CPD module: Understanding and preparing for the Competence and Conduct Standard

The government’s Competence and Conduct Standard for social housing will come into force across England in October 2026.

This major regulatory change will apply to both registered providers (housing associations and local authority landlords) and to service providers and sub-contractors delivering housing management services.

This CPD article briefly outlines the requirements of the standard, but focuses primarily on the practical steps that housing providers can take to prepare for its implementation.

Why is the Competence and Conduct Standard being introduced?

The government is introducing the standard as part of its wider social housing reforms, to ensure social housing staff “have the appropriate skills, knowledge and experience to provide high-quality and respectful services to all tenants”. 

The decision to set this standard was a direct response to the Grenfell Tower Inquiry, which found that a lack of appropriate staff training and the dismissal of residents’ concerns contributed to the disaster, and to the tragedy of Awaab Ishak’s death, which also highlighted systemic failures around tenant engagement.

By embedding competence, conduct and qualifications as core requirements for social housing staff, the standard will be “an important step in professionalising the sector” and “will drive the culture change necessary to eradicate unprofessional attitudes and stigma”, according to the government.

What are the key elements and requirements of the Competence and Conduct Standard?

The two key elements of the standard are the general standard, which applies to all staff who deliver housing management services and aims to embed a positive culture and set of behaviours, and the qualification requirements, which require staff in certain senior roles to hold (or be working towards) a relevant housing qualification.

General standard

This requires a code of conduct setting clear expectations for staff regarding professional behaviour, ethics and respectful treatment of tenants, and a policy setting out how competence will be developed and maintained among staff. As this applies immediately, both of these need to be written and in place by October 2026, and tenants must have access to both.

Qualification requirements

This requires staff in certain senior roles – including senior housing managers and executives – to hold, or be working towards, a relevant housing qualification by the end of the relevant transition period (three or four years, depending on the size of provider) after the standard has come into force in October 2026. 

• Senior housing managers will need: an Ofqual-regulated Level 4 in housing management (or equivalent)
• Senior housing executives will need: an Ofqual-regulated Level 5 in housing or foundation degree (or equivalent)

The policy statement clarifies that:

• Equivalent or higher qualifications (eg degrees, CIH PQ, DipHE, HND) will be recognised if they meet content criteria
• Partially compliant qualifications can be “topped up” with additional accredited training modules
• Apprenticeships are explicitly recognised where they meet content and assessment requirements
• All qualifications must meet course-content criteria and the minimum TQT (total qualification time) of 120 hours

See this explainer article for more details on which roles will need qualifications, which roles are exempt and how much time staff will have to enrol on qualifications (including leeway and exceptional circumstances).

What are the timescales for implementation?

The Competence and Conduct Standard will come into force in October 2026, but there is a transition period:

• Large providers (managing more than 1,000 homes) will have three years to comply
• Smaller providers (managing fewer than 1,000 homes) will have four years to comply

How will the outcomes of the standard be monitored and enforced?

The standard will be monitored by both the government and the Regulator of Social Housing (RSH). The RSH will conduct an assurance-based approach to regulation, using its enforcement powers where improvement is necessary, while the government will monitor outcomes including levels of upheld complaints and tenant satisfaction measures. These processes are explained in full here.

How can landlords check if their staff members’ qualifications meet the content criteria? 

The government’s policy statement provides guidance on this. To check whether staff members’ qualifications meet the criteria, refer to Chapter 3 of the government’s policy statement, ‘Relevant Qualifications’ (page five).

As it is the responsibility of providers to ensure compliance, familiarity with this policy is very important.

How much will the qualifications cost, in both time and money? 

In the government’s consultation, providers expressed concerns about the cost of required qualifications for staff members, as well as the cost of working hours lost from staff while they undertake these qualifications. 

Monetary cost

The government’s impact assessment has assumed that the cost of a Level 4 qualification (for senior housing managers) is between £148 and £2,500, and the cost of a Level 5 qualification (for senior housing executives) is between £188 and £2,995.

It has also estimated a one-off ‘familiarisation cost’ (meaning the time taken for staff to learn about and understand new regulations, systems and procedures under the standard) of £7.3m across the sector for the first year – assuming that 25% of familiarisation time will be executive time, and 75% senior management time.

