Competence and Conduct Standard for social housing: government response

Question 1

Executive summary

Accepted Answer

The government has set out its plans to deliver a decade of renewal in social and affordable housing, focused on delivery of the biggest increase in supply in a generation alongside a transformation and lasting change in the safety and quality of homes.

The government is committed to ensuring that tenants’ experiences and voices are at the heart of the social and affordable housing system and inform the design and delivery of our reforms. The government’s 5 step plan for renewal, published in July, set out that the Competence and Conduct Standard would come into force in October 2026, with a 3-year transition period before senior housing managers and executives must have or be working towards a relevant qualification (4 years for registered providers that own fewer than 1000 homes and their services providers).

The introduction of the Competence and Conduct Standard stems directly from the evidence heard by the Grenfell Inquiry and forms part of the government’s wider response to the tragedy. The Inquiry heard that a lack of appropriate staff training contributed to the tragedy and that residents’ fears and complaints about living conditions were disregarded by staff. The social housing green paper consultation highlighted similar concerns relating to the safety and quality of social housing, and we heard from many tenants who felt they were not always treated with respect. This suggested that the issues uncovered following the Grenfell tragedy were indicative of the wider experiences of social tenants across the country.

The standard will play a pivotal role in the wider work taking place across government to improve the quality of social housing, and it is an important step in professionalising the sector. It will drive the culture change necessary to eradicate unprofessional attitudes and stigma. The new standard achieves this by introducing clear requirements around the systems and processes that social landlords must have in place to ensure that their staff have the appropriate skills, knowledge and experience required to provide high quality and respectful services to all tenants.

The new standard was developed following a government-led review of professional training and development which considered the appropriate qualifications and standards for social housing staff in different roles, including senior staff. The Professionalisation Review (2022) (PDF, 473 KB) concluded that measures should be introduced to drive organisational-wide culture change within the social housing sector and recommended that any qualification requirements should be focused on senior staff who are best placed to cascade their knowledge throughout the organisation.

Following the review, the previous government made provision through the Social Housing (Regulation) Act 2023 for a new regulatory standard on staff competence and conduct, including a requirement for senior housing managers and senior housing executives to hold appropriate qualifications. The final Grenfell Inquiry phase 2 report stated that it had not made any recommendations in relation to the competence and conduct of social housing staff because the power to set this standard has been taken through the act.

In early 2024, the previous government ran a consultation on proposals to implement a new Competence and Conduct Standard – this included a draft direction to the Regulator to set the Standard, and an associated draft policy statement setting out the detail of the proposed qualification requirements for senior managers and senior executives. A consultation stage impact assessment was also published, and the consultation sought views on the estimated costs and benefits of the standard.

The consultation set out proposed requirements for registered providers to have up to date written policies setting out their approach to managing and developing the skills, knowledge, experience and conduct of their staff, and to adopt and embed codes of conduct.

It also sought views on our proposals for who is in scope of the qualification requirements, and the criteria that qualifications must meet. It proposed a 24-month transition period during which relevant staff must begin working towards a relevant qualification. The detailed proposals can be found in the consultation document and are summarised below.

Analysis of the responses to the consultation found there was broad agreement with the majority of the policy proposals set out in the consultation, particularly in relation to the outcome-based standard relating to the competence and conduct of all staff, and the proposed criteria that qualifications for senior staff must meet.

There were more divergent views on the proposals for which roles would be in scope of the qualifications requirements, where certain respondents said that the guidance was not sufficiently clear and there was a lack of clarity around the level of management or types of senior roles in scope. The responses also indicated to us that there was some uncertainty about how the standard will apply in respect to services providers. A significant number of respondents felt the transition period should be longer than the 24 months which was proposed.

We would like to take the opportunity to thank everyone who has submitted their views and evidence in response to proposals and the questions posed in the consultation.

Having considered the responses, the government is issuing the final direction and accompanying policy statement alongside this government response to the consultation. In summary, the direction requires the Regulator to set a standard which requires registered providers to:

secure that those of their staff who are relevant individuals have the necessary skills, knowledge and experience, and exhibit the behaviours needed, for the relevant services provided by those individuals to be of a good quality
take appropriate steps to secure that those of their services providers’ staff who are relevant individuals have the necessary skills, knowledge and experience, and exhibit the behaviours needed, for the relevant services provided by those individuals, under or pursuant to the relevant management services agreement, to be of a good quality
have a written policy setting out their approach to a number of things such as learning and development, appraising staff, and managing poor performance
adopt or develop an appropriate code of conduct for those of their staff who are relevant individuals and to ensure this is embedded within their organisation
give tenants meaningful opportunities to influence and scrutinise the development of the policy, and decisions relating to the code of conduct, and ensure they are made accessible to tenants and kept up to date and fit for purpose
comply with all applicable requirements relating to the qualification requirements as set out in Chapters 1 to 6 of the policy statement, which means they must secure that their Senior Housing Executives and Senior Housing Managers have, or are working towards, a specified qualification, or type of qualification, in housing management and take steps to secure that Relevant Managers of their services providers also gain a specified qualification

The standard will come into force in October 2026, with a transition period before all relevant staff must have or be working towards an appropriate qualification. The transition period is 3 years for large registered providers and their services providers (1,000 homes or more) and 4 years for small registered providers and their services providers (under 1,000 homes).

Additionally, implied terms have been incorporated into management services agreements between registered providers and services providers by s217A of the 2008 Act. These have the effect that, from the point the standard comes into force, services providers will be contractually obliged to secure that their senior housing managers and senior housing executives within scope of the policy (‘Relevant SP Managers’) gain appropriate qualifications, subject to the relevant transition period. The implied terms relate only to the qualification requirements, and not to the broader requirements of the Standard. Section 6.5 of the policy statement sets out exemptions which apply in relation to services providers and the guidance set out in Annex A of the policy statement (paragraphs 1 to 37) supports assessments of which roles are in scope.

The qualification requirements will only apply in relation to services providers who provide a comprehensive social housing management service to the registered provider, meaning that they deliver all or the majority of the housing management functions set out at paragraph 59 of the policy statement in relation to the registered provider’s social housing. Where a services provider manages delivery of only one housing management function, such as asset management for example, an exemption would apply in relation to their Relevant SP Managers.

This document sets out the findings of the consultation, the government’s response to the findings, and amendments that have been made to the policy as a result.

The consultation: content and approach

The purpose of the consultation was to seek views from social housing tenants, landlords, services providers and from other interested organisations across the sector, on our detailed policy proposals relating to a proposed new regulatory standard on competence and conduct. In particular, the consultation sought views on a number of different proposals which are detailed throughout this government response.

The consultation was open between 6 February to 5 April 2024. Respondents could respond via online survey, email or by post.

We asked 44 questions in total (not including the demographic questions), including questions that invited either a ‘yes’ or ‘no’ response, as well as questions inviting further elaboration in a free text box.

Responses to free-text questions were analysed to identify common themes and coded where possible to collate similar views and comments. These questions asked respondents to provide further details if they disagreed with a proposal, but the analysis showed that in some instances respondents also used these to indicate whether they agreed in full, or with an aspect of the proposal. Key themes or issues are presented to provide a summary of these responses.

The following terms have been used in summarising additional points raised in the free-text responses:

‘many’ respondents indicates more than 50% of those who provided a free text box response
‘some respondents’ refers to the range between approximately 10% and 50%
‘a few respondents’ means fewer than 10%

For some of the questions which were only to be answered by certain respondent groups, we have excluded other groups from the analysis - where we have done this, it has been clearly set out. A very small number of respondents who ticked the ‘other’ category were recategorised into a suitable group.

The consultation adhered to the consultation principles guidance issued by Cabinet Office. As noted above, it was accompanied by an analysis of impact. We have now developed an updated impact assessment, informed by evidence received through the consultation, which we are publishing alongside this government response.

Summary of consultation responses

The consultation received 366 responses in total. Please see below the breakdown of responses received by groups.

Group	No of responses
Registered providers and services providers	195
Landlord representative group	11
Local authority registered provider who delegates the management of some or all of their properties to one or more services provider	11
Local authority registered provider with retained stock (i.e. who own and manage their properties)	66
Private registered provider	88
Arms-length management organisation	11
Tenant management organisation (TMO)	3
Organisation representing services providers	1
Other services provider	4
Social tenants	47
Tenant representative group	11
Social housing tenant	36
Other groups	124
Local authority that is not a registered provider	1
Individual (not a tenant of the social housing sector)	23
Charity	18
Government body	1
Housing association that is not a private registered provider	43
Other	34
Prefer not to say	4

As well as setting out the summary of consultation responses from all respondents, we have in some instances also set out how responses differed for 2 key groupings of respondents:

social tenants
registered providers and services providers

The analysis relating to these groups in subsequent questions are calculated using the totals set out within the table above.

Question 2

Section 1: The broad standard relating to the competence and conduct of all social housing staff

Accepted Answer

The consultation proposed that the direction to the Regulator should require registered providers to have regularly updated written policies in place which set out their approach to managing and developing the skills, knowledge, experience and conduct of their housing management staff, and the steps they will take to secure that their service providers’ staff have the necessary skills et cetera.

Policies must cover learning and development, appraising staff performance, and managing poor performance. It also proposed that registered providers should adopt or develop and embed appropriate codes of conduct.

Question 1

Do you agree with the content of the direction to setting the broad standard relating to the competence and conduct of all social housing staff?

If no, please specify which aspects you don’t agree with and explain why.

There were 349 responses to this part of the question.

Option	Total	Percent
Yes	265	72.40%
No	84	22.95%
Not answered	17	4.64%

44 of these responses were completed by social tenants and groups representing them.

189 of these responses were completed by registered providers of social housing, services providers who manage services on their behalf and bodies representing them.

