Open consultation

Consultation on changes to our consumer standards and requirements (accessible version)

Published 9 December 2025

Applies to England

List of annexes in the consultation  

These documents can be found on the consultation web page on the proposed Transparency, Influence and Accountability Standard; Consumer Standards Code of Practice; & Electrical Safety Checks Tenant Satisfaction Measure 

Annex 1	Proposed revised Transparency, Influence and Accountability Standard (with changes highlighted against the current standard)
Annex 2	Clean copy of proposed revised Transparency, Influence and Accountability Standard
Annex 3	Proposed revised Consumer Standards Code of Practice (with changes highlighted against the current version)
Annex 4	Clean copy of proposed revised Consumer Standards Code of Practice
Annex 5	Regulatory and equality impact considerations

Foreword 

I am pleased to launch our consultation on changes to our consumer standards and requirements. 

The changes we’re consulting on aim to strengthen the transparency and accountability of landlords to their tenants. We continue to reinforce the importance of landlords listening to tenants, treating them with fairness and respect, and acting in a transparent manner. These are essential components to improve the overall quality of social housing and services to tenants. The government has recently published policies in relation to both Social Tenant Access to Information Requirements (STAIRs) and competence and conduct requirements following its own consultations. In this consultation, we are asking for stakeholders’ views on how we have interpreted the government’s Directions to us on each of these areas.    

A further focus of this consultation is a new electrical safety checks Tenant Satisfaction Measure (TSM). The proposed new TSM is aimed at providing a source of insight on the completion of electrical safety checks. The TSMs have already proven to be a valuable source of information for tenants and landlords, as well as us as the regulator. The electrical safety checks TSM, will work alongside the other existing building safety TSMs to help strengthen transparency on the safety of tenants’ homes.  

The government has made its expectations for the sector clear, with its strong ambition for housing delivery, as well as its focus on improving the quality of social housing. At the same time, landlords face a challenging operating environment. Our regulatory casework shows that good governance – including listening to tenants and embedding their feedback in decision making as required by the Transparency, Influence and Accountability Standard – is essential if landlords are to achieve their core purpose and are to deliver more and better social homes. The changes we now propose to the Transparency Influence & Accountability Standard will help drive landlords to deliver better outcomes for social housing tenants.  

As a Board we welcome this consultation and encourage all stakeholders, particularly landlords and tenant representatives, to respond. This consultation provides an important opportunity for stakeholders to consider our proposals and make sure the changes we are implementing reflect the Government’s consultation outcomes and directions to us. We look forward to hearing your feedback.  

Bernadette Conroy 

Chair

Scope of the consultation 

Topic of this consultation	This consultation is set out in three parts:  - Part 1 Proposed changes to the Transparency, Influence and Accountability (TI&A) Standard  - Part 2 Proposed changes to the Consumer Standards Code of Practice (the Code).  - Part 3 The proposed introduction of an electrical safety checks Tenant Satisfaction Measure.

Part 1 (TI&A Standard) and Part 2 (Code):

We are proposing to amend the Transparency, Influence and Accountability (TI&A) Standard to reflect new Directions issued by government:  - Direction on the Social Tenant Access to Information Standard 2025 (STAIRs Direction)  - Direction on the Regulatory Standards (Competence and Conduct) 2025 (Competence and Conduct Direction).  The Directions require the regulator to set standards on the Social Tenant Access to Information Requirements (STAIRs) and competence and conduct requirements. This consultation also seeks views on proposed updates to the Code to provide further detail about how we expect landlords [footnote 1] to deliver the outcomes required by those standards.   At the same time, we are taking this opportunity to consult on proposed changes to the TI&A Standard and Code in respect of the Tenant Satisfaction Measures (TSMs). The TSMs are a set of management information and tenant perception measures prescribed by the regulator and were first introduced in 2023. The proposed changes reflect that we will be reissuing the requirements for landlords to collect, process and publish TSMs, and requiring completion of our annual TSM returns, using new powers that were introduced by the Social Housing (Regulation) Act 2023 (SHRA 2023). The powers weren’t available to us when the TSM regime was first introduced. Other than the proposed introduction of an electrical safety checks TSM described below, these changes do not alter the TSMs themselves or the technical and tenant survey requirements and so will not change what landlords need to do to meet them.  Subject to the outcome of this consultation, it is proposed that the revised TI&A Standard and the revised Code will come into force on 1st October 2026.

	Part 3 (Electrical Safety Checks (TSM)):
	The government has introduced a legislative change [footnote 2] that extends mandatory electrical safety checks to the social rented sector. We are therefore proposing to introduce an electrical safety checks TSM to help provide tenants with greater transparency and provide the regulator with information on landlords meeting their obligations. We are seeking views on the proposed TSM.
Scope of this consultation	This consultation represents an opportunity for interested persons and organisations to influence the proposed changes to the TI&A Standard and the Code, and the proposed introduction of an electrical safety checks TSM.  The regulator will review its proposals for the revised TI&A Standard, the revised Code and the electrical safety checks TSM in light of the responses received to this consultation.
Geographical scope	These proposals relate to registered providers of social housing in England.
Impact assessments	See section titled Impact Assessments and Annex 5 for details of our approach to considering the regulatory and equalities impacts of our proposals, and a summary of our considerations.

Basic Information
To:	The regulator’s statutory consultees [footnote 3], private registered providers and local authority registered providers, tenants and residents of registered providers, lenders and any other stakeholders who have an interest in the regulation of registered providers of social housing in England.
Body responsible for the consultation:	The Regulator of Social Housing
Duration:	This consultation will last for 12 weeks from 9 December 2025. The closing date is 3 March 2026.
Enquiries:	For any enquiries about the consultation please contact our Referrals and Regulatory Enquiries Team on 0300 124 5225 or enquiries@rsh.gov.uk who will be pleased to help.

