The Standard

The Competence and Conduct Standard: culture and behaviour requirements

The Competence and Conduct Standard comes into force in October 2026. It applies to all registered providers of social housing in England and sets requirements across two areas: qualifications for senior staff, and the culture, behaviours, and conduct expectations that apply to everyone involved in delivering housing management services.

This page focuses on the second part - the culture and behaviour requirements. These are the clauses that receive less attention than the qualification headlines but will, for most providers, require more fundamental work. The qualification requirements have a defined path. The culture requirements ask each provider to build its own.

The two halves of the standard

The qualification requirements get most of the attention. The culture requirements will do most of the work.

The Competence and Conduct Standard has two distinct parts, and the sector conversation has overwhelmingly focused on one of them.

The qualification requirements are specific: Level 4 for senior housing managers, Level 5 or a foundation degree for senior housing executives, a transition period of three years for larger providers and four for smaller ones, and a growing number of courses from CIH and others to get people enrolled. Challenging to implement at scale, but structured. There is a defined path to compliance.

The culture and behaviour requirements are different. They apply to all staff involved in delivering housing management services - not just senior leaders - and they cover territory that no course can certify: how people behave, how conduct is defined and embedded, how residents experience the service, and whether the organisation can evidence that its development work is producing real change.

This distinction matters because it shapes how providers need to prepare. The qualifications programme is a project with a clear endpoint. The culture work is an ongoing commitment with no finish line - and the Regulator will expect to see it underway from October 2026, not deferred until the qualifications are sorted.

What the Direction requires on culture and conduct

Six specific obligations - each one carrying more practical weight than it first appears.

The government's Direction to the Regulator of Social Housing, published in September 2025, sets out exactly what the standard must require. On the culture and conduct side, registered providers must:

Ensure staff have the right behaviours - not just the right knowledge

The Direction requires that staff "exhibit the behaviours needed for the relevant services provided by those individuals to be of a good quality." This is a deliberate step beyond competence as knowledge. It means the standard covers how people treat residents, how they handle complaints, how they respond when something goes wrong - not just whether they have the technical knowledge to do their job.

For most providers, this is where the gap between existing practice and what the standard expects will be widest. Technical competence is already managed through recruitment, training, and appraisal. Behavioural competence - the ability to consistently demonstrate the right conduct in real interactions - is harder to define, harder to develop, and harder to evidence.

Have a written policy on workforce development

Providers must maintain a written policy covering their approach to managing and developing the skills, knowledge, experience, and conduct of their staff. The policy must cover learning and development, staff appraisal, and the management of poor performance. It must be kept up to date and fit for purpose.

This goes beyond having an L&D strategy document. The standard expects the policy to be a working document that connects development activity to outcomes - and one that addresses poor performance and conduct explicitly, not just skills gaps.

Adopt or develop - and embed - a code of conduct

Providers must adopt or develop an appropriate code of conduct for all relevant staff and ensure it is embedded within the organisation. The code must be kept up to date and fit for purpose.

The word "embedded" is doing significant work here. A code of conduct that exists as a document signed at induction does not meet this requirement. Embedded means staff can articulate the expected behaviours in practice, managers feel equipped to hold people to them, and the code is a living reference point for decisions and conversations - not a policy that sits in a folder.

Give residents meaningful opportunities to influence the code

Providers must give tenants meaningful opportunities to influence and scrutinise the development of the policy and decisions relating to the code of conduct. Both must be made accessible to tenants.

This requirement was added to the Direction after the consultation, in direct response to feedback from tenants and tenant representative groups. The government's response makes clear that this is about influence, not just consultation. It reflects the evidence from the Grenfell Tower Inquiry, where residents reported that their concerns were ignored or disregarded, and the Social Housing Green Paper consultation, where tenants described feeling excluded from decisions about how services were delivered.

In practice, this means involving residents in defining what good conduct looks like - not presenting a finished code of conduct for comment.

Apply the same expectations to service providers

Providers must take appropriate steps to ensure that their service providers' staff also have the necessary skills, knowledge, experience, and behaviours. The standard does not stop at the provider's own workforce. If housing management services are delivered through contractors or managing agents, the provider remains accountable for the quality of conduct those staff demonstrate.

