This Q&A follows the Homes England virtual session for providers, mortgage advisors and associated industry groups on 19 June. The purpose of this session was to explain the changes made to section 6 of the Shared Ownership chapter on 10 June 2025 and answer questions. This section sets out our expectations and requirements of the financial assessment process to determine the share a customer can afford to purchase.
Q1: Do these affordability guidance changes take effect immediately i.e. from 10/06/25?
A1: We expect the updates to be adopted as soon as practical. We did not set a specific implementation timescale when we initially published on 10 June because some changes to processes and procedures may require internal approval before implementation. However, we understand there has been some confusion about whether there is a deadline. Therefore, to support internal prioritisation, the deadline for providers to adopt the new sign-off forms and begin issuing the important information for applicants is Tuesday, 30 September 2025 at the latest. If you are unable to meet this deadline, please contact us at sharedownership@homesengland.gov.uk with your reason and implementation date.
Please note, the recent updates to section 6 do not affect any transactions which are already progressing.
Q2: From a Compliance Audit perspective how will the changes apply to sales/resales which are currently taking place?
A2: The purpose of our Compliance Audit is to verify a provider has met all our funding conditions and requirements i.e., in the grant agreement supported by the CFG. Therefore, the new ‘Important Information for Applicants’ should be addressed in the same way as all our conditions and requirements and may be subject to audit in the future.
To note there is not a specific question in the 2025/26 audit checklist (which was published on GOV.UK on the 17 June) because this audit is looking at transactions which have already taken place. However, this will likely appear in future iterations of the audit checklist. Therefore, providers should continue to keep evidence of their adherence to the affordability guidance.
The existing suite of example sign-off forms are unaffected. The revised way of operating in respect of resales outside of a nominations period, or where a non-panel advisor provides an alternative view after a panel advisor sign-off are intended to supersede/supplement the existing sign-off forms once providers adopt their use. For audit purposes, the supplementary sign off forms should be kept with the original sign- off where appropriate. Please note, the answer to Q1 regarding the timescale for implementing the recent changes to the affordability guidance.
Q3: Should the financial assessment be free of charge to the applicant?
A3: Yes. It is a requirement that the affordability assessment carried out by an advisor up to and including determining the suitable share to be purchased and provision of the budget planner should be done free of charge to the applicant (see paragraphs 6.1.3 and 6.5.4). As an affordable housing product there should be no unnecessary cost barriers to enter the scheme, which any form of application or assessment fee would constitute. An applicant can only be charged a fee by an advisor if they engage them to undertake further work on their behalf, such as submitting a mortgage application.
This does not prevent a provider from making a payment to their panel advisors for the assessment, but this cannot be passed on to the applicant. We are aware that some providers are outsourcing additional work from their panel advisors such as document collection and AML checks. These are requirements that Homes England does not expect advisors to undertake and are primarily the responsibility of providers. Any arrangement between provider and advisor, including any fee agreed for such work, should be formalised either through a written agreement, Service Level Agreement or similar (see paragraph 6.3.8).
Q4: If it becomes necessary for providers to pay a fee to our panel advisors for the affordability assessments they undertake, is it possible for providers to recoup this cost from Homes England?
A4: The payment of such fees is not eligible expenditure under the terms of a provider’s grant agreement, and as such cannot be recouped via grant-funding from Homes England. Grant-funding is provided to help facilitate the development and construction of new homes and the associated costs of this. It does not extend to the costs incurred as part of any onward sale of the homes once developed. Any such fees would be considered in the same vein as those paid to a provider’s plot sales solicitor, valuers and site sales agents. Providers should therefore account from any such expenditure in a similar way, presumably from their Sales and Marketing budget.
Homes England will not mandate the payment of fees for any element of the shared ownership affordability assessment process. Any payment arrangement is for providers and advisors to agree - as with other professional fees agreed with solicitors, valuers and sales agents. As set out in paragraph 6.3.8 providers should formalise the relationship with their panel advisors by means of a written agreement including any commercial terms that have been agreed.
Homes England has continued to work with providers and advisors to minimise the administrative burden on them when they have fed back concerns to us. The latest CFG changes aim to smooth the process where a non-panel advisor subsequently becomes involved, and on resales, especially those outside the nomination period, when the shared owner is selling via an estate agent and the shared ownership provider has limited or no control over the sale. These changes are intended to reduce the need for a re-referral / referral to a panel advisor to ‘check’ the work of a non-panel advisor.
Providers and advisors should also consider how they work together and ways in which they may be able to avoid duplication. As well as reducing their respective administrative burdens this may serve to negate or reduce the need for the charging of fees. For instance, they may agree who undertakes activities such as AML checks and document collection, as well as agree the basis of referrals and any fees which may be payable. Referral ‘ratios’ could be agreed as set out in paragraph 6.5.3, or fees to providers confined to applications where the advisor does not have the opportunity to earn a fee.
Q5: Where the ‘Shared Ownership – Important Information for Applicants – Guidance Note’ references provision of the relevant Key Information Document (KID), does this just mean the ‘Key Information about the Shared Ownership home KID’, and if this is already published on our website for the home in question, will a link to it suffice?
A5: For the purposes of the provision of the Important Information for Applicants, this KID may be attached to the email sent to the applicant (or provided as a hard copy if this is the applicant’s preference), but equally may be provided by means of a link where the KID in question is published on the provider’s website.
Q6: Applicants often go to a non-panel adviser for their mortgage following their sign-off from a panel advisor, or where they are purchasing a shared ownership resale home outside of the nomination period. Can you confirm the correct use of the two new sign-off forms please?
A6: The updated ‘Affordability sign-off sheets – guidance note’, as well as the new ‘Resales affordability check’ and ‘Non-panel advisor – different affordability outcome’ forms can be found at the bottom of Chapter 1, paragraph 6.8.16 of the Capital Funding Guide (CFG). The correct use of these forms is clearly detailed in the sign off sheet guidance note and the CFG.
The resales affordability check is covered in paragraphs 6.8.10 to 6.8.12, and the non-panel advisor – different affordability outcome in paragraphs 6.8.13 to 6.8.16. There is an additional paragraph, 6.8.18, which refers to the signing and retention of these forms for compliance audit purposes.
Q7: Could you please confirm what we as providers are required to do in respect of Anti-Money Laundering (AML) checks, or is this the responsibility of the advisor or solicitor to complete?
Additionally, as providers are responsible for notifying applicants of the outcome of their assessment, what do we do in a scenario where an applicant cannot be signed off because they have failed the AML check?
A7: Homes England cannot provide advice in respect of a Provider’s AML responsibilities. You should seek your own advice on this matter.