Time/opportunity cost 

A Level 4 qualification will take each individual 195-360 hours, a Level 4 apprenticeship 496 hours and a Level 5 qualification 380-385 hours, which effectively means the individual learner commitment is up to eight hours per week.

This study time could present a service delivery risk for providers, should services to tenants be disrupted by large numbers of staff taking this time out at once. See below for how landlords can prepare appropriately.

The government’s equality impact assessment notes that the extra academic and time responsibilities incurred by the qualification requirements may negatively impact protected groups within the workforce, including women, disabled staff members and staff members taking maternity leave.

Will the standard have an impact on staff recruitment and retention, and how can landlords mitigate this risk?

Some providers have raised concerns that the standard’s qualification requirement could make it more challenging to recruit new staff, or lead to existing staff leaving the sector.

This particularly applies to experienced senior housing executives within smaller landlords, who fulfil a wide breadth of functions but who hold high-level qualifications only for some elements of their role. 

Additionally, if staff ‘in scope’ of the qualification requirements either refuse to undertake or fail to achieve the relevant qualification, they could potentially have to be dismissed despite performing well in their role for years.

To mitigate financial and staff losses, landlords may want to look at restructuring management and executive teams, and reallocating responsibilities to reduce the number of people required to obtain qualifications.

This approach does risk allowing structural changes to drive decisions in a way that could negatively affect service delivery. For advice on how to manage this, see below.

To plan for staff training, it will be crucial for providers to assess who is in scope and who among them does not meet the qualification requirements.

Providers should conduct a knowledge and skills audit that does the following:

• Identifies which roles within their organisation should be defined as ‘in scope’
• Maps out who already holds the right qualifications, skills and experience, who needs to upskill and who has existing qualifications that partially count and can be topped up

A transition period of three years for large providers and four years for small providers means that, if planned in advance, providers can split in-scope staff into cohorts to allow them to obtain their qualifications sequentially.

What other steps can housing providers take to start preparing for the standard now? 

Following the government’s policy update in October, providers can now make specific plans to ensure compliance.

This preparation needs to be holistic: HR and learning and development teams will have a critical role to play in planning, governance boards will need assurance that compliance plans are in place, and the relevant staff members in procurement or contract management will need to oversee contractor management and terms of service contracts to ensure compliance.

Steps that housing providers can take now: 

• Identify which roles fall within the scope of the qualification requirement. Managers should review the guidance in Annex A of the policy statement to help assess which roles fall in or out of scope.
• Review existing qualifications held by staff and contractors. Managers should conduct a knowledge and skills audit (see above) to identify any gaps in these individuals’ existing qualifications. Begin conversations now with accredited training providers, professional bodies and learning partners.
• Establish development programmes to ensure that staff are able to meet the general standard during the transition period. Based on the new code of conduct and written policy, providers should assess where training may be needed to educate and support staff to comply, making clear records of training needs, qualifications held and plans to close any gaps. This also helps to evidence that staff understand these documents and that they are genuinely embedded.
• Plan for the additional training and study time costs. Managers should consider financial resources to cover these and when they might be incurred, planning training timing to mitigate against impact on service delivery (see above). Consider flexible learning options and reasonable adjustments to meet the varied needs of teams – including for disabled staff who may have difficulties accessing traditional learning and assessment methods.
• Carry out strategic workforce planning to ensure that services continue to be provided when staff are taking time out for study. Where possible, providers should ensure that any expected pinch points in service delivery are factored into the timing of staff undertaking training courses.
• Consider arrangements for backfilling to cover training commitments. Providers should plan training times for when cover (from other staff or temporary resource) is more likely to be readily available.
• Ensure there are sufficient performance management processes in place. These should specifically reinforce the expected standards of competence, conduct and professional behaviour in the code of conduct. Landlords should keep records showing how poor performance and conduct are managed.
• Consider how tenants can become involved. The general standard requires landlords to engage customers in co-designing or updating their code of conduct and written policy, in order to strengthen trust and accountability and lead to better outcomes. Focus groups, surveys and customer panels are all effective ways to engage with tenants.

Summary

The Competence and Conduct Standard is an important step in eradicating unprofessional attitudes among housing staff, but it potentially will present a service delivery risk for providers. Consider advance planning to mitigate financial and time costs, and conducting a knowledge and skills audit to prepare for the new qualification requirements.

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