Equality impact assessment (EIA) form: evidencing paying due regard to protected characteristics

(Form updated October 2023)

 

Tenancy Agreement and Tenancy Policy Changes

 

Equality Impact Assessments (EIAs) are public documents.  EIAs accompanying reports going to County Councillors for decisions are published with the committee papers on our website and are available in hard copy at the relevant meeting.  To help people to find completed EIAs we also publish them in the Equality and Diversity section of our website.  This will help people to see for themselves how we have paid due regard in order to meet statutory requirements. 

 

Name of Directorate and Service Area

Community Development - Housing

 

Lead Officer and contact details

Carl Doolan – Head of Housing Management and Landlord Services

 

Names and roles of other people involved in carrying out the EIA

Imogen Downie

How will you pay due regard? e.g. working group, individual officer

This overarching EIA has been carried out by the Housing Policy and Strategy Officer (Service Improvement).

 

 

When did the due regard process start?

September 2025

 

 

 

 

Section 1. Please describe briefly what this EIA is about. (e.g. are you starting a new service, changing how you do something, stopping doing something?)

 

This Equality Impact Assessment (EIA) assesses the impact of proposals to harmonise tenancy arrangements across North Yorkshire Council’s housing stock by adopting a unified Tenancy Agreement for secure and introductory tenancies (from April 2026), replacing legacy agreements inherited from Harrogate, Richmondshire and Selby. Existing Harrogate and Selby flexible tenancies will remain on legacy terms until their fixed term ends. In parallel, amendments to the Tenancy Policy include introducing a 52‑week rent collection period and aligning tenancy start/end dates with weekly rent cycles. The changes are intended to improve legal compliance, operational efficiency and consistency for tenants.  

 

 

 

Section 2. Why is this being proposed? What are the aims? What does the authority hope to achieve by it? (e.g. to save money, meet increased demand, do things in a better way.)

 

This proposal is being brought forward as part of North Yorkshire Council’s Housing Revenue Account Policy Framework following local government reorganisation. The Council inherited multiple tenancy agreements and housing policies from three legacy authorities, resulting in inconsistency, inefficiency, and potential inequity in service delivery.

 

The aims of the proposal are to

  • Introduce a new NYC Tenancy Agreement for secure and introductory tenancies to provide a consistent legal framework and improve clarity for most tenants.

·         Retain existing Harrogate and Selby flexible tenancies on their legacy agreements until the end of their fixed term, in line with external legal advice on the complexities of varying these agreements.

·         Ensure that, upon expiry of their fixed term, flexible tenancies convert to the NYC Tenancy Agreement.

  • Improve legal compliance by aligning tenancy terms with current legislation and best practice.
  • Enhance operational efficiency by streamlining tenancy management processes and reducing administrative complexity.
  • Support financial sustainability through proposed amendments to the Tenancy Policy, including a 52-week rent collection period and revised tenancy start dates, which are expected to improve rent collection and simplify accounting.
  • Promote transparency and tenant engagement by undertaking meaningful consultation and ensuring tenants have a clear understanding of their rights and responsibilities.

 

While the proposal will significantly reduce inconsistencies across the Council’s housing stock, full harmonisation will only be achieved once all legacy flexible tenancies have expired and converted to the NYC secure tenancy agreement.

 

Section 3. What will change? What will be different for customers and/or staff?

 

The proposal will introduce a new North Yorkshire Council (NYC) Tenancy Agreement for secure and introductory tenancies, replacing the legacy agreements inherited from Harrogate, Selby, and Richmondshire. This will create a consistent legal framework for most tenants and simplify tenancy management processes.

However, existing Harrogate and Selby flexible tenancies will remain on their legacy agreements until the end of their fixed term. These tenancies will not be varied to the new NYC Tenancy Agreement due to the legal complexities and risks identified by external Counsel. Upon expiry of the fixed term, these flexible tenancies will convert to the NYC Tenancy Agreement.

