented sector and strengthening renters’ rights, and around the acceleration of domestic retrofit.

2.2.    The objectives and expected outcomes of the programme are set out in the Improving London’s Housing Stock delivery plan which is appended as Appendix 2.

2.3.    The core London-level outcomes to which this programme will contribute are: Londoners’ homes are safe and decent and London is a net-zero carbon city. This reflects the impacts on Londoners’ mental and physical health and financial wellbeing of homes that are unsafe, cold and damp, poorly insulated and expensive to heat, with the poorest and most disadvantaged Londoners disproportionately likely to live in these properties. It also reflects the significant carbon impact of domestic buildings in London, with the capital’s homes currently responsible for approximately a third of overall emissions.
 

3.1.    Under section 149 of the Equality Act 2010, the Mayor and GLA must comply with the public sector equality duty (PSED) and must have due regard to the need to:

•    eliminate unlawful discrimination, harassment and victimisation and any other conduct that is prohibited by or under the Equality Act
•    advance equality of opportunity between people who share a relevant protected characteristic and those who do not
•    foster good relations between people who share a relevant protected characteristic and those who do not.

3.2.    The ‘protected characteristics’ are: age, disability, gender re-assignment, pregnancy and maternity, marriage and civil partnership (but only in respect of the requirements to have due regard to the need to eliminate discrimination), race (ethnic or national origins, colour or nationality), religion or belief (including lack of belief), sex, and sexual orientation. 

3.3.    Consideration of the PSED is not a one-off task. The duty must be fulfilled before taking a decision, at the time of taking a decision, and after the decision has been taken, to ensure that equalities impacts are kept under ongoing review.

3.4.    The Improving London’s Housing Stock delivery plan helps achieve a number of the Mayor’s statutory equality objectives, and progress on delivery of these objectives is reported on each year in the Mayor’s Annual Equality Report.

3.5.    Overall, London’s disadvantaged and marginalised communities suffer disproportionately from poor housing. In the private rented sector, Black, Asian and minoritized ethnic Londoners are more likely than others to live in homes that do not meet the Decent Homes Standard, and Black households are significantly more likely than others to report moving because their landlord ended the tenancy or evicted them. Black, Asian and minoritized ethnic Londoners are also more likely suffer from fuel poverty and the impacts of cold homes, and to live in buildings which still have unsafe cladding.

3.6.    Similarly, Londoners on low incomes and with disabilities or long-term conditions are more likely to live in poor-quality homes and/or to face fuel poverty. Older Londoners are less likely to live in fuel poverty but at greater risk of hospitalisation due to cold, damp homes.

3.7.    In addition to the financial impacts, cold, damp and mouldy homes can create major risks to physical health, for example leading to or worsening respiratory conditions, allergic reactions, diabetes, arthritis and circulatory issues. Such housing can also affect mental health, as can the threat of unexpected eviction or the awareness of living with a heightened and unaddressed fire risk. These factors are exacerbated by the disproportionate numbers of vulnerable and/or disadvantaged Londoners living in such homes, with the result that poor housing is an important driver of health inequalities.

3.8.    Well-targeted action through the projects set out in this delivery plan can therefore help many people with protected characteristics, by accelerating the pace of work to address safety risks, improving insulation and reducing energy bills, driving up standards in the private and social rented sectors and providing renters with greater security and stability of tenure.
 

Risks and issues

4.1.    The following programme-level risks to the delivery of the Improving London’s Housing Stock programme have been identified:

4.2.    The Executive Director of Good Growth as the SRO for the Improving London’s Housing Stock programme will be responsible for implementing and overseeing a risk framework for that programme. Project risks and mitigations will be managed as they are currently at a project level and reported periodically to the Programme Board. The Programme Board will also review the above programme-level risks and mitigations, reporting to the Mayoral Delivery Board alongside progress against programme objectives as part of the GLA’s quarterly reporting regime. 

Links to Mayoral strategies and priorities

4.3.    The programmes outlined in this decision support the following Mayoral strategies:

•    The London Housing Strategy, which includes policies and objectives to ensure that both new and existing homes are high-quality, safe and sustainable, to improve the energy efficiency of existing homes, and to improve the quality of private renting.
•    The London Environment Strategy, which includes policies and objectives to improve energy efficiency and reduce fuel bills, and to support the roll out of low-carbon technologies such as heat pumps and solar. The delivery plan also supports the Mayor’s subsequent ambition for London to achieve net zero carbon emissions by 2030 and reflects his preferred ‘accelerated green’ pathway to achieve that goal.
•    The London Health Inequalities Strategy, which recognises the negative impact of poor quality and insecure housing on Londoners’ mental and physical help, particularly for those from marginalised or disadvantaged groups.
•    Inclusive London, the Mayor’s equality, diversity and inclusion strategy, which includes policies and objectives to lower the capital’s carbon emissions, address the barriers faced by Londoners most likely to experience financial hardship (including fuel poverty), and address the reasons for physical and mental health inequalities.

Consultations

4.4.    For projects which already have a formal decision form in place, the consultation undertaken for these projects is set out in the relevant decision forms.

4.5.    The level and timing of consultation will vary for those projects not requiring a subsequent formal decision form. This will be a mixture of informal consultation with key stakeholders, as well as formal consultation.  

4.6.    Where further Mayoral Decision forms will be required to progress the projects in the Improving London’s Housing Stock delivery plan, consultation will be undertaken where appropriate; this will be shaped through engagement with relevant stakeholders such as delivery partners, community stakeholders and advisory groups.

4.7.    There are no conflicts of interest arising from those involved in the drafting and clearance of this Decision form. As and when individual conflicts of interest arise during the delivery of initiatives contained in the Improving London’s Housing Stock delivery plan, they will be handled in line with the GLA policy on registering and declaring interests.
 

5.1.    The programme budget is set out in the delivery plan and summarised in the table below. 

5.2.    The budget allocated to this delivery plan is presented in the GLA: Mayor budget 2025-26 approved on 31 March 2025 under MD3330 as below:

5.3.    Budget will be transferred between this programme’s delivery plan to other programmes’ delivery plans in accordance with our governance processes, subject to Mayoral approval of this Mayoral Decision, as follows:

5.4.    The budget will be updated to reflect reserve transfers, fundraising and external income, subject to Mayoral approval of this Mayoral Decision, as follows:

5.5.    The budget set out at paragraph 5.1 reflects the net effect of these budget transfers and additional income.

5.6.    Any budget commitments for future years are subject to the annual budget setting process.

5.7.    Any further transfers and movements within the budget for this programme, or between this and other programmes, will be handled in accordance with the GLA’s governance processes.
 

6.1.    Under section 30(1) of the Greater London Authority Act 1999 (the GLA Act), the Mayor acting on behalf of the GLA has the power to do anything that he considers will further any one or more of the GLA’s principal purposes, which are:

•    promoting economic development and wealth creation in Greater London
•    promoting social development in Greater London
•    promoting the improvement of the environment in Greater London. 

6.2.    In deciding whether or how to exercise the general power in section 30(1), section 30 (4) of the GLA Act requires the GLA to have regard to the effect which the proposed exercise of the power would have on:

•    the health of persons in Greater London
•    health inequalities between persons living in Greater London
•    the achievement of sustainable development in the UK
•    climate change, and the consequences of climate change. 

6.3.    Where the GLA exercises the power under section 30(1), pursuant to section 30(5) it must do so in the way which it considers best calculated to:

•    promote improvements in the health of persons in Greater London
•    promote the reduction of health inequalities between persons living in Greater London
•    contribute towards the achievement of sustainable development in the United Kingdom
•    contribute towards the mitigation of, or adaptation to, climate change, in the United Kingdom.

