At a recent Housing Governance Conference, I had the opportunity to reflect on the evolving landscape of governance in the housing sector. With over two decades of experience supporting housing associations through regulatory challenges, I’ve seen time and again how what appears to be a minor operational issue often signals deeper systemic governance failures.

Organisations are becoming increasingly adept at identifying clear breaches of the Consumer Standards, particularly among private registered providers. However, the real challenge lies in what comes next: using these breaches as a mirror to examine the strength of internal assurance and control systems. 

Any problem which could constitute a breach of the law or any of the regulatory standards, which could damage the sector’s reputation, or which could indicate a weakness in the organisation’s controls and assurance framework is a breach of the Governance and Financial Viability Standard (GFVS). This broader, more integrated view is essential for modern housing governance.

One of the most powerful tools available to organisations is the self-referral process. The quality of a self-referral can significantly influence the regulator’s response, and the process of assessing whether a self-referral is necessary requires organisations to scrutinise not just what went wrong, but what that says about the organisation. It’s about demonstrating a deep understanding of the issue: who was affected, how long it persisted, why it happened, and what has been done to resolve it. It’s about showing not only that the steps taken to fix the issue are sustainable but that the organisation has taken the opportunity to identify wider ways they can strengthen their controls and assurance framework and make sure it is working effectively. This kind of embedded learning is not only valued by the Regulator but is also critical to building long-term resilience.

There are, however, common red flags that suggest systems and processes may be flawed. These include not identifying obvious warning signs such as tenant complaints and satisfaction data, failing to act early and effectively on known issues (that pernicious repair that isn’t repaired despite repeated visits), treating problems as isolated rather than systemic, and either lacking external assurance or relying on it too heavily without proper scrutiny. Not understanding what individual issues are telling you about the organisation. 

Often, it’s the governance team that spots the regulatory implications of what others see as operational problems. That’s why regulatory compliance must be hard-wired into every part of the organisation – it’s everyone’s business.

Boards have a particularly important role to play. A lack of sector awareness, insufficient challenge, and difficulty interpreting complex board reports can all hinder effective oversight. Boards must shift their mindset from viewing issues as operational hiccups and instead recognise them as governance signals. They must ask the right questions, seek genuine assurance, and stay attuned to the messages coming from tenant feedback, compliance data, and staff experiences.

Ultimately, every failure is an opportunity to learn and improve. Organisations that embrace this mindset and embed it into their governance culture are far better positioned to assure both themselves and the regulator that they are fit for purpose.

If you would like any further guidance or support, please contact me.