Option	Total	Percent
Yes	35	74.47%
No	9	19.15%
Not answered	3	6.38%

Registered providers and services providers

Option	Total	Percent
Yes	140	71.79%
No	49	25.13%
Not answered	6	3.08%

Summary of consultation responses

As a whole, 265 (72%) of respondents agreed with the content of the direction. However, of those who disagreed, some were concerned that implementing the new standard would be burdensome on the sector and would exacerbate existing pressures on landlords.

Many of the respondents who provided a free text box response to this question focused their responses on the qualification requirements. The issues raised about qualification requirements have been addressed within relevant sections of this government response. Some of those who provided a written response to this question thought that there was too much focus either by government or within the sector on the qualification element of the standard and not enough consideration of the broader obligations it will place on registered providers to ensure their staff have the right behaviours, attributes and conduct. Concerns were also raised that qualification requirements would not enact the wider culture change needed across the sector.

Generally, respondents agreed with our approach to direct the Regulator to set a broad standard which is not overly prescriptive so that there is sufficient flexibility to apply this to diverse housing providers with differing structures and operating models. However, a few respondents felt that further guidance or ‘best practice’ advice was needed on how providers should comply with the standard to ensure some level of consistency across the sector. A few respondents also said that the direction doesn’t

Suggestions were made about how the direction could be strengthened, for example, that the standard should prescribe the specific recruitment, appraisal and performance management practices that landlords should have in place, and that the standard should mandate a continuous professional development (CPD) framework.

A few respondents, particularly tenants and tenant representative groups, suggested that the standard should require registered providers to consult with tenants when developing their codes of conduct and written policies and that the documentation should be made accessible to them.

Government response

Whilst we acknowledge concerns about the pressures on social housing providers, the standard is a necessary part of addressing poor practices amongst some social landlords and services providers. The Grenfell Inquiry Phase 2 report highlighted that key managerial staff at the Royal Borough of Kensington and Chelsea Tenant Management Organisation (KCTMO) did not have adequate training or qualifications for their roles^{[footnote 1]}. Residents of Grenfell Tower said they had voiced fears for their safety or complained about living conditions but were ignored or disregarded by the staff of the KCTMO. The Inquiry found that “ignoring residents’ views was entirely consistent with the KCTMO’s approach to engagement with its residents”^{[footnote 2]}.

In line with the feedback received, we have amended the direction to the Regulator, introducing additional requirements with regard to registered providers’ codes of conduct, and written policies which set out their approach to managing and developing the skills, knowledge, experience and conduct of relevant staff. 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
ensure that the policy and code of conduct is made accessible to tenants

We have also strengthened the wording of the requirement for registered providers to update their policies regularly, now stating that these policies must be kept up to date and fit for purpose. A new requirement has also been added for codes of conduct to be kept up to date and fit for purpose.

The Standard will be regulated in line with the Regulator’s outcomes focused approach. This approach reflects the Regulator’s statutory duties to carry out their role in a way that minimises interference of landlords and, where possible, is proportionate, consistent, transparent and accountable. An outcomes focused approach, as opposed to a prescriptive approach, will allow landlords to deliver the outcomes required of them in the most appropriate way for their organisation and, importantly, their tenants. This approach will create opportunities for providers to collaborate with tenants when developing the systems and processes needed to comply with the new standard and ensure their staff have the skills, knowledge, experience and behaviours needed to deliver good quality services to tenants.

Question 3

Section 2: Who is in scope of the qualification element of the Competence and Conduct Standard

Accepted Answer

The ‘substantive role’ rule

The consultation proposed that the qualification requirement will capture persons where they have a substantive role in managing delivery of housing management services, meaning they are expected by the registered provider to spend a significant portion of their working time exercising their responsibilities for housing management services delivered to the registered provider’s social housing tenants. These responsibilities would be “an important and substantial aspect of their role” and in many (but not all) instances they will take up more than half of that individual’s working time.

Question 2

As set out in paragraphs 15a and 46b of the policy statement, do you agree that only individuals who have a substantive role in managing delivery of housing management services should be in scope?

If no, please explain why.

There were 342 responses to this part of the question.

Option	Total	Percent
Yes	265	72.40%
No	84	22.95%
Not answered	17	4.64%

44 of these responses were completed by social tenants and groups representing them:

188 of these responses were completed by registered providers of social housing, services providers who manage services on their behalf and bodies representing them.

Option	Total	Percent
Yes	35	74.47%
No	9	19.15%
Not answered	3	6.38%

Option	Total	Percent
Yes	140	71.79%
No	49	25.13%
Not answered	6	3.08%

Summary of consultation responses

69% of respondents agreed that only individuals who have a substantive role in managing delivery of housing management services should be in scope, whereas 25% disagreed. Some respondents who provided a free text box response believed the breadth of staff in scope was too small. It was also suggested that all staff involved in delivering housing management services should be in scope including frontline staff and middle managers. These respondents argued that, without including all staff, the policy would not achieve the intended culture change. Another example of reasons given for disagreement with this proposal was an opposition to the policy overall, and the view that no staff should be required to have a qualification.

Some respondents to this question raised confusion about the ‘substantive role’ rule, particularly around how this would apply where staff had cross cutting roles. Some also said that a clearer definition of senior housing managers and executives was needed, partly as organisational structures were so varied that it would be difficult for landlords to judge which of their staff played a major role in managing the services. A few respondents also raised concerns that the rule was too prescriptive, and that there might be instances where responsibilities for managing housing management services take up less than half a person’s working time, but that they should still be in scope.

Government response

As 69% of respondents agreed with this proposal, we do not consider that this aspect of the policy requires amendment. However, we have refined and expanded our explanation of what a ‘substantive role’ means in this context, namely that a person is expected to spend the majority (usually more than half) of their working time managing delivery of housing management services to the registered provider’s social housing tenants, or that managing delivery of housing management services is an important and substantial aspect of their role. Guidance has also been provided in Annex A of the policy statement to support registered providers’ and services providers’ assessments of which roles are in scope.

Our guidance that a person will only usually come into scope if their responsibilities for managing delivery of housing management services take up more than half of their working time is not intended to be prescriptive or ‘one size fits all’.

Roles in and out of scope of the qualification requirement

The consultation set out proposed guidance on the scope of housing management services and the functions we expect senior housing managers and senior housing executives to deliver. Senior housing managers will usually manage the direct delivery of housing management services to tenants with managerial responsibilities in respect of things like tenancy management, tenant involvement, customer services and repairs and maintenance services. Whereas the executives will provide strategic direction and have accountability in relation to housing management services. Our proposed guidance also set out which functions would not be in scope, such as back office functions.

Question 3

Do you agree with the guidance on the scope of housing management services (paragraphs 1 to 3 of Annex B1)?

If no, please explain why.

There were 329 responses to this question.

Option	Total	Percent
Yes	251	68.58%
No	78	21.31%
Not answered	37	10.11%

41 of these responses were completed by social tenants and groups representing them:

184 of these responses were completed by registered providers of social housing, services providers who manage services on their behalf and bodies representing them.

Question 4

This question was for registered providers and services providers only. Other response groups have been excluded.

In addition to the definitions provided within legislation, does the guidance at Annex B1 of the policy statement on which functions will be in scope provide sufficient clarity to enable you to assess which individuals within your organisation will need to gain a qualification? If no, please explain why and specify whether your answer relates to a senior housing manager, senior housing executive, or both.

There were 176 responses to this question. It is worth noting that others did respond to this question.^{[footnote 3]}

Option	Total	Percent
Agree that the guidance provided on key responsibilities and functions is sufficiently clear	77	39.49%
Do not agree that it is clear	99	50.77%
Percentage whose disagreement related to senior housing managers	15	15.15%
Percentage whose disagreement related to senior housing executives	7	7.07%
Percentage whose disagreement related to both	60	60.61%
Percentage disagreed but did not specify which role	17	17.17%
Not answered	19	9.74%

Question 5

Do you think that there are any other functions not listed above which should be in scope?

If yes, please explain why and specify whether your answer relates to a senior housing manager, senior housing executive, or both.

Option	Total	Percent
Yes	84	22.95%
No	244	66.67%
Not answered	38	10.38%

Question 6

Are there any functions listed above that you think should not be in scope?

If yes, please explain why and specify whether your answer relates to a senior housing manager, senior housing executive, or both.

There were 328 responses to question 5, and 322 responses to question 6.

Option	Total	Percent
Yes	93	25.41%
No	229	62.57%
Not Answered	44	12.02%

Question 7

This question was for registered providers and services providers only. Other response groups have been excluded.

Does Chapter 5 and section 6.5 of the policy statement relating to exemptions and paragraphs 18 to 21 of Annex B1 of the policy statement provide sufficient clarity to help you to assess which individuals within your organisation will not be in scope of the qualification requirement?  If no, please explain what further clarity is needed.

There were 175 responses to this part of the question.

Option	Total	Percent
Yes	119	61.03%
No	56	28.72%
Not answered	20	10.26%

Summary of consultation responses

51% of those who answered question 4 thought that the definitions provided in the legislation and the guidance provided on key responsibilities and functions were not sufficiently clear. Many said that there was a lack of clarity around what constitutes a senior manager or a senior executive, making it difficult for them to assess which of their staff would be in scope. Conversely, it was also said that the government should avoid being overly prescriptive within the guidance and that organisations should have the flexibility to identify which of their staff should be in scope.

It was suggested that providing real life examples could help in clarifying the types of scenarios where staff might be in scope or alternatively including a list of example job roles and titles.

A few respondents said that they were unsure about team leaders or those who are responsible for managing frontline housing officers or operatives. A few respondents also said that there was a lack of clarity around chief executive officers (CEOs). A few respondents also said that the guidance should better reflect the key differences between large and small organisations. They highlighted that larger organisations often have multiple levels of management and said they did not feel it was clear enough how many layers of the management structure would be in scope of the qualification requirements or whether the requirements would apply to multiple levels of management.

Some respondents to Q4 were unsure about how the requirements would apply to different types of housing, for example, supported housing, sheltered schemes, temporary accommodation and homelessness services, leasehold and shared ownership.

