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Categorisation of housing providers and housing associations

This section provides information on how registered agencies are categorised based on the risk level of the registered agency.

Rental housing agencies are registered under the Housing Act 1983 (Vic) (Housing Act) as either 'housing associations' or 'housing providers.' Section 87 of the Housing Act allows the Registrar of Housing Agencies (Registrar) to change the category of registration if the circumstances of the registered agency change.

The Registrar will determine the category of registration based on an assessment of the risk the registered agency presents. This will include reference to the size and scale of the operations of the registered agency and its development pipeline.

The Office of the Housing Registrar assesses the application to transition the category of registration considering the registered agency’s capacity to meet Performance Standards for housing associations under the Evidence Guidelines. The assessment of the application will include a focus on the risks associated with:

  • willingness and ability to take on debt – a housing association needs to have a risk appetite for debt that supports sustained growth at scale within the context of the registered agency’s operating environment. At scale is a relative term and depends on the capacity of the registered agency to obtain and service additional debt.
  • cashflow to sustain necessary debt – housing associations must be able to repay additional debt while ensuring that future growth is not jeopardised by the burden of existing debt and other commitments.
  • board skills and expertise – the additional risk associated with operation as a housing association requires a stronger and more skilled board, with expertise that covers the range of business risks and opportunities facing the housing association.
  • senior workforce skills – housing associations must have well qualified and experienced management and staff that are able to make decisions and analyse opportunities for the agency. Housing associations are required to demonstrate leadership and be innovative in identifying and presenting growth opportunities and present well balanced and researched proposals to government and other investors.
  • project delivery – registered agencies must be able to demonstrate strong capacity or prior experience in larger scale development projects (or other complex housing projects) that have been implemented on time and on budget to be considered for housing association status.
  • demonstrated innovation – in the current economic and policy climate housing associations must be able to identify and explore opportunities to increase the supply of social housing to house more disadvantaged Victorians. Registered agencies that are currently developing at scale and have strategies and plans to grow social housing are preferred.
  • asset management capacity – this is fundamental to property owners and managers with responsibilities to Government and tenants in need of social housing.

Registered agencies are required to contact their lead regulator to submit a request to change the category of registration under the Housing Act.

Following the assessment, the Office of the Housing Registrar makes a recommendation and presents the final assessment to the Registrar of Housing Agencies. The Registrar makes the final decision to change the category of registration and registered agencies are advised by the Office of the Housing Registrar of the outcome and the reasons for the decision.

  • Under the Housing Act, the Registrar can categorise a registered agency as a housing association or a housing provider based on the level of regulatory risk associated with a registered agency’s operations. Factors which determine this level of risk include the size of a registered agency, its plans for growth at scale and the complexity of its operations.

    Housing associations are assessed as having an increased level of risk due to the scale and scope of their operations and are generally larger, more complex registered agencies. Housing associations expand new housing through construction, purchase or acquisition, using a mix of government funds and private sector investment. Housing associations also manage housing properties which they own or lease from other parties, such as the Director of Housing located within the Department of Families, Fairness and Housing.

    Registered housing associations drive growth at scale in their housing portfolios as well as manage a larger portfolio of housing. This ensures that housing associations continue to demonstrate their financial viability and their ability to leverage government grants to deliver larger more complex developments. Financing of a proportion of the growth occurs through funding sources external to government, including private debt.

    Housing associations have the highest regulatory reporting requirements due to their increased level of risk. For high-risk agencies, the potential impact of failure is greater due to their size, complexity and the level of development activity (or the amount of development funding). This is demonstrated by:

    • obligations arising from capital projects
    • management of loan covenants and development timelines
    • complexity from loan arrangements and structures
    • consideration given to organisational capacity and risk management.
  • Housing providers are assessed as having a lower level of risk within their operations and range in size from smaller to medium-sized registered agencies. Housing providers primarily manage rental housing portfolios for other parties, such as the Director of Housing located within the Department of Families, Fairness and Housing.

    Some housing providers own properties and drive growth in their housing portfolios, however, their growth is smaller in scale compared with housing associations. Housing providers often specialise in targeting particular client groups which may include disability housing, older people and youth housing.

    A housing provider may apply to the Registrar of Housing Agencies for a change of category to a housing association, however, it must be able to demonstrate that they meet the requirements for transition between the two categories.

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Reviewed 17 December 2021

Housing Registrar

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