NHF response to consultation on reforming our approach to floods funding

In June 2025, the government lanched a consultation on a new approach to funding flood and coastal erosion projects, specifically how it can simplify its approach, speed up delivery, and respond to the changing nature of risk. The new approach will be launched in time for the start of our new flood investment programme in April 2026. We sent the following repsonse.

Introduction

We strongly encourage the inclusion and prioritisation of property flood resilience (PFR) in government funded flood risk mitigation and urge the government to ensure that this funding is made available to housing associations. This will help to protect lower-income residents who are disproportionately affected by flooding, as well as to preserve valuable social homes and boost general community resilience.

Consultation questions

Part 3: Changing our approach to funding flood and coastal erosion projects

16. Do you agree PFR is an appropriate option to include in government funded flood risk mitigation?

Strongly agree.

17. Please explain your answer to Question 16.

Housing associations across the country are becoming increasingly aware of rising flood risk and the importance of taking action to protect their residents and homes. However, housing associations’ income is predominantly comprised of rents which are well below market rates in order to ensure they are genuinely affordable to people on the lowest incomes. Housing associations’ finite financial resources are already stretched due to multiple new regulatory requirements and different financial and operational pressures. Understanding and navigating the complexities of PFR is also resource intensive, and negative press or misconceptions about PFR can be off-putting for social landlords. On top of this, funding opportunities have not always been easy to access, or near adequate enough to meet total demand. For these reasons, flood resilience measures are often deprioritised, especially by smaller housing associations with less all-round capacity.

Impact of flooding on housing associations and their residents

Residents of housing associations often face higher levels of disadvantage which could render them particularly vulnerable to a flooding event. Social housing residents are three times as likely to be economically inactive than the average person, and those in work earn less than the national average. Lower-income households are most exposed to the financial consequences of a flood, and research has shown how flooding disproportionately affects the least well off, exacerbating existing inequalities and creating long-term challenges.

Recently on 1 January 2025, numerous housing associations were affected by flooding after around 90mm of rainfall fell within 24 hours across England and Wales. Across just one North West housing association, 60 families were forced to evacuate their homes. Most of those families had no home contents insurance, many lost treasured possessions, and some have not been able to return to their homes.

Alongside the life-altering impact on residents, housing associations themselves face significant adverse effects on their businesses after a flooding event, including disruption to services, challenging clean-up and refurbishment operations and higher insurance premiums. Flooding significantly exacerbates social housing shortages, a valuable resource already far too scarce. We simply cannot afford to leave our social homes unprotected against flooding.

Benefits of PFR funding

With increased government funding for PFR measures, accessible to housing associations, social landlords would be better able to take the crucial action needed to protect their residents and homes. A PFR approach to flood defence would allow housing associations and their residents to take more control over their own flood defences, which can ensure better preparedness and reduce anxiety about the prospect of flooding.

The installation of PFR across housing associations aligns strongly with the community-oriented, holistic approach to PFR set out in the consultation. Our members house over six million people and build strong, sustainable communities across the country. Therefore, housing associations should be viewed as key stakeholders in the community-level drive for PFR installation implied in this consultation.

We were pleased that the NHF was recently invited by DEFRA to join the Floodready Taskforce, which is supporting an Environment Agency commissioned independent review of PFR. This invitation recognised housing associations as key stakeholders in national flood resilience planning. That central role should be similarly realised by ensuring that housing associations are eligible for future PFR funding.

We lastly want to emphasise that funding opportunities should not only be available but easily accessible and suitably signposted. Greater education initiatives about PFR would also help raise awareness, encourage uptake and build greater trust in the process.

21. Do you think a similar provision to the ‘2012 rule’ remains necessary under the new approach?

We encourage the government to remove the 2012 rule within the new proposed funding approach, which has up until now restricted properties built after 2012 from accessing government grants. Over the course of the last decade housing associations have typically built 40,000 to 50,000 new homes per year. Climate change means that existing communities, including those living in homes built recently, may now face risks that were not previously identified at the time of development. Even in recent years, properties built in high flood risk areas are not always equipped with flood resilience measures due to regulatory gaps. To fully protect communities, all homes in need of flood resilience measures should be eligible for government funding.