Many (67%) of those who responded to Q5 didn’t think there were any additional functions that should be in scope beyond those listed, and many of those who responded to Q6 (63%) didn’t think any of the listed functions should not be in scope. However, some respondents did raise that those who deal with allocations or assessing housing need should be in scope.

Some respondents thought that functions related to building and fire safety; accountable persons under the Building Safety Regulation Act 2022; and / or staff with responsibility for the housing health and safety rating system (HHSRS) for social homes should be explicitly listed as in scope, as these roles have significant responsibilities for ensuring services to tenants are safe.

When asked whether there were functions listed which should not be in scope, approximately 10% of respondents who provided a free text box response to Q6 thought that technical roles such as asset managers and property managers, capital or major works and repairs and maintenance roles should be out of scope. The primary reason for this was that these roles already require specific qualifications, such as those provided by the Chartered Institute of Building (CIOB), and often would not be tenant facing. But also respondents argued that some technical staff are already covered by other requirements relating to competency such as the PAS8673.

Some of those who responded to Q4 thought that there was a lack of clarity about whether non-housing specific roles were in scope, such as legal services and finance teams and suggested it would be inappropriate and disproportionate to apply qualification requirements to these staff. There was also some confusion around roles which are not delivered by someone within the organisation’s housing function but elsewhere in the organisation such as a corporate hub. This was particularly true for roles which oversee anti-social behaviour (ASB) management, and customer services across a wide range of local authority services.

Government response

We recognise the importance of providing clear guidance to ensure that registered providers and services providers are able to make their own assessments of which staff are in scope of the requirements. It is now stated more explicitly that the guidance provided at Annex A of the policy statement is intended to assist providers in carrying out their own assessments of which roles within their organisation meet the definitions of senior housing manager and senior housing executive as set out in the legislation. Recognising that there is a wide variety of organisations and management structures, the guidance is not intended to be prescriptive and it should be interpreted by providers’ in accordance with their own organisational structures and individual role profiles.

Based on the feedback provided, we have expanded our guidance and have provided additional example scenarios illustrating where certain roles would or would not be in scope. This includes examples relevant to CEOs and to the managers of frontline housing officers or operatives.

As suggested by respondents, we have delineated how the requirements would apply differently to smaller and larger organisations and made it explicit that all types of social housing could be in scope where it is provided by a registered provider, including sheltered accommodation and temporary social housing.

We have also expanded the definition of the ‘letting management’ function to explain that this will also include managing delivery of the allocations and lettings processes, including managing pre-tenancy stages, transfers and mutual exchanges.

Additional clarity has also been provided on types of housing or roles that would be out of scope, for example, roles associated with the development of new buildings or management of unoccupied homes are not in scope. Also, functions which involve overseeing or managing the housing register and making statutory assessments or decisions relating to housing need or homelessness, including local authorities’ strategic housing functions would not be in scope on the basis that these roles are subject to separate legal requirements placed on local authorities to set up and maintain an allocation scheme under Part 6 of the Housing Act 1996. It has also been made clear that corporate or centralised roles, such as staff who manage a wide range of local authority services are not expected to be in scope unless they have a substantive role in managing the delivery of social housing.

As set out later in section 2, unpaid volunteer roles will also be out of scope, in order to avoid disproportionate impacts on organisations with volunteers which are typically smaller, such as co-operatives and almshouses.

In response to the feedback around technical roles (such as asset management and major works), we have assessed that it is important that these roles remain in scope where they manage the direct delivery of services to tenants. We have also more explicitly set out that these technical functions also include the management of building and fire safety. This is because post-holders’ decisions often have a large impact on the quality and safety of the service provided to tenants, and it is essential that technical staff are skilled in engaging with tenants on the issues that are important to them. However, we have provided more clarity on the eligibility of technical qualifications which are appropriate for these roles and how they can be ‘topped up’ with additional training which is focused on meeting tenant’s needs (please see section 6 for more detail).

We have also provided guidance to indicate how the standard interacts with other relevant requirements under the Building Safety Regulation Act 2022, particularly around whether accountable persons could come into scope.

Timescales for enrolling on qualifications

The consultation proposed that staff will need to enrol on qualifications within 6 months of starting a new role which is in scope of the requirements, or 9 months if they have a probation period.

Question 8

Do you agree with the proposal outlined above that individuals must have been in their role for more than 6 months to be classed as a Relevant Person or Relevant SP Manager (except where they are subject to a probationary period) as detailed in paragraph 15c, 46d and 46e of the policy statement?

If no, please state whether you think that the threshold should be less, or more than 6 months (please explain why and specify how long).

There were 334 responses to this part of the question. 42 of these responses were completed by social tenants and groups representing them:

184 of these responses were completed by registered providers of social housing, services providers who manage services on their behalf and bodies representing them.

Option	Total	Percent
Yes	197	53.83%
No, the threshold should be less than 6 months	38	10.38%
No, the threshold should be more than 6 months	99	27.05%
Not answered	32	8.74%

42 of these responses were completed by social tenants and groups representing them:

184 of these responses were completed by registered providers of social housing, services providers who manage services on their behalf and bodies representing them.

Option	Total	Percent
Yes	28	59.57%
No, the threshold should be less than 6 months	6	12.77%
No, the threshold should be more than 6 months	8	17.02%
Not answered	5	10.64%

Option	Total	Percent
Yes	110	56.41%
No, the threshold should be less than 6 months	17	8.72%
No, the threshold should be more than 6 months	57	29.23%
Not answered	11	5.64%

Question 9

Do you agree with the proposal that those staff who have a probation period should have, or be working towards, a qualification within 9 months from the point at which they take up their role as detailed in paragraph 15d and 46f of the policy statement?

If no, please explain why and your alternative suggestion.

There were 331 responses to this part of the question.

42 of these responses were completed by social tenants and groups representing them:

183 of these responses were completed by registered providers of social housing, services providers who manage services on their behalf and bodies representing them.

Option	Total	Percent
Yes	180	49.18%
No	151	41.26%
Not Answered	35	9.56%

Summary of consultation responses

54% of respondents agreed with our proposals relating to the timescales within which staff should enrol on qualifications after moving into a new role. Many social tenants and their representatives (60%) agreed with the 6 month threshold, and many (66%) agreed with the 9 month threshold for staff with a probation period. Whereas registered providers, services providers and their representatives were less likely to agree, 56% agreed with the 6 month threshold and 48% with a 9 month threshold.

13% of social tenants thought that the threshold should be less than 6 months. A few respondents argued that landlords should be required to only recruit those who are already qualified. The main reasons given was that managers should be suitably qualified and competent from the outset as they are accountable for service quality and safety from day one. A few respondents argued that 3 months was more appropriate, or that staff should enrol on qualifications as soon as they complete their probation.

29% of registered providers and services providers argued the threshold should be more than 6 months. When asked what their alternative suggestion would be, across both of the 2 questions ~40% of those registered providers and services providers who provided a free text box response said the threshold should be 12 months.

Common reasons given by those who argued for enrolment timescales to be longer than 6 months were that staff would need time within the first year of their employment to settle into their roles, get up to speed with the work, and undertake other core organisational training before having to take time out to undertake the qualification. Concerns were raised by the sector about the need to get staff qualified in their first year of employment, as it could mean landlords investing in training for staff who may then quickly leave the sector. As a result, some respondents said that a person should not come into scope until they have passed their probation, and that the timescales should be extended if probation periods are extended. Availability of courses was also a concern, as the 3-month period post probation might not be long enough to find a course and enrol.

Many of those who provided a free text box response said that there should be a 12 month grace period for all after starting a new role before they need to get qualified, regardless of probation. It was thought that this might be simpler to administrate and it would also allow organisations to better manage their capacity and budgets.

A few respondents said that registered providers should have the flexibility to make their own decisions about the timescales within which staff should enrol on qualifications based on their own resourcing and capacity issues.

A few respondents also said that these thresholds should not apply to temporary / interim staff on fixed term contracts or those on secondment as this would inhibit organisations’ ability to find cover for maternity and sickness leave.

Government response

Whilst many respondents agreed with this proposal, a substantial minority did not support the timescales, largely due to concerns about the practical impacts for registered providers when it comes to onboarding new or temporary staff.

Whilst we recognise it is necessary that staff are upskilled quickly once in post, we want to ensure that the approach does not impede upon the effective and efficient delivery of landlords’ services to tenants. We have assessed that new staff in scope, including temporary staff and those with or without a probation period, will have 12 months to enrol on qualifications.

This change will ensure that those who move to a role in scope have sufficient time to settle into their roles, familiarise themselves with their responsibilities, and undertake other core organisational training before taking time out to undertake a qualification.

In addition, we recognise the concerns raised by respondents about temporary or interim staff, and we do not want to discourage landlords from upskilling their staff or covering staff absences through temporary promotion and interim roles. Giving relevant managers a year before they must enrol will allow more flexibility for landlords in their workforce planning and ensure that they are well placed to make arrangements to cover maternity leave or sickness absence.

Finally, we have assessed that it would not be appropriate to set different timeframes for those with or without a probation period, or permanent versus temporary staff, as this would create further complexity to the requirements. Setting a consistent timeframe of 12 months for all new staff to enrol will make the qualification requirements more practical to administrate, thereby freeing up management time to focus on the substantive question of assessing whether staff have the right skills, knowledge, experience and behaviours to deliver good services to tenants.

Unpaid volunteers

Question 10

Do you agree with our proposal that unpaid volunteers should not be required to gain a relevant qualification as detailed at paragraphs 15b and 46c?

If no, please explain why.

There were 331 responses to part of the question.

Option	Total	Percent
Yes	280	76.50%
No	51	13.93%
Not answered	35	9.56%

Question 11

This questions was or registered providers and services providers only. Other response groups have been excluded.

