Company Secretary Snapshot – September 2026

Welcome back! With a new Prime Minister in post, a new Housing Secretary leading the Government's housing agenda and the Regulator of Social Housing (RSH) starting to shape its future approach to economic regulation, there has been plenty to keep us occupied over the summer period.

In this edition of the Snapshot we look at a range of developments affecting company secretaries and governance professionals, including the progress of More and better social homes, the new NHF Code of Conduct, preparations for Awaab's Law Phase 2, the evolving regulatory landscape for heat networks and supported housing, and key lessons from recent RSH/Charity Commission publications and regulatory judgements.

RSH review of economic regulation – call for evidence

Following publication of its discussion paper More and Better Social Homes in June, the RSH has continued engagement with the sector ahead of the 30 September deadline for responses. The RSH has reiterated that this exercise is intended to inform a formal consultation on revised economic standards in 2027 and implementation of the new economic standards from April 2028.

Our June snapshot set out the key aspects of the call for evidence and Bevan Brittan has submitted its own response, informed by engagement with our clients and key sector stakeholders.

Please get in touch with Sarah Greenhalgh and/or Rose Klemperer if you would like to discuss the document or our response.

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Awaab’s Law Phase 2: Guidance for Social Housing Landlords

Updated guidance on Phase 2 of Awaab's Law was published on 13 July 2026 ahead of implementation on 30 November 2026.

Whilst Phase 1 focused primarily on damp and mould alongside emergency hazards, Phase 2 represents a significant expansion of the statutory regime. Registered providers of social housing (RPs) will need to ensure that their compliance systems are capable of identifying, assessing and responding to a much wider range of hazards within the newly prescribed statutory timescales.

With implementation fast approaching, boards should seek assurance that their organisation's policies, processes, reporting arrangements and contractor management frameworks are capable of meeting the more extensive requirements under Phase 2.

Please see our dedicated insight for RPs: Awaab’s Law Phase 2: What social housing landlords need to do before November 2026.

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Heat networks: compliance deadline approaching

The regulation of heat networks has undergone significant change this year, with Ofgem taking on its new role as regulator and a comprehensive set of authorisation conditions which came into force on 27 January 2026.

For RPs operating communal or district heat networks, the new regulatory framework represents a major change in the way heating services must be managed. The deadline for registration of existing heat networks is 26 January 2027, so RPs should now be considering whether their existing arrangements are capable of meeting the new requirements. Boards should be seeking assurance that a clear compliance programme is in place and appropriately resourced. The requirements extend across areas including consumer protection, complaints handling, transparency, governance and operational performance, with Ofgem having powers to investigate and enforce non-compliance.

In addition, RPs should be reviewing tenancy agreements, leases and other property documentation to ensure they remain fit for purpose under the new regime, as well as considering requirements such as registration with the Energy Ombudsman.

Please see our dedicated insight for RPs: Heat networks regulation: what do social landlords need to know?

Please get in touch with Carrie Davies to discuss the approaching deadline.

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Social Tenants Access to Information Requirements (STAIRs): do we need to publish board papers and minutes?

As RPs prepare for ‘go live’ on their STAIRs publication scheme (see more information on the requirements here) on 1 October 2026, one question we are frequently being asked is whether RPs will be required to publish board papers and board minutes.

Whilst STAIRs introduces significant new transparency obligations, the position is more nuanced than some initial commentary may suggest. The publication requirements focus on specified categories of information and tenants' rights to access information relating to the management of social housing. However, this does not mean that all board and committee papers must automatically be published. RPs will still need to consider issues such as legal privilege, confidentiality, commercial sensitivity, personal data and statutory restrictions on disclosure.

The key challenge for boards will be striking an appropriate balance between greater transparency and the need to protect genuinely confidential information. For a more detailed analysis, see our insight: STAIRs publication scheme – do we need to publish board papers and minutes?

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Consumer Standards Update: October 2026 changes confirmed

On 9 July, the RSH confirmed the following changes which are due to come into force on 1 October 2026:

• Revisions to the Transparency, Influence and Accountability Standard, including incorporation of the STAIRs.

• Introduction of a new Tenant Satisfaction Measure (TSM) relating to reporting on electrical safety compliance.

• Introduction of a new Competence and Conduct Standard, setting expectations regarding the skills, knowledge, experience and behaviours required of individuals responsible for delivering landlord services.

• Publication of a revised Consumer Standards Code of Practice to support implementation of the updated standards.

Boards should seek assurance that their organisation has appropriate arrangements in place ahead of implementation, particularly in relation to responding to information requests under STAIRs, embedding the new competence requirements and collecting and reporting the additional TSM data.

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RSH publishes Regulatory Casework Review 2026

On 28 July 2026, the RSH published its annual Regulatory Casework Review 2026, which provides a valuable insight into the issues most commonly encountered through the RSH’s casework and engagement with RPs. The review is essential reading for boards and governance professionals, as it highlights the practical lessons emerging from the RSH’s governance, viability and consumer regulation work over the past year.

The review concludes that strong governance, effective risk management, good quality data and a continued focus on tenant outcomes remain fundamental to the delivery of safe, sustainable and high-quality landlord services. The RSH also reiterates the importance of the co-regulatory model, emphasising the benefits of transparent engagement, early identification of issues and timely self-referrals where material concerns arise.

