Challenges

Six culture challenges in the Competence and Conduct Standard

1. 01

   Evidencing culture change - not just training delivery

   What the standard requires

   Providers must show that staff development translates into outcomes - not just attendance records. The Regulator will focus on the quality of your evidence and the efficacy of your systems. Comprehensive records of competence gaps and clear plans to close them will be expected, along with evidence that training has led to measurable improvements in service delivery and resident outcomes.

   Why this is hard

   Most housing providers have well-established systems for tracking training. Completion rates, course attendance, CPD hours - these are straightforward to record and report. But the standard is asking for something different: evidence that development has changed how people behave, not just what they know.

   That's a fundamentally different kind of evidence. It means connecting your L&D activity to resident-facing metrics - tenant satisfaction measures, complaint patterns, service quality indicators. It means being able to answer the question the Regulator is likely to ask: what has changed in your organisation as a result of this investment in development?

   The gap between "we delivered the training" and "here's what changed because of it" is where most providers will need to do new thinking.

   A starting point

   Map your current L&D reporting against the evidence the Regulator is likely to expect. If your reports show inputs (who attended what) but not outcomes (what changed as a result), that gap is your first priority. Resident feedback, complaint trends, and tenant satisfaction data are the closest most providers already have to culture outcome measures - the challenge is connecting them to your development programmes.

2. 02

   Defining professional behaviours when the Regulator won’t do it for you

   What the standard requires

   Providers must ensure that all relevant staff have the right behaviours - not just the right knowledge and skills - to deliver high-quality housing services. This includes adopting or developing a code of conduct, ensuring it is understood and applied across the organisation, and keeping it current. But the RSH will not provide a single framework of key skills and behaviours. Each organisation must determine what competence and conduct looks like for its own context and services.

   Why this is hard

   Qualifications have clear criteria. Behaviours don't. Defining what "good conduct" means in practice - in a way that is specific enough to be meaningful, broad enough to apply across diverse roles, and grounded enough to be evidenced - is a genuinely difficult piece of work.

   Many providers have existing values statements and codes of conduct. But there's a difference between a values poster in the break room and a set of behavioural expectations that staff can describe in their own words, that managers feel confident holding people to, and that residents would recognise in their day-to-day experience.

   The temptation is to adopt a generic framework. The risk is that a borrowed framework doesn't reflect your organisation's actual culture, context, or the specific needs of the communities you serve - and the Regulator will be looking for something that is genuinely embedded, not imported.

   A starting point

   Test what you already have. Ask five front-line colleagues to describe the behaviours expected of them - without looking anything up. If the answers are consistent and sound like real life rather than a policy document, your code is embedded. If the answers vary widely or sound rehearsed, the standard will surface that gap. Start there before investing in new frameworks.

3. 03

   Giving residents genuine influence over your code of conduct

   What the standard requires

   Providers must give tenants meaningful opportunities to influence and scrutinise the development of their competence policy and decisions relating to the code of conduct. Both must be accessible to tenants and kept up to date. This is a requirement rooted in the evidence heard by the Grenfell Tower Inquiry and the Social Housing Green Paper consultation, where residents reported feeling ignored, excluded from decisions, and subject to dismissive attitudes from staff.

   Why this is hard

   Most providers have well-developed resident engagement structures - panels, surveys, scrutiny groups. But the standard draws a distinction that matters: influence is not the same as consultation.

   Consultation typically asks residents to respond to something that has already been designed. Influence asks residents to shape the thing being designed, from the start. It means involving residents in defining what good conduct looks like, not reviewing a finished code of conduct.

   This is unfamiliar territory for many providers. It requires a different kind of conversation with residents - one that starts with their experience of how staff interact with them and works forward to what expectations should look like, rather than starting with an organisational document and asking for feedback.

   A starting point

   Review how your current code of conduct was developed. If residents were involved, at what stage? If they reviewed a draft, that's consultation. If their lived experience shaped the content before it was drafted, that's influence. The standard requires the latter. If there's a gap, the good news is that residents are usually willing to contribute to this work - the question is whether they're invited early enough to make a real difference.