Do you assess that any of your unpaid volunteers undertake roles which meet the criteria set out above in Chapter 2 and the guidance in Annex B1 of the policy statement?

There were 214 responses to this question.

Option	Total	Percent
Yes	27	7.38%
No	187	13.93%
Not answered	152	51.09%

Summary of consultation responses

Many respondents (77%) agreed with the proposal that unpaid volunteers should not be required to gain a relevant qualification. Many registered providers and services providers also agreed with the proposal (84%). Comparatively, the proportion of social tenants and representatives who agreed with the proposal was smaller (53%).

A few respondents acknowledged that requiring unpaid volunteers to gain a relevant qualification could deter them from volunteering in the sector, which may have a disproportionate impact on smaller or volunteer-led organisations such as alms-houses and co-operatives.

A few respondents highlighted that they would not expect unpaid volunteers to hold any significant responsibilities for housing management services or decision-making that impact tenants and it is therefore correct that volunteers should remain out of scope.

Some respondents recommended that unpaid volunteers should still be expected to complete some training to develop the soft skills required for the role, and some argued that unpaid volunteers should be required to gain a relevant qualification in the same way as paid staff. An example of reasons given were that unpaid volunteers might hold significant responsibilities for housing management services in some organisations and the same issues around competence and conduct still apply.

Some respondents also recommended that some unpaid volunteers such as board members or trustees should be required to gain a relevant qualification due to the level of responsibility of the role.

Government response

As set out in the consultation, we recognise the importance of driving up standards across the social housing sector. However, it is also important that we avoid adverse impacts on some of the smallest organisations who are more likely to be staffed by unpaid volunteers. Setting the expectations that unpaid individuals should gain qualifications would be disproportionate.

Given this, and the fact that many respondents agreed with our proposal, our position remains that unpaid volunteers should not be required to gain a relevant qualification.

Our direction sets out that the broad competence and conduct standard must require registered providers to ensure that all ‘relevant individuals’ (which means individuals involved in the provision of services in connection with the management of social housing provided by the registered provider) have the appropriate skills, knowledge, experience and behaviours. This would apply to unpaid volunteers.

Question 4

Section 3: Criteria that qualifications must meet

Accepted Answer

Level of qualification required

The consultation proposed that the level of a relevant qualification should be a level 4 for senior housing managers and a level 5 or a foundation degree for senior housing executives. An Ofqual-regulated qualification which is higher than the proposed level would also be acceptable provided it also meets the course content criteria.

Question 12

As outlined in section 3.1 of the policy statement, do you agree that a level 4 qualification is the correct level for a senior housing manager and individual who is a services provider?

If no, please explain why.

Question 13

As outlined in section 3.1 of the policy statement, do you agree that a level 5 qualification or a foundation degree is the correct level for a senior housing executive?

If no, please explain why.

There were 332 and 330 responses to these 2 questions respectively.

Level 4

Option	Total	Percent
Yes	250	68.31%
No	82	22.40%
Not answered	34	9.29%

Level 5

Option	Total	Percent
Yes	244	66.67%
No	86	23.50%
Not answered	36	9.84%

Summary of consultation responses

In both questions, over half of respondents agreed (as set out in the tables above) with the proposed qualification level that should be obtained by a senior housing manager and a senior housing executive.

Of those who answered no and provided a free text box response to question 12, approximately 10% recommended that the qualification should be higher than a level 4 qualification with a few recommending that a level 5 qualification would be more appropriate for a senior housing manager. A few respondents said that the qualification should be lower than a level 4.

Comparatively, approximately 6% of those who provided a free text box response to question 13 said that the qualification should be higher than a level 5. Around 7% said that the qualification should be lower than a level 5.

A few respondents who provided free text box responses recommended that it should be at the discretion of the registered provider and individual in scope to choose the level of qualification that a senior housing manager or senior housing executive should be required to take.

Of those who disagreed with the proposal, examples of reasons given were that professionalisation of the sector would be better achieved by introducing a system of recognising prior experience and continuous professional development, as opposed to requiring specific qualifications. A few respondents suggested that more experienced people should not have to undertake a qualification at all.

Respondents also raised concerns about whether equivalent or higher level qualifications which are delivered by higher education providers would be recognised, including Diplomas of Higher Education (DipHE), Higher National Certificates (HNCs) and Higher National Diplomas (HNDs).

Government response

As many respondents agreed with the proposal, we consider that the level of qualifications proposed in the consultation is appropriate for a senior manager and executive. We acknowledge the suggestion that registered providers should be able to choose the qualification level, however it is important that the qualification requirements are applied consistently to ensure the best outcomes for tenants.

In addition to prescribing the level of qualification, we have set out requirements on the length of the qualifications to ensure that the qualifications undertaken by their staff sufficiently cover the breadth and depth of knowledge for their roles. Qualifications must amount to a total qualification time (TQT) of over 120 hours.

In addition, the policy statement has been amended to ensure that qualifications which are not Ofqual regulated because they are delivered by higher education providers, or because their development pre-dated the current regulatory framework are recognised. Section 3.3 of the policy statement states that a person that has an equivalent or higher level apprenticeship or qualification such as a certificate of higher education (CertHE), HNC, DipHE, HND and the Chartered Institute of Housing Professional Qualification (PQ) is not required to also undertake a specified qualification.

Regulation of qualifications

The consultation proposed that qualifications can be regulated by a predecessor of Ofqual or a stipulated equivalent body including the Scottish Qualifications Authority (SQA), Qualifications Wales (QW), or the Council for the Curriculum, Examinations and Assessment (CCEA) (or a predecessor of one of those bodies) if the qualification meets other criteria relating to the level and the course content criteria.

Question 14

Do you agree with our proposals outlined above and in section 3.4 of the policy statement that qualifications can be regulated by an equivalent body to Ofqual or a predecessor body?

If no, please explain why.

Summary of consultation responses

There were 332 responses to this part of the question.

Option	Total	Percent
Yes	300	81.97%
No	32	8.74%
Not Answered	34	9.29%

Many respondents agreed (82%) with the proposal set out above. However, some respondents highlighted potential difficulties with identifying what would constitute an equivalent or predecessor body to Ofqual and asked for clarification on this. A few also said that it may be difficult to find information relating to older qualifications and to identify the body that the qualification was regulated by. Concerns were raised that those individuals who could not verify their older qualifications would then be required to retake a qualification.

There were varying views on the subject of older qualifications, with a few respondents arguing that all older housing management qualifications should be eligible regardless of their course content. In contrast, a few respondents thought that very old qualifications, such as those over 30 years old, should not be allowed as they would be outdated and the course content not relevant to staff delivering housing management today.

Some respondents said that other qualifications, accreditations or prior experience should be recognised or should be an alternative route to getting qualified, for example, professional memberships.

Government response

It is important to note that the consultation did not seek views on whether a qualification should be regulated by Ofqual. This is because the SHRA specifies that a specified qualification must be regulated by Ofqual, or it can be a foundation degree in the case of a senior housing executive. However, it is vital that equivalent housing management qualifications, including those obtained in Scotland, Wales and Northern Island, are recognised.

Having considered the feedback, we have assessed that our initial proposal that a person will not be required to undertake a specified qualification if they hold a qualification regulated by a stipulated equivalent body to Ofqual, or a predecessor body, is appropriate, provided the equivalent qualification is of the required level and covers the necessary course content. We believe this is the best way to ensure that staff who have already undertaken a qualification which has equipped them with the required knowledge and skills do not have to unnecessarily undertake another qualification.

Course content criteria

The consultation proposed that qualifications must meet specific criteria relating to course content.

Question 15

Do you agree that the criteria that qualifications must meet as set out in section 3.2 of the policy statement is appropriate for ensuring senior housing managers and senior housing executives gain the skills, knowledge, experience and behaviours they need to deliver high quality and professional services to tenants?

If no, please explain why and specify whether your objection relates to a senior housing manager, senior housing executive, or both.

There were 234 responses to this question. 42 responses were completed by social tenants and groups representing them and 183 responses were completed by registered providers of social housing and groups representing them.

Option	Total	Percent
Yes	188	51.37%
No	146	39.89%
Not Answered	32	8.74%

Option	Total	Percent
Yes	33	70.21%
No	9	19.15%
Not answered	5	10.64%

Option	Total	Percent
Yes	100	51.28%
No	83	42.56%
Not answered	12	6.15%

Question 16

This question was for registered providers and services providers only. Other response groups have been excluded.

Does section 3.2 of the policy statement provide sufficient information to allow you to identify which qualifications would meet the requirements for a senior housing manager and senior housing executive?

If no, please explain what further information is needed and specify whether your response relates to a senior housing manager, senior housing executive, or both.

There were 174 responses to this question.

Option	Total	Percent
Yes	89	45.64%
No	85	43.59%
Not answered	21	10.77%

Summary of consultation responses

51% of all respondents to question 15 (including 70% of social tenants and representatives and 51% of registered providers and services providers) agreed that the proposed course content criteria are appropriate. Noting that question 16 was only for registered providers and services providers to respond to, just under half of respondents agreed that section 3.2 of the policy statement provides sufficient information to help identify which qualifications would meet the requirements.

Some respondents said that the criteria are too narrow or prescriptive and do not appropriately reflect the diversity of roles across the sector. One key reason given for this was that the course content criteria only permit staff to complete qualifications which would not be appropriate for technical roles such as asset management and repairs and maintenance, and that these staff require specialist qualifications.

A few respondents recommended that providers should have the discretion to choose which qualification is appropriate for their staff based on their roles. Some respondents also advised that further information is needed on how existing qualifications will be recognised and some called for further information about the transitional arrangement for partially relevant qualifications.

On the other hand, some respondents to question 15 thought that the proposed course content criteria should focus on other areas of learning, for example, building safety and issues, damp and mould, housing finance or budget management, anti-racism and the history of social housing. Additionally, a few respondents said that the course content is too academic and argued it would not therefore drive culture change. A few respondents suggested that the course content requirements should be applied to both senior managers and senior executives consistently, particularly modules such as housing law, housing policy and ethical practices.

