03/02/2026

Welcome to the first Company Secretary Snapshot of 2026! 

We’re kicking off the year with a roundup of key regulatory and sector developments you need to know. Enjoy and, if it’s not too late to say, Happy New Year! 

Contents

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. 

Our Housing Management team is monitoring development closely. For more information on the Renters’ Rights Act 2025, please see our articles:

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Consultation on changes to the Transparency, Influence and Accountability Standard 

Following the long-awaited Government announcements on the Social Tenant Access to Information Requirements (STAIRs) and the Competence and Conduct requirements (see more), the RSH has launched a 12-week consultation on revisions to the Transparency, Influence and Accountability Standard, Consumer Standards Code of Practice, and the Tenant Satisfaction Measures to reflect these changes. 

These consultation looks to align these standards with broader regulatory outcomes.The consultation runs until 3 March 2026 and, subject to feedback, would apply from 1 October 2026. The consultation documents are available here.

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Tenant Satisfaction Measures

Linked to the above update, the RSH has also published a draft TSM Direction. This consolidates current TSM technical and tenant survey requirements into a single formal document. The draft Direction sets out:

  • In Part A, a summary of the TSMs and the specific requirements for each; and
  • In Part B, further requirements as to how registered providers are required to conduct tenant perception surveys to generate a subset of TSMs.

The full direction can be found here.

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RSH Quarterly Survey

On 20 November 2025, the RSH published the results of its latest quarterly survey on the financial health of private RPs. The report covers the period 1 July to 30 September 2025 and reflects a continuation of existing financial trends across the sector; ongoing pressure on cashflow and interest cover, set against strong investment activity and improved conditions in capital markets. Key points include: 

  • Investment in existing homes has continued to rise, with landlords spending £9.3 billion on repairs and maintenance (being 10% higher than the £8.4 billion invested in the previous year);
  • Although the 12 months to September saw £13.2bn spent on development (compared to £13.7 billion the previous year), forecast development for the next year has increased slightly to £14.9 billion, in part due to underspends in the current quarter being re-profiled into future periods;
  • Though cash balances remain at historically low levels, total available liquidity (£34.5 billion) is sufficient to cover forecast expenditure on net interest costs, loan repayments and net development for the next year;
  • Investment in the sector remains strong, with capital market issuances being at the highest level in four years;
  • Cash interest cover (excluding sales) in the year to September dropped to 78%  and is expected to remain constrained, with the sector’s forecast interest cover projected to total 67% over the next year.

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Global Accounts

The 2025 Global Accounts, which provides a financial overview of private registered providers of social housing for the year up to 31 March 2025, published by the RSH in January, show a sector that continues to invest heavily in both existing stock and new supply, while managing tight liquidity and operating pressures. 

Key points include:

  • nineteen providers, many of which have significant operations in London and the South East, where costs are generally higher, collectively account for 42% of the sector by units owned and 47% by turnover, and their increased exposure to higher repairs and maintenance expenditure has a material impact on the aggregate performance of the sector;
  • 54,000 new social homes were delivered, broadly consistent with 2024;
  • the sector agreed new facilities of £12.3bn in the year, including refinancing, and reported undrawn facilities of £30.6bn in March 2025; and 
  • operating margins, whilst still at historically low levels, showed a marginal improvement for the second consecutive year to reach 17.3%.

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Fire Safety in Social Housing 

On 19 December 2025, the RSH published their fire safety survey findings relating to buildings of 11 metre+ in size within the social housing sector. There were 16,990 relevant buildings reported, and of these, 1,867 were identified as having a life-critical fire safety defect (LCFS) relating to the external wall system. Furthermore, 71.7% of these relevant buildings are expected to be remediated within the next five years. The survey also found that since June 2017, of the 2,641 buildings identified as having LCFS defects, only 932 have been remediated. The RSH has indicated their intention of continuing to monitor the performance of social landlords in remediating these 11 metre+ buildings. The RSH is hopeful that this continuous monitoring will increase engagement in ensuring that necessary remedial works are completed promptly.

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Regulator of Social Housing (RSH) Regulatory Judgements

Continuing our review of regulatory gradings, recent gradings continue to reflect a mixed picture across the sector. Most notably:

  • Broxtowe Borough Council - C3:
    • Thousands of overdue fire-safety remedial actions; 
    • Weaknesses in property compliance systems and data; and 
    • Insufficient assurance and oversight arrangements. 
  • Gosport Borough Council – C4:
    • Very serious failings including overdue fire and electrical safety actions
    • Inadequate stock condition information and incomplete hazard assessment; and
    • Capability and monitoring weaknesses. 
  • Bournemouth, Christchurch & Poole Council – C1: 
    • Accurate, up-to-data understanding of the condition of most of its home with the data being used to inform strategic asset management; 
    • Effective repairs, maintenance and health and safety compliance;
    • Proactive approach to dealing with damp and mould.

Other key themes from recent judgements include:

  • Fire and electrical safety compliance remaining a key area for poor consumer gradings, particularly where backlogs have persisted;
  • Data quality and up-to-date stock condition information are recurrent weaknesses undermining providers’ ability to evidence compliance;
  • Tenant engagement and transparency issues feature prominently in gradings where consumer outcomes are not met.  

For the full list of regulatory judgements, enforcement notices and gradings, please refer to the website.

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Guidance on Reporting on Payment Data in Directors' Reports

The Department for Business and Trade has recently published guidance to help companies that are required to report on payment data in their directors’ reports under The Companies (Directors’ Report) (Payment Reporting) Regulations 2025 (the Regulations).

The Regulations require qualifying large companies to include prescribed payment practices and data in their directors’ reports, as part of the annual reporting package. The guidance confirms that the companies that are required to report are those which are not in their first financial year and exceed two or more of the following thresholds:  

  • Annual turnover of £54 million 
  • Balance sheet total of £27 million 
  • 250 employees 

For the housing sector, community benefit societies (CBSs) are generally out of scope, but where a CBS sits within a group with companies, the corporate entities may need to report on their own and, in some cases, subsidiary payment data.

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Employment Rights Act 2025 – helping you prepare for the changes ahead

The Employment Rights Act 2025 represents the most significant overhaul of employment law in a generation. These reforms extend well beyond HR, influencing finance teams, senior management and boards.

To keep your organisation ahead, we have launched our Employment Rights Act 2025 Hub. A dedicated resource with tools, guidance, and updates as the changes roll out. Whether shaping strategy, managing budgets, or ensuring compliance, our Hub will help you stay informed, prepared, and responsive in this evolving legal landscape.

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AOB

Upcoming events

SID network 

Join us for our first SID network meeting of 2026, delivered in partnership with Savills. 

We are 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.  

Date: 10th February
Time: 2pm 

Please get in touch with Rose Klemperer 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. 

For more information, please contact Kate Lorraine-Francis.

Other articles you might be interested in:

Unlock the secrets of the sector by following our Housing page for tailored news, legal updates and topical issues.

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