Company Secretary Snapshot – October 2026

As the evenings get darker, attention turns to 2027 business plans and registered providers (RPs) continue to navigate a busy regulatory landscape. October has seen a number of important developments, including implementation of the revised consumer standards, the first phase of STAIRs and publication of the Regulator of Social Housing's (RSH) latest financial forecasts.

In this edition of the Snapshot, we look at the closure of the More and Better Social Homes call for evidence, the latest RSH financial forecasts, the Sector Risk Profile, consultation on the revised National Housing Federation (NHF) Code of Governance and the key lessons emerging from recent regulatory judgements.

RSH publishes Sector Risk Profile 2026

Always an important read, the Sector Risk Profile 2026, published by the RSH on 22 October 2026, highlights the increasingly challenging environment facing RPs as they balance significant investment in existing homes with the need to deliver new housing supply. The report identifies a range of interconnected risks, including building safety, stock quality, Awaab's Law compliance, energy efficiency requirements, financial resilience, development risk, cyber security and data quality.

The RSH emphasises that boards and councillors should maintain a clear strategic direction, take a long-term view of competing priorities and ensure that robust governance and risk management arrangements are in place. Particular focus is given to the need for organisations to understand their capacity to deliver both investment in existing homes and future development ambitions whilst remaining financially resilient.

Boards should review their risk registers and business plans against the themes identified in the report, challenge assumptions around development capacity and funding, and ensure they have reliable data, strong cyber resilience and a clear strategy for meeting evolving quality, safety and sustainability requirements.

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More and Better Social Homes – call for evidence closes

The RSH's call for evidence on More and Better Social Homes closed on 30 September 2026. The exercise forms the first stage of the RSH’s review of economic regulation and will inform consultation on revised economic standards expected in 2027, with implementation anticipated from April 2028. The review is considering how economic regulation can support investment in existing homes, delivery of new supply, financial resilience and long-term value for money.

We submitted a response to the call for evidence informed by discussions with clients and sector stakeholders.

Please get in touch with Sarah Greenhalgh and/or Rose Klemperer if you would like to discuss the review or receive a copy of our response.

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RSH Financial Forecasts 2026: Balancing Investment and Growth

On 6 October 2026, the RSH published its annual financial forecasts, showing that RPs are planning record levels of investment in repairs and existing homes, whilst also maintaining ambitions to build more affordable housing. The forecasts indicate increasing borrowing requirements across the sector, with RPs continuing to face difficult trade-offs between investment in existing stock, new supply and long-term financial resilience.

The RSH noted that aggregate interest cover has stabilised compared to recent years, although material risks remain, particularly for larger RPs undertaking significant development programmes.

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New Consumer Standards - now in force

The revised RSH Consumer Standards came into force on 1 October 2026. This includes revisions to the Transparency, Influence and Accountability Standard, introduction of the new Competence and Conduct Standard, a revised Consumer Standards Code of Practice, and additional requirements relating to Tenant Satisfaction Measures.

The changes form part of the RSH’s continued focus on transparency, accountability, professionalism and tenant voice. Of particular note is the new Competence and Conduct Standard, which introduces requirements around the skills, knowledge, experience and behaviours of those delivering landlord services, including qualification requirements for certain senior housing managers and executives.

Boards should seek assurance that governance arrangements, workforce development plans and reporting frameworks are aligned with the new requirements and that clear evidence is being maintained to demonstrate compliance.

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STAIRs: one month on

Phase 1 of the Social Tenant Access to Information Requirements (STAIRs) came into force on 1 October 2026. Private RPs are now required to publish specified categories of information regarding governance, performance, services and housing stock. Further rights enabling tenants to request information directly from RPs commence in April 2027. A second phase, due to commence in April 2027, will introduce rights for tenants to request certain information directly from their landlord.

In the run-up to implementation, the National Housing Federation updated its STAIRs guidance to provide further practical assistance for RPs on complying with the new requirements. Following feedback from the sector, this update removed guidance that RPs should be routinely publishing their board minutes. This follows feedback from the sector which was reflected in our recent article: STAIRs publication scheme – do we need to publish board papers and minutes?

Whilst STAIRs significantly increases transparency expectations, providers continue to retain protections relating to confidentiality, legal privilege, commercial sensitivity and personal data.

Although the tenant request regime does not commence until April 2027, now is the time for RPs to prepare. They should use the intervening period to review the information they currently publish, test internal processes for identifying and responding to information requests, and ensure clear governance arrangements are in place for handling requests that may engage data protection, confidentiality, legal privilege or commercial sensitivity considerations. Early preparation should help RPs respond consistently and within the required timescales once the second phase of STAIRs comes into force.

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Review of the NHF Code of Governance

The NHF has commenced a review of its Code of Governance, seeking views from boards, governance professionals, residents and wider stakeholders on how the Code is operating in practice and whether any changes may be required. The current Code was published in 2020 and the review follows a period of significant regulatory change across the sector. The NHF has indicated that it is particularly interested in understanding where the Code has worked well, whether any provisions have proven challenging in practice, and whether there are areas that are not currently addressed sufficiently.

The NHF intends to publish an updated Code in early 2027.

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Regulatory Judgements: early lessons from October Consumer Gradings

October has seen a further tranche of regulatory judgements published by the RSH, including some RPs receiving their first consumer gradings. Recent compliant gradings have highlighted the importance of effective oversight, clear accountability and organisations being able to demonstrate that they not only identify service delivery issues, but also act promptly to remedy them and minimise the risk of recurrence.

At the other end of the spectrum, recent lower consumer gradings across the sector continue to reflect recurring themes such as weaknesses in landlord health and safety assurance, incomplete or unreliable stock condition data, shortcomings in repairs and maintenance services, insufficient assurance over compliance obligations, and weaknesses in tenant engagement and oversight arrangements. The RSH has also continued to emphasise the importance of boards having a clear understanding of operational performance and obtaining sufficiently robust assurance that services are being delivered effectively in practice.

Recent governance and viability gradings demonstrate the RSH’s continued focus on effective risk management, board assurance and financial resilience. In particular, boards are expected to understand and actively monitor key strategic risks, including development programmes, treasury exposures and the assumptions underpinning long-term business plans.

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Companies House reforms continue

The rollout of the Economic Crime and Corporate Transparency Act 2023 remains a key focus for company secretaries and governance teams with companies and LLPs in their group structures. The Government updated its Companies House transition plan on 23 October 2026, confirming that certain elements of the implementation programme have been deferred. However, mandatory identity verification for directors and persons with significant control remains a key priority, with the transition period due to conclude at the end of 2026. Organisations should continue preparing for the increased compliance and filing requirements being introduced under the reforms

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Looking ahead

By the time this snapshot lands in your inbox, all eyes will be on the Chancellor's red box. With the Autumn Budget 2026 delivered on Wednesday, we'll save detailed commentary for next month's edition once everyone has had a chance to digest the announcements. In the meantime, we'll be watching closely for anything affecting social housing investment, regulation and development ambitions.

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AOB

Conferences

We are attending the following conferences, get in touch if you are too.

NHF Audit and Risk conference

11th – 12th November

Lead: Rose Klemperer

Housing Investment & Delivery Symposium

25th November

Lead: Louise Leaver and Katie Dyer

Leaseholder and Tenant Service Charges Conference 2026

25th November

Lead: Alex Dunne, Raman Thandi-Bal

Social Housing Leaders Conference

26th November

Lead: Louise Leaver and Katie Dyer

Events

AI, complaints and Unreasonable Behaviour in Housing | Webinar | Wednesday 4 November 2026 | 14:00 - 14:45 | 45 Minutes

Join us for a practical webinar exploring how AI is transforming complaints handling in the housing sector. We'll examine the rise of AI-generated complaints, how to distinguish legitimate challenge from unreasonable behaviour, and effective approaches for managing high-volume correspondence while maintaining a fair, positive complaints culture.

Register here

Understanding Modern Slavery: Employer Responsibilities and Practical Action| Webinar | Thursday 5 November 2026 | 13:00-14:00 | 1 Hour

Join Bevan Brittan's employment, immigration and regulatory specialists for a practical one-hour webinar exploring the current modern slavery landscape and the responsibilities placed on employers. Drawing on real-world experience, our speakers will examine where modern slavery risks can arise in the workplace, the interaction between employment and immigration compliance, and the steps organisations can take to strengthen their governance and safeguard vulnerable individuals.

Register here

Housing Disrepair Update Webinar: Challenges facing Landlords in defending Housing Disrepair claims | Webinar | Friday 6 November 2026 | 10:00 - 11:30 | 90 Mins

Please join us for this legal update, focusing on:

• Phase 2 of Awaab’s Law and how to best prepare your organisation.

• Challenging Claimant Expert reports.

• Track allocation including costs implications under Birmingham v Lee.

• Making the best use of CPR Pt 36

Register here

Housing Management Update | Webinar | Tuesday 10 November 2026 | 14:00 - 15:00 | 1 Hour

In this session, we will cover a number of key topics for the housing sector, including:

• The latest developments in tenancy fraud and practical approaches to investigations

• An update on the Crime and Policing Act 2026 and what it means for housing providers

• A consideration of tenancy fraud and advancing litigation

• A focus on the introduction of phase two of Awaab’s Law

Register here

Our next meeting of the ACCN is on the 1st December. Please get in touch with Stacey Butterworth (Stacey.butterworth@bevanbrittan.com) for more information.

Other articles you might be interested in:

STAIRs publication scheme – do we need to publish board papers and minutes?

Awaab’s Law Phase 2: What social housing landlords need to do before November 2026

Respect Orders: practical steps for Housing Providers ahead of 26 October 2026

Sexual Harassment Duties Strengthened from October 2026: Is Your Organisation Ready?

Getting Ready for the New Era of Trade Union Rights | Employment Rights Act 2025 Changes

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