A few respondents highlighted that some of the course content requirements were not clear enough, particularly the criterion ‘ensuring needs of tenants are met’, and suggested that the module descriptions should be expanded to include more detail on what the course should cover.

Some respondents also thought that there should be other routes to meeting the qualification requirement, especially for highly knowledgeable and experienced staff, for example, a professional assessment of competence or a professional practice test, or an option for staff to submit a portfolio to demonstrate their competence, without the need to study for a formal qualification. It was also said that membership with a relevant professional body such as the Chartered Institute of Housing should be deemed to either partially or fully meet the requirement as this would reduce the risks of staff leaving the sector to avoid getting qualified.

Government response

Course content requirements

We acknowledge the concerns raised in response to the consultation that diverse roles within the sector may require different qualifications. We have therefore taken a more flexible approach to setting a framework of course content criteria required for different types of roles including general housing management roles (subsection A), technical roles (subsection B), and cross-tenure roles, i.e. those working across social rent, shared ownership and leasehold properties (subsection C).

Course content requirements for ‘general housing management roles’ is similar to those proposed in the consultation, focusing on criteria such as professional practice skills, customer service and equality, diversity and inclusion, as well as leadership and management and stakeholder engagement for senior housing executives. However, we have amended certain aspects of these criteria in response to the feedback received. We have updated the ‘ensuring needs of tenants are met’ criterion, instead referring to ‘equality, diversity and inclusion, and awareness of a range of needs and vulnerabilities (for example, disabilities)’. We have also provided further clarification on ‘national housing policy and current trends driving the housing sector’ instead referring to ‘national housing policy (including its historical context), and law and regulation relevant to housing management in social housing.’

We considered the feedback that the course content requirements are too narrow and prescriptive, therefore limiting the number of qualifications which meet the criteria. We have simplified the course content requirements for general housing management roles, removing reference to training such as ‘strategic and business planning’ and ‘embedding organisational policies in housing organisations’.

Staff in scope which perform technical roles will need either to hold or obtain a qualification which meets the same criteria in subsection A, or a technical qualification in an area such as construction, building safety, or estate management, provided it is broadly relevant to their role and it meets the other necessary criteria set out in the policy statement. Staff in cross tenure roles will be able to undertake a qualification in leasehold management and/or residential property management or a qualification which meets the criteria in subsection A or B.

We recognise there will be some roles that are cross-cutting between these areas, for example, managers or executives overseeing both general housing management and technical functions. In these instances, it will be for the registered provider to determine which criteria are most suitable for that person (and it is expected that services providers will make this judgement for their own staff).

This 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 should also be noted that the course content requirements we have set serve as a minimum baseline of what a compliant qualification must cover, and it is expected that the scope of most qualifications will exceed this. Ultimately, our aim is 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. We also expect qualifications providers to support with this by updating their qualifications where necessary to cover all criteria, and by providing guidance on whether their qualifications cover the criteria.

Additional training modules (‘top up training’)

Based on feedback received from tenants and tenant groups, we think it is essential that qualification courses equip staff not only with relevant technical, legal or business knowledge and skills but also with the softer skills they need to engage with tenants positively. In the consultation we proposed a transitional arrangement, whereby staff with a partially relevant qualification could undertake ‘top up training’ to cover unmet criteria such as this. The aim of this proposal was to ensure that staff with technical qualifications would not be required to unnecessarily undertake an additional full qualification in an area that is not best suited to their role. We have now made this top up provision permanent, so that staff can top up training after the transition period. As an example, those who have undertaken a technical qualification such as a quantity surveying degree would be required to undertake a ‘top up’ module in customer service in housing, including effective engagement with tenants and delivering respectful and professional housing services, if this is not already covered in their qualification. Further guidance has been provided within Annex A of the policy statement on what constitutes a partially relevant qualification (please see section 6 for more detail).

Recognising existing knowledge and experience

Some respondents called for existing training, qualifications or professional memberships to be recognised. Most qualifications providers will have systems in place for recognising prior learning, which means that learners may be exempted from certain modules of the qualification if they can evidence that they have met the learning outcomes and assessment criteria. We encourage 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. We also encourage awarding bodies and qualifications providers to explore other practical routes for highly experienced and knowledgeable staff to gain qualifications, such as portfolio-based assessments. We are pleased to see that steps have already been taken to deliver these options.

It is worth noting that the Social Housing (Regulation) Act 2023 (SHRA) clearly sets out that the requirement set by the standard should be for relevant staff to have a specified qualification or type of qualification in housing management. As such, professional memberships cannot be specified qualifications and where a person has a professional membership such as with the Chartered Institute of Housing, the Chartered Institute of Building, or the Royal Institution of Chartered Surveyors, but did not undertake a qualification as part of gaining their membership, they would not meet the requirements.

Question 5

Section 4: What constitutes ‘working towards’ a qualification for the staff of both registered providers and services providers

Accepted Answer

‘Working towards’ a qualification

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 6 months (except where there is no available course start date, in which case they should start within 12 months of enrolment). Where a person enrols but then needs to take an extended period of absence from work, for example due to maternity leave or sickness, they would need to start making progress towards completing their qualification as soon as is reasonably practicable thereafter. Staff should also complete the qualification within the time limit or estimate set by the qualifications provider for that qualification, or no more than 2 years if no time limit is set.

Question 17

Do you agree with our approach to defining what it means to be ‘working towards’ a relevant qualification as outlined in the policy statement?

If no, please explain which aspect you do not agree with and why.

There were 326 responses to this question. 40 of these responses were completed by social tenants and groups representing them. 182 of these responses were completed by registered providers and services providers.

Option	Total	Percent
Yes	265	72.40%
No	84	22.95%
Not answered	17	4.64%

Question 18

This question was for registered providers and services providers only. Other response groups have been excluded.

Does the information provided above and within Chapter 1 and Chapter 6 paragraph 44b of the policy statement provide sufficient clarity to help you understand the circumstances in which individuals in scope will be deemed to be ‘working towards’ a qualification?

If no, please explain which aspect is not clear and why.

There were 176 responses to this question.

Option	Total	Percent
Yes	156	80%
No	20	10.26%
Not answered	19	9.74%

Summary of consultation response

Many respondents agreed with the proposed definition of what it means to be ‘working towards’ a relevant qualification. 85% of social tenants and groups representing them agreed, whilst 79% of registered providers and services providers agreed.

Respondents also overwhelmingly agreed (80%) that the policy statement provided sufficient clarity to help understand when an individual is deemed to be ‘working towards’ a qualification.

However, some respondents had concerns that the policy statement does not adequately consider certain instances for why staff may have difficulties making progress towards completing a qualification due to personal circumstances. Some examples given were interim staff or those taking sabbaticals, secondments or shared parental leave. Another example was staff with additional learning needs or disabilities, who may require reasonable adjustments, and staff working part-time.

Some respondents objected to the fact that staff must complete their qualification within 2 years of enrolment if a time period has not been set by the qualification provider. Reasons for this varied, but one of the concerns were that the 2-year period may elapse if staff fail the course. Respondents also had concerns around the pressure on staff to complete the qualification whilst also managing their job responsibilities.

Government response

We acknowledge that there are many circumstances whereby staff may be absent from work and unable to make progress towards or to enrol on a relevant qualification within the specified timescales. The examples of reasons where staff may be absent from work or due to begin an extended absence from work within the policy statement are intended to be non-exhaustive.

Having considered this feedback, we have updated the policy statement to allow for other instances where staff may not be enrolled, be making progress towards, or may not have completed a relevant qualification within the stipulated timescales. This includes instances where a person requires a reasonable adjustment due to a disability (as defined under the Equality Act), and where they are undertaking a longer duration course such as an undergraduate or postgraduate degree which cannot be completed within the maximum 2-year limit. We have also clarified under what circumstances a person is deemed to be ‘working towards’ a partially compliant qualification, or an additional training module.

We acknowledge concerns about part time staff or staff with caring responsibilities, and we strongly encourage qualification providers to put reasonable measures in place to accommodate some flexibility for these staff in terms of timescales for completing qualifications.

In circumstances where staff fail to be awarded a relevant qualification, we have amended the policy to require registered providers to ensure staff retake the course or enrol upon another relevant qualification within 6 months of failing their course.

Question 6

Section 5: Transition period

Accepted Answer

The consultation proposes a transition period of 24 months within which relevant staff must have, or must be working towards, a relevant qualification. It also proposes that 50% of those staff should have, or be working towards, a qualification within the first year.

Question 19

Considering the costs and benefits outlined within the impact assessment, do you agree that all existing staff within the sector should have, or should begin working towards a relevant qualification within 24 months as outlined in section 4.1 of the policy statement?

If no, please explain why?

There were 337 responses to this question.

Option	Total	Percent
Yes	134	36.61%
No	203	55.46%
Not answered	29	7.92%

42 of these responses were completed by social tenants and groups representing them:

189 of these responses were completed by registered providers of social housing, services providers who manage services on their behalf and bodies representing them.

Option	Total	Percent
Yes	31	65.96%
No	11	23.40%
Not answered	5	10.64%

Option	Total	Percent
Yes	53	27.18%
No	136	69.74%
Not answered	6	3.08%

Question 21

This question was for registered providers and services providers only. Other response groups have been excluded.

Does the information provided above and in section 4.1 of the policy statement provide sufficient clarity on the time limits within which individuals will need to hold or be working towards a relevant qualification within the transition period?

If no, please explain why?

There were 171 responses to this question.

Option	Total	Percent
Yes	159	81.54%
No	12	6.15%
Not answered	24	12.31%

Question 22

This question was for qualification providers only but due to the low response rate from this group, other response groups have been included.