For tenants, the changes will mean clearer and more consistent tenancy terms for secure and introductory tenancies, improved understanding of rights and responsibilities, and greater transparency. Flexible tenants will continue under their current agreements for the duration of their fixed term, but the NYC Tenancy Agreement sets out how legacy succession and assignment rights will apply during this transitional period.

For staff, the introduction of the NYC Tenancy Agreement will reduce complexity for most tenancy types, improve operational efficiency, and enable consistent advice and enforcement. Some variation will remain until all flexible tenancies have expired, so staff will need to continue managing these legacy agreements alongside the new framework.

Overall, the changes will significantly reduce inconsistencies across the housing service, but full harmonisation will only be achieved once all legacy flexible tenancies have converted to the NYC secure tenancy agreement.

 

Section 4. Involvement and consultation (What involvement and consultation has been done regarding the proposal and what are the results? What consultation will be needed and how will it be done?)

Initial engagement has taken place with internal stakeholders, including Housing Management teams, Legal Services, and Communications officers. These teams have contributed to the development of the proposed North Yorkshire Council Tenancy Agreement by reviewing legacy agreements and identifying areas requiring harmonisation. Legal Services have also referred the draft agreement to Counsel for review, with particular focus on succession and assignment clauses.

Formal statutory consultation with tenants was undertaken between 26 November and 31 December 2025, in accordance with Sections 102 and 103 of the Housing Act 1985 (variation of secure tenancies), Section 105 of the Housing Act 1985 (housing management matters) and Section 137 of the Housing Act 1996 (introductory tenancies). Consultation covered both the proposed North Yorkshire Council Tenancy Agreement and the proposed amendments to the Tenancy Policy, including the introduction of a 52‑week rent collection period and changes to tenancy start dates. While the consultations ran concurrently, they were treated as distinct processes with separate materials and feedback mechanisms.

A total of 89 responses were received. Feedback demonstrated broad understanding and acceptance of the need to modernise and harmonise tenancy arrangements. Queries and comments focused on specific issues such as succession, joint tenancies, rent payment arrangements and the clarity of language used. All responses were carefully considered. No substantive changes to the proposals are recommended; however, minor drafting refinements and clarifications have been made to improve clarity and tenant understanding. The overall policy intent and approach to harmonisation remain unchanged.

 

 

 

Section 5. What impact will this proposal have on council budgets? Will it be cost neutral, have increased cost or reduce costs?

 

The proposal is expected to be cost neutral in terms of day-to-day operations. The variation of tenancy agreements and the associated consultation process formalise statutory procedures that the Council is already required to follow. Costs associated with legal advice, including referral to Counsel, and the preparation of consultation materials will be met from existing Housing Revenue Account (HRA) budgets.

 

In the longer term, the implementation of a unified tenancy agreement is anticipated to generate efficiencies by reducing duplication, streamlining tenancy management processes, and improving clarity for both tenants and staff. These operational benefits will support improved value for money and contribute to the Council’s wider housing transformation programme.

 

The proposed amendments to the Tenancy Policy, including the introduction of a 52-week rent collection period and potential change to tenancy start dates, may also deliver financial benefits. These changes are expected to improve rent collection, reduce arrears, and simplify rent accounting, thereby reducing administrative overheads.

 

 

Section 6. How will this proposal affect people with protected characteristics?

No impact

Make things better

Make things worse

Why will it have this effect? Provide evidence from engagement, consultation and/or service user data or demographic information etc.

Age

x

 

 

From information currently available we can estimate that 51% of our tenants are aged over 60. In 2021, 25% of the county’s adult population was over the age of 65. This is higher than the national percentage of

18.4%. This means that our tenant population is significantly more aged than the average population for North Yorkshire and the country.

 

By 2035, 32.60% of North Yorkshire’s total population will be aged 65+ and 5.97% will be aged 85+.

 

Nationally 23.26% will be 65+ and 4.05% will be 85+ by 2035.

 

Less than 5% of our tenant population are under 29. North Yorkshire has a lower proportion of young people than the national average- 24.5% under 25 compared to 29.2% nationally.

