CIH responds to Competence and Conduct Standard for social housing consultation

We have submitted a full response to the government’s consultation on the Competence and Conduct Standard for social housing. Read the full response here.

We believe that people working in housing want to work in a professional sector they can be proud of, and every resident should expect to receive a professional service from their housing provider.

The requirements around professional qualifications are now set out in law, and our collective focus must be on ensuring that regulation is meaningful, accessible, and deliverable, with as smooth a transition as possible. CIH believe qualifications are an effective way to ensure professionals have the required knowledge and skills to provide high-quality services to people living in social housing. We also recognise professionalism is more than a qualification; it is about displaying the right behaviours and attitudes and following a code of conduct and ethics. To that end, we welcome the introduction of a broad Standard that relates to all who work in social housing.

The introduction of mandatory qualifications is a significant change for the social housing sector coming at a challenging time. With stretched capacity and resources across the sector, our response to the government’s consultation highlights areas in which we believe further consideration would be helpful to achieve the intended outcomes without negatively impacting the service delivery. In summary, our response includes:

• Timescale – Extending the transition period to three years, with a focus on a minimum of 50 per cent of qualification enrolments commencing within the first 18 months following introduction would alleviate capacity pressures on landlords and study centres. This would ensure a smoother, more manageable roll out enabling landlords to continue to focus on service delivery and study centres to efficiently manage the throughflow of new learners.  Our discussions have highlighted concerns that a two-year timeframe for rollout from 1 April 2025 could negatively impact services to tenants.  We have also highlighted a further potential constraint in access to appropriately knowledgeable tutors and trainers. We have noted that this could have implications for the capacity of approved study centres to accommodate the number of new learners. A longer transition period would allow study centres time to scale up capacity to the levels required.
• New burdens funding for local authority landlords – Government should ensure local authority Housing Revenue Accounts have sufficient capacity to introduce the changes through new burdens funding. In addition, opening access to the apprenticeship levy to allow the fund to pay directly for qualifications would reduce the burden on social landlords.
• Recruitment and retention – Extension of the proposed transition period from two to three years would help to address the risk of senior professionals exiting the sector or retiring early, or disincentivising skilled professionals from other sectors from moving into housing. This would also recognise existing recruitment and retention challenges within the social housing sector.
• Approach to large and small providers – We agree there should be longer period for smaller providers to comply with the new Standard. The Regulator of Social Housing already has a definition for smaller providers of 1000 homes or less and is sensible to use this definition. In addition, where a provider manages a high proportion of supported housing, there should be additional time for supported housing staff to qualify. This reflects the tight margins and viability of some supported housing schemes and the ongoing recruitment and retention challenges that exist within supported housing.
• Inclusion of service providers – Service providers who solely deliver repairs and maintenance services for social landlords should be exempt from the Competence and Conduct Standard. Whilst we understand the logic behind extending the qualification requirement to contractors the definition of ‘service providers’ is broad and there is a risk that those delivering repair services may choose to withdraw from the sector rather than commit to undertake the necessary training or seek to recruit qualified staff from within housing providers. In addition, landlords, by complying with the Competence and Conduct Standard would have qualified, in-house housing professionals who would seek to manage and oversee repairs and maintenance contracts in a way that delivers for those living in social housing and provide sufficient assurance to tenants that there are qualified persons involved in the delivery of the repairs and maintenance service.
• Equality, diversity and inclusion (EDI) – In instances where people have challenges in accessing learning, e.g. through experiencing learning difficulties or being neurodiverse we would like to see a pragmatic approach adopted that enables those learners an extended period to complete their studies. This could be included alongside the flexibilities already included for those on maternity leave or long-term sickness absence. The impact of the qualifications on diversity should also be measured to ensure the new standard delivers for all.
• Future proofing – To avoid some people having to undertake multiple qualifications, e.g. with CIH and RICS, relevant providers of technical qualifications should be encouraged to ensure that their qualifications are compliant with the Standard. This could be in the form of integrated qualifications or ‘top up’ training. To this end, it would be helpful to understand the extent to which the proposals are informed by other regulatory regimes for professionals, such as the Financial Conduct Authority (FCA).

Read the full response