Considering the total number of staff in the sector that will need to enrol on qualifications within the transition period as outlined in the impact assessment, and noting that our intention is for the Standard to come into force in April 2025 ^{[footnote 4]}, do you believe that you can meet the demand for enrolling learners on qualifications within the 24-month transition period?

If no, please specify the length of transition period that you believe would be necessary to meet this demand.

There were 87 responses to this question.

Option	Total	Percent
Yes	42	11.44%
No	45	12.26%
Not answered	279	76.02%

Summary of consultation response

55% of all respondents disagreed that all existing staff within the sector should have, or should begin working towards, a relevant qualification within 24 months. When broken down in terms of respondent groups, disagreement was particularly high amongst registered providers and services providers, with 70% disagreeing with the proposed transition period.

Approximately 76% of the 209 respondents (and approximately 85% of the 140 registered providers and services providers) who suggested an alternative length of transition period in response to question 19 stated that the transition period should be more than 24 months.

Of the respondents that said the transition period should be over 24 months, around 30% suggested 36 months as an alternative, 22% recommended 48 months, and 19% said the transition period should be 60 months.

Overall, only 8% of those who suggested an alternative length said that the transition period should be less than 24 months. But out of the 11 social tenants and tenant groups that provided a free text box response, just over half (55%) suggested that there should be a shorter transition period. Some, for example, argued that 18 months would be more appropriate to ensure that improvements to housing management services begin at the earliest possible opportunity. A few respondents, primarily tenants or tenant groups argued that registered providers and services providers have already had a number of months’ notice that the qualification requirements will be coming into force, and therefore should not need 24 months within which to comply.

Some respondents, particularly social landlords and groups representing them, had concerns about the increasing pressures on landlords, including as a result of other government requirements relating to the SHRA, for example, the need to decarbonise and remediate stock, alongside the costs of qualification on providers. A few respondents said that the requirements could lead to landlords increasing tenants’ rents. Of those who raised these concerns, the primary example given of a way to mitigate these risks to some extent was to have a longer transition period.

Some respondents highlighted a concern that there could be a potential disruption to services to tenants due to large numbers of their staff being absent at one time, citing concern about the estimated time commitment of 8 hours per week to completing qualifications. They argued that a longer transition period would help to spread out the loss of staff time over a longer period, which would therefore reduce the impact on services to tenants.

Some respondents were worried about a possible shortage of qualification courses available, including top up courses, causing some providers to say they were not confident they would be able to comply with the proposed transition period. Respondents said that a longer transition period would allow time for more courses to come onto the market and to ensure the right ‘top up’ modules were available for those with partially compliant qualifications.

82% felt that the policy statement provided sufficient information to providers to help them understand and determine which individuals will need to hold or be working towards a relevant qualification within the transition period, however a few respondents requested further clarity on how the transition period would apply to those staff working part-time or on long term sick.

Government response

The government believes it is vital to professionalise the social rented sector in order to raise standards and make sure tenants receive a good quality service from their landlord. At the same time, it is essential that landlords are able to get their staff qualified in a phased way so that they can effectively manage impacts on staffing capacity and services to tenants. In response to the feedback received, we will apply a transition period of 3 years for large providers (and 4 years for small providers with less than 1,000 units), which we assess strikes the right balance between driving progress on professionalising the sector and ensuring the standard is deliverable. This will also help to ensure there is sufficient time for qualifications providers to develop their offering so that qualifications can be rolled out on the scale needed.

We will provide greater flexibility to landlords by removing the requirement for a proportion of staff to be enrolled half way into the transition period, but we expect landlords to exercise reasonable judgement in considering when their staff should be enrolled throughout the transition period, to ensure they are moving as rapidly as possible to upskill their staff.

Adjusted transition period for smaller providers

An adjusted transition period of twice the amount of time (4 years based on the 24-month transition period proposed in the consultation) should apply to registered providers which provide fewer than 50 units of stock. It was proposed that this same adjusted transition period should also apply in relation to the services providers of those registered providers who provide fewer than 50 units of stock.

Question 23

Do you agree with the proposal that an adjusted transition period (twice the amount of time) should apply to registered providers which provide fewer than 50 units of stock, and will also apply in relation to their services providers?

If no, please state whether you disagree that the threshold should be 50 units of stock, or that the adjusted transition period should be twice the amount of time (in both instances, please explain why and if you have an alternative suggestion).

There were 301 responses to this question^{[footnote 5]}. 38 of these responses were completed by social tenants and groups representing them. 166 of these responses were completed by registered providers and services providers.

Option	Total	Percent
Yes	100	51.28%
No	83	42.56%
Not answered	12	6.15%

Summary of consultation responses

Many respondents agreed with this proposal, however, a substantial minority disagreed. Broken down by respondent group, 63% of social tenants, and 59% of registered providers and services providers who responded to the question agreed with the overarching proposal.

A few respondents thought that this proposed transitional arrangement provides too much flexibility, and that the standard should be applied consistently to all providers with no exceptions for smaller organisations.

Conversely, concerns were raised, particularly by landlords and their representatives, about the potential impacts of the qualification requirements on smaller organisations who have more than 50 units of stock, and thought that there should be a longer transition period for these organisations.

The threshold should be 50 units of stock

13% of social tenants, and 28% of registered providers and services providers who responded to the question disagreed that that the threshold should be 50 units of stock proposal.

Approximately 36% of registered providers and services providers (and approximately 23% of all respondents) who provided a free text box response said that the threshold should be higher than 50 units. The most common suggested alternative was 1,000 units. One of the reasons given was that this would align with the Regulator of Social Housing’s (RSH) definition of small registered providers and would be a consistent approach to how regulatory standards are applied across the sector.

A few respondents also argued that the threshold should be based on the number of managers in scope instead of the number of units. On the other hand, a few respondents argued that larger organisations (i.e. those with a higher number of units) needed a longer transition period as they have more managers in scope that would need to get qualified. A few also said that the number of units of stock an organisation had would not make any material difference to the pressures of implementing these requirements.

The adjusted transition period should be twice the amount of time

Many respondents agreed that the adjusted transition period should be 48 months, with only 14% disagreeing (as above). When broken down by respondent group, 25% of social tenants, and 14% of registered providers and services providers who responded to the question disagreed that the adjusted period should be twice the amount of time. One example of reasons given for respondents’ disagreement was that the 48 month transition period should be extended to all registered providers, regardless of their size. Also, approximately 13% of registered providers and services providers thought that it should be higher than 48 months, with a few respondents suggesting 60 months as an alternative. Conversely, a few respondents thought that there should be no adjusted transition period, arguing that tenants should expect the same level of service, regardless of the size of their provider.

Government response

Although many respondents agreed with this proposal, we have reconsidered the position based on overall feedback, concerns raised about the transition period, and pressures on providers in the sector more widely. As such, we have refined our policy so that smaller organisations are identified as those organisations with less than 1,000 units and that these organisations will have a 4 year transition period. This will ensure consistency with other regulatory standards, and it will mean that organisations with smaller numbers of staff are not disproportionately impacted by these requirements as they will be able to split the costs and loss of staff working hours over a longer period.

Question 7

Section 6: Transitional arrangements for partially compliant qualifications and apprenticeships

Accepted Answer

Transitional arrangements for partially compliant qualifications

The consultation proposed that during the transition period, those who hold a qualification which partially covers the course content criteria, must complete additional accredited training or accredited continuing professional development modules to cover the remaining criteria.

Question 24

Do you agree with our proposal as outlined above and described in section 3.6 of the policy statement that there should be transitional arrangements in place for those with partially relevant qualifications (which meet or exceed the requirements in section 3.1 of the policy statement, but do not meet all the course content criteria in section 3.2).

If no, please explain why.

There were 326 responses to this question.

Option	Total	Percent
Yes	265	72.40%
No	84	22.95%
Not answered	17	4.64%

Question 25

This question was for qualifications providers only but due to the low response rate from this group, other response groups have been included.

Where your course does not cover all the criteria listed above, do you plan to update your qualifications to ensure that you cover the proposed course content requirements? If no, please explain why.

It is worth noting that there were only 6 respondents to this question who categorised themselves as a qualification provider (4 of which said “yes”, one said “no”, and one did not answer). Many of the other responses came from registered providers and services providers.

Option	Total	Percent
Yes	244	66.67%
No	86	23.50%
Not answered	36	9.84%

Summary of consultation responses

Many respondents (73%) were in agreement with this proposal. Of those who disagreed, some said that technical qualifications such as property surveying degrees should be fully compliant even though they often do not meet all the course content criteria. Some respondents raised concerns about this only applying during the transition period, and argued it should be made permanent. The main reason given was that staff who have technical qualifications could move or be promoted into roles in scope after the transition period and, under current proposals, they would then be required to undertake a second qualification. Some respondents said that it would be disproportionate to require technical staff to undertake dual qualifications and that this could have unintended consequences, with many technical staff leaving the sector.

Some respondents had concerns around the practicalities of the proposed transitional arrangements for top up courses. Approximately 30% of the free text box responses to question 24 requested more clarity about which type of qualifications would be considered partially relevant and which types of top up courses were allowed. These respondents were also concerned that it would be difficult to access information on the course content of historic qualifications to assess whether they meet the criteria. It was suggested that government should work with qualifications providers to map partially relevant qualifications against the criteria so registered providers and services providers can easily understand where top up training is required.

A few respondents said that this provision should also apply to staff with other relevant qualifications such as leadership or chartered management qualifications.

There were also concerns about the potential for limited availability of top up training, and that this could create a monopoly for some of the key training providers.

Government response

In response to the feedback received, we have amended the policy statement to make this transitional arrangement permanent so staff do not have to undertake a full additional qualification if they already have a partially relevant qualification. This change, alongside other changes made to the course content requirements, is intended to mitigate landlords’ concerns about recruitment and retention of staff, particularly technical and specialist roles. It will also ensure that all staff who manage direct delivery of services to tenants will be required to develop core skills in areas such as customer services and equality and diversity.