 

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy are not expected to have a disproportionate impact on any age group. The changes aim to harmonise tenancy terms and improve service delivery for all tenants, regardless of age.

Disability

x

 

 

North Yorkshire has a lower proportion (19.3%) of people with a disability or long-term limiting illness whose day-to-day activities are limited a lot- against the national average of 23.69%.

 

However, this will rise to 20.89% of the 65+ population in North Yorkshire, against a national average of 24.86%.

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy are not expected to have a disproportionate impact on people with disabilities. The changes aim to harmonise tenancy terms and improve service delivery, without introducing new barriers or exclusions.

Sex

x

 

 

The proportion of females is slightly higher (51%) than that of males (49%).

 

This pattern is reflected across all localities, with the exception of Richmondshire, where the large number of predominantly male military personnel have the effect of reversing the proportions.

 

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy are not expected to have any disproportionate impact based on sex. The changes apply equally to all tenants, regardless of gender, and do not introduce any criteria or processes that would disadvantage individuals based on sex.

Race

x

 

 

 

North Yorkshire has a much lower proportion (4.77%) of people who identify with a non-UK identity than the national average (12%).

 

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy are not expected to have any disproportionate impact on individuals based on race or ethnicity. The changes apply equally to all tenants, regardless of racial or ethnic identity, and do not introduce any barriers, exclusions, or differential treatment.

Gender reassignment

x

 

 

In the 2021 census 1478 (0.28%) of residents across North Yorkshire identified themselves as transsexual or with a gender identity different to that registered at birth.

 

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy are not expected to have any disproportionate impact on individuals who share this protected characteristic. The changes apply equally to all tenants and do not introduce any barriers or exclusions based on gender identity. The Council is committed to ensuring that all tenants are treated with dignity and respect, and that housing services are inclusive and accessible to all.

Sexual orientation

x

 

 

In the 2021 census 11,291 (2.2%) of residents across North Yorkshire identified themselves as Lesbian, Gay, Bisexual, or Other (LGB+).

 

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy are not expected to have any disproportionate impact on individuals based on sexual orientation. The changes apply equally to all tenants and do not introduce any barriers or exclusions related to sexual orientation. The Council is committed to ensuring that housing services are inclusive and respectful of all sexual orientations, and that all tenants are able to participate fully in the consultation process.

Religion or belief

x

 

 

North Yorkshire has higher levels of Christians (55.6%) than the national average (46.2%), and lower levels of all other religions than the national average. Percentages of those with no religion or not stating their religion are broadly similar to the national average.

 

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy are not expected to have any disproportionate impact based on religion or belief. The changes apply equally to all tenants and do not introduce any criteria, processes, or service standards that would disadvantage individuals based on their faith or belief system. The Council remains committed to ensuring that housing services are inclusive and respectful of all religious and non-religious beliefs.

Pregnancy or maternity

x

 

 

 

In 2021 there were 5133 live births in North Yorkshire.

 

In 2020 the conception rate per 1000 for under 18’s was 10.9. This is below the rate for England (13).

 

In 2020/21 4.2% of deliveries in North Yorkshire were to mothers from ethnic minorities, compared to the England value of 21.6%.

 

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy are not expected to have any disproportionate impact on individuals who are pregnant or on maternity leave. The changes apply equally to all tenants and do not introduce any barriers or exclusions based on pregnancy or maternity status.

Marriage or civil partnership

x

 

 

A higher percentage of North Yorkshire’s population is married or in a civil partnership (53.7%) than the national average (46.8%)

 

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy are not expected to have any disproportionate impact on individuals based on marital or partnership status. The changes apply equally to all tenants, regardless of their relationship status, and do not introduce any barriers or exclusions related to this characteristic. The Council remains committed to ensuring that all tenants are treated fairly and consistently.

 

 

Section 7. How will this proposal affect people who…

No impact

Make things better

Make things worse

Why will it have this effect? Provide evidence from engagement, consultation and/or service user data or demographic information etc.

