Meeting the Competence and Conduct Standard

Could the Competence and Conduct Standard affect the way you work? Thaine Wilson and Andrew Harmer look at its potential impact on the social housing sector.

The Government recently began a consultation for the implementation of the Competence and Conduct Standard (CCS).

This would be a big step towards enhancing professional standards within the UK’s social housing sector.

The initiative is part of the Social Housing (Regulation) Act 2023, which aims to ensure that those involved in the management of social housing possess the necessary qualifications and demonstrate appropriate conduct.

The Department for Levelling Up, Housing and Communities released this consultation on 6 February 2024, seeking feedback from registered providers on the proposed standards.

What is the CCS?

The Regulator of Social Housing (RSH) will use the CCS to evaluate the performance of registered providers, leveraging new enforcement powers granted by the act.

This includes requiring registered providers to develop and execute performance improvement plans where necessary.

One of the core aspects of the consultation is the emphasis on the qualifications required for senior housing managers and executives, defining ‘relevant persons’ who must hold or be working towards specific qualifications.

For instance, senior housing managers are expected to manage housing services directly provided to tenants, while senior housing executives typically offer strategic direction as heads of services or directors.

The consultation specifies that a Level 4 qualification would be necessary for senior housing managers, with a Level 5 qualification or foundation degree required for senior housing executives.

These will likely cover areas such as housing management, ethical practices and professional skills.

Problems with the CCS

A significant concern for many social housing landlords is the financial implications of meeting these new standards.

The consultation does not mention financial support for registered providers, who are already navigating high costs and tight margins.

The cost impact assessment accompanying the consultation indicates that the qualification requirements could amount to an estimated £63.6 million.

The consultation also highlights the challenge of maintaining operational standards during periods when staff are away for training.

Registered providers were encouraged to participate in the consultation process before its closing date on 2 April 2024.

This presented an opportunity for providers to influence the final standards, ensuring they are both meaningful and achievable within the constraints of their operational and financial realities.

How might this affect you?

As a social housing landlord, the implementation of the CCS (following this consultation) could have significant implications for your operations and financial planning.

The requirement for senior housing managers and executives to hold specific qualifications aims to raise the standard of social housing management, directly impacting the quality of service provided to tenants.

This means you will need to ensure that staff, especially those in key managerial positions, either already possess the requisite qualifications or are enrolled in appropriate courses to acquire them within the designated timeframe.

While this upskilling initiative is poised to enhance the professionalism and effectiveness of services, it also necessitates a review of current staff’s qualifications and potentially, the development of a structured training plan to comply with the new standards.

Financially, the consultation does not address the provision of funding to support the upskilling of staff, which could place a substantial burden on resources.

The estimated cost of compliance with the qualification requirements alone is significant, and there are additional considerations such as covering for staff absences during training.

This situation calls for careful financial planning and possibly seeking external funding or reallocating existing resources to cover these costs.

Moreover, the transition period, although intended to allow for adjustment, requires swift action to ensure compliance without disrupting your service provision.

Thaine Wilson and Andrew Harmer are partners at Birketts.