6.4.    The GLA must also make arrangements with a view to securing that in the exercise of the power in section 30(1) there is due regard to the principle that there should be equality of opportunity for all people in accordance with section 33 of the GLA Act and consult with such bodies or persons as the GLA may consider appropriate in this particular case in accordance with section 32 of the GLA Act.

6.5.    Under section 34 of the GLA Act, the GLA, acting by the Mayor, the Assembly, or both jointly, may do anything that is calculated to facilitate, or is conducive or incidental to, the exercise of any functions of the GLA exercisable by the Mayor; or, as the case may be, by the Assembly, or by both acting jointly. The foregoing sections of this report indicate that the decisions requested of the Mayor concern the exercise of the GLA’s powers under section 30 and section 34 of the GLA Act. 

6.6.    Under section 38 of the GLA Act, any function exercisable by the Mayor on behalf of the GLA may also be exercised by a member of the GLA’s staff – albeit subject to any conditions that the Mayor sees fit to impose. To this end, the Mayor may make the requested delegation to the Executive Director for Good Growth, subject to the conditions and requirements set out in this Mayoral Decision. 

6.7.    Section 31 of the GLA Act places limits on the general power and prohibits the GLA from incurring expenditure on anything which may be done by TfL, MOPAC or the LFC.

6.8.    In taking the decisions requested of him, the Mayor must comply with the Public Sector Equality Duty (PSED) contained in section 149 of the Equality Act 2010. To this end, the Mayor should have particular regard to section three (above) of this report.

6.9.    If the Mayor makes the decisions sought, officers must also ensure that:

•    no reliance is placed on, nor commitments made in reliance of:
-    third party funding until legally binding commitments are secured for it and officers are satisfied that their proposed use of the same aligns with any conditions of award
-    future budgets remaining subject to the outcome of the budget setting process for future financial years, until those budget setting exercises are completed
-    “returned funding” without confirmation that it can be used as proposed and, where applicable, liaising with third party funders and varying current GLA funding agreements to reflect the reallocation of funding
•    where applicable, the Subsidy Control Act 2022 is observed
•    where expenditure concerns: 
-    purchase of services: they are procured in accordance with the GLA’s Contracts and Funding Code (the “Code”) and where applicable the Procurement Act 2023 (the “Act”); officers liaise with Transport for London’s procurement and supply chain team, which will determine the detail of the procurement strategy to be adopted in accordance with the Code and the Act; and put in place appropriate contractual documentation and ensure it is executed by the chosen service provider and GLA before the commencement of those services 
-    the award of grant funding such awards are made fairly, transparently, in accordance with the GLA’s equalities requirements and with the requirements of GLA’s Contracts and Funding Code and funding agreements are put in place between and executed by the GLA and recipients before any commitment to fund is made.

6.10.    If the Mayor makes the decisions sought, the Executive Director for Good Growth must comply with the obligations set out in The Openness of Local Government Bodies Regulations 2014 when taking decisions in accordance with the delegations set out in this decision form or any other delegations in existing Mayoral Decisions. In particular regulation 7 which provides that where a decision has been delegated to an officer either (a) under a specific express authorisation or (b) under a general authorisation and the effect of the decision is to award a contract or incur expenditure which, in either case, materially affects the GLA’s financial position, the officer to whom the delegation has been made must produce a written record of the decision (regulation 7(1) and (2)). Regulation 7(3) provides that the written record must be produced as soon as reasonably practicable after the decision has been taken and must contain the date the decision was taken, a record of the decision taken with reasons, details of options considered and rejected, if any, and where a decision is delegated under a specific express authorisation, any conflicts of interest. Regulation 8 requires the written record, together with any background papers, must as soon as reasonably practicable after the record is made, be made available for inspection by members of the public including on the GLA’s website.

6.11.    Decision 3, above, approves the receipt of £2.5m of UK government funding for a Local Remediation Acceleration Plan for London. Officers are reminded to comply with the conditions, which the UK government has placed on the use of the funding by the GLA. 
 

7.1.    Timelines are as set out in the delivery plan appended as Appendix 2.