Accredited official statistics

Social housing sales and demolitions 2022-23: technical notes

Updated 27 June 2024

Applies to England

1. Accredited Official Statistics Status

This publication is badged as Accredited Official Statistics (referred to as ‘National Statistics’ in the 2007 Statistics Act).

Accredited Official Statistics status means that our statistics meet the highest standards of trustworthiness, quality and public value as set out in the Code of Practice for Statistics. It is the Department for Levelling Up, Housing and Communities’ statisticians’ responsibility to maintain compliance with these standards. The designation of these statistics as Accredited Official Statistics was first confirmed in December 2011 following an assessment by the UK Statistics Authority. These statistics last underwent a compliance check against the Code of Practice for Statistics in June 2018.

The section on Net Supply of Affordable Housing is badged as Official Statistics in Development (formerly known as Experimental Statistics). The statistics in that section are in the testing phase and not yet fully developed. Users should be aware that Official Statistics in Development will potentially have a wider degree of uncertainty. The limitations of the statistics are explained below.

2. Data collection

The statistics in this publication and related tables are based on six sources:

1. The Local Authority Housing Statistics (LAHS) data collection administered by DLUHC and its predecessors;

2. The Statistical Data Return (SDR) from the Regulator of Social Housing (RSH);

3. The COntinuous REcording (CORE) of social housing sales data collection run by DLUHC;

4. The Investment Management System (IMS) administration system run by Homes England;

5. The GLAOps system used by the Greater London Authority;

6. Affordable Housing Supply statistics.

Right to Buy Sales of local authority stock are collected through LAHS. This provides information at district level for all local authority council Right to Buy sales as well as discounts. The Regulator of Social Housing collects stock sale information from private registered providers through the Statistical Data Return (SDR).

Data from LAHS and the SDR is used to compile social housing sales totals in Live Table 678, demolitions in Live Table 684 and the headline figures for this report. These sections include sales under the Right to Buy, Preserved Right to Buy, Voluntary Right to Buy, Right to Acquire, Social HomeBuy, 100% staircased low-cost home ownership and sales for non-social use. The figures exclude initial sales (first tranche) through low-cost home ownership schemes, such as shared ownership, and those sales which do not relate to existing social stock, i.e. sales of newly built homes for shared ownership or acquisitions of private sector homes for affordable home ownership. Sale and transfers of social housing stock for social housing use between social housing providers are also excluded.

Since the January 2022 release, to maintain consistency with other columns in table 678, the main source for these sales has been changed to LAHS and the P1B forms, the precursor to LAHS. In previous versions of this publication, the Pooling of Capital Receipts return was used as the main source of data for local authority Right to Buy sales.

The number of 100% staircased sales of shared ownership properties by local authorities is also included in table 678. Data on these sales by local authorities are only available from 2018-19.

Shared equity sales to tenants are recorded at the point of initial sale in CORE. Private Registered Providers are required to complete CORE Sales logs. Social landlords that are not registered with the Social Housing Regulator but affiliated to the National Housing Federation are invited on a voluntary basis to complete CORE Sales logs. Local authorities are also invited to return the forms on a voluntary basis, but only a small number choose to do so. The data from CORE is therefore almost exclusively consistent of PRP sales. Additionally, some entries are imputed or removed where appropriate due to incompleteness or data quality issues in the financial information. As such, the CORE Sales figures reported in this release do not cover all private registered provider sales, and instead should be considered a subset of private registered provider sales and be treated as a convenience sample.

The CORE Sales return captures information on each individual sale ^{[footnote 1]}, including the demographic characteristics of the purchaser. These demographic questions are voluntary however and not reported for all sales. CORE is also used to estimate the proportion of Right to Buy sales that are flats. CORE records for Shared Ownership sales are included in the characteristics and financial sections. 

The IMS is a Homes England system for administering grants. In areas coved by the GLA this is now recorded by GLAOps as part of the GLA’s Affordable Housing Statistics. These sources provide data on private registered provider Right to Acquire and Social HomeBuy sales. These are considered the preferred sources for these data. However, data on these schemes collected through the SDR is used in the headline figures and Live Table 678 for consistency with other data. Data from these sources is presented in Live Tables 677 and 683, respectively.

Affordable Housing Supply statistics are collated from LAHS, GLAOps and the IMS, as well as:

• The Project Control System (PCS) used by Homes England and, until 2017-18, by the Greater London Authority, which contains data on a number of housing and regeneration programmes. These data are also published in Homes England’s Housing statistics publication.

• Homes England’s figures for Private Finance Initiative (these ceased in 2017-18).

• Greater London Authority’s figures on additional units not reported in the main IMS/GLAOps returns.

• Administrative data from the Department’s Affordable Homes Guarantees programme delivery partner.

• The July data from the bi-annual Traveller Caravan count (TCC) published by DLUHC, which records the number of caravans and pitches on sites across England at January and July.

3. Data quality

3.1 Things to note on this release

All local authority sales and demolitions are available broken down by Local Authority from 1999-00 to 2021-22, with PRP sales and demolitions broken down by local authority area available from 2011-12 to 2021-22. We are releasing an open data format file alongside this publication, including the time series of the social housing sales and demolitions data from 1980-81 onwards. Data for private registered providers is only available at England level before 2011-12. Please see the “Accompanying tables and open data” section below for further details.

Sections B and K of the Local Authority Housing Statistics (LAHS) are released alongside this publication. We expect to publish the final version of this year’s data in June/July 2024 following the scheduled revisions for LAHS.

In June 2024 the methodology for Live Table 682 was updated. The new methodology differs in that it excludes data from local authorities where one of their values for number of sales, selling price or discount is either missing or is 0 – this avoids including in the table returns where local authorities have reported incomplete data, e.g. reported sales but not provided information on how much money they received (which would skew the average national values). Returns since 2014 are also suppressed that indicate an average percentage discount above 70% (which is not allowed by the regulations), as well as average monetary discounts above the maximum threshold for the year/authority.

4. Assessment of data quality

In 2015, the UK Statistics Authority (UKSA) published a regulatory standard for the quality assurance of administrative data. To assess the quality of the data provided for this release, the department has followed that standard. The standard is supported with an Administrative Data Quality Assurance Toolkit which provides useful guidance on the practices that can be adopted to assure the quality of the data they utilise.

The Social Housing Sales and Demolitions statistical release is produced by DLUHC based on data provided by Homes England, the Regulator of Social Housing, the Greater London Authority, Local Authorities and other data collections held by the department. An assessment of the level of risk based on the Quality Assurance Toolkit is as follows:

Risk/Profile Matrix Statistical Series	Administrative Source	Data Quality Concern	Public Interest	Matrix Classification
Social Housing Sales Statistics	Homes England, GLA and Local Authorities’ individual data systems.	Low	Medium	Low Risk [A1]

The publication of Social Housing Sales and Demolitions statistics can be considered as medium profile, as there has been mainstream media interest, with moderate economic and/or political sensitivity. The data quality concern is considered low given that the data is checked by providers and most of the data would have been released in publications that are compliant with the Code of Practice for Statistics and subject to data quality checks prior to publication. Overall, the Social Housing Sales and Demolitions statistics have been assessed as A1/Low Risk.

External data sources (GLAOps, IMS and the SDR) undergo their own internal data quality processes. Statistics which come from these sources are compared by DLUHC statisticians to previous years’ data, and DLUHC will contact the data providers if any potential issues are identified.

LAHS and CORE sales data are collected and quality assured by DLUHC statisticians. The LAHS collection is on the Single Data List, and continuous engagement with the Central Local Information Partnership Housing (CLIP-H) subgroup ensures that changes to the form are approved by providers. If changes are not approved, changes can be either adapted, dropped or further burden assessments performed.

All data are pulled together into live tables and the statistical bulletin, which is quality assured by another statistician.

5. Operational context and administrative data collection

As some Local Authorities do not own any stock and therefore cannot make any social housing sales, they provide no information through their LAHS return. As at 31 March 2023 there were 309 local authorities, of which 165 reported having a Housing Revenue Account. Local authorities are required to have an HRA if they own at least 200 units, and some local authorities may own a small amount of stock without having an HRA. Local authorities which own stock but do not have an HRA may still report sales to tenants of relevant residual stock. In 2022-23, 1 local authority did not submit any data and 4 submitted unfinalized data.

Every effort is made to collect data from every Local Authority but on occasion estimates may be used (see imputation). Care should be taken using data at a Local Authority level as the totals are low and therefore can vary greatly year on year.