4. 04

   The risk of treating culture change as a compliance exercise

   What the standard requires

   The Competence and Conduct Standard is outcome-based and assurance-led. Providers must be able to demonstrate that they meet the standard - not through a checklist, but through evidence of genuine change in how their organisation operates and how residents experience their services.

   Why this is hard

   There's a real tension in how the sector is approaching this. The standard was designed to drive culture change - the government's consultation response explicitly states it aims to "drive the culture change necessary to eradicate unprofessional attitudes and stigma." But culture change is hard to systematise, and the natural instinct in a regulated sector is to turn requirements into processes, policies, and checklists.

   The risk is that providers build an impressive compliance architecture around the standard - written policies, recorded training, documented codes - without the underlying culture shifting. Boards report compliance. Staff experience no change. Residents notice no difference. The Regulator, taking an assurance-based approach, will be looking beyond the documentation.

   This risk is heightened by the decision to incorporate the competence and conduct requirements into the existing Transparency, Influence and Accountability Standard rather than as a standalone standard. CIH has raised concerns that this approach could signal a "downgrading of the importance of the requirements" and risks them not being taken seriously enough.

   A starting point

   Ask your board a simple question: are we preparing for this standard as a compliance exercise or as a culture change programme? If the honest answer is compliance, the approach will need to shift. Compliance produces documentation. Culture change produces different resident experiences. The Regulator will be asking about the latter.

5. 05

   Culture change takes years - but the requirements start in October 2026

   What the standard requires

   The qualification requirements have a transition period - three years for larger providers, four for smaller ones. The broader culture and behaviour requirements do not have a separate transition period. They apply from October 2026.

   Why this is hard

   Research consistently suggests that meaningful culture change takes three to five years. That's not a comfortable timeline for a standard that comes into force in six months. Providers who haven't yet started the culture work - as distinct from the qualifications work - face a genuine challenge of sequencing.

   The Regulator is unlikely to expect complete culture transformation by October 2026. But it will expect to see that the work has started, that there is a credible plan, and that progress is demonstrable. The difference between "we haven't started this yet" and "here is where we are, here is where we're heading, and here is how we'll know it's working" is significant.

   There's also a sequencing question that many providers are navigating: the qualifications programme and the culture programme are related but different workstreams. The risk is that the urgency of qualifications - which have hard deadlines and defined courses - crowds out the culture work, which is less structured and easier to defer.

   A starting point

   If you haven't already, separate the two workstreams explicitly. Give the culture work its own plan, its own timeline, its own leadership. It doesn't need to be finished by October 2026 - but it does need to be visibly underway, with clear milestones and a way of measuring progress. The Regulator will want to see trajectory, not perfection.

6. 06

   Making this a cross-functional priority - not just an HR project

   What the standard requires

   The standard places obligations on the provider as a whole. Written policies on workforce development, codes of conduct, resident engagement mechanisms, evidence of outcomes - these are organisational responsibilities, not departmental ones. Boards and governance committees are expected to be the first point of contact for the Regulator and must have the right information to demonstrate compliance.

   Why this is hard

   The natural home for this work in most housing organisations is HR or L&D. They own workforce development, they manage training programmes, they hold the competency frameworks. But the culture requirements of the standard reach well beyond what HR can deliver alone.

   Embedding a code of conduct requires operational managers to model and reinforce behaviours daily. Evidencing culture change requires data from resident-facing teams - complaints, satisfaction measures, service quality. Giving residents genuine influence requires collaboration with engagement teams. Getting the board ready to assure the Regulator requires governance input.

   When the work sits solely with HR, it tends to produce excellent policies and training programmes. What it often doesn't produce is the cross-functional alignment needed for culture to shift at the level the standard demands. The gap isn't capability - most HR and L&D teams are highly capable. The gap is mandate, resourcing, and organisational buy-in.

   A starting point

   Review who currently owns your Competence and Conduct Standard preparation. If it sits entirely within one function, consider whether the culture and behaviour workstream needs a cross-functional steering group with senior leadership sponsorship. This doesn't mean creating bureaucracy - it means ensuring the people who will need to embed, evidence, and sustain the culture work are part of shaping it.