How to respond to this consultation

If you need this consultation document in an alternative format, please make a request using any of the contact details below. 

Please submit your response to the consultation by 3 March 2026. If you respond after this date, your response may not be considered.   

We encourage you to answer as many questions as possible, but you do not have to respond to every question.   

Online 

Where possible, please respond to the questions in this consultation online  

Email or post 

If you are unable to complete an online response, you can email your response to: consultation@rsh.gov.uk.  Please include “Consultation on changes to the consumer standards and requirements” in the subject heading.  

Alternatively, you can send a written response to:  

The Regulator of Social Housing 
Referrals and Regulatory Enquiries team 
Level 2 
7-8 Wellington Place 
Leeds
LS1 4AP 

Please mark the envelope “Consultation on changes to the consumer standards and requirements”.  

If you are responding by email or post, please make it clear which questions in this consultation you are responding to.  

Please respond using only one means e.g., if you respond online, you do not need to email or post your response to us.  

After the closing date of this consultation, we intend to publish a list of all the organisations that have responded.   

To help us understand who responds to this consultation and the context of their answers, please include:  

• your name 
• whether you are responding as an individual or on behalf of an organisation
• whether you are a (please select one):  
  
  - social housing tenant in rental accommodation 
  
  - shared owner in social housing 
  
  - private registered provider 
  
  - local authority registered provider 
  
  - stakeholder organisation 
  
  - other (please specify) 
• the name of the organisation (if applicable) and
• a contact email address (if possible) 

If responding to this consultation through the online survey it will be possible to have a copy of your final response emailed to you. Please ensure that you select this option in the online survey when prompted, as we will not otherwise be able to acknowledge receipt of your response to the consultation or send you a copy of your response.  

After the closing date of this consultation, we intend to publish a summary of the responses we receive. Please do not share any information in your response which you would not be happy for us to make publicly available, identifies other individuals, or contains sensitive personal data (e.g. health information).  

Your response to this consultation may be disclosed on request in accordance with the Freedom of Information Act 2000 (FOIA) and the Environmental Information Regulations 2004 (EIR), however any disclosure will be in line with the requirements of the Data Protection Act 2018 (DPA) and the UK General Data Protection Regulation (UK GDPR). 

If you consider the information that you provide to be confidential it would be helpful if you could explain to us why you regard the information to be confidential, so that this may be considered if the regulator should receive a request for the information under FOIA or EIR. The regulator cannot however provide assurance that the information will not be disclosed.  

The lawful basis for processing your personal data as part of this consultation is a public task. Consultation responses will be anonymised within eight months from the consultation deadline. For more information about how we process and protect personal data see our privacy notice. 

This consultation is not a route for making a referral about a landlord. If you need to contact us about your landlord our contact details are below: 

Email: enquiries@rsh.gov.uk or call: 0300 124 5225 

In writing to:

The Regulator of Social Housing 
Referrals and Regulatory Enquiries team 
Level 2 
7-8 Wellington Place 
Leeds
LS1 4AP 

About this consultation 

This consultation document and consultation process have been developed to adhere to the Consultation Principles issued by the Cabinet Office.  

Thank you for taking the time to read this document and respond. Your opinions are valuable to us.

Executive Summary 

The regulator is proposing to amend the existing Transparency, Influence and Accountability (TI&A) Standard and the Consumer Standards Code of Practice (Code). We are also proposing to introduce an electrical safety checks TSM. This consultation is presented in three parts: 

• Part 1 Proposed changes to the TI&A Standard 

• Part 2 Proposed changes to the Code 

• Part 3 The proposed introduction of an electrical safety checks TSM. 

Through this consultation, the regulator will satisfy its duty under sections 196 and 198(3) of the Housing and Regeneration Act 2008 (HRA 2008), which requires certain parties to have been consulted before the regulator sets, revises or withdraws standards or a code of practice.  

We will review our proposals in light of the responses received to this consultation. It is intended that the revised TI&A Standard and the revised Code would apply from 1 October 2026, until which time our existing TI&A Standard and Code would continue to apply. Subject to this consultation, we intend to introduce the electrical safety checks TSM in or before June 2026, so that it can be reported as part of TSMs covering 2026-27.^{[footnote 4]} 

Part 1 TI&A Standard and Part 2 Code 

Certain proposed changes to the TI&A Standard arise from the Secretary of State for Housing, Communities and Local Government issuing Directions to the regulator on Social Tenant Access to Information Requirements (STAIRs) and competence and conduct requirements. Revisions to the Code are proposed to amplify these proposed changes in the TI&A Standard.  

We are also taking the opportunity to consult on proposed changes to the TI&A Standard and Code to better align the TSMs with our new powers under the HRA 2008 ^{[footnote 5]}. The proposed changes reflect that we will be reissuing requirements for landlords to collect, process and publish information about their performance against our TSMs, and issuing our annual requests for landlords to send us related information, using our new performance information powers ^{[footnote 6]}. These powers weren’t available when we set up the TSM regime and as they’re now available, we will be using them to better align our TSM regime with our revised statutory framework. In effect, from October 2026 the ‘Tenant Satisfaction Measures - Technical requirements’ and ‘Tenant Satisfaction Measures - Tenant survey requirements’ documents will become a Direction to landlords (the TSM Direction – a draft of which can be found here Draft TSM Direction), and we will use our new performance information power to issue our annual TSM returns to registered providers. Except for the proposed addition of an electrical safety checks TSM, described below, there are no changes to the TSMs themselves or the technical and tenant survey requirements and so this will not change what landlords need to do to meet them.  

Parts 1 and 2 of this consultation are seeking views on changes to the TI&A Standard and the Code that we are proposing to make in connection with three areas: (a) the STAIRs Direction, (b) the Competence and Conduct Direction, and (c) our plan to use our new performance information powers for parts of our TSM regime. The rest of the TI&A Standard and Code is not subject to any proposed changes and so is not part of this consultation.  