All private registered provider social landlords that are registered with the RSH complete the SDR which includes data on changes to their stock, including sales and demolitions. The SDR sales data does not include information on property type. Until 2022-23, the data for sales to sitting tenants was not broken down by type of sale at local authority level, but from this year this breakdown is included in the open data. This information is only available from large providers with over 1,000 stock.

Instead, data on the characteristics of the properties sold by private registered providers is taken from COntinuous REcording (CORE) returns. This method assumes that the property type distribution of any sales not reported on CORE, such as those by small PRPs, is the same as those for larger PRPs.  

The SDR does not ask private registered providers to provide financial information on their sales of stock. However, CORE returns do include financial data on social housing sales. The financial information is instead taken from CORE and summarised as the arithmetic mean values for the reported sales.

The CORE Sales data undergoes some imputation of financial variables such as mortgage, property value, and deposit. For the purposes of analysing financial data, some entries are removed due to missing data or data quality issues . As a result, the final data used for this release has complete financial information, some of which has been imputed.

Homes England and the GLA collect information provided by PRPs that have applied to receive grants on the number of Right to Acquire and PRP Social HomeBuy figures. Because they are based on grant funded completions, these are the preferred series for these data, and they are published in Live Tables 677 and 683 respectively. However, data on Right to Acquire and Social HomeBuy are also reported through the SDR and used for the headline figure and as part of Live Table 678, for consistency of data sources in that table.

6. Communication with data supply partners

There are regular contacts with the data suppliers for this release to ensure that there is a common understanding of what information is being supplied. Communication with suppliers is managed through a number of formats, e.g. regular contact with local authority data providers and the Central Local Information Partnership Housing subgroup (CLIP-H).

For data collected in LAHS please see the technical notes. CORE Sales communication is delivered primarily via its website.

There is a clear Memorandum of Understanding between DLUHC, Homes England and the GLA outlining the terms of what data are provided and timescales.

7. QA principles, standards and checks by data suppliers

The SDR collection and release have been assessed and are badged as an Accredited Official Statistics Publication.

The LAHS data return is also badged as Accredited Official Statistics and contains mandatory and non-mandatory questions. Validation rules have been developed at both collection point and during data processing. Where a validation rule has triggered values, these are queried with the respective local authority. Further details on the QA of this return can be found in the LAHS technical notes.

The Mayor of London has a commitment to achieve full compliance with the Code of Practice and the GLA revises its data to ensure quality of information. Details of the operational context and quality assurance procedures of how these figures are collected are included in those sources.

The CORE Sales data is provided from around 170 Private Registered Providers, the Department does not have full oversight of their systems and quality procedures. We provide clear guidance and documentation to them via the CORE system. Data received by the Department undergoes an extensive validation and imputation process.

7.1 Producers’ QA investigation and documentation

Whilst providers are expected to carry out their own checks before the data is submitted for this publication, further quality assurance is carried out once the data is received by the responsible statisticians for this publication. The data are compiled together and compared to the raw data, published figures, historical time series and policy information that may have impacted the figures. Queries are escalated to producers if it is necessary to clarify further. The data, report and tables are quality assured independently by another statistician in the production team. Further final checks are performed to the final end product.

These checks use a clear checklist approach to ensure the figures are consistent across the release and live tables, with each check being systematically signed off when it has been completed.

8. Imputation 

Imputations are performed on CORE Sales data.

Imputation rules are based on checks of multiple fields and examination of extreme or inconsistent values. For this release, imputation is performed in cases where the mortgage and/or deposit are unknown, but the sale price was known. Where either mortgage or the deposit are missing, the missing value is calculated based on the other value and the sale price. Where both entries were missing, the deposit is assumed to be equal to 10% of the sale price. Entries with impossible values (e.g. a deposit greater than the market value of the property) are corrected or imputed where possible based on the available values, or otherwise removed. More detail on the imputation process is available upon request.  

Imputation is not performed on Section B of LAHS used in this release, however, for Section K, imputations are done in cases where the sum of categories does not match the corresponding total. For further details, please see the LAHS technical notes.

The Regulator of Social Housing does not apply imputation to their data but does apply weighting. For further details, see the SDR technical notes.

9. Definitions

Figures on social housing sales include only sales which result in existing stock leaving the social sector. These include sales under Right to Buy (RTB), Preserved Right to Buy (PRTB), Voluntary Right to Buy (VRTB), Right to Acquire (RTA), Social HomeBuy (SHB), other outright or shared equity sales to tenants and sales for non-social use (to other private registered providers or to the private sector). Also included are sales of low cost home ownership stock, like shared ownership, where the tenant has reached 100% ownership through staircasing transactions.

Sales of other kinds, such as initial shared ownership sales (first tranche) of newly built social stock or of private sector stock, partial staircasing transactions, stock transfers to Registered Providers, either from Local Authorities or other PRPs, are not included in the total social housing sales figures.

The figures do not include sales and transfers between local authorities and PRPs. Large Scale Voluntary Transfers (LSVTs) of local authority stock to PRPs and sales and transfers between PRPs for social housing purposes are not included in these figures. Further information on Large Scale Voluntary Transfers (LSVTs) of local authority stock to PRPs can be found in DLUHC’s Local Authority Housing Statistics (LAHS) and the RSH’s Statistical Data Return (SDR).

Demolitions are not included in the total social housing sales figures and are presented separately.

9.1 Other definitions

The definitions used in this publication can be found in the ‘Housing statistics and English Housing survey’s glossary published by DLUHC.

10. Revisions policy

This policy has been developed in accordance with the UK Statistics Authority’s Code of Practice for Statistics and the DLUHC Revisions Policy. It covers two types of revisions that the policy covers;

10.1 Non-Scheduled Revisions

Where a substantial error has occurred as a result of the compilation, imputation or dissemination process, the statistical release, live tables and other accompanying releases will be updated with a correction notice as soon as is practical.

10.2 Scheduled Revisions

Revisions to previous annual data are generally incorporated in the next release. Figures are not published in these statistics with a provisional status (but imputed estimates may be used). Revised figures are highlighted in the live tables.

Following scheduled revisions to the LAHS datasets in June/July 2024, Live Tables 678, 681, 682, 684 and 691b may also be revised, should it be necessary.

11. Other information

11.1 Uses of these statistics

These statistics are used to monitor social housing sales including Right to Buy sales and analyse the effectiveness of policy changes around Right to Buy and the housing sector. These statistics also allow to have a measure of the two main types of losses to the social housing sector: sales and demolitions of existing stock.

We have included a section contrasting the number of sales and demolitions of social housing with comparable new supply of affordable housing for rent (including acquisitions).

Data published alongside this release also provides important information on personal and financial characteristics of some of those buying properties through private registered providers, including existing tenants, those using Shared Ownership schemes or buying outright. These data also provide further information on these schemes. For instance, in LAHS, there is information now being collected on local authority Shared Ownership staircasing transactions that helps monitor the effectiveness of this scheme and the number of transactions that lead to the maximum allowed ownership. Data on staircasing of private registered provider shared ownership sales has been collected since April 2021.

12. Net Supply of Affordable Housing for Rent (Official Statistics in Development)

12.1 Background

The statistics presented in this section are a first step to address the July 2020 recommendation by the Housing Communities and Local Government select committee that:

The government must publish statistics on net additions of the different tenures of affordable housing per year, taking into account completions, sales, demolitions and conversions. These statistics are currently disparate or not collected. This is especially important to track changes in social rented stock which has been affected by significant number of conversions to affordable rent and Right to Buy sales. Data will need to be collected on Right to Buy sales for each tenure, demolitions per tenure, change of use per tenure, and all other reductions. This will bring social housing data in line with overall housing supply data.

In October of 2020, the government published its response to the select committee report. Specifically to the recommendation above, it responded that :

The department already publishes overall stock figures for local authority and private registered providers, the latter collected by the Regulator of Social Housing, including some information by social and affordable rent. Data already collected and published includes:

• Local Authority stock, including the social and affordable rent stock held within Housing Revenue Accounts;

• Demolitions and conversions by local authorities;

• Similar information for Private Registered Providers, which is collected by the Regulator of Social Housing;

• Social Housing sales, including Right to Buy and;

• Additional units to the affordable housing stock, by tenure, including those of local authorities, Private Registered Providers and Non-Registered Providers

The department will investigate the feasibility of publishing data on affordable housing.

Work has been ongoing with local authorities and the Regulator of Social Housing (which collects data from private registered providers) to collect all data necessary to provide a more comprehensive estimate, including by tenure. With this release we have included a new analysis on net supply of affordable housing for rent by tenure at England level.