In response to requests from registered providers and services providers for more clarity on how the provision for partially relevant qualifications will work in practice, we have provided additional guidance within Annex A of the policy statement. The guidance provides examples of the types of qualifications which would be deemed partially compliant.

In line with the RSH’s outcomes focused approach, we have not been prescriptive about which specific courses could constitute top up modules. Instead, we have made it clear that the employer is expected to identify training modules of an appropriate volume, quality and level to cover the outstanding criteria. Regarding concerns about the lack of availability of top up modules, we note that training providers are already taking steps to make suitable courses available to the sector and we encourage qualifications providers to continue to develop this offering.

Finally, the legislation stipulates that qualifications must be focused on housing management. This is to ensure that managerial staff are sufficiently skilled in managing the specific set of issues faced by the social tenants. As such, leadership or chartered management qualifications or qualifications in disciplines such as planning, sociology, social policy and geography which are not specific to housing management would not be deemed to be partially compliant for the purposes of the rules set in the policy statement. However, these types of qualification may be recognised under qualifications providers’ systems as prior learning which means that learners may be exempted from certain modules of the qualification if they can evidence that they have met the learning outcomes and assessment criteria.

Transitional arrangements for apprenticeship programmes

The consultation proposed that, during the transition period, those who complete (or have completed) an apprenticeship programme without a qualification element will be compliant.

Question 26

Do you agree with our proposal as outlined above and described in section 3.7 of the policy statement that there should be transitional arrangements in place for those who have completed an apprenticeship programme without a qualification element provided they meet other criteria (as above)?

If no, please explain why.

There were 312 responses to this question.

Option	Total	Percent
Yes	281	76.78%
No	31	8.47%
Not answered	54	14.75%

Summary of consultation responses

Many respondents (77%) agreed that apprenticeships should meet the requirements during the transition period, even if they do not include a qualification element. Some respondents who provided a free text box response said that this arrangement should be made permanent. A few respondents expressed some disappointment that, under the current proposals, employers who put their staff through an apprenticeship would still need to pay a registration fee for the qualification as it would not be covered by the apprenticeship levy.

Government response

In response to the feedback received, we have amended the policy statement to make this transitional arrangement permanent. This means that 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. Apprenticeships must still be of the required level and cover the necessary course content criteria and learners must pass their apprenticeship assessment. We are confident that apprenticeships will equip learners with the necessary skills and knowledge to deliver a good service to tenants.

Question 8

Section 7: Requirements for registered providers in respect of the relevant managers of services providers

Accepted Answer

We have set out guidance on the requirements which apply to registered providers in respect of the staff of services providers, as well as guidance for services providers to help them to understand what the implications of the Act are for services providers.

Question 27

This questions was for registered providers only. Other response groups have been excluded.

Having read the information provided above and in Chapter 6 of the policy statement, are you clear on what your responsibilities are in relation to Relevant SP Managers?

If no, please explain what further clarity is needed.

There were 152 responses to this question.

Option	Total	Percent
Yes	114	64.77%
No	38	21.59%
Not answered	24	13.64%

Question 28

Based on the information provided in section 6.1 and Annex B2 of the policy statement, are you clear on what would classify someone as a Relevant SP Manager?

If no, please explain what further clarity is needed.

There were 151 responses to this question.

Option	Total	Percent
Yes	102	57.95%
No	49	27.84%
Not answered	25	14.20%

Question 29

Does the guidance in Annex B2 of the policy statement enable you to understand what the implications of these requirements are for your organisation and your obligations under the terms implied by section 217A of the Housing and Regeneration Act 2008?

If no, please explain what further clarity is needed.

There were 12 responses to this question.

Option	Total	Percent
Yes	12	63.16%
No	0	0%
Not answered	7	36.84%

Question 30

Does the information provided in Chapter 6 of the policy statement enable you to understand the requirements placed on registered providers in relation to services providers?

If no, please explain what further clarity is needed.

There were 13 responses to this question.

Option	Total	Percent
Yes	13	68.42%
No	0	0%
Not answered	6	31.58%

Summary of consultation responses

There was some uncertainty amongst respondents about how the standard applies to contractors and sub-contractors and which types of providers would have staff in scope and many respondents said that more clarity is needed. Whilst there was general agreement that where the entire housing management service is contracted out (e.g., to an Arms-Length Management Organisation), the services provider should be expected to comply with the requirements, some thought that contractors who deliver smaller, individual elements of the overarching service should not be in scope.

Concerns were raised about private and commercial contractors potentially being in scope, particularly those who deliver repairs and maintenance works. Some respondents who disagreed that the qualification requirements should be applied to private contractors had concerns about the impact this would have on services, citing the existing shortage of repairs and maintenance contractors as an existing pressure. They also stated that the new requirements could lead skilled workers to prioritise contracts within the private sector instead, where qualification requirements are not currently in place, ahead of social rented sector contracts. It was said that registered providers may decide to use larger contractors who are more likely to have capacity to meet the requirements, which could have wide negative impacts on smaller contractors and growth in the repairs and maintenance sector. A few respondents also said that there was a lack of awareness of these new requirements amongst private sector contractors.

As such, some respondents suggested that the requirements should only be applied to services providers managing ‘core housing management functions’ or a substantial part of registered providers’ services, and that it would be disproportionate to apply qualification requirements to providers who only deliver individual elements of the service. A few respondents also had concerns about how this would apply to smaller TMOs, with respondents making the point that this was not a traditional client-contractor relationship.

Some respondents raised concerns about how the requirements would apply in the context of supported housing, in particular how they would apply to managing agents, or registered providers who use managing agents in a social housing setting.

A few respondents were unclear whether it was likely that one or more managers or executives on the ‘client side’, i.e. the person employed by the registered provider, would be in scope as well as managers and executives working for the services provider.

A few respondents were also unclear on what the requirement that they ‘take steps to secure’ means, and raised concerns about how they would monitor and enforce the requirements, particularly what recourse they would have if services providers breached the requirements or refused to get their staff qualified. There was some clear misunderstanding of the implied terms provision, with respondents raising that it would be difficult to get their contractors to consent to amending their management agreements. It was also queried who would be liable for costs of implementing the requirements between registered providers or services providers.

Government response

In response to the feedback received, we have introduced an exemption from the qualification requirements for services providers who do not provide a comprehensive social housing management service to the registered provider meaning that they do not deliver all or the majority of the functions listed in section 6.5 in relation to the registered provider’s social housing. Services providers would only have staff in scope if they deliver all or the majority of those functions in relation to the registered provider’s social housing. The staff of services providers that only deliver individual functions, or a small number of functions (such as an asset management contractor for example) would not have staff in scope.

It is vital that those senior managers and executives of services providers who have a substantial influence over the quality and safety of the overarching housing management service remain in scope. However, it is also important that the policy is proportionate, and we must avoid restricting registered providers’ ability to procure skilled contractors to deliver timely repairs and maintenance works. We have assessed that targeting qualification requirements at those staff responsible for making decisions about the service as a whole is the best way to ensure tenants receive a consistently high quality service.

The exemption referenced above applies to the qualification requirements only. Under the broad, outcome-based standard, registered providers will still need to take appropriate steps to ensure services providers’ staff who are involved in the provision of services in connection with the management of social housing have the necessary skills, knowledge and experience, and exhibit the behaviours needed to deliver a good quality service. This will include the staff of all services providers, including contractors who deliver smaller scale housing management functions only such as asset management.

In response to feedback received, we have also provided additional guidance to help registered providers and services providers to identify where services providers’ staff would be in scope of the qualifications requirements. Guidance has also been provided on how registered providers are expected to enforce compliance with the standard, and on how the qualification requirement applies where it is the local authority contracting out housing management services rather than the registered provider.

Other issues

Question 32

Are there any other issues you want to raise, or anything you believe has not been considered in relation to proposals 16 and 17?

There were 139 written responses to this part of the question.

Summary of consultation responses

A number of concerns were raised in this section, many of which related to other consultation questions and have been addressed in the sections above. Some respondents raised that they needed further clarity on the requirements for services providers and sub-contractors, and a few respondents raised concerns here that these new requirements might discourage services providers from working with registered providers.

Some respondents raised concerns about the potential impacts the new requirements could have on recruitment and retention in the sector (this was both in relation to registered provider and services provider staff), including the risk of competent and experienced people choosing to leave the sector. This was a concern that was raised consistently across responses to many other questions within the consultation.

Although not directly relevant to the question, a few respondents raised concerns about the impacts of this reform on individuals with protected characteristics. They queried whether it would be possible for reasonable adjustments to be made for their staff when undertaking courses, for example for those with learning disabilities or neurodivergence. There were also concerns about older members of staff and on those who work part time or have caring responsibilities who might find it more difficult to study for a qualification. A few respondents also queried the interaction between these requirements and employment law, and what registered providers might do if their staff refused to undertake qualifications.

Some respondents also raised concerns about the cost of funding the requirements for registered providers and services providers. A few respondents questioned the underpinning rationale for the policy and did not agree that qualification requirements were the right way to improve professional standards in the sector and drive culture change.

Government response

The government response to many of these issues have been set out in detail across our responses to other sections. On employment law, our guidance outlines that providers must secure that in-scope staff hold or are working towards a relevant qualification, and that if a person persistently fails to complete or pass the qualification or refuses to undertake the course, providers are expected to address this in accordance with their own HR or disciplinary processes and procedures.

Question 9

Section 8: Questions related to the impact assessment

Accepted Answer

It is worth noting that we have only included the analysis for the questions which had a ‘free text’ element in the section below. The quantitative data received through responses to questions 34- 43 of the consultation were instead used to inform our impact assessment and more detail on this is set out in our impact assessment.

Question 20

Do you have any additional comments or evidence about the potential impact of the policy proposals as assessed in our impact assessment?

If yes, please explain?

There were 321 responses to this question.

