The Competence and Conduct Standard: what social housing providers must do

The Competence and Conduct Standard is a consumer standard set by the Regulator of Social Housing (RSH). It applies to all registered providers of social housing in England from 1 October 2026. Providers must make sure staff involved in landlord services have the skills, knowledge, experience and behaviours they need, keep a written policy on developing them, and adopt a code of conduct. Senior housing managers and senior housing executives must also hold, or be working towards, a qualification at a specified level.

The Standard is now in force. It’s the latest step in the push to professionalise social housing, and the message behind it is simple: tenants should be able to trust that the people running their homes know what they’re doing and behave well. If you work in HR, L&D or governance at a housing association, ALMO or local authority landlord, you’ve probably got three questions: who in my organisation is affected, by when, and what do I do first?

This guide answers all three. We cover who’s in scope, which roles need a qualification, the real deadlines, what you have to write down (and what you don’t), and the first steps you can defend in a board paper. It covers England only: the Standard doesn’t apply in Scotland, Wales or Northern Ireland.

What the Competence and Conduct Standard actually is

The Competence and Conduct Standard is one of RSH’s consumer standards. It sets out how landlords must make sure their workforce has the skills, knowledge, experience and behaviours to deliver good services, and which senior people need a qualification.

It isn’t new legislation or a statutory instrument. It’s a Government Direction plus a regulator’s decision, resting on three layers:

• The statute gives the powers. The Housing and Regeneration Act 2008 (ss.194A–194B, 217A), as amended by section 21 of the Social Housing (Regulation) Act 2023, lets Government direct the regulator. It also implies a contractual information term on contractors (s.217A)
• The Direction and Policy Statement set the qualification detail. The Direction, made on 23 September 2025, told RSH to set the standard. The Policy Statement covers roles, levels, content, equivalents and transition periods
• The Standard sets what you’re judged against. The Standard, issued through Decision Instrument RSH12 with effect from 1 October 2026, holds the workforce requirements. The revised Code of Practice is guidance on how RSH reads it

A useful rule of thumb: go to the Standard for what you must do, the Policy Statement for anything about qualifications, and the Code for how the regulator will interpret both. RSH originally consulted on folding this into the Transparency, Influence and Accountability Standard, but in July 2026 made it a separate standard, so older articles may say otherwise.

Who the Standard applies to

The Competence and Conduct Standard applies to all registered providers of social housing in England, both private registered providers and local authority landlords. Within that, what applies to each person depends on their role, not on the size of the organisation.

Size doesn’t exempt you

The threshold of fewer than 1,000 social housing units changes your transition period from 36 months to 48 months. It doesn’t take you out of scope. Small housing associations must meet every requirement in the Standard, and the workforce requirements applied to them from day one.

Exemptions are role-based

The Policy Statement exempts functions, not organisations. The following are outside the qualification requirement:

• Back-office managerial roles that don’t involve managing direct delivery of services to tenants, such as legal, IT support, data, procurement and HR
• Construction of new buildings and management of unoccupied buildings
• Delivery of care and support
• Oversight of the housing register and making statutory homelessness assessments

Contractors are in scope too

The competence outcome covers your services providers: you must take appropriate steps to make sure their relevant staff have the skills, knowledge, experience and behaviours needed. The qualification requirement is narrower. It only applies to relevant managers of services providers delivering a comprehensive social housing management service, meaning all or most of the housing management functions listed in the Policy Statement.

An ALMO or managing agent running most of your housing service is likely to be in scope, while a firm handling a single function, such as asset management, isn’t. An implied contractual term (s.217A) requires in-scope services providers to respond to reasonable requests for information showing whether the qualification standard is met.

Which roles need a qualification

Senior housing managers need a Level 4 qualification and senior housing executives need a foundation degree or Level 5 qualification, in each case regulated by Ofqual or an equivalent or higher. Other relevant staff have no qualification requirement.

What the qualification has to include:

• Volume. The qualification must have a total qualification time (TQT) of over 120 hours. That’s TQT, not guided learning hours: they’re different measures, and several sector summaries mix them up. TQT includes self-study and assessment time as well as taught time, so a course with fewer than 120 guided hours can still qualify
• Content. Requirements depend on the role:
  • General housing management (such as lettings, tenancies, income, complaints and ASB). Covers professional practice, equality and diversity, customer service, and national housing policy. Executives also need leadership and stakeholder engagement
  • Technical roles (such as repairs, asset management and building safety). Either the general route, or a relevant technical qualification that also covers customer service and equality and diversity
  • Cross-tenure roles. Either of the above, or a leasehold or residential property management qualification that also covers customer service and equality and diversity

• Equivalents. The Policy Statement accepts CertHE and HNC at Level 4; DipHE and HND at Level 5; apprenticeships at the equivalent level or higher; SQA, Qualifications Wales and CCEA equivalents; undergraduate and postgraduate degrees; and the CIH Professional Qualification for executives
• Top-ups. A partially compliant qualification, one that meets the level but only part of the content requirements, can be completed with additional training modules of appropriate volume, quality and level. The person doesn’t have to start again

There’s no official approved qualification list

The Policy Statement names no approved qualifications or awarding bodies. The CIH Professional Qualification appears only as an example of an equivalent, and nothing indicates a list is coming. Compliance is assurance-based: you decide whether a qualification meets the requirements, and you must be able to defend that decision.

