On 30 September 2025, the Government published its response to the consultation on the Competence and Conduct Standard for Social Housing, requiring the Regulator of Social Housing to introduce a Competence and Conduct Standard for social housing providers, effective from October 2026. 

We published a blog post in February 2024 reviewing the consultation document. In light of the Government’s responses to the consultation document, we have highlighted the key updates and changes below: 

The Regulator will be required to set a standard relating to the competence and conduct of all social housing staff

• The Government has amended its direction to the Regulator to include additional requirements in the standard. These relate to registered providers’ codes of conduct and written policies, which outline the registered providers’ approach to managing and developing the skills, knowledge, experience and conduct of relevant staff.
• In particular, registered providers will be required to:
  • Give tenants meaningful opportunities to influence and scrutinise the development of the policy and decisions relating to the adoption or development of the code of conduct; and
  • ensure that the policy and code of conduct are made accessible to tenants.
• The standard will be regulated in line with the Regulator’s outcomes-focused approach. 

Relevant persons who require relevant qualifications are further defined

• The Government has confirmed that senior housing managers must hold a level 4 qualification and senior housing executives must hold a level 5 qualification or a foundation degree. There is no change here. 
• However, the Government has refined and expanded its explanation of what a substantive role means in this context. A person is expected to spend the majority (usually more than half) of their working time managing delivery of housing management services to tenants, or managing the delivery of housing management services is an important and substantial aspect of their role. Annex A of the statement policy provides more guidance.

Service providers in the scope of the standard

• The Government introduced an exemption to the scope of the standard, which applies in relation to the relevant service provider managers of service providers that do not provide a comprehensive social housing management service to the registered provider. Service providers will only have staff who must work towards achieving the relevant qualification where the service provider delivers all or the majority of the functions in section 6.5 of the statement policy in relation to the registered provider’s social housing. 
• This includes: customer services management; complaints management; tenant involvement or empowerment; allocations and lettings management; management of tenancies and/or licenses; income management; repairs and maintenance; asset management (including building and/or fire safety management); anti-social behaviour management; estate management; and capital/major works within occupied buildings.

Relevant qualifications must contain certain areas of study. 

• The Government confirmed that relevant qualifications must amount to a total qualification time (TQT) of over 120 hours. 
• The policy statement has been amended to include that:
  • Staff do not need to undertake a full additional qualification if they already have a partially relevant qualification, and can undertake ‘top-up training’ modules to cover unmet criteria. For example, an employee with a technical training in quantity surveying would be required to undertake a 'top-up' module in housing customer service. Relevant staff who undertake a housing management-related apprenticeship and pass their apprenticeship assessment will not be required to undertake a specified qualification, either during or after the transition period. 
  • A recognition of qualifications which are not Ofqual regulated (because they are delivered by a higher education provider), or ones whose development pre-dated the current regulatory framework. We are pleased to see that the Government encourages qualifications providers to develop and update their systems for recognising prior learning to ensure that they are fit for purpose in the context of these new qualification requirements and encourages awarding bodies and qualifications providers to explore other practical routes for highly experienced and knowledgeable staff to gain qualifications, such as portfolio-based assessments.
  • The revised approach will enable staff to undertake qualifications most relevant to their roles and will mean that it is unlikely staff will need to hold multiple qualifications. It is the Government's aim for registered providers to have a level of flexibility to choose which housing-related qualifications are suitable for their staff’s roles and the needs of their organisation.
• These changes, alongside other changes made to the course content requirements, are intended to mitigate landlords’ concerns about recruitment and retention of staff, particularly in technical and specialist roles.

What does ‘working towards’ mean? 

• The consultation proposed that for staff to be ‘working towards’ a qualification, they must commence their course and start making progress towards completing their qualification within six months (except where there is no available course start date, in which case they should start within 12 months of enrolment).
• The definition of ‘working towards’ has been broadened. It now includes staff:
  • who are not yet enrolled but are making progress towards a relevant qualification, who have not completed a relevant qualification within the stipulated timescale due to two permitted reasons: 1) a person requires a reasonable adjustment due to a disability and 2) where the relevant qualification cannot be completed within the maximum two-year limit (such as an undergraduate degree). 
• Where staff fail to be awarded a relevant qualification, the policy has been amended to require the staff to retake the course or enrol on another relevant qualification within six months. 

The transition period 

• This period has now been extended from two years from the standard coming into force, to:
  • Three years for providers with 1,000 or more units.
  • Four years for providers with less than 1,000 units. 

Key preparation actions for employers to take

1. Review and update your policies and code of conduct to align with the new Standard and ensure tenants are given meaningful opportunities to influence these policies.
2. Assess staff roles and qualifications if you have not yet done so.
3. Engage with your service providers to decide whether they fall within the scope of the standard.
4. Plan for qualification compliance.
5. Support your staff ‘working towards’ qualifications - i.e., track progress, including those not yet enrolled, allow for reasonable adjustments and longer qualification timelines where justified.
6. Prepare for the transition period.

How we can help

Registered providers should take steps to ensure compliance with the standard when it comes into force. 

At Anthony Collins, we understand the unique challenges faced by registered providers. Our team of legal experts are well-equipped to provide advice to help registered providers thrive under the new standard. 

If you would like more information, have any questions about preparing for the Competence and Conduct Standard for Social Housing or need to draw on legal and strategic support, please contact me.