Fraud remains one of the fastest-growing and most damaging risks facing social housing providers. It is becoming more sophisticated, harder to identify, and more costly to ignore - with impacts that extend beyond financial loss into service disruption, reputational damage and regulatory scrutiny.  

Many providers are also operating through ongoing organisational change and increasing digitalisation, creating new vulnerabilities and opportunities for criminal exploitation. Building fraud resilience has never been more important.

Who We Are

We are a dedicated fraud protection and detection team supporting social housing providers to strengthen resilience and safeguard resources. 

Our work is practical and collaborative, combining frontline experience across investigations, governance, risk management and regulatory compliance.  We help organisations understand where fraud risk sits within operations, how it may present in practice, and what steps can be taken to prevent, detect and respond effectively.

Why Fraud Happens 

Fraud rarely occurs in isolation. It is typically driven by a combination of:

• Opportunity (weak controls, limited oversight, poor segregation of duties) 
• Pressure (financial stress, personal circumstances, organisational change) 
• Rationalisation (“I’ll pay it back”, “they won’t notice”, “everyone does it”)

A strong fraud control framework reduces opportunity, improves visibility, and builds a culture where concerns are raised early. 

What an Effective Fraud Control Framework Looks Like 

Fraud control is strongest when prevention and detection work together.

1. Protection (prevention)

Effective prevention starts with strong foundations, including:

• clear policies and procedures 
• robust internal controls and approvals 
• fraud risk assessments aligned to key operational areas 
• staff awareness and training 
• leadership commitment and accountability

2. Detection 

Detection requires organisations to actively look for warning signs, supported by:

• monitoring and data insight 
• internal reporting routes and escalation processes 
• intelligence-led indicators and practical red flags 
• confidence to challenge unusual activity

3. Response 

When fraud is suspected, providers must respond quickly and appropriately through:

• lawful, proportionate investigation processes 
• clear documentation and evidence handling 
• timely decision-making and escalation 
• learning and control improvements following incidents

Common Fraud Themes in Social Housing 

Providers may face a range of fraud risks, including:

• tenancy fraud and tenancy misuse 
• procurement fraud and conflicts of interest 
• falsified documentation and misrepresentation 
• insider abuse of position 
• cyber-enabled fraud and payment diversion

Case experience across the sector shows repeated themes: missed warning signs, control gaps that persist over time, and delayed escalation.

The Legal and Regulatory Landscape 

Fraud risk is now firmly a governance, assurance and compliance priority.  

Boards and executives must consider legal duties around fraud offences, reporting obligations, data handling and financial controls - alongside regulatory expectations around integrity, transparency and effective risk management. 

Failure to Prevent Fraud (from 1 September 2025) 

The introduction of the Failure to Prevent Fraud corporate criminal offence (under the Economic Crime and Corporate Transparency Act 2023) significantly increases organisational exposure. 

It introduces strict liability where an associated person (including employees, agents, contractors, subsidiaries or others providing services) commits a fraud offence intended to benefit the organisation - unless the organisation can demonstrate it had reasonable fraud prevention procedures in place. 

This applies to organisations meeting at least two of the following thresholds:

• more than 250 employees 
• more than £36 million turnover 
• more than £18 million in assets

Statutory guidance sets out six key principles expected to be embedded:

• top-level commitment 
• risk assessment 
• proportionate procedures 
• due diligence 
• communication and training 
• monitoring and review

Why Reporting Matters (Including Tenancy Fraud) 

Timely reporting is essential - not only for regulatory compliance, but to protect scarce housing resources and maintain public trust. 

Reporting supports:

• early investigation and containment 
• clear escalation and governance oversight 
• transparency and accountability 
• wider sector intelligence and awareness of emerging trends

Tenancy fraud remains one of the most widespread and damaging forms of abuse.  Every unreported case is potentially a home withheld from someone in genuine need. 

Key Takeaways 

Fraud preparedness is no longer optional. Providers should focus on:

• strengthening preventative controls and oversight 
• improving detection capability and escalation routes 
• ensuring investigation and response processes are robust 
• embedding a culture where fraud concerns are raised early 
• reviewing compliance readiness for Failure to Prevent Fraud

How We Can Help 

If you are interested in strengthening your fraud framework, or you are currently being affected by suspected or confirmed fraud, we encourage you to get in touch.  Early support can help limit impact, strengthen controls, and ensure the right actions are taken. 

For further advice, guidance or support, please contact: