Proposed changes to the consumer standards

The Regulator of Social Housing (the Regulator) has launched a consultation on proposed changes to its consumer standards. The consultation covers three areas of proposed change:

• Part 1: Proposed revisions to the Transparency, Influence and Accountability (TI&A) Standard – to reflect the following new Directions issued by the government under the Social Housing Regulation Act 2023:
  • Direction on the Social Tenant Access to Information Standard 2025 (STAIRs)
  • Direction on the Regulatory Standards (Competence and Conduct) 2025

It is also seeking views on proposed amendments to the TI&A Standard to reflect its plan to use new performance information powers (introduced under the Social Housing (Regulation) Act 2023) for parts of the Tenant Satisfaction Measures (TSM) regime.

• Part 2: Proposed changes to the Consumer Standards Code of Practice (the Code) – changes to the Code in relation to the Directions on STAIRs and competence and conduct requirements, as well as TSM-related changes.
• Part 3: Electrical Safety Checks Tenant Satisfaction Measure – the Regulator is seeking feedback on the wording of a new TSM requirement in relation to mandatory electrical safety checks brought in for the social rented sector as a result of the introduction of The Electrical Safety Standards in the Private Rented Sector (England) (Amendment) (Extension to the Social Rented Sector) Regulations 2025.

Part 1: Proposed revisions to the TI&A Standard

The Regulator is proposing to amend the TI&A Standard to reflect the new Directions issued by the Government, requiring the Regulator to set standards on tenant access to information and competence and conduct. It is intended that the revised TI&A Standard would apply from 1 October 2026. The consultation seeks views on whether the proposed changes to the TI&A Standard accurately reflect these Directions.

Revising the TI&A Standard to reflect the STAIRs Direction

The Regulator is proposing adding a required outcome to the TI&A Standard that RPs must provide information to their tenants concerning the accommodation, facilities and services provided by them in connection with social housing.

The consultation asks whether this proposed change accurately reflects the government’s STAIRs Direction to the Regulator.

Revising the TI&A Standard to reflect the Competence and Conduct Direction

The Regulator proposes adding a required outcome requiring RPs to:

• Ensure their relevant staff (those involved in landlord services) have the necessary skills, knowledge, experience, and behaviours to deliver good-quality services; and
• Take appropriate steps to ensure that the relevant staff of their services providers have the same standards

The Regulator also proposes including the following specific expectations of RPs in relation to competence and conduct:

• Comply with all qualification requirements set out in the Government’s Policy Statement on Qualifications Requirements for Social Housing;
• Maintain a written policy covering staff development, learning, performance review, and steps to ensure service providers’ staff meet required standards;
• Adopt and embed a code of conduct for relevant staff; and
• Keep both the policy and code up to date, accessible to tenants, and provide meaningful opportunities for tenants to influence their development.

The consultation asks whether these changes accurately reflect the Competence and Conduct Direction.

TSM related revisions to the TI&A Standard

To align with its new powers under the Social Housing Regulation Act 2023, the Regulator proposes:

• Removing specific expectations relating to performance information that would otherwise duplicate requirements in the new TSM Direction; and