12.2 Data collection and quality – Net Supply of Affordable Housing

This subsection applies only to the net supply of Affordable Housing for rent section. For the rest of the release, see the previous sections of these technical notes.

Statistics on Net Supply of Affordable Housing are badged as Official Statistics in Development (formerly known as Experimental Statistics). This means that these statistics are in the testing phase and not yet fully developed. Users should be aware that Official Statistics in Development will potentially have a wider degree of uncertainty.

These statistics are based on data are published in the Affordable Housing Supply statistics publication and the Local Authority Housing Statistics (LAHS) dataset released by the Department of Levelling Up, Housing and Communities and the Statistical Data Return (SDR) published by the Regulator of Social Housing.

The main source for supply gains is the Affordable Housing Supply publication, which covers new stock to affordable housing, complemented by some information on changes of use from the SDR and transfers between private registered providers and local authorities from LAHS and the SDR. Data on stock losses are sourced from LAHS and SDR.

Comparison between these statistics and rental stock figures between years show some differences, which are likely due to a combination of the following factors:

• these statistics only cover affordable housing for rent (those used for social rent, Affordable Rent, London Affordable Rent and intermediate rent);

• they only cover local authority and private registered provider stock; stock owned by non-registered providers is excluded, as is new supply where the provider is unknown;

• additionally only losses from stock owned by local authorities with a Housing Revenue Account ^{[footnote 2]} and larger private registered providers ^{[footnote 3]} are included in the data for some categories of stock losses (both of these account for nearly all local authority and private registered provider stock);

• there are gaps in the existing data, including limited or unavailable data for gains and losses of existing affordable housing, such as conversions and changes of tenure;

• the data are compiled across different sources, which while similar, occasionally do not cover exactly the same categories and definitions;

• there may also be differences due to timing issues, particularly with units delivered near the end of the financial year.

A new section, Section K, covering local authority changes to stock, has been introduced into LAHS. For 2021-22 submission of this section was voluntary and response rate was low – in 2022-23 the section was made mandatory. However, as the response rate was still not 100% and providers are still embedding the questions into their systems, we advise treating data collected this year with some caution.

As these are Official Statistics in Development, we are particularly keen to receive feedback via [email protected] on whether readers find them relevant, valuable, or whether there are any other comments.

13. Related Statistics

The Department for Levelling Up, Housing and Communities is part of a cross-government working group, including devolved administrations and the Office for National Statistics, working to improve the trustworthiness, quality and value of housing and planning statistics across the UK. This working group has published an action plan to make the planned improvements on house building statistics clear and transparent to users. Details of this work and how you can provide feedback are available via the Government Statistical Service website.

13.1 Social Housing Sales and Demolitions (this release)

• Source: DLUHC
• Annual estimates of sales for social housing stock in England. Characteristics for PRP sales are also shown. Annual - usually published in December/January
• Data Sources:
  • The Local Authority Housing Statistics (LAHS) form administered by DLUHC
  • The Pooling of Housing Capital Receipts return administered by DLUHC
  • The Statistical Data Return (SDR) from the RSH
  • The COntinuous REcording (CORE) data collection run by DLUHC
  • The Investment Management System (IMS) administration system run by the HE
  • Greater London Affordable Housing Statistics from the GLA.
• These figures provide an overview of all sales of social housing stock in England. Shared ownership sales are not counted as they are treated as supply and not the sale of existing stock.
• These figures provide characteristics for PRP sales that have been recorded in CORE sales.

13.2 Quarterly Right to Buy Management Information

• Source: DLUHC
• Quarterly estimates of Local Authority Right to Buy
• Data provided directly by local authorities
• ‘Leading indicator’ for the Right to Buy policy.
• Figures provided are Local Authority Right to Buy sales, the associated receipts. The starts on site and acquisitions of the delivered replacements.

13.3 Voluntary Right to Buy Midlands pilot Management Information

• Annual
• Published on 23 February 2023
• Data provided directly by Registered Providers
• Update on the progress of homes sold and replacements under the Voluntary Right to Buy (VRTB) Midlands pilot, which was launched in August 2018

13.4 Right to Buy Sales and Replacements

• Annual audited figures on Right to Buy Sales and Replacement of stock sold
• Published in August 2023
• Data provided directly by local authorities
• Figures provided are Local Authority Right to Buy sales, the associated receipts, as well as the starts on site and acquisitions of the delivered replacements.