..live in a rural area?

x

 

 

The population in North Yorkshire is generally sparser than the national average (77 people per square kilometre as opposed to 434 nationally). In some parts of the county this is lower still (Ryedale 36, Richmondshire 38, Craven 48, Hambleton 69).

 

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy are not expected to have a disproportionate impact on tenants living in rural areas. The changes aim to harmonise tenancy terms and improve service delivery across all localities, including rural communities.

 

…have a low income?

x

 

 

 

The proportion of households in deprivation in North Yorkshire reduced between 2011 and 2021. In 2011 52.1% of households in North Yorkshire were deprived in at least one of the four dimensions (employment, education, health and disability, housing).

 

By 2021 this had fallen to 46.7%. This 5.4 percentage point reduction in North Yorkshire compared with a 5.9 percentage point reduction across England as a whole, with the proportion of households in deprivation in North Yorkshire remaining below the national average.

 

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy are not expected to have a disproportionate impact on low-income households. The changes do not introduce new financial obligations or barriers. While the proposed 52-week rent collection model may alter payment schedules, it is intended to support more consistent budgeting and reduce confusion around non-collection weeks.

…are carers (unpaid family or friend)?

 

x

 

 

Carers’ allowance claimants make up 0.98% of North Yorkshire’s population.

 

This is lower than the average for England (1.42%) but there are variations across the county. It is likely, however, that these figures do not reflect the true number of people carrying out caring roles in the county as many do not claim allowances.

 

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy are not expected to have a disproportionate impact on unpaid carers. The changes apply equally to all tenants and do not introduce any barriers or exclusions based on caring responsibilities.

 

 ….. are from the Armed Forces Community

 

x

 

 

 

North Yorkshire has 29,831 Armed Forces Veterans. Richmondshire has the highest proportion of Armed Forces Veterans in North Yorkshire at 9.5% (3,962), which is the third highest nationally.

 

The proportion of veterans in Richmondshire is more than double the national average rate, which is 3.8%.

 

Harrogate has the highest number of Armed Forces Veterans in North Yorkshire with 7,076 (5.2%).

 

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy are not expected to have a disproportionate impact on members of the Armed Forces Community. The changes apply equally to all tenants, including those with military service, and do not introduce any barriers or exclusions. The Council recognises the unique needs of veterans and remains committed to ensuring that housing services are inclusive and responsive to this community.

 

 

Section 8. Geographic impact – Please detail where the impact will be (please tick all that apply)

North Yorkshire wide

 

 

Craven

 

 

Hambleton

 

 

Harrogate

x

Richmondshire

x

Ryedale

 

 

Scarborough

 

 

Selby

x

If you have ticked one or more areas, will specific town(s)/village(s) be particularly impacted? If so, please specify below.

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy apply to tenants living in council-owned housing stock. Currently, this stock is concentrated in the former stock-holding areas of Harrogate, Richmondshire, and Selby. These areas will be most directly affected by the changes.

As North Yorkshire Council continues to expand its housing provision across the county, the unified tenancy agreement and policy framework will ensure a consistent and equitable approach to tenancy management in any new areas where council housing is developed or acquired. The proposal supports county-wide harmonisation and will ultimately benefit tenants across all localities.

 

Section 9. Will the proposal affect anyone more because of a combination of protected characteristics? (e.g. older women or young gay men) State what you think the effect may be and why, providing evidence from engagement, consultation and/or service user data or demographic information etc.

 

There is no current evidence to suggest that the proposed variation to the Tenancy Agreement or amendments to the Tenancy Policy will disproportionately affect individuals due to a combination of protected characteristics. The changes apply equally to all tenants, regardless of their personal characteristics or circumstances.

