27/02/2026
Spring is finally in the air and the end of the financial year is upon us. This month we have our usual bite-sized updates covering updates from the Regulator of Social Housing and Charity Commission and some welcome news from the FCA Mutuals Team around processing timeframes for applications. Enjoy!
Regulator of Social Housing (RSH) - Regulatory judgements
Key themes arising from this month’s regulatory judgements include:
- Failure to have up to date stock condition surveys – and, vitally, not having plans in place to remedy this which may be the difference between a C2 and a non-compliant grading
- No meaningful opportunities for resident engagement and not having data to understand the diverse needs of tenants
- Not monitoring and/or reporting on key issues including hazards
- The importance of good communication (in particular) when managing complaints and managing them in a timely way
- Non-compliance with the tenancy standard
Rent Standard 2026
The RSH published the new Rent Standard this month, reflecting the revised Policy Statement on Rents for Social Housing (published 28 January). This will apply from 1 April 2026 and reflects the Government’s 10-year rent settlement including rent convergence where social rent is less than ‘formula rent’. Convergence can start from 1 April 2027.
RPs will need to consider the Rent Standard carefully, particularly in relation to how they apply rent convergence and any exemptions, to ensure they implement it correctly across their homes. Shared ownership rents must also be increased in line with lease terms.
The RSH has also updated two of its guidance notes this month:
- How we approach regulatory judgements and gradings – updated to reflect when it will publish regulatory judgements i.e. following a programmed inspection, stability check or following regulatory engagement which is not programmed. Interim judgements may also be issued where there has been a significant constitutional change or restructure (such as a merger).
- Regular reviews between programmed inspections – reflects updated guidance on rent data reviews
Mutual Societies Development Unit (MSDU)
The FCA has launched the MSDU with a view to supporting ‘the sustainable development of the mutual societies model’. It provides a dedicated point of contact for support and insight.
In December the FCA also published a number of helpful reports, including a ‘mutuals landscape report’ and ‘mutuals report’. The latter identifies a number of recommendations for the reform of the FCA’s function and approach, including:
- Implementation of a process for timely consideration of company law reform, for assimilation to society law
- Improvement in visibility and transparency of societies, including enhancing the Mutuals Public Register
- Removal of the requirement for a statutory declaration on application forms
- Speeding up application processing times from 15 working days to 10 from 1 April 2026
- Offering a pre-application support service, including at ‘ideas stage’
It also identifies that 46.2% of RPs are societies.
These are welcome reforms, especially in terms of speeding up the registration of transactions and enhancing the availability of information on the register.
Mutual Societies Development Unit | FCA
Companies House Campaign: Getting help with identity verification
Companies House has launched a campaign as a result of the number of queries it is getting around identity verification. The campaign includes a summary of the requirements, when they must be implemented and some helpful video guides.
We are working with a number of clients to review their structures and confirm action required – both now and in respect of future reforms relating to e.g. corporate directorship. Please do get in touch if we can help.
Getting help with identity verification - Changes to UK company law
Charity Commission guidance
The Charity Commission has recently published some helpful guidance notes which may be of interest to charitable RPs (noting that exempt charities should also have regard to Charity Commission guidance when conducting their activities).
How charities can respond to the current hostile environment – this guidance reflects that organisations are working in circumstances where there may be risk associated with contested social policy debates. The guidance includes some helpful questions for organisations to ask about safety and recommended actions relating to the on-going review and management of this risk depending on activities, news, social media etc.
RPs may also undertake fundraising activities – directly or through foundations within their structure. The Charity Commission has updated its fundraising guidance to reflect the updated Code of Fundraising Practice, which came into effect in November 2025. This includes in relation to ‘failed appeals’.
Financial Reporting Council (FRC) publishes updated strategic report guidance
The FRC has issued updated guidance to assist companies in producing high quality, cohesive annual reports that meet their legal obligations. The FRC recognises that high-quality strategic reports focus on the needs of shareholders and other primary users of the annual report (for RPs this will include regulators, customers and other stakeholders). The guidance has been updated to reflect recent changes including the UK Corporate Governance Code 2024; legislative changes to directors’ report disclosures and other developments in sustainability-related and wider corporate reporting practice.
In addition to this guidance the FRC has also published updated Scoping Tables to support entities in complying with disclosure requirements.
To access the full publication please see link: FRC publishes updated strategic report guidance
The Department for Business and Trade also published the final UK Sustainability Reporting Standards.