Part 1 provides further context, explains the proposed changes to the TI&A Standard, and includes consultation questions for each area. Part 2 explains the proposed changes to the Code followed by an overarching consultation question covering all three areas.

Part 3 Electrical Safety Checks TSM 

We are proposing to introduce an electrical safety checks TSM following the introduction of The Electrical Safety Standards in the Private Rented Sector (England) (Amendment) (Extension to the Social Rented Sector) Regulations 2025. The regulations extend mandatory electrical safety checks to the social rented sector.  

We have previously explained that we would decide on the most appropriate action to take in relation to introducing a TSM on electrical safety after the government had finalised its policy on electrical safety for the social rented sector. Now that new legal requirements in this area have been introduced, we are consulting on an electrical safety checks TSM that will work alongside the existing building safety TSMs on gas, fire, water, asbestos and passenger lift safety checks. 

As with the other TSMs, we aim for the electrical safety checks TSM to provide tenants with greater transparency about their landlord’s performance and inform the regulator about how well a landlord is delivering the outcomes of our consumer standards.  

Part 3 provides further context on the development of this proposed TSM, followed by a consultation question on this. 

Assessing the impact 

In Annex 5 we have described our approach to considering the regulatory and equality impacts of our proposals and have summarised our considerations. We have also included an overarching question relating to our considerations.

Draft timetable for introducing the revised TI&A Standard, revised Code and Electrical Safety Checks TSM 

Proposed timings	Anticipated activity
3 March 2026	This consultation closes. Responses submitted after this date may not be considered.
May/June 2026	The regulator publishes a decision statement which will summarise key areas of feedback on the proposed electrical safety checks TSM and set out the final form of the TSM.
Summer 2026	The regulator publishes a decision statement which will summarise the key areas of feedback from the consultation, and set out our decision, on revising the TI&A Standard and Code.
1 October 2026	The revised TI&A Standard and the TSM Direction [footnote 7] will come into force alongside the revised Code.

About the Regulator of Social Housing 

We regulate for a viable, efficient and well-governed social housing sector able to deliver quality homes and services for current and future tenants. Our approach to regulation is driven by our statutory fundamental objectives as set out in the Housing and Regeneration Act 2008.

We have a consumer regulation objective. This covers a range of areas including the safety, quality, and management of social homes; transparency to tenants as well as tenants having opportunities for involvement in how their home is managed and to hold their landlord to account. The consumer standards apply to all landlords registered with us. Throughout this document and the consumer standards ‘tenants’ means tenants and other occupiers of social housing which includes licensees and shared owners (unless explicitly stated). 

We also have an economic regulation objective. The areas this covers include governance, financial viability and value for money. The Governance and Financial Viability Standard and the Value for Money Standard apply only to private registered providers and the Rent Standard applies to all landlords registered with us, including local authorities.

To deliver consumer regulation, we have powers ^{[footnote 8]} to set standards for all landlords registered with us, and the power ^{[footnote 9]} to issue a Code of Practice in relation to those standards. In setting standards, we must have regard to the desirability of landlords being free to choose how to provide services and conduct business. The standards we set are outcome-focused, meaning that landlords can deliver the outcomes in the most appropriate way for their tenants and their business. 

We take a co-regulatory, risk-based approach to regulation, which allows us to exercise our functions in a way that minimises interference, and (so far as is possible) is proportionate, consistent, transparent and accountable, in line with our statutory duty ^{[footnote 10]}. 

Further information on our role and approach to regulating landlords can be found here About us and here How we regulate.

Part 1: Proposed revisions to the TI&A Standard  

Overview 

Our standards are a key part of our regulatory framework. The consumer standards set the outcomes (required outcomes and specific expectations) that landlords must deliver so that homes are decent, safe and well-maintained and tenants receive quality landlord services and are treated with fairness and respect. On 1 April 2024, we implemented our new suite of consumer standards, which included the TI&A Standard.  

The government has the power ^{[footnote 11]} to issue Directions to the regulator to set standards on certain issues. Once issued, we must comply with the Direction. We are, therefore, proposing changes to the TI&A Standard to reflect the Directions issued by government on STAIRs and competence and conduct requirements. We are not inviting views on the content of these Directions or the policy statements they relate to because these have already been consulted on and published by government. The regulator must now comply with the Directions. We are asking respondents to highlight any instances where they consider that the regulator has not accurately reflected the content of government’s Directions in the proposed revised TI&A Standard, and whether they agree with related revisions to the Code.  

We are also consulting on the proposed changes we have made to the TI&A Standard and the Code to reflect our plan to use our new performance information powers for parts of our TSM regime. We are not consulting on the TSM Direction ^{[footnote 12]} under which we are planning to re-issue our ‘Tenant Satisfaction Measures - Technical requirements’ and ‘Tenant Satisfaction Measures - Tenant survey requirements’. Re-issuing those requirements under the TSM Direction will not change what landlords need to do to meet them.  

The proposed changes to the TI&A Standard are covered in part 1 (a-c) of this consultation document. The proposed changes to the TI&A Standard are highlighted in a draft of this standard at Annex 1. We have also included at Annex 2 a version of what the draft standard would look like when published if these changes are adopted.

Our regulatory approach 

We take a co-regulatory, risk-based approach to regulation, which allows us to exercise our functions in a way that minimises interference, and (so far as is possible) is proportionate, consistent, transparent and accountable, in line with our statutory duty. We will continue to regulate the TI&A Standard in a way that is consistent with this approach.  