13.5 Social Housing Lettings

• Source: DLUHC
• Annual estimates of lettings for social housing
• Last published January 2024
• Sources:
• The COntinuous REcording (CORE) data collection run by DLUHC.
• The Local Authority Housing Statistics (LAHS) form administered by DLUHC.
• These figures provide an overview of all lettings of social housing stock in England.

13.6 Affordable Housing Supply

• Source: DLUHC
• Overall affordable housing supply (new build and acquisitions )
• Annual, usually published in November
• Sourced from Homes England and Greater London Authority data which is published every six months combined with and Local Authority Housing Statistics Data
• Provides the most complete estimate of affordable housing supply. Affordable housing figures are a subset of total housing supply.

13.7 Local Authority Housing Statistics

• Source: DLUHC
• Stock and condition of Local Authority owned housing, including information on rents and waiting lists
• Annual
• No longer has a dedicated bulletin, the data is published between November and January
• Data provided directly by local authorities Information on the stock, condition and changes to local authority owned properties
• Different sections published usually between November and January.

13.8 Statistical Data Return

• Source: RSH
• Stock and condition of Private Registered Provider owned housing
• Annual
• Data provided directly by Private Registered Provider to the Regulator of Social Housing Information on the stock, condition and changes to Private Registered Provider owned properties. Local Authority Data Return Stock, rents and condition of Local Authority owned housing Annual Data provided directly by Local Authorities to the Regulator of Social Housing

13.9 Housing supply: indicators of new supply statistics

• Source: DLUHC
• Quarterly estimates of new build starts and completions
• Sourced from building control officers at:
• National House Building Council
• Local Authorities
• Approved Inspectors
• This is a ‘leading indicator’ of house building, available soon (< 2 months) after each quarter’s end

13.10 Housing supply; net additional dwellings

• Source: DLUHC
• Total housing supply that comprises all new build, conversions , change of use, other gains/losses and demolitions
• Annual, usually published in November
• Comes from local authorities outside London (Housing Flows Reconciliation Return) and for London boroughs is provided by Greater London Authority (London Development Database)
• Provides an accurate assessment of annual change in all housing stock and is the most comprehensive estimate of supply.

13.11 Dwelling Stock estimates

• Source: DLUHC
• Total housing stock, split by tenure
• Annual
• Usually published in May
• Overall change in stock from Net Additional Dwellings
• Tenure information provided directly from Local Authorities and Housing Associations.
• Provides an accurate assessment of the total size of the housing stock and how it is split by tenure

14. Devolved administration statistics

14.1 Wales

The Welsh Government publishes information on social housing sales, which does include information on Right to Buy sales. On 26 January 2019 ‘Right to Buy’ was repealed for all council and housing association tenants.

14.2 Scotland

The Scottish Government publishes information on social housing sales, however, from 1 August 2016 the ‘Right to Buy’ has been repealed for all council and housing association tenants.

14.3 Northern Ireland

In Northern Ireland social tenants have the right to a statutory house sale, which is similar to a “Right to Buy”, with data published online.

15. User engagement

Users are encouraged to provide feedback on how these statistics are used and how well they meet user needs. Comments on any issues relating to this statistical release are welcomed and encouraged. Responses should be addressed to the Housing Statistics inbox

The Department has published an engagement strategy to meet the needs of statistics users.

1. The latest forms are available online. Older forms are available upon request from [email protected]. ↩

2. Any local housing authority that owns 200 or more social dwellings are required to account for them within a Housing Revenue Account. ↩

3. The SDR only collects stock flow data from private registered providers (PRP) owning 1,000 or more units of social housing who are registered on 31 March each year. This means that stock flow data for smaller providers, or those who have developed within year but subsequently deregistered, will not be captured. Additionally, as providers only report activities which they have undertaken, units transferred into a provider may include development activity carried out by precursor bodies prior to a merger (e.g. PRP A develops 200 units prior to merging with into PRP B and transferring all of its stock. PRP B does not record this as development activity because it did not carry out the work and the 200 units would be recorded under the total units transferred into it). Units developed by subsidiaries or third parties that have ownership moved to a large SDR-submitting private registered provider may also sometimes be recorded as something other than new build activity depending on the legal form the change of ownership took. ↩