What the Standard requires of everyone else

For everyone involved in landlord services, the Standard sets an outcome, a written policy, a code of conduct and a duty to keep both current. These apply from 1 October 2026, with no transition period. For most providers, this is the bigger piece of work: it touches every frontline colleague, not just a handful of senior managers.

• The outcome (1.1). Providers must secure that relevant staff, meaning staff involved in providing landlord services, have the skills, knowledge and experience, and exhibit the behaviours, needed for landlord services to be of good quality. They must also take appropriate steps to secure the same for services providers’ staff
• A written policy (2.2). It must cover your approach to managing and developing skills, knowledge, experience and behaviours tailored to roles; your approach to learning and development; your approach to appraising and regularly reviewing performance, including managing poor performance; and the steps you take to secure the same for services providers’ staff
• A code of conduct (2.3). Providers must develop or adopt an appropriate code of conduct for relevant staff and ensure it is embedded in the organisation
• Kept current and accessible (2.4). Policies and codes must be kept up to date, fit for purpose and accessible to tenants, and tenants must have the opportunity to influence how they develop

The conduct element is about staff having the right behaviours and the provider adopting and embedding a code of conduct.

The dates that matter

The Competence and Conduct Standard came into force on 1 October 2026. Two rules decide when a senior person needs to hold or be working towards a qualification.

First, the 12-month rule. The qualification requirement only applies to someone who has been a senior housing manager or senior housing executive with your organisation for more than 12 months. A new appointee isn’t in scope on day one. They come into scope once they pass 12 months in the role.

Second, the transition window. The transition period only covers people who come into scope before a cut-off:

• 1 October 2026. The Standard came into force. The outcome, policy, code of conduct and accessibility requirements all apply from this date
• Large providers (1,000 or more social housing units). 24 months from 1 October 2026, so the transition period ends on 30 September 2029
• Small providers (fewer than 1,000 units). 36 months from 1 October 2026, so the transition period ends on 30 September 2030

The primary sources state the periods; the calendar dates are arithmetic. The Policy Statement doesn’t address what happens if a small provider grows past 1,000 units during its transition period, so if that’s likely for you, plan to the shorter deadline.

What “working towards” means

“Working towards” has a precise meaning in the Policy Statement (para 13), and it’s broader than simply being on a course. Someone counts as working towards a qualification if any of these applies:

• They are enrolled and making progress, within the completion period the qualifications provider sets or estimates. If no period is set, no more than two years should have passed since enrolment
• They are enrolled but not yet making progress, and no more than six months have passed since enrolment
• They enrolled more than six months ago but can’t progress because the course hasn’t started yet, and you have plans in place to get them progressing as soon as reasonably practicable
• They are absent from work, or about to start an extended absence such as maternity leave, sickness, compassionate leave, public duties or reserve service, and you have plans in place for them to pick it back up
• They are not yet enrolled because of an extended absence, and you have plans to enrol them within six months of their return
• They failed the qualification within the last six months, and you have plans for them to complete it or enrol on another relevant qualification within six months of failing
• They were awarded a lower-level qualification that’s a prerequisite for the relevant one within the last six months

Where no completion period is mandated or estimated, no more than two years should have passed since enrolment. Extensions apply for reasonable adjustments and for longer qualifications such as degrees.

New appointments

Anyone who is a relevant person at the start of the transition period, or becomes one within its first 12 months, must hold or be working towards the qualification by the end of the transition period. After that 12-month window, the normal rules apply: the person must hold, or be working towards, the qualification.

That has a knock-on for recruitment. Once the window closes, a new senior housing manager or executive needs to arrive qualified or start working towards a qualification. It’s worth updating job descriptions, adverts and offer letters now, so candidates know what’s expected.

What you have to record, and what you don’t

The Standard requires a written policy and an embedded code of conduct. It doesn’t require a training register, qualification register or completion records. The table separates what’s required from what’s guidance and what’s simply common practice.

Records aren’t a formal requirement, but in practice they’re how most providers will evidence the decisions the Code asks about. Treat them as a means to that end, not as compliance in themselves. A register nobody trusts is worse than a short, accurate one.

What HR and L&D teams should start doing now

None of the following is required by the Standard in these words; it’s how providers are approaching it. The workforce requirements and the contractor steps already apply, so steps 3, 4 and 5 are the most urgent if you don’t have them covered.