Our regulatory standards are outcome focussed. We focus on whether landlords are delivering the outcomes of the standard without prescribing how they should do it.  For example, in relation to the competence and conduct requirements, we will, through our regulation, focus our attention where we judge the risks to landlords delivering services that are of good quality are greatest. Our focus will remain on whether landlords are delivering the outcomes of the standards, and it is for landlords to assure themselves how they are delivering those outcomes.

a) Revising the TI&A Standard to reflect the STAIRs Direction

Background 

As part of the reforms set out in the Charter for Social Housing Residents: Social Housing White Paper (2020), the then government committed to introducing an access to information scheme for the social housing tenants of private registered providers to support building a culture of openness and transparency across the social housing sector.  

Subsequently, the SHRA 2023: 

• Amended the fundamental objectives ^{[footnote 13]} of the regulator to include transparency to ensure registered providers act in a transparent manner in relation to their tenants.  

• Introduced a new power ^{[footnote 14]} to enable the regulator to set standards for registered providers in matters relating to the provision of information and transparency to social housing tenants and to the regulator.

Following the introduction of the SHRA 2023, the Secretary of State has used their power ^{[footnote 15]} to direct the regulator to set a standard with a view to achieving (so far as possible) that private registered providers comply with the expectations set out in the government’s Social Tenants Access to Information Requirements (STAIRs) policy statement. This will allow tenants of private registered providers or their designated representatives to access relevant information on request and will require landlords to publish more information about their management of social housing. The government’s aim is to ensure tenants can access the information they need to hold their landlords to account.  

In May 2024, alongside the draft Policy Statement, the then government consulted on the content of the draft Direction and issued the final Direction to us on 30 September 2025. The final Direction and the final STAIRs policy statement can be found on the MHCLG website. It sets out when different elements of the policy statement will become active. 

The requirements of the STAIRs scheme do not apply to local authorities or their Tenant Management Organisations (TMOs) ^{[footnote 16]}. Tenants of local authorities can already access information held by their landlord through the Freedom of Information Act 2000 (FOIA) and the government has committed to extending the FOIA to cover local authority TMOs so that tenants in homes managed by TMOs will be able to access information held by them. 

The proposed changes will apply to all private registered providers in England. This consultation is seeking views on whether the government’s published Direction on STAIRs has been accurately reflected in our proposed changes to the TI&A standard.

Proposed amendment to the TI&A Standard to reflect the STAIRS Direction  

The government’s 2025 Direction to the regulator on STAIRs is available at Social Tenant Access to Information Requirements: consultation - GOV.UK 

We are proposing that the following required outcome should be added to the TI&A Standard to reflect the Government’s direction to us:

Required outcomes

1.7 Social Tenant Access to Information Requirements (STAIRs)

1.7.1 Private registered providers~ must provide information to their tenants concerning the accommodation, facilities and services provided by them in connection with social housing. In doing so they must meet the expectations set out in the government’s policy statement entitled Social Tenant Access to Information Requirements dated 30 September 2025~~

~ apply to private registered providers only

~~ The Social Tenant Access to Information Requirements (STAIRs) - Gov.UK

Consultation question on the proposed amendment to the TI&A Standard to reflect the STAIRS Direction 

Consultation question 1 

Do you agree or disagree that the proposed change to the Transparency, Influence and Accountability Standard accurately reflects the government’s STAIRs Direction to the regulator?  

Please state if you agree or disagree, or if you don’t know.  

Please provide comments if you wish to explain your response.

(b)  Revising the TI&A Standard to reflect the Competence and Conduct Direction  

Background 

As part of the reforms set out in the Charter for Social Housing Residents: Social Housing White Paper (2020), the then government committed to conducting a review of ‘professional training and development’ provision to consider the appropriate qualifications and standards for social housing staff in different roles. The review concluded that many landlords need to do more to improve staff professionalism and make sure all staff treat residents with respect at all times. It recommended that if qualifications were to be introduced, they should be focused on senior managers and executives, as they’re best placed to drive organisational culture change.

Subsequently, the SHRA 2023 introduced a new power ^{[footnote 17]} to the regulator to set standards for registered providers in matters relating to the competence and conduct of individuals involved in the provision of services in connection with the management of social housing. The Secretary of State has used their power ^{[footnote 18]} to direct the regulator to introduce a standard that must include certain requirements for landlords in relation to ensuring that relevant individuals ^{[footnote 19]} 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. In addition (and among other things), the standard must also require landlords to have a written policy in place which must include certain matters and how those will be delivered. The scope of these requirements include those of the landlord’s services providers’ staff who are relevant individuals ^{[footnote 20]}.

In February 2024, the then government consulted on the content of a draft Direction and draft Policy Statement. The final Direction was issued to us on 30 September 2025. 

To comply with the Direction, the standard must also require landlords to meet all applicable requirements set out in chapters 1-6 of the Policy Statement on Qualification Requirements for Social Housing. ^{[footnote 21]} The Policy Statement sets out requirements for landlords in relation to securing that relevant senior housing managers and executives, including those of relevant service providers, have or are working to gain certain types of qualification. The qualifications requirements do not apply in relation to relevant individuals of service providers that do not provide a comprehensive social housing management service to the landlord. ^{[footnote 22]}  The transition period for the qualifications requirements is set out in the Policy Statement.

This consultation is seeking views from respondents as to whether the government’s published Direction on competence and conduct requirements has been accurately reflected in our proposed changes to the TI&A Standard. 

Proposed amendments to the TI&A Standard to reflect the Competence and Conduct Direction 

The government’s 2025 Direction to the regulator on competence and conduct requirements is available at Direction on the Regulatory Standards (Competence and Conduct) 2025 - GOV.UK. 

We are proposing that the following required outcome and specific expectations should be added to the TI&A Standard to reflect the government’s Direction to us:

Required outcomes

1.8 Competence and Conduct

1.8.1 Registered providers must

a) secure that their relevant staff have the necessary skills, knowledge and experience, and exhibit the behaviours needed, for the landlord services to be of good quality.

b) take appropriate steps to secure that the relevant staff of their services providers have the necessary skills, knowledge and experience, and exhibit the behaviours needed, for the landlord services to be of good quality.