 

 

Section 10. Next steps to address the anticipated impact. Select one of the following options and explain why this has been chosen. (Remember: we have an anticipatory duty to make reasonable adjustments so that disabled people can access services and work for us)

Tick option chosen

1.      No adverse impact - no major change needed to the proposal. There is no potential for discrimination or adverse impact identified.

x

2.      Adverse impact - adjust the proposal - The EIA identifies potential problems or missed opportunities. We will change our proposal to reduce or remove these adverse impacts, or we will achieve our aim in another way which will not make things worse for people.

 

3.      Adverse impact - continue the proposal - The EIA identifies potential problems or missed opportunities. We cannot change our proposal to reduce or remove these adverse impacts, nor can we achieve our aim in another way which will not make things worse for people. (There must be compelling reasons for continuing with proposals which will have the most adverse impacts. Get advice from Legal Services)

 

4.      Actual or potential unlawful discrimination - stop and remove the proposal – The EIA identifies actual or potential unlawful discrimination. It must be stopped.

 

Explanation of why option has been chosen. (Include any advice given by Legal Services.)

 

The proposed variation to the tenancy agreement and amendments to the Tenancy Policy formalise procedures that are already in place under national legislation and across the former district councils of Harrogate, Richmondshire, and Selby. The changes do not introduce new eligibility criteria or restrictions, but instead consolidate existing practices into a single, consistent framework for North Yorkshire Council.

 

Legal Services have reviewed the proposal and confirmed that the approach is compliant with statutory requirements under the Housing Acts 1985 and 1996. The consultation process will be inclusive and accessible, and reasonable adjustments will be made to ensure that disabled tenants and others with protected characteristics can participate fully.

 

 

 

Section 11. If the proposal is to be implemented how will you find out how it is really affecting people? (How will you monitor and review the changes?)

 

The Council will monitor the impact of the proposed tenancy agreement and Tenancy Policy amendments by reviewing service data, including customer contact, complaints, and feedback received during and after the consultation period. This will help identify any unintended impacts on tenants with protected characteristics.

 

Post-implementation reviews will be conducted to assess how the changes are working in practice. Adjustments will be made where necessary to ensure fairness, accessibility, and compliance with equality duties. Feedback from tenants and frontline staff will be used to inform future improvements to tenancy management and policy development.

 

 

 

Section 12. Action plan. List any actions you need to take which have been identified in this EIA, including post implementation review to find out how the outcomes have been achieved in practice and what impacts there have actually been on people with protected characteristics.

Action

Lead

By when

Progress

Monitoring arrangements

 

 

 

 

 

 

 

 

 

 

Section 13. Summary Summarise the findings of your EIA, including impacts, recommendation in relation to addressing impacts, including any legal advice, and next steps. This summary should be used as part of the report to the decision maker.

 

This Equality Impact Assessment has considered the potential effects of the proposed introduction of the NYC Tenancy Agreement for secure and introductory tenancies and amendments to the Tenancy Policy, including the introduction of a 52-week rent collection period and potential change to tenancy start dates.

The proposal aims to harmonise tenancy terms across most of the Council’s housing stock, replacing legacy agreements for secure and introductory tenancies. Existing Harrogate and Selby flexible tenancies will remain on their legacy agreements until the end of their fixed term, after which they will convert to the NYC secure tenancy agreement.

No adverse impacts have been identified for individuals with protected characteristics. The changes apply equally to all tenants within the scope of the agreement and do not introduce new eligibility criteria or restrictions. The consultation process will be inclusive and accessible, with reasonable adjustments made to ensure participation from all tenant groups.

Legal Services have reviewed the proposal and confirmed its compliance with statutory requirements under the Housing Acts 1985 and 1996. Ongoing monitoring will be undertaken to assess the real-world impact of the changes and ensure that any unintended consequences are addressed.

The proposal is recommended for implementation.

 

 

Section 14. Sign off section

 

This full EIA was completed by:

 

Name: Imogen Downie

Job title: Housing Policy and Strategy Officer (Service Improvement)

Directorate: Community Development

Signature: Imogen Downie

 

Completion date: Sept 2025

 

Authorised by relevant Assistant Director (signature): A Rowe

 

Date: 15 January 2026