Key themes identified by the RSH include:

• Knowing that tenants are safe in their homes

• Having an effective risk management culture

• Using data and insight to drive continuous improvement

• Demonstrating delivery of strategic value for money

• Ensuring strong governance of financial performance and financial risks

• Working with the RSH to make improvements

• Listening to tenants and using their feedback to shape services and decision-making.

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RSH - Regulatory judgements

Key findings from regulatory judgements and regulatory announcements over the summer include:

• A number of RPs achieved upgrades to C1, with the RSH highlighting improvements in areas such as understanding stock condition, health and safety management, tenant engagement and assurance arrangements.

• Whilst some RPs achieved upgrades, the RSH continued to identify consumer standard failings linked to repairs performance, compliance assurance and service delivery. In its summer judgements, the RSH repeatedly emphasised the importance of landlords being able to evidence effective delivery of services in practice, rather than relying solely on policies and governance frameworks.

• The RSH continued to take regulatory action where significant concerns were identified and made use of its “gradings under review” process pending further investigation. The cases published during the period highlighted recurring themes including weaknesses in governance and board oversight, consumer standard compliance, health and safety management, service delivery failures, and concerns regarding the RPs’ overall capacity to meet regulatory expectations.

The RSH's summer judgements continued to demonstrate a particular focus on repairs services, stock condition information, health and safety compliance and tenant engagement. Overall, recent judgements reinforce a consistent message from the RSH: boards are expected not only to maintain appropriate governance structures, but also to obtain robust assurance that residents are receiving safe, compliant and effective services in practice.

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Revised National Housing Federation (NHF) Code of Conduct 2026

On 28 July 2026, the National Housing Federation published its revised Code of Conduct 2026, following engagement with the sector. The updated Code has been designed to reflect current expectations around behaviour, culture, accountability and resident involvement, whilst also helping RPs prepare for the new Competence and Conduct Standard, which comes into force on 1 October 2026. The NHF intends the Code to be a practical framework that members can adopt and tailor locally.

Notable changes include:

• a stronger focus on resident scrutiny, influence and oversight

• greater emphasis on transparency and accountability

• enhanced expectations regarding complaints and whistleblowing

• clearer guidance on data protection, cyber security and the use of artificial intelligence

• an increased focus on learning, professional development and risk escalation

The Code also reflects lessons from recent regulatory developments and the sector's wider commitment to improving resident engagement and trust.

Boards may wish to review their existing codes of conduct ahead of October 2026 to ensure they align with the new Competence and Conduct Standard and reflect the increased regulatory focus on culture, accountability, professional behaviours and resident voice.

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Implementation of the Supported Housing (Regulatory Oversight) Act 2023

The Supported Housing (Regulatory Oversight) Act 2023 (the “Act”) received Royal Assent on 29 June 2023. It was introduced to improve standards in the sector and strengthen local authority oversight of the minority of providers exploiting the Housing Benefit system by charging high rents while providing inadequate accommodation or support.

In June 2026, the Government also updated its response to the consultation on the implementation of the Supported Housing (Regulatory Oversight) Act 2023, providing much-awaited detail on the future regulatory framework for supported housing.

Please see our insight for RPs: Supported Housing (Regulatory Oversight) Act 2023.

RPs operating supported housing should begin considering how the proposed National Supported Housing Standards, licensing requirements and local authority oversight arrangements will affect their services. Boards may wish to seek assurance that existing governance, compliance and quality assurance arrangements are capable of demonstrating compliance with the new regime once implemented.

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Charity Commission updates

Over the summer, the Charity Commission (the Commission) published a number of updates and resources aimed at supporting good governance, accountability and financial transparency, including the publication of the Charity Sector Risk Assessment 2026. This highlights key risks facing charities, including fraud, cyber security, financial resilience and governance failures, and reminding trustees of the importance of effective oversight and risk management.

This reflects the Commission’s continuing focus on strengthening governance and supporting trustees in meeting their legal duties, which will be particularly important for RPs which are registered charities but is also relevant to any exempt charities.

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AOB

Conferences

We will be attending the NHF Treasury conference on 8th October 2026. Get in touch if you are attending too.

Events

Housing Disrepair Update: Challenges Facing Landlords in Defending Claims

Join us in person or online for this practical legal update on the latest developments in housing disrepair. We'll explore Phase 2 of Awaab's Law, challenging claimant expert reports, the impact of Birmingham v Lee on costs and track allocation, and making the best use of CPR Part 36. Attend in the format that suits you, or join both sessions to maximise your learning and engagement.

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.

Senior Independent Director network | 7th October

Are you a Senior Independent Director? Our next SID network meeting is on the 7th October and we will be discussing Board Dynamics and the SID's Role.

As we enter the business planning season, with boards facing increasing pressure to deliver strategic value for money, make difficult trade-offs and consider opportunities to increase new supply, the session will explore the role of the Senior Independent Director in helping to ensure all voices are heard while maintaining collective responsibility for decisions.

Please get in touch with Rose Klemperer for more information.

Other articles you might be interested in:

Heat networks regulation: what do social landlords need to know?

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

Stonewater v Harris, “Forced Entry”, and a Big Step Forward for Social Landlords

Consultation on emergency repairs for Higher-Risk Buildings

Supported Housing (Regulatory Oversight) Act 2023

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