ESMA consults on amendments to MAR guidelines on delay in disclosure of inside information
Where organisations have listed bonds (‘issuers’) they must disclose ‘directly relevant inside information’ to the public as soon as possible. There are certain circumstances in which disclosures can be delayed – provided that there is a legitimate interest to delay the disclosure, the public is not to be misled and confidentiality is ensured. The ESMA guidelines list instances where delayed disclosure may be possible.
The proposed amendments to these guidelines reflect that protracted processes will no longer be subject to the obligation to disclose inside information until completion. They also replace the requirement that the delay should not mislead the public, with the requirement that the information the issuer intends to delay should not be in contrast with its latest announcement on the same matter.
Inside information rules are complex and we often see a lack of awareness around these requirements. We can support you to implement policies and processes, and provide training to relevant colleagues and committees/boards.
Case Law update: Execution of deeds
In a recent (and rare!) case regarding the interpretation of the Companies Act 2006, the Court of Appeal considered the circumstances under which the statutory presumption of ‘due execution’ in section 44(5) of the Companies Act applies. This states that, "in favour of a purchaser", a document is treated as duly executed if it purports to be signed in accordance with the requirements of section 44(2), with "purchaser" defined as a person acting in good faith for valuable consideration.
In the current case, a lease was granted between a company and its subsidiary, and an underlease of the same property between the subsidiary and the claimant. The sole director of all three companies had directed an employee to sign the leases on his behalf in his name. The Court held that:
- The statutory presumption applied in favour of a purchaser and this did not apply in these circumstances.
- The purchaser under each document was not ‘in good faith’ because the sole director knew that he had not personally signed the documents, and this knowledge was attributable to the companies.
This is a helpful clarification in relation to the application of this rule in circumstances where there may be defects in the execution of a document, and knowledge of this defect being attributed to the corporate body on behalf of a director.
FTSE Women Leaders Review report
The latest Women Leaders Review report was published setting out gender balance on boards and in leadership positions in the FTSE 350 and 50 of the UK’s largest private companies.
Below is a summary of the main findings:
- Women hold 42.7% of board roles on FTSE 350 companies and there were no all men boards
- In private companies 30.1% of board roles are held by women and the number of all men boards decreased to 3
- The number of women in leadership roles (being the executive committee and the director reports to the executive committee) was 35.9% for FTSE 350 companies and 37.1% for the 50 private companies – so 31% of the FTSE 350 and 38% of the 50 private companies met or exceeded the 40% target for women in leadership
- In relation to the four ‘key roles’:
- Chair - FTSE 350 decreased from 60 to 59; private companies increased to 10 from 7
- Senior Independent Director – FTSE 350 increased to 209 from 192; private companies reduced to 10 from 15
- CEOs – FTSE 350 increased to 21 from 19; private companies 10 increased from 8
- Finance Director - FTSE 350 decreased from 57 to 54; private companies remained at 11
AOB
Renters' Rights Act 2025
The Renters’ Rights Act 2025 brings substantial reform of the regulatory framework for the rented sector with the majority of changes coming into effect on 1 May 2026.
The changes will have wide-ranging implications for compliance obligations, policy frameworks and operational controls. Implementation will be phased and will require coordinated organisational planning and robust governance oversight.
We recognise that the Act brings complexity as well as opportunity. To support teams, we are providing up-to-date guidance, practical tools and commentary as the legislation is implemented. Access key information including timelines, a library of resources and events here.
Events and articles
SID network
We recently held our first SID network meeting of 2026, delivered in partnership with Savills.
We were pleased to welcome Brands with Values to the meeting who will lead a focussed discussion on How SIDS and NEDs can expose cultural risk early and strengthen governance assurance across housing providers.
The next meeting is on the 6th May.
Please get in touch with Kate Lorraine-Francis for more information.
Upcoming webinars
Keeping residents safe – 24th March
This webinar will explore how organisations can take a proportionate, defensible, and resident-focused approach to safety and risk management, considering resident wellbeing, needs and expectations as well as what is reasonable, legal duties, compliance requirements, competing priorities and cost.
Conferences we are attending
- Affordable Housing Conference – 4th March
- SHLA conference – 12th March
- National Housing Federation Housing Finance Conference – 25th – 26th March
- Housing Brighton: People and Place 2026 – 6th – 7th May
- UKREiiF – 19th – 21st May
- NHF Governance Conference – 18th June
- Housing 2026 - 23rd- 25th June
Other articles you might be interested in:
Pet Requests in Social Housing | A key time to review policies
Housing Ombudsman Service Compensation Guidance | a key time to review policies/procedures
Social and Affordable Homes Programmes (SAHP) | Supporting you from application to documentation