Option	Total	Percent
Yes	134	36.61%
No	203	55.46%
Not answered	29	7.92%

Summary of consultation responses

215 respondents provided a free text box response to this question. ~35% of those raised concerns about cost and funding. Local authorities were particularly concerned about their ability to fund the implementation of this standard through existing Housing Revenue Accounts (HRAs), stating that it would cause further strain to local authorities’ existing budgets. A few respondents, namely social landlords, said they were concerned that the costs of meeting the qualification requirements could have an impact on rents. Registered providers also raised concerns that they would have to redirect designated learning and development budgets to fund the new qualification requirement and that this would mean staff in other roles may have less access to training as a consequence.

A few housing providers flagged that the impact assessment undervalued the cost of the qualifications available, and some thought it underestimated the familiarisation and implementation costs. It was also flagged that the impact assessment did not fully consider the increased costs associated with recruitment and retention.

Additionally, a few respondents were concerned about meeting staff’s higher expectations around salaries which may result from the qualification requirements.

Some respondents were concerned that the qualification requirements would have an adverse effect on services to tenants, and that learners would need to commit a large amount of time to undertaking the qualification which would take them away from delivering day to day services. They said that providers would face large costs in backfilling the roles of staff that were absent.

Some had some concerns about availability of training providers including potential for regional differences in supply and demand. A few respondents also raised concerns about some qualifications providers having a monopoly over the market, and that they might increase the prices of qualifications.

Government response

Our response to some of the points raised in response to this question have been acknowledged and responded to in other areas of this government response.

We acknowledge landlords’ concerns about recruitment and retention in the sector. We believe that these measures are necessary to drive up professional standards across the sector and ensure that staff have the right skills, knowledge, experience and behaviours. Measures have been designed into the policy to aid implementation and to reduce impacts on service provision, such as the 3 year transition period for large providers and 4 year transition period for smaller providers. In addition, the transition period will mean that staff who are very close to retirement could retire before the end of the transition period, without needing to enrol on a qualification. There is also no requirement for staff to hold qualifications before they can be offered a post. It is hoped that the requirements will make a career in housing more attractive to high quality candidates and therefore encourage new people into the sector.

We believe that tenants should receive a consistent standard of service, and all staff managing the delivery of their services should have the skills, experience and behaviours to deliver those services with confidence.

Question 33

In paragraph 64 of the impact assessment, we have set out our assumptions around the familiarisation / implementation costs to registered providers and services providers for the implementation of the full Competence and Conduct Standard including the qualification element of the Standard?

Do you agree with these assumptions? If no, please explain why and provide an alternative.

There were 165 responses to this question.

Option	Total	Percent
Yes	45	23.08%
No	66	33.85%
Don’t know	54	27.69%
Not answered	30	15.38%

Summary of consultation responses

The impact assessment assumed that familiarisation and implementation of the standard would require one working day for small providers, and 10 working days for large providers. 62% of respondents disagreed with or said that they didn’t know whether they agreed with our assumptions made about the familiarisation and implementation costs in the impact assessment. Some providers thought that the impact assessment underestimated the familiarisation and implementation costs of the “full” competence and conduct standard (this means all of the requirements on registered providers as set out in the draft direction, including the qualification requirements).

Familiarisation costs take into account the time needed for an organisation to learn about and understand new regulations, systems, or procedures. In this context, the costs relate to the time organisations will take to undertake tasks such as reviewing policies and existing codes of practice, developing communications plans for staff and services providers (where applicable), determining which staff are required to do the qualification, and reviewing their service delivery plans.

Some respondents felt that the assumptions made did not take into account all the costs and impacts to providers and some respondents re-raised concerns about costs associated with the loss of staff time to qualifications in response to this question.

Government response

Our initial assessments of costs as set out in our impact assessment were modelled from a variety of sources including research commissioned from IFF Research by the government, surveys undertaken by the National Housing Federation and Local Government Association and, estimates from qualifications providers and the Annual Survey of Hours and Earning. We have refined our assumptions following consideration of responses to this consultation.

Based on the feedback received, we agree that the number of days for familiarisation should be increased. Our revised estimates are that large registered providers will need between 20-30 working days to familiarise themselves, while small registered providers (with under 1,000 homes) will need on average 5-10 working days.

The impact assessment also includes a separate assessment of ‘opportunity costs’ which reflect the costs to providers of staff having to spend time on completing their qualifications. More detail is set out in the ‘monetised costs’ section of the impact assessment.

The impact assessment set out the cost of the level 4 and level 5 qualification based on the market prices for the existing CIH qualification. Since the publication of consultation, there have been changes to the range of prices charged by study centres offering the CIH qualification and new qualifications have come onto the market. These changes have been reflected in the updated impact assessment.

Question 44

This question was for qualification providers only but due to the low response rate from this group, other response groups have been included.

We have made an assumption that where people undertake a qualification (not as part of an apprenticeship programme), this will require a commitment from the learner of 8 hours per week over approximately 12 months for both level 4 and 5. This will amount to around 320 hours of study for senior housing executives and 360 hours of study for senior housing managers in total.

Do you agree with this assumption?

There were 74 responses to this question. Although this was a question for qualification providers, we received responses from other types of respondents which are included in this figure.

Option	Total	Percent
Yes	42	11.48%
No	11	3.01%
Don’t know	21	5.74%
Not answered	292	79.78%

Summary of consultation responses

It is worth noting that this question was for qualification providers only, but the majority of responses came from local authority or private registered providers (we have included their responses in our analysis).

Only 8 qualification providers responded. 6 out of these 8 qualification providers agreed with our assumptions that the qualifications would amount to approximately 320 hours of study for senior housing executives and 360 hours for senior housing managers.

A few respondents, primarily landlords commented that our assumption relating to the 8 hours per week time commitment did not take into consideration the fact that some staff with different learning needs and abilities may require additional time to study each week. Concerns were expressed about the additional time it might take for individuals who have a learning disability or are neurodivergent to complete the qualification.

Again, some respondents were also concerned that 8 hours per week was a significant time commitment, and expressed concerns about the impact this could have on delivery of services.

Government response

We recognise that some learners may need additional time to complete the qualification, and have made relevant amendments to the policy to provide more flexibility for those who have a disability as defined under the Equality Act. There is also a provision in place for those who are unable to make progress towards completing the qualification in some instances due to absences from work or extended leave for example.

The policy statement has been revised to include a minimum total qualification time requirement of >120 hours. We note that some new qualifications have already entered the market in response to the consultation, and we expect that qualification providers will move to offer some courses that align with the minimum threshold set, alongside longer duration courses. For the purposes of the impact assessment, we have taken into account that the minimum requirement of >120 hours is lower than any courses being offered at the time of writing, and it may take time before courses of >120 hours are available. Our impact assessment therefore assumes that in year 1 of the policy, the time taken to complete the course will be based on those which currently exist (between 195-360 hours for the level 4 and 380-385 hours for the level 5), and that this will reduce to 120 hours over 3 years, anticipating that by the third year of the standard being in place, relevant qualifications which align with the minimum course duration will be available on the market.

Phase 2 report - Grenfell Tower Inquiry, section 31.22, section 39.34. ↩
Phase 2 report - Grenfell Tower Inquiry, section 33.52-58. ↩
A small number of respondents responded that they agree the guidance is sufficiently clear, but specified that their disagreement related to senior managers and / or executives so this data has been disregarded. ↩
To note that the standard will now come into force in October 2026. ↩
Please note, 1 respondent selected that they agreed with the statement, but then selected that they disagreed that the threshold should be 50 units of stock. This individual is currently counted in both the ‘Yes’ and the ‘No, I disagree that the threshold should be 50 units of stock…’ groups.

76 individuals stated that they disagreed with the threshold statement, and of these 76, 13 individuals also disagreed with the transition period. 39 individuals disagreed with the transition period statement but did not disagree with the threshold statement. ↩

Option	Total	Percent
Yes	187	51.09%
No, I disagree that the threshold should be 50 units of stock (please explain why and if you have an alternative suggestion)	76	20.77%
No, I disagree that the adjusted transition period should be twice the amount of time (please explain why and if you have an alternative suggestion)	52	14.21%
Not answered	65	17.76%

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Executive summary

The consultation: content and approach

Summary of consultation responses

Section 1: The broad standard relating to the competence and conduct of all social housing staff

Question 1

Social tenants and representatives

Registered providers and services providers

Summary of consultation responses

Government response

Section 2: Who is in scope of the qualification element of the Competence and Conduct Standard

The ‘substantive role’ rule

Question 2

Social tenants and representatives

Registered providers of social housing and services

Summary of consultation responses

Government response

Roles in and out of scope of the qualification requirement

Question 3

Question 4

Question 5

Question 6

Question 7

Summary of consultation responses

Government response

Timescales for enrolling on qualifications

Question 8

Social tenants and representatives

Registered providers of social housing and services providers

Question 9

Summary of consultation responses

Government response

Unpaid volunteers

Question 10

Question 11

Summary of consultation responses

Government response

Section 3: Criteria that qualifications must meet

Level of qualification required

Question 12

Question 13

Level 4

Level 5

Summary of consultation responses

Government response

Regulation of qualifications

Question 14

Summary of consultation responses

Government response

Course content criteria

Question 15

Social tenants and representatives

Registered providers of social housing and services providers

Question 16

Summary of consultation responses

Government response

Course content requirements

Additional training modules (‘top up training’)

Recognising existing knowledge and experience

Section 4: What constitutes ‘working towards’ a qualification for the staff of both registered providers and services providers

‘Working towards’ a qualification

Question 17

Question 18

Summary of consultation response

Government response

Section 5: Transition period

Question 19

Social tenants and representatives

Registered providers of social housing and services providers

Question 21

Question 22

Summary of consultation response

Government response

Adjusted transition period for smaller providers

Question 23

Summary of consultation responses

The threshold should be 50 units of stock

The adjusted transition period should be twice the amount of time

Government response

Section 6: Transitional arrangements for partially compliant qualifications and apprenticeships