CIH responds to RICS’ residential stock condition survey code of practice

The document is clear, well-structured and professionally yet accessibly written. It therefore reads as a very practical guide rather than a technical standard you would expect from a code of practice.

The structure is logical, easy to understand and opens with definitions of key terms, which is helpful. The flow of the document also reflects the actual process of a real stock condition survey, from initial scoping right through to delivery and assurance, which is a helpful way to set it out.

The distinction between what is regarded as core data and what would be classified as optional or supplementary is helpful and clearly set out.

Some sections, especially those related to the design and delivery of surveys, may appear dense; this is by necessity. It could, however, be helpful to include a visual representation, such as a process map or flow diagram.

An overview of minimum expectations alongside optional/enhanced practices would also be helpful and practical for clarity. This would enable housing organisations to learn from and apply best practice, while also meeting a minimum requirement. 

The structure is logical and intuitive, with section summaries at the front of the document making navigation straightforward. The sequencing reflects how organisations typically approach stock condition surveys in practice, which will be particularly helpful for providers seeking to review or strengthen existing approaches.

As above, there may be scope to support readability through additional signposting or summary tools, but the overall structure is clear and coherent.

The document is comprehensive; this is to be expected given the wide range of technical and operational considerations it must cover. Rather than any omissions, what could improve the document is some clarity around certain expectations for providers.

An example would be the inclusion of a short, high-level section outlining the minimum expectations for a stock condition survey. Whilst this is covered to a degree, the document could benefit from being more explicit about core expectations and those where organisations may reasonably go further, depending on risk, stock profile or organisational context.

The document covers a broad range of stock types and components and is likely to have covered all the appropriate stocks for most providers.

It may be helpful for the document to provide additional accompanying guidance for specialist providers, particularly in relation to supported and specialist housing, where additional components and compliance considerations are often present. There may also be value in further elaboration on non-traditional construction and high-rise buildings, given the specific risks and access issues linked with these stock types. However, the overall coverage is strong and comprehensive, and these points may be better covered in additional guidance or linking to existing documentation rather than lengthening the code.

The guidance on preparing, designing and delivering a survey is detailed, practical and useful, setting out consistent approaches and good practice. Likewise, details on pre- and post-survey data management are helpful.

The code provides a clear 'manual' for providers wishing to undertake a stock condition survey from the beginning, or to 'check in' on their current approach. It has everything required to support the design, commissioning, review and delivery of residential stock surveys. It highlights vital points on scoping, asset validation and data quality, as well as maintenance and quality assurance.

It may be that some providers find their current approach already aligns well with the code. For those not at that point, practical examples or process diagrams could help develop the application. This could be particularly helpful in clarifying the responsibilities between surveyors on site and wider teams in the organisation. However, these could work well as supporting guidance that sits alongside the code, rather than within the core document.

The document appropriately requires assessment of all Housing Health and Safety Rating System (HHSRS) hazards and recognises the role of hazard assessment in meeting legal and regulatory requirements. It also clearly situates hazard identification within the wider context of Decent Homes and fitness standards.

As housing standards and assessment frameworks continue to evolve, including any future updates to HHSRS and the recent Decent Homes update, it will be important for the code to be reviewed and updated to remain aligned with policy and regulatory expectations.

There may be scope to strengthen this section by providing clearer expectations for the minimum information to be recorded when hazards are identified, including location, severity, risk immediacy and required actions. Some additional clarity on how hazard information should interact with component condition data, and how findings should be escalated within organisations, could support consistency and assurance. This would be particularly helpful considering Awaab’s Law and the increasing regulatory focus on damp, mould and environmental hazards.

This also reflects a broader shift towards more holistic, risk-based approaches to housing quality. It recognises that the impact of hazards is shaped by both the condition of homes and how they are occupied, and that effective responses rely on coordination between technical assessment, resident insight and organisational decision-making.

The draft code would be useful in practice for registered providers as part of their approach to regulatory assurance. It reflects the Regulator of Social Housing’s expectations for an accurate, property-level understanding of stock condition, supported by regular physical inspection and high-quality data.

Its focus on quality assurance, access and communication reflects issues raised by recent regulatory findings. Clearer signposting of how different stages of the survey process support delivery of the Safety and Quality Standard and related consumer standards would help strengthen its use as an assurance tool, while recognising that regulatory interpretation and judgement remain a matter for the Regulator rather than RICS.

We found the document sufficiently robust to adopt as a code of practice. It sets out clear, consistent and practical guidance and operating principles that can be effectively interpreted and applied across different organisational contexts.

Some organisations may choose to use the code alongside their own local templates, processes or guidance, which makes operational sense, especially given differences in stock, resources and risk.

The document could benefit from a clearer distinction between minimum expectations and enhanced or best-practice approaches, which may help its adoption across a wide range of providers.

The draft code is timely and welcome, given the pace of regulatory change and the growing reliance on stock condition data to evidence safety, decency and compliance. Much of the content reflects established practice across the sector and provides a sensible framework for consistency while allowing space for professional judgement.

The main area where the code could go further is in being clearer about baseline expectations and how these should be applied proportionately in practice. This is particularly relevant in relation to hazards, access, and the use of survey data for assurance. Simple supporting tools, such as short summaries or process diagrams, could help with usability without widening the scope of the code or changing its technical intent.

The code’s references to resident communication and access are also helpful. Consumer regulation is clear that providers are expected to take all reasonable steps to access homes and to understand the condition in the context of tenants’ needs. From a practice perspective, established engagement principles, including those promoted by Tenants Participation Advisory Service (TPAS), highlight the importance of clear purpose, respectful communication and transparency in enabling access to reliable data. In the context of stock condition surveys, this is about supporting effective assessment and risk identification, rather than extending surveys into wider housing management or participation activity.

These comments draw on CIH’s recent work on housing decency and conditions, alongside regulatory publications from the Regulator of Social Housing and sector engagement with providers.

Read more on the survey and draft code of practice at the RICS website.

For more information on our response, please contact Dr Eve Blezard, CIH policy lead – asset management, building safety and culture: eve.blezard@cih.org.