28/11/2025
November has been a busy month, with lots of publications leading up to the Christmas period. Below we’ve summarised key updates from the Regulator of Social Housing, Companies House and Government reviews of regulation and cyber security. Enjoy!
Sector Risk Profile
The Regulator of Social Housing’s (RSH) annual Sector Risk Profile (SRP) has been published. This sets out the RSH’s view of the most significant risks to RPs and their ability to comply with the regulatory standards.
The SRP paints a picture of a social housing sector facing significant and compounding risks, noting that long-standing challenges (such as investment in existing homes, safety, build/new supply, cost inflation, interest rates) remain, but that the risk environment has become more severe. It highlights the implementation risk arising from new regulation, supply chain and market weakness, refinancing pressures, and the need to make strategic trade-offs.
Boards are warned that they have “very little margin for error”, and the RSH emphasises the importance of good governance in managing these risks.
Charity Commission and the RSH Memorandum of Understanding
The RSH and the Charity Commission have agreed a new Memorandum of Understanding (MoU) setting out how they will work together. Although the MoU is not legally binding, it does include commitments to:
- share information
- raise issues at an early stage
- signpost enquirers to each other where appropriate
- discuss matters of mutual interest
- avoid duplication
- ensure consistent treatment for bodies regulated by both organisations
This is a helpful clarification of the way in which the RSH and Charity Commission work together, particularly for RPs who are actively regulated by both. It is also worth noting that, although many RPs are not registered with the Charity Commission and are ‘exempt’ charities, the Charity Commission still has some limited powers under charities legislation.
RSH Guidance on Whistleblowing
The RSH has updated its guidance on whistleblowing, including how to make a referral to the RSH, and has also issued its Whistleblowing Report for 2024-2025. The report summarises how the RSH has actioned each of the whistleblowing referrals made to it, noting that in each case the RSH will consider its remit to investigate and will consider whether a matter is best referred on to another organisation better placed to investigate.
Please see the guidance and the full report.
RSH Corporate Plan for 2025 - 2028
The RSH has published its Corporate Plan for 2025-2028 which sets out (amongst other details) the RSH’s purpose, objectives and vision, the sector and policy environment it works in and how the RSH works. The RSH has set itself four strategic objectives for the three-year period of this plan, being:
- Driving improvement
- Maintaining confidence
- Working with others
- Building the organisation
Changes at Companies House and Economic Crime and Corporate Transparency Act 2023 (ECCTA) update
Companies House is increasing a number of its filing fees in February 2026.
On 18 November 2025 the following requirements of ECCTA took effect:
- ID verification is now mandatory for all newly appointed directors, LLP members and people with significant control (PSCs) of companies and LLPs.
- Existing directors, LLP members and PSCs will need to verify their ID before the next confirmation statement date.
- The requirement for (a) companies to maintain their own registers of directors, directors' residential addresses, secretaries and PSCs and (b) LLPs to maintain registers of members and PSCs, has been replaced with a requirement for companies to file the specified information at Companies House, meaning the Companies House records will take primacy over locally held versions of these registers.
Community benefit societies are not affected by these changes, unless they are a corporate director or PSC of a company. However, companies in their group structure will be affected. It is therefore worth implementing ID verification early, and checking any appointments / PSC registrations to ensure that you are compliant in good time for your confirmation statement.
Read the detailed fee changes.
Regulation Action Plan
The Government published its ‘Regulation Action Plan’ in March, setting out its vision to re-energise the regulatory system to balance safeguards/protection for consumers with support for investment and innovation.
The most relevant updates for RPs include:
- the Government’s planning reforms, which it expects to deliver £272m in administrative savings;
- changes to corporate reporting obligations, including by exempting most medium-sized private companies and wholly-owned subsidiaries from the requirement to produce a strategic report in their annual report and removing the requirement for any company to produce a directors' report;
- streamlining the Senior Managers and Certification regime (for those RPs who are regulated by the Financial Conduct Authority for consumer credit purposes); and
- consolidation of regulators including anti-money laundering and counter-terrorist financing supervisory functions which will be moved to the Financial Conduct Authority.
The report is an interesting insight into the Government’s aims here, and although the Regulator of Social Housing is not included in the current list of ‘key regulators’, RPs will still be affected by the changes above and those being made by other regulators such as the Information Commissioner’s Office and Financial Conduct Authority.
Ministerial letter on cyber security to leading UK companies
On 14 October 2025, the Government published a letter that has been sent to all companies in the FTSE100 and FTSE250 (as well as a number of other leading UK firms) with urgent advice to help ensure such companies are best protected against cyber threats.
The letter sets out three actions that large business can take to improve their cyber resilience, being:
- Make cyber risk a Board-level priority using the Cyber Governance Code of Practice
- Sign up to the National Cyber Security Centre’s Early Warning service
- Require Cyber Essentials in your supply chain
AOB
Catch up on our recent housing events using the links below:
Other articles you might be interested in:
- Subsidy Control: Two key takeaways for RPs accepting loans or other public funding
- Inquests and Housing: Practical tips for managing the inquest process
We’ll be taking a break from the Snapshot in December, so may we take the opportunity to wish all clients and contacts a wonderful and restful Christmas break. We look forward to delivering a bumper January edition!
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