1. Scope your people. Map every role against the definitions of senior housing executive, senior housing manager and relevant staff, using the three questions above, and record why each decision was made. The Code asks providers to be able to evidence these decisions, so the reasoning matters as much as the answer. Restructures, promotions and new appointments change who’s in scope, so revisit the map at least once a year and add qualification expectations to senior job descriptions now.
2. Audit existing qualifications. Check what senior staff already hold: level, regulator, TQT and content coverage. This is where the partially compliant route may save people from starting again. Write one assurance note per qualification type, then plan who enrols when, prioritising people with the furthest to go and roles with the biggest impact on tenants.
3. Scope your contractors. Scope your contractors, and act now. Unlike the qualification deadlines, the contractor steps in paragraph 46 of the Policy Statement have no transition period. They’ve applied since 1 October 2026. You should already be doing four things:

• Considering how you’ll use the implied contractual terms (s.217A)
• Bringing the qualification element to the attention of services providers you have a management services agreement with
• Taking steps to make sure those providers understand their obligations
• Making sure they do the same with their own sub-contractors

1. Write or update the policy. Cover the areas the Standard names: skills and behaviours by role, learning and development, and appraisal and performance review, including poor performance. Review your existing L&D and performance policies before creating anything new; you may be closer than you think. Write the policy you actually run, then close the gaps, and give tenants a genuine chance to influence it.
2. Develop or adopt a code of conduct. Then evidence that it’s embedded, not just published. Embedding is the word the Standard uses, so build the code into induction, objectives and reviews, and keep a record of when colleagues confirm they’ve read updates.
3. Work out how you would evidence competence. Decide how you would answer, today, the question “show me that this person is competent for this role”. Whether the answer lives in a spreadsheet, an HR system or an LMS, the point is that you can produce it consistently across a dispersed workforce. The same evidence should let you give your board a one-page update on scope, deadline, current position, cost and progress.

Where a learning system helps

Let’s be clear: a learning management system won’t hand your senior managers a regulated qualification. What it can do is take the admin out of everything around it. That means less time chasing spreadsheets and more time developing your people.

With the right system in place, you can:

• Give every role the learning it needs through role-based skill profiles, so frontline, repairs and neighbourhood teams aren’t left guessing
• See who’s done what as it happens, and pull compliance reporting for your board or audit committee without a week of spreadsheet wrangling
• Keep qualifications, top-up modules and code of conduct sign-off in one place, ready when the regulator asks
• Connect learning to performance and development reviews, the very thing your policy already has to describe

The result is confidence under scrutiny. When someone asks you to show that a colleague is competent for their role, you’ve got the answer ready.

“The Competence and Conduct Standard is helping to drive greater focus on professional standards across the housing sector and provides an important opportunity to strengthen how we support colleague development and customer outcomes. At Citizen, we’re using Kallidus Learn to deliver and evidence learning, while Kallidus Perform supports ongoing performance conversations, objective setting and the management of competence and conduct through regular reviews. Together, this gives us greater visibility of workforce capability and helps us demonstrate that colleagues have the knowledge, skills and behaviours needed to deliver safe, high-quality services for our customers. We’re also exploring the skills functionality to help us map, track and monitor competencies across the organisation, supporting workforce planning and long-term capability development.” – Laura Folan, Learning & Development Business Partner, Citizen Housing

At Kallidus, we prove the way housing providers build compliant, skilled, and high-performing teams. If you’re reviewing your compliance training in light of the Standard, see our learning and compliance software for housing providers.

Frequently asked questions

When does the Competence and Conduct Standard come into force?

It came into force on 1 October 2026. The workforce requirements apply immediately. Large providers have 36 months for the qualification requirements, to 30 September 2029, and small providers have 48 months, to 30 September 2030.

Does the Competence and Conduct Standard apply to local authority landlords?

Yes. It applies to all registered providers of social housing in England, private and local authority alike.

What qualification does a senior housing manager need?

A Level 4 qualification regulated by Ofqual, or an equivalent or higher qualification, with a total qualification time of over 120 hours and the required content coverage. Senior housing executives need a foundation degree or Level 5 qualification, or equivalent.

Do small housing associations have to comply?

Yes. Providers with fewer than 1,000 social housing units get a longer transition period of 48 months for the qualification requirements. Every other requirement has applied since 1 October 2026, including the contractor steps in paragraph 46 of the Policy Statement.

Is there approved Competence and Conduct Standard training?

No. There’s no official approved qualification list and no approved awarding bodies. Providers must satisfy themselves that a qualification meets the level, TQT and content requirements in the Policy Statement, and be able to defend that decision.

What happens if we don’t comply?

The Standard is a consumer standard, so a failure to meet it is a breach of a consumer standard. Large landlords receive C1–C4 consumer gradings following programmed inspections, and the regulator may take enforcement action at C4. RSH’s current gradings guidance predates the Standard, so how it will be inspected in practice isn’t yet clear.

Talk to us about your housing workforce today.

Sources

• Competence and Conduct Standard (RSH, Annex 2)
• Policy Statement on Qualifications Requirements (MHCLG)
• Consumer Standards Code of Practice (RSH, Annex 3)
• Decision Instrument RSH12
• Direction on the Regulatory Standards (Competence and Conduct) 2025
• Social Housing (Regulation) Act 2023, section 21
• RSH: how we approach regulatory judgements and gradings
• CIH Competence and Conduct Standard hub (secondary sector source)
• Competence & Conduct Standard – Frequently Asked Questions

This guide is for general information and isn’t legal advice. Check the primary sources, and take advice where you need it, before making decisions.