Specific expectations

2.6 Competence and Conduct

2.6.1 Registered providers must meet all applicable requirements as set out in Chapters 1 to 6 of the Government’s Policy Statement on Qualifications

2.6.2   Registered providers must have a written policy which includes:

a) their approach to managing and developing the skills, knowledge, experience and behaviours of their relevant staff and how they will tailor this approach, as appropriate, to the different roles of relevant staff within their organisation;

b) their approach to learning and development for their relevant staff. This must include how they ensure that their relevant staff maintain and demonstrate appropriate and up to date skills, knowledge, experience and behaviours in their roles;

c) their approach to appraising and regularly reviewing the performance of their relevant staff, including their approach to managing poor performance; and

d) the appropriate steps they will take to secure that the relevant staff of their services providers have the necessary skills, knowledge and experience, and exhibit the behaviours needed, for the landlord services to be of good quality.

2.6.3   Registered providers must develop or adopt an appropriate code of conduct for their relevant staff and ensure it is embedded within their organisation.

2.6.4  Registered providers must ensure that the written policy and the code of conduct referred to in 2.6.2 and 2.6.3 are kept up to date, fit for purpose and are accessible to tenants. Tenants must be given meaningful opportunities to influence and scrutinise the development of the written policy and decisions relating to the adoption or development of the code of conduct.

Definitions used in this standard

3.4 For the purposes of paragraphs 1.8.1 and 2.6.1-2.6.4, ‘relevant staff’ means staff involved in the provision of landlord services and ‘landlord services’ are services in connection with the management of social housing provided by the registered provider. ‘Services provider’ has the same meaning as in Part 2 of the Housing and Regeneration Act 2008.

Consultation question on the proposed amendments to the TI&A Standard to reflect the Competence and Conduct Direction

Consultation question 2

Do you agree or disagree that the proposed changes to the Transparency, Influence and Accountability Standard accurately reflects the government’s Competence and Conduct Direction to the regulator? 

Please state if you agree or disagree, or if you don’t know.

Please provide comments if you wish to explain your response.

c) TSM related revisions to the TI&A Standard

Background

Landlords have been required to collect TSM data from 1 April 2023, including both TSMs generated from landlord’s management information and TSMs generated from tenant perception surveys. Setting clearly defined requirements on TSMs that apply across different landlords provides a valuable tool supporting tenants to scrutinise their landlord’s performance and provides a source of intelligence to the regulator on how well landlords are delivering the outcomes of the standards.

The amended HRA 2008 gives the regulator the power to direct landlords to collect, process and publish information about their performance in relation to matters covered by our regulatory standards^{[footnote 23]}. It also gives the regulator the power to request that landlords send us certain information related to any performance information Direction we give to them ^{[footnote 24]}. As the powers became available to us after the initial introduction of the TSMs, we are taking this opportunity to use them to better align our TSM regime with our revised statutory framework.

We are proposing changes to the TI&A Standard and Code to reflect that we are reissuing requirements for landlords to collect, process and publish information about their performance against our TSMs, and issuing our annual requests for landlords to send us related information, using these new performance information powers. When the revised TI&A Standard comes into effect, we will be re-publishing the existing ‘Tenant Satisfaction Measures - Technical requirements’ and ‘Tenant Satisfaction Measures - Tenant survey requirements’ documents as a Direction to landlords (the TSM Direction). We will also use our performance information powers to issue our annual TSM returns to landlords. Other than the proposed introduction of an electrical safety TSM (described in part 3), there are no changes to the TSMs themselves or the technical or tenant survey requirements, and so this will not change what landlords are required to do to meet them.

Proposed TSM-related amendments to the TI&A Standard

Specific expectations landlords are expected to deliver in respect of the TSMs are set out at 2.4.1, 2.4.2 and 2.4.3 of the current TI&A Standard – see Annex 1. To reflect that we will be using our new powers to reissue the requirements for landlords to collect, process and publish information about their performance against our TSMs, and to issue our annual requests for landlords to send us related information, we are proposing to:

• Remove 2.4.1 and 2.4.2 (a) and (b) as these would otherwise duplicate requirements the new TSM Direction would provide for.
• Remove 2.4.2 (c) to reflect that we will be using our new performance information power to issue our usual TSM returns to landlords.
• Broadly retain requirement 2.4.3 by removing it but replacing it with a similar requirement as specific expectation 2.4.1. To support effective tenant scrutiny, this sets a wider expectation that landlords ensure that their reported TSM information is an accurate, reliable, valid, and transparent reflection of their performance against the TSMs. This goes beyond landlords complying with the technical and tenant survey requirements in the TSM Direction.

We are proposing that the new specific expectation 2.4.1 in the TI&A Standard (which would replace and broadly replicate the existing specific expectation at 2.4.3) would be as follows:

Specific expectations

2.4 Performance information

2.4.1 Registered providers must ensure that their reported tenant satisfaction measure information is an accurate, reliable, valid, and transparent reflection of their performance against the tenant satisfaction measures prescribed by the regulator.

Definitions used in this standard

3.3 In relation to 2.4.1, ‘reported tenant satisfaction measure information’ means information published pursuant to the requirements of a TSM Direction, or submitted to the regulator pursuant to any request for that information or for other information about the registered provider’s performance against TSMs. The ‘tenant satisfaction measures prescribed by the regulator’ (‘TSMs’) refers to the tenant satisfaction measures set out in the relevant TSM Direction. ‘TSM Direction’ refers to a direction given by the regulator (as amended from time to time) which the regulator specifies as being a direction on tenant satisfaction measures. ~

~ Draft TSM Direction - GOV.UK

Consultation question on the proposed amendments to the TI&A Standard related to TSMs

Consultation question 3

Do you agree or disagree with the proposed changes to the specific expectations in the Transparency, Influence and Accountability Standard for the TSMs?

