Back in October 2025, I reported that the Government has now confirmed the timeline for introducing the new Competency and Conduct Standard (CCS) for social housing, with implementation due in October 2026. You can read my blog about the Government's response to the consultation here. While additional transition time will come as a relief to many registered providers, the scale of change should not be underestimated.

In a recent article for Inside Housing, I explored the CCS from an employment law perspective, focusing on what it will mean in practice for providers, their workforce and their contractors. Four themes in particular stand out.

1. More time – but no room for complacency

Most registered providers will have up to three years to achieve full compliance once the standard comes into force, with smaller providers (under 1,000 units) given up to four years. This is more generous than originally proposed, but the work involved mapping affected roles, assessing qualifications, updating contracts and embedding cultural change means early planning is essential.

2. The CCS is about behaviour and culture, not just qualifications

Although much attention has focused on the requirement for housing managers and executives to work towards Level 4 and Level 5 qualifications, the CCS goes much further. It is equally concerned with professional conduct, competence and organisational culture, requiring providers to evidence how these expectations are embedded across HR systems, performance management and day‑to‑day practice.

3. Tenants will have a stronger voice

A notable shift is the requirement for tenants to have a meaningful opportunity to influence and scrutinise key policies and the new code of conduct. This moves providers beyond traditional consultation and towards ongoing tenant oversight, for example, through customer influence committees or formal scrutiny panels.

4. Workforce and resourcing risks need careful management

Training costs, capacity pressures and the risk of experienced staff choosing to exit rather than retrain could create real skills gaps, particularly for smaller providers. Support packages, flexible training routes and carefully drafted, staggered training‑repayment clauses may all play a role in retaining talent while remaining fair and legally compliant.

The CCS sits alongside other major reforms, including Awaab’s Law and the strengthened consumer standards, making this a challenging period for the sector. However, providers that embrace the spirit rather than the letter of the CCS, focusing on professionalism, competence and tenant respect, will be better placed to deliver safe, high‑quality services in the long term. 

Who might be interested?
This article is particularly relevant for HR and people teams, housing executives, boards, governance professionals, in‑house lawyers, and advisers working with registered providers, as well as contractors delivering housing management services.

How can we help?

For tailored advice for your organisation on issues including interpreting the guidance and helping you audit which roles are in scope, establishing robust policies and codes of conduct, dealing with the employment law implications of non-compliance, adapting your employment contracts and more, please contact Katherine Sinclair.