28/10/2025
Welcome to this month’s update. Autumn is here and so are lots of timely and important updates for the sector. This month we consider key updates from Social Tenant Access to Information Requirements and the Competence and Conduct Standard to the latest from the Housing Ombudsman, Companies House and the Regulator of Social Housing.
Significant Government policy announcements for the sector
Two significant updates were announced by the Government in the past month, one relating to STAIRs and another regarding the Competence and Conduct Standard:
Social Tenant Access to Information Requirements (STAIRs)
After the conclusion of the consultation in July 2024, the government has published its long awaited policy statement on STAIRs. STAIRs gives tenants of private registered providers new rights to access certain information about how their homes are managed, albeit tenants of local authority owned housing stock can already access this information under the Freedom of Information Act.
For more information please read this article.
Competence and Conduct Standard
The long-anticipated Competence and Conduct Standard will take effect in October 2026. The new Standard is said to represent a major step in the professionalisation of the social housing sector, with the new framework introducing defined expectations for staff, including mandatory professional qualifications, standards of conduct and ongoing development requirements.
For more information please read this article.
Compliance lessons for in-house legal teams
The High Court’s decision in Mazur and Stuart v Charles Russell Speechlys LLP provides a valuable reminder to the leaders of large in-house legal teams on management and supervision of non-qualified (or overseas-qualified) staff handling litigation. The decision highlights the potential risks of using teams of paralegals to deliver volume, possibly fixed-costs litigation. It is clear that “exercising professional judgment” – potentially, the delivery of merits advice and decision-making on the conduct of litigation – cannot be delegated to unqualified staff but must be taken or at least approved by a qualified solicitor.
For more information please read this article.
Housing Ombudsman Annual Complaint Review
The Housing Ombudsman has published its Annual Complaint Review for 2024-25 which shows some encouraging signs that landlord handling is improving despite the fact that complaints are still rising.
It is clear to see from the findings of the review that the focus of complaints remains to be property condition (there having been a 43% increase in the number of complaints about repairs) along with a large increase relating to complaints handling. Social landlords are going to continue to face a very difficult landscape with the introduction of Phase 1 of Awaab’s Law this month along with a reformed Decent Homes Standard and the new Competence and Conduct Standard in the not too distant future.
We are currently assisting clients with reviews of policies/procedures and those associated processes to support them with tackling these challenges. Please do get in touch if you’d like to discuss.
Changes at Companies House
As of 13 October 2025, Companies House has migrated to using the GOV.UK One Login for access to its web-filing and document upload services. This means that it will no longer be possible to access these services using a previous web-filing login and users will instead be required to set up a GOV.UK One Login.
Looking further ahead, identity verification for directors and PSCs will become mandatory from 18 November 2025, albeit there will be up to a 12-month grace period (depending on when a company’s next annual confirmation statement is due) for compliance following this date. Directors and PSCs can verify their identity via GOV.UK One Login or an Authorised Corporate Service Provider and, once they have done so, will be issued with an 11 character code (personal to them not the company) for use at Companies House.
If you have companies in your group, you should ensure that you are up to date with these requirements and assist your directors to complete verification in good time.
RSH Small Provider TSM Data Submission
The RSH has published the full report from its voluntary pilot of the Tenant Satisfaction Measures (TSMs) submission exercise involving small social housing providers.
The pilot included a diverse mix of small providers and explored their capacity to collect, analyse and report TSM data. Whilst the exercise confirmed the value of gathering tenant feedback for transparency and service improvement, the RSH concluded that requiring small providers to submit data centrally would not be proportionate this stage. That being said, small providers are still required to collect TSMs and publish the results.
This outcome has been broadly welcomed by smaller housing providers as a pragmatic balance between regulatory transparency and administrative burden. Smaller providers are encouraged to use their TSM data proactively to drive service improvement and demonstrate accountability to tenants.
RSH Fire Safety Remediation Report
On 25 September 2025, the Regulator of Social Housing released its latest fire safety remediation survey for 11-metre-plus social housing buildings in England, covering the period 23 June to 21 July 2025.
Of the 17,146 relevant buildings reported, 1,926 were identified as having a life-critical fire safety (LCFS) defect relating to the external wall system. Of the 2,672 buildings identified as having LCFS defects since June 2017, (only) 906 have been remediated.
The report confirms that "Landlords are expected to take timely action to remediate LCFS defects from the buildings they are responsible for, so that tenants are safe and can feel safe in their homes. It is for boards and councillors to ensure these plans are delivered. Risks to tenants in any interim period before works are complete, including whilst works are being undertaken, must be fully understood, with landlords taking the necessary mitigating actions to protect tenants".
The RSH will continue to monitor the performance of social landlords in remediating 11 metre plus buildings and the progress they are making against their plans.
Mutuals Registration Update
The Financial Conduct Authority (the FCA) (in its role as the registering authority for mutual societies) has recently published an update on its work. Some key points to note include:
- a proposal for the FCA to put forward a plan to remove statutory declarations from their forms where the law does not require them;
- a reminder that as of 18 November 2025 directors of companies will need to prove their identity with Companies House, but directors of societies will not need to do this with the FCA as this change does not apply to them;
- a reminder that it is quicker to submit annual returns and accounts through the mutuals society portal, with returns and accounts submitted in this way being processed in as quick as two working days; and
- a reminder that you can get information about societies (including their reporting classification) from the mutuals register, and this can be read alongside the glossary page.
AOB
Procurement Act
The Procurement Act is here and we’ve developed a practical tool to help you stay compliant with ease. For more information, click here or contact Emily Heard to find out how we can support you.
Costs
Have you considered your costs work? Our experienced team of Cost Lawyers and Draftspersons can help with every stage — from recovery to dispute — across all areas of litigation. Costs are a vital part of any case and can often exceed the claim’s value, so early, expert advice is essential to manage budgets, negotiations, and assessments effectively. Get in touch with Mark Holloway or Sophie Jones to find out more.
Events
Housing Management Update
In this session, we will cover a number of key topics for the Housing sector, including:
- Advice on manging cases involving hoarding
- Tackling abuse and threats towards housing staff
- Shared Ownership and leasehold post the Renters’ Rights Bill
- Focus on access to properties to secure safety compliance
- Time for Q&As from attendees
Register here.
The Crime and Policing Bill | What you need to know
In this session, we will look at the key aspects of the Crime and Policing Bill and how they will affect landlords. We will cover:
- An outline of the Bill
- What changes the Bill will make to the management of ASB
- Respect Orders
- Extended powers to seek closure orders
- Impact of the new powers on procedures and best practice
- Time for Q&As
Register here.
Conferences we are attending
- Audit and Risk Conference - 12/13th November
- London Build Expo - 19th and 20th November
- Housing Week conferences - 25th and 26th November