Please state if you agree or disagree, or if you don’t know.

Please provide comments if you wish to explain your response.

Part 2: Proposed changes to the Code

Overview

On 1 April 2024, we issued a Consumer Standards Code of Practice to help tenants and landlords understand what is expected under the consumer standards and how landlords might deliver the outcomes of the standards. The Code has a statutory footing and the legislation makes it explicit that the regulator may have regard to it in considering whether standards have been met^{[footnote 25]}.

We are proposing to make a small number of updates to the Code in relation to STAIRs, competence and conduct requirements and the TSM related requirements where we consider further amplification to be helpful.

The full Code with the proposed changes highlighted is contained in Annex 3. We have also included at Annex 4 a version of what the draft Code would look like when published if these changes are adopted.

We are seeking feedback on new or amended elements of the Code as part of this consultation and not on the rest of the Code.

Proposed STAIRs revisions to the Code

(Relevant to the Transparency, Influence and Accountability Standard 1.7.1) 

58 - The expectations set out in the Government’s policy statement, ‘Social Tenant Access to Information Requirements’ (STAIRs) apply to private registered providers only. In delivering the required outcome, private registered providers must publish certain information about their activities and provide relevant information in response to requests from tenants unless it is reasonable to withhold the information from disclosure. They are also expected to demonstrate a commitment to transparency, accountability and tenant involvement. Registered providers must ensure communication with and information for tenants is clear, accessible, relevant, timely and appropriate to the diverse needs of tenants.

59 - It is for private registered providers to decide whether it is reasonable to withhold information from disclosure in line with the expectations set out in the policy statement. In deciding this, the Government’s policy statement makes it clear that private registered providers must have regard to the protections afforded to certain classes of information (and to how those classes of information are defined) in the Freedom of Information Act 2000 and Data Protection Act, and any other relevant statutes. Further information about relevant protections can be found on the Information Commissioner’s Office website.

Proposed competence and conduct revisions to the Code

(Relevant to the Transparency, Influence and Accountability Standard required outcome 1.8.1 and specific expectations 2.6.1 - 2.6.4~)

60 - For landlord services to be of good quality, relevant staff need to have the necessary skills, knowledge and experience, and exhibit the behaviours needed. Part of delivering good quality landlord services involves delivering fair and equitable outcomes for tenants (and, where relevant, prospective tenants) and treating them with fairness and respect.

61 - In meeting the required outcome, registered providers must have a robust and evidenced approach to:

• managing and developing the skills, knowledge and experience of their relevant staff and ensuring they exhibit the behaviours needed for the landlord services to be of good quality; and
• the steps they are taking to secure that the relevant staff of their services providers also have these attributes.

62 - Registered providers should assure themselves and be able to evidence decisions about which of their staff meet the definition of relevant staff and which of their roles are in scope of the qualifications requirements.

63 - Registered providers should have a clear understanding of which of their contractors and sub-contractors meet the definition of services providers and which of their services providers have relevant managers within scope of the qualifications requirements. Outcomes 1.8.1b and 2.6.2d in the Transparency, Influence and Accountability Standard apply in relation to the relevant staff of all their services providers as defined in the legislation~~. Relevant managers of a services provider will not be in scope of the qualification requirements if the services provider does not provide a comprehensive social housing management service to the registered provider, as detailed in paragraph 59 of the Government’s Policy Statement on Qualifications Requirements for Social Housing.~~~

64 - In delivering the outcomes, registered providers must ensure that the opportunities they provide to tenants to influence and scrutinise their approach are meaningful. This includes in the development of the written policy and when they develop or adopt the code of conduct, as well as when these are reviewed.

65 - In meeting the specific expectations in 2.6.2 to 2.6.4, registered providers are free to choose whether the written policy and/or the code of conduct cover a wider range of matters or staff than those specific expectations require. They must ensure the requirements of the standard are met, and that the written policy and code of conduct ultimately support the delivery of the required outcome in 1.8.1 of the standard.

~ In this section of the Code, ‘relevant staff’, ‘landlord services’ and ‘services provider’ have the same meaning as given in the Transparency Influence & Accountability Standard for the purposes of outcomes 1.8.1 and 2.6.1 to 2.6.4. Those outcomes have been set under section 194A of the Housing and Regeneration Act 2008.

~~ See s.194B(2) of the Housing and Regeneration Act 2008.

~~~ Competence and Conduct Standard: Policy statement

Proposed TSM revisions to the Code

Relevant to the Transparency, Influence and Accountability Standard 1.5.1 and 2.4.1 and 2.4.2).  

We do not propose making any changes to paragraphs 50-52 of the existing Code.

47 - Tenants having access to reliable and accurate performance information about landlord services helps to ensure transparency and to drive effective tenant scrutiny.

48 - Registered providers must ensure they meet the regulator’s TSM Direction.~,~~ The regulator’s TSM Direction sets requirements that registered providers must meet to ensure TSMs are collected, processed and reported by registered providers on a consistent basis. It may give registered providers flexibility about how they will meet its requirements. Registered providers should meet those requirements in a way that ensures that their reported tenant satisfaction measure information is an accurate, reliable, valid, and transparent reflection of their performance against the TSMs, which supports effective tenant scrutiny. Registered providers should also consider how all the different elements of the business involved in collecting, processing and reporting relevant information (systems, processes, data etc) work to ensure this. For example, where management information is used in generating TSM information, registered providers should consider how they ensure that their approach to collecting and processing that management information is robust and enables them to deliver the relevant outcomes in relation to their reported tenant satisfaction measure information.

49 - In addition to what is required to meet the regulator’s TSM Direction, registered providers should, following engagement with their tenants, also consider publishing some or all of their TSM related information at a more granular level and/or on a more frequent basis, to support effective tenant scrutiny. For example, they may publish some or all of their TSM related information separately for:

• entities within their group
• specific property types such as general needs or housing for older people
• different geographical areas, and/or
• specific tenant groups (such as tenants who share different protected characteristics).

50 - Where a registered provider publishes more detailed or more frequent TSM related information (as referred to in the paragraph above), it should ensure (as far as possible), that it collects, processes and publishes that information in line with the requirements in the regulator’s TSM Direction. Any significant deviation from those requirements should be clearly set out alongside the additional published TSM related information.

~  Draft TSM Direction - GOV.UK

~~ In this Code, ‘TSM Direction’, ‘TSMs’ and ‘reported tenant satisfaction measure information’ have the same meaning that those expressions are given in our Transparency Influence & Accountability Standard.

Consultation question on proposed changes to the Code

Consultation question 4

Do you agree or disagree with the proposed changes to the Code?

Please state if you agree or disagree, or if you don’t know.  

Please provide comments if you wish to explain your response.

Part 3: Proposed introduction of the Electrical Safety Checks TSM

Overview

In December 2021 we consulted on the original suite of TSMs. During this consultation we said that we would decide on the most appropriate action to take in relation to introducing a TSM on electrical safety once the government had concluded its consultation on electrical safety in the social rented sector. Furthermore, we confirmed we would consult on any proposal to introduce an electrical safety TSM.  

In February 2025 the government published its response to the Grenfell Tower inquiry, which committed to legislate to require social landlords to carry out stringent regular electrical safety checks. The government has recently introduced The Electrical Safety Standards in the Private Rented Sector (England) (Amendment) (Extension to the Social Rented Sector) Regulations 2025. These new regulations apply certain duties to carry out electrical safety checks to the social rented sector, and so we are now seeking views on the proposed TSM. 

The new regulations will apply for new tenancies from November 2025 and existing tenancies the following year. It covers both checks on electrical installations and electrical equipment provided as part of the tenancy and requires landlords to carry out electrical safety checks at least every five years. 

The definitions and common requirements set out in ‘Tenant Satisfaction Measures - Technical requirements’ would apply to the TSM, which is intended to be read alongside the existing building safety TSMs. These cover statutory obligations for gas, fire, asbestos, water and lift safety checks. We previously consulted on the common approach underpinning the building safety TSMs as part of the consultation on the suite of TSMs. This includes that:

• the building safety TSMs generally relate to all statutory obligations in carrying out safety checks for the area of building safety they concern (as opposed to being limited to checks required by a specific piece of legislation),
• the calculation of the TSMs is based on dwelling units (as opposed to, say, numbers of safety checks, communal parts, or communal blocks). They measure the number of relevant individual homes (including individual bedspaces in a non-self-contained property) for which all relevant safety checks have been completed, as a proportion of all homes which required the specified safety checks, - in relation to each relevant home they also capture safety checks for relevant communal or other parts of the building that the home is in, including checks for which a third party is responsible,
• the measures reflect the compliance position in relation to safety checks as at the year end of the TSM reporting year, and
• broadly speaking they do not measure the completion of remedial actions that may be identified in safety checks (although they underline that landlords must of course ensure that these are carried out as required).

Maintaining this approach for electrical safety makes a clear and consistent set of building safety TSMs that can be read alongside each other. We propose that our electrical safety checks TSM should be consistent with this approach, and our proposed wording of the TSM is intended to reflect this. 

In line with the other building safety TSMs the proposed TSM covers all statutory obligations in relation to carrying out electrical safety checks relating to the dwelling unit (including all checks required both for the dwelling and on any communal or relevant part that serves the dwelling). Those statutory obligations are wider than those in the new regulations referred to above.

Given risks relating to electrical installations and electrical equipment in communal areas we consider it is important to include these areas for all low cost rental accommodation and low-cost home ownership accommodation homes ^{[footnote 26]}. This would also be in line with the other building safety TSMs.

We recognise that the government has committed to exploring the option of legislative changes to mandate electrical installation checks within owner-occupied leasehold homes in social housing blocks ^{[footnote 27]}. This could include low cost home ownership accommodation. We plan to consider this TSM in the light of any legislative changes in this area once these have been brought forward. 

Like our existing building safety TSMs, our proposed electrical safety checks TSM aims to provide a baseline level of assurance that required safety checks have been completed. The TSMs do not change the requirement for landlords to comply with all health and safety obligations and to inform the regulator of any significant health and safety compliance issues (including any relating to outstanding remedial actions) in real time.  

As the TSM relates to checks as at the year end, we anticipate it will be in place to cover the 2026/27 reporting year for large landlords, and all subsequent reporting years ^{[footnote 28]}.

Proposed: Electrical Safety Checks TSM

TSM	Proportion of homes for which all required electrical safety checks have been carried out
TSM calculation	A. Number of dwelling units owned for which all required electrical safety checks were carried out and recorded as at year end.  ​Divided by: ​  B. Number of dwelling units owned for which electrical safety checks were required to have been carried out as at year end. ​  Multiplied by 100​
Stock types included	LCRA and LCHO stock only (combined). For this TSM, this includes all such units that require electrical safety checks for the dwelling, and all such units served by communal or other relevant parts that require electrical safety checks.​
Further requirements	In order to report that all required electrical safety checks were carried out for a particular dwelling unit, providers must ensure that all statutory obligations in relation to carrying out electrical safety checks relating to this unit were met, all physical checks had taken place and that these were appropriately recorded.​  Electrical safety checks include inspections, testing and investigative work that relate to the electrical safety of electrical installations or electrical equipment. ​  Statutory obligations in relation to carrying out electrical safety checks include statutory obligations for keeping electrical safety checks up-to-date, but not the completion of remedial actions (except for those related to further investigative work specifically) that may be identified in electrical safety checks. Although this TSM does not measure remedial actions, providers must of course ensure that these are carried out as required. ​  Electrical safety checks relating to a dwelling unit include all checks required both for the dwelling and on any communal or relevant part that serves the dwelling. For example, if an electrical safety check is required on an electrical installation (or other fixture), fitting or appliance that serves a number of relevant dwelling units, providers must ensure that this check is carried out to be able to report compliance for these units.​  For the purposes of this TSM, dwelling units for which all required electrical safety checks were not carried out as at year end must not be counted within item A of the TSM calculation, even if the reason for this concerned an inability to gain access to the dwelling unit (or a communal or other relevant part). For the avoidance of doubt, ‘statutory obligations’ above refers to the obligations as they would have applied if access were not prevented. If multiple electrical safety checks were required for a dwelling unit (e.g. both on an electrical installation and electrical equipment) providers must have ensured that all these checks were carried out in order to report compliance – dwelling units must not be double counted in either part A or B of the TSM calculation. ​  Providers must determine what statutory obligations with respect to electrical safety checks apply to any vacant LCRA or LCHO dwellings and reflect these in the calculation of this TSM. If any vacant LCRA or LCHO dwellings were served by communal or related parts requiring an electrical safety check, these dwellings must be included in reported compliance with respect to these communal or related parts. ​  The calculation of this TSM must reflect all electrical safety checks that relate to dwelling units owned by the provider, including checks for which a third party is responsible. These may include, for example, checks on an electrical installation (or other fixture) in a building owned by a third-party landlord, which serves LCRA and/or LCHO units owned by the provider. In these circumstances, a dwelling unit must not be counted within item A of the TSM calculation if the provider was not able to obtain evidence or otherwise make sure that required checks on communal or other parts that serve the dwelling were carried out.  This TSM must reflect the compliance position at the end of each reporting year.​ Subject to statutory obligations, it may reflect electrical safety checks conducted within the current reporting year or previous reporting years.

Consultation question on proposed Electrical Safety Checks TSM 

Consultation question 5: 

Do you agree or disagree that the proposed TSM will provide an appropriate level of information about landlord performance in carrying out required electrical safety checks?  

Please state if you agree or disagree, or if you don’t know.

If you disagree, please explain and provide any alternative suggestions on the proposed TSM. 

Please tell us if you have any other comments on the electrical safety checks TSM.

Impact assessments

The government has the power to issue Directions to the regulator to set standards and once issued, we must comply with them. The government has carried out its own impact assessments relating to the policy content for both STAIRs and competence and conduct requirements. In this context, we have judged it to be proportionate to limit our consideration of the impacts to the scope of this consultation; specifically, how we are proposing to apply our discretion to reflect the Directions issued by government in the TI&A Standard and how we are proposing to amplify the requirements in the Code.

Annex 5 summarises our considerations of the regulatory and equality impacts of all the proposed changes, including in relation to the reissuing of TSM requirements under our new powers and the proposed introduction of the electrical safety checks TSM.

Consultation question on impacts

Consultation question 6

We want to explore whether there might be any regulatory impacts or impacts on people who share protected characteristics which we haven’t thought about in relation to our proposed changes (within the scope of this consultation).

Do you agree or disagree with our regulatory and equality impact considerations in Annex 5?

Please state if you agree or disagree, or if you don’t know.

Please provide comments if you wish to explain your response and include anything else you think we should examine.

Please do not provide sensitive personal data or data belonging to others in your response.

1. The term landlords throughout this document means registered providers of social housing unless otherwise stated. ↩

2. The Electrical Safety Standards in the Private Rented Sector (England) (Amendment) (Extension to the Social Rented Sector) Regulations 2025 ↩

3. As set out in S196 Housing and Regeneration Act 2008 ↩

4. Submissions are made at year end, with all building safety measures covering the period ‘as at’ the year end date of the reporting year. For large landlords the year end date of their reporting years is 31 March. Small landlords may use different reporting years. We anticipate the requirement being in place for reporting years ending on or after 31 March 2027. ↩

5. Powers introduced by amendments made to the Housing and Regeneration Act 2008 under the SHRA 2023. ↩

6. S198C Housing and Regeneration Act 2008 ↩

7. Draft of the TSM Direction for information. ↩

8. See, in particular, sections 193, 194A and 194C of the Housing and Regeneration Act 2008. ↩

9. Section 195(1) Housing and Regeneration Act 2008 ↩

10. Section 92K(5) Housing and Regeneration Act 2008 ↩

11. Section 197 Housing and Regeneration Act 2008 ↩

12. For completeness, please also note that our power to give Directions under s.198C HRA 2008 is not subject to a statutory duty to consult. ↩

13. S92K Housing and Regeneration Act 2008 ↩

14. S194C Housing and Regeneration Act 2008 ↩

15. S197 Housing and Regeneration Act 2008 ↩

16. Unless they are registered with us as a private registered provider ↩

17. S194A Housing and Regeneration Act 2008 ↩

18. S194A Housing and Regeneration Act 2008 ↩

19. S197 Housing and Regeneration Act 2008 ↩

20. Defined as individuals involved in the provision of services in connection to the management of social housing ↩

21. Competence and Conduct – Policy Statement on Qualifications Requirements for Social Housing ↩

22. See paragraph 59 of the Policy Statement on Qualification Requirements for Social Housing. ↩

23. S198C Housing and Regeneration Act 2008 as amended by the SHRA 2023 ↩

24. S198C(5) Housing and Regeneration Act 2008. ↩

25. S195 Housing and Regeneration Act 2008. ↩

26. For the purposes of the TSMs, low cost rental accommodation and low cost home ownership accommodation are defined according to their respective definitions in s.69 and 70 of the Housing and Regeneration Act 2008. ↩

27. See Government response to the call for evidence for leasehold properties in social housing blocks - GOV.UK ↩

28. This is the year ending 31 March 2027. For small landlords we anticipate this will cover reporting years that end on 31 March 2027 onwards. ↩