04 Mar 2026
CIH response to consultation on changes to the Transparency, Influence & Accountability Standard to reflect both the government’s Social Tenant Access to Information Requirements (STAIR)s Direction to the Regulator of Social Housing (RSH) and the government’s Competence and Conduct Direction to the RSH
Summary
CIH agrees that the RSH has reflected the government’s STAIRs Direction accurately in the proposed change to the TI&A Standard. We also agree with the proposed changes to the TSMs to incorporate monitoring of the new electrical safety standard requirements. However, CIH does not agree the RSH has reflected the government’s Competence and Conduct Direction accurately by embedding the requirements in the existing TI&A Standard rather than establishing a new stand-alone Competence and Conduct Standard as expected. There are references to “the Competence and Conduct Standard” throughout the direction, unlike for the Social Tenant Access to Information Requirements (STAIRs) where the direction specifically talks about requirements, not a standard. This was spoken about as a key response to the Grenfell Inquiry and has been discussed as a new and separate standard for social housing amongst MHCLG, providers and stakeholders for some time now.
“While embedding the new competence and conduct requirements within the existing Transparency, Influence and Accountability Standard may support coherence across the consumer standards, we believe a standalone standard would have provided a stronger signal about the centrality of competence and professional conduct to service quality and resident safety.”
We were surprised not to see a separate and standalone competence and conduct standard and would welcome assurance from the regulator that this approach does not in any way signal a downgrading of the importance of these requirements within the consumer standards.”
Responses to consultation questions
Agree.
Comments
The required outcomes relating to STAIRs clearly set out the scope of the information covered by regulation and point to the Government’s policy statement dated 30 September 2025 for the detail on the expectations.
Disagree.
Comments
The government’s direction to the RSH clearly states that “the regulator must set a standard for registered providers in matters relating to the competence and conduct of relevant individuals.”
There are references to “the Competence and Conduct Standard” throughout the direction, unlike for the Social Tenant Access to Information Requirements (STAIRs) where it specifically talks about requirements, not a standard; “STAIRs will be integrated into the social housing regulatory environment, tailored to the needs of tenants, and enforced as part of the Regulator’s consumer standards.”
The government stated in its consultation response that “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.” A new and separate standard for social housing has therefore been expected and discussed amongst MHCLG, providers and stakeholders for some time now. So, although we understand the same requirements are still included in the TI&A Standard, we are surprised to see competence and conduct condensed into an outcome in section 1.8 of the TI&A standard. We believe it should have been a separate standard to fully extrapolate the detail and re-iterate its importance for the sector to get these fundamental requirements right.
We are concerned that the inclusion of competence and conduct into the existing TI&A standard signals a downgrading of the importance of the requirements and risks them not being taken as seriously by registered providers and the RSH as they should be.
Rob Gershon, council tenant and activist recently commented in a blog for HQN, “I really feel like tenants expected more from the Regulation of Social Housing Act – and the regulator – than a sub-category of another standard to cover all of the issues they should expect their landlords to cover in Competence and Conduct policy.”
If this is not to be changed, we hope to see the RSH make it quite clear, through its statements, inspections and reports, how important these new requirements are to being fully compliant with social housing regulation. It should reinforce that the requirements expressed in this way continue to carry full regulatory and legal weight.
Agree for STAIRs.
Disagree for Competence and Conduct.
Comments
CIH agrees that the proposed changes to the Consumer Standards Code of Practice reflect the policy statement and the direction to the RSH for STAIRs.
CIH believes that Competence and Conduct should be a separate and distinct standard which should be reflected in the Code of Practice.
Disagree
Comments
Disagree – for Competence and Conduct - as the impact assessment was carried out on what MHCLG termed “The Competence & Conduct (C&C) Standard” and was intended to “help improve the quality of Housing Management Services provided to tenants in the social housing sector by addressing the identified skills, knowledge, experience, and behaviour gap which presents a barrier to the social housing workforce providing a consistently high standard of Housing Management Services.”
We believe that the decision not to have a separate, clearly identifiable standard for competence and conduct may lead to less of an impact on the social housing sector than the government intended, especially for more disadvantaged tenants, and not “be proportionate” to the seriousness of the issues that the Grenfell inquiry looked into and tenants raised during the Social Housing Green paper process.
For more information, please contact Chloe Fletcher, head of policy and external affairs at chloe.fletcher@cih.org