Keep everything current and evidenced

The policy and code of conduct must be kept up to date and fit for purpose - a strengthened requirement introduced after the consultation. The Regulator will expect to see evidence that these are living documents, regularly reviewed and responsive to what is happening in practice, not static policies produced to meet a deadline.

What the standard deliberately does not prescribe

The Regulator will not tell you what good conduct looks like in your organisation. That is the point.

One of the most important features of the standard is what it does not do. It does not provide a national framework of expected behaviours. It does not prescribe what a code of conduct should contain. It does not mandate specific recruitment, appraisal, or performance management practices. It does not define what "embedded" looks like in operational terms.

This is deliberate. The government's consultation response is explicit: the standard takes an outcomes-focused approach rather than a prescriptive one, reflecting the Regulator's statutory duty to minimise interference and allow providers to deliver outcomes in the way that best fits their organisation and their tenants.

For providers, this creates both freedom and difficulty. Freedom, because the approach can be shaped to the organisation's context, communities, and services. Difficulty, because the work of defining what good conduct means - in specific, observable, evidenceable terms - now sits with each individual provider. There is no template to adopt that will satisfy the Regulator. The expectation is that what you produce is genuinely yours, genuinely embedded, and genuinely making a difference to how residents experience your services.

How it will be regulated

Outcomes-focused, assurance-led, and folded into an existing standard.

The Regulator of Social Housing will incorporate the competence and conduct requirements into the existing Transparency, Influence and Accountability Standard, rather than creating a standalone standard. The RSH launched its own consultation on this integration in December 2025.

This approach has practical implications. It means competence and conduct will be regulated alongside requirements around resident engagement, transparency, and accountability - which is logical, given the overlap. But it also means the requirements will sit within a broader framework rather than standing alone as a distinct regulatory focus.

CIH has publicly raised concerns about this approach, arguing that folding competence and conduct into the TI&A Standard could signal a downgrading of the importance of the requirements and risks them not being taken seriously enough by some providers. Whether that concern proves justified will depend on how prominently the Regulator treats these requirements in its assurance work.

The regulatory approach is outcomes-focused. The Regulator will not inspect against a checklist of prescribed practices. Instead, it will look at whether providers can demonstrate that their approach is working - that behaviours are genuinely embedded, that residents have genuinely influenced the code of conduct, that development activity is producing measurable improvements, and that poor conduct is being addressed.

For boards and governance committees, this means being prepared for a conversation about evidence and outcomes, not a document review. The Regulator will want to understand what has changed as a result of the work - not just what policies are in place.

Where this came from

Grenfell, the Green Paper, and a professionalisation review that concluded culture change was necessary.

The Competence and Conduct Standard did not emerge from a policy exercise. It emerged from a series of failures in how social housing providers treated the people they serve.

The Grenfell Tower Inquiry heard evidence that key managerial staff at the Tenant Management Organisation did not have adequate training or qualifications for their roles. More fundamentally, it found that residents who voiced safety concerns and complaints about living conditions were ignored or disregarded - and that this was entirely consistent with the organisation's approach to engagement with its residents.

The Social Housing Green Paper consultation in 2018 heard from tenants across the country who described a breakdown of trust between themselves and their landlords. They reported feeling ignored, excluded from decisions that affected their lives, and subject to dismissive or disrespectful attitudes from staff. The government's own assessment was that the issues uncovered at Grenfell were indicative of the wider experiences of social tenants across the country.

A Professionalisation Review in 2022 concluded that measures should be introduced to drive organisational-wide culture change within the social housing sector. It recommended qualification requirements for senior staff - but it was clear that qualifications alone would not be sufficient. The culture had to change, not just the credentials.

The Social Housing (Regulation) Act 2023 gave the government the power to direct the Regulator to set the standard. The Direction was issued in September 2025. The standard comes into force in October 2026.

This history matters because it shapes what the Regulator will be looking for. The standard was not created to add another compliance layer. It was created because residents were being failed by the culture of the organisations that were supposed to serve them. The Regulator will be asking whether that culture is genuinely changing - not just whether the paperwork is in order.

The standard is clear about what it expects. The challenge is in the execution - particularly on the culture and behaviour side, where there is no prescribed path and no template to follow.

Three resources on this site are designed to help leadership teams work through that challenge: