Temporary Accommodation - Property Management Direct Award

Westminster City Council intends to put in place a six‑month interim contract for the management of its Temporary Accommodation (TA) property portfolio to ensure continuity of statutory housing, safety and compliance obligations while the competitive procurement for the long‑term contract is completed. The service includes compliance and safety checks, maintenance and repairs, inspections, tenant and void management, and out‑of‑hours support for residents in Council‑owned and leased temporary accommodation.

The existing contract expires on 31 March 2026, while the newly tendered service is scheduled to commence on 1 October 2026, creating a required interim period.

Regulation 26(h) – Direct award to a supplier that is not an excluded supplier

The contract is being awarded directly to Places for People Group Ltd, which is not an excluded supplier, because a direct award justification applies under section 41(1)(a) of the Procurement Act 2023.

Regulation 26(i) – Applicable direct award justification and explanation

The Council relies on the following direct award justifications set out in Schedule 5 to the Procurement Act 2023:

Paragraph 6 – Technical reasons

Paragraph 7 – Exclusivity due to compatibility requirements

Explanation:

The incumbent provider holds all relevant statutory safety data, compliance records, operational processes, and systems fully embedded across a portfolio of over 2,000 properties.

Replacing the incumbent for a short six‑month period would create technical incompatibility, disproportionate operational difficulty, and material risk to compliance with statutory housing and safety duties.

No alternative provider could mobilise safely or compliantly within the available timeframe before 1 April 2026, and market interest in a contract of this duration is highly unlikely.

An interim arrangement with the incumbent is therefore required to ensure continuity of legally compliant housing services during the transition to the new long‑term contract.

Regulation 26(r): Assessment of suitability for SMEs and VCSEs

The contracting authority does not consider that this contract is particularly suitable to be awarded to:

(i) a small or medium‑sized enterprise (SME), or

(ii) a non‑governmental, value‑driven organisation that principally reinvests its surpluses (VCSE),

because:

The service requires an incumbent‑level operational footprint, including embedded compliance systems, established data management processes, and detailed knowledge of a large and complex Temporary Accommodation portfolio of over 2,000 properties.

Delivering the required statutory functions safely and compliantly within the six‑month period requires continuity of existing operational systems, supply chain arrangements, and staff knowledge, which SMEs and VCSEs are unlikely to be able to mobilise within the extremely limited timeframe.

Market engagement and prior contract history indicate that the service model, scale, and mobilisation demands are such that the contract is not well‑suited to smaller or value‑driven organisations for this interim period.

Therefore, the Council does not consider the contract to be particularly suitable for SMEs or VCSEs under Regulation 26(r).

Regulation 26(s): Description of risks

The contracting authority has identified the following risks which:

(aa) could jeopardise the satisfactory performance of the contract, but

(bb) because of their nature, may not be fully addressed in the contract as awarded,

and

(ii) may require a subsequent modification under Schedule 8, paragraph 5 of the Procurement Act 2023 if these risks materialise.

Identified Known Risks

1. Data reconciliation and systems‑integration risk

The interim contract relies on transferring and aligning existing compliance data, safety records, and asset information from legacy systems. Variations or gaps detected after service commencement may require technical adjustments not foreseen at award.

Such technical risks may necessitate amendments to data‑handling processes or reporting requirements under Schedule 8(5).

2. Supply‑chain continuity and contractor availability risk

The incumbent’s subcontractor and specialist supply chain may be subject to unforeseen capacity pressures or market constraints. If supply‑chain instability occurs, the Council may need to vary elements of the service delivery model or response times.

This risk cannot be fully mitigated at award due to external factors and may require modification to maintain service continuity.

3. Volume and demand fluctuation risk within the TA portfolio

Unexpected increases in the number of properties managed, or spikes in repairs and safety‑check demand, could exceed the forecast workloads assumed in the six‑month period.

If this occurs, additional service capacity or varied service volume may need to be added via lawful modification.

4. Statutory compliance and safety regime changes

Changes in safety regulations (gas, electrical, fire safety) or urgent compliance directives issued during the contract term could require additional inspections, revised timeframes or expanded duties not fully captured in the initial scope.

As compliance obligations externally change, the awarded contract may need modification to remain legally compliant.

5. Access and safeguarding‑related risks

Where tenants refuse access, or where safeguarding issues escalate, additional interventions or specialised support may be required.

These risks cannot be fully addressed in the contract at award and may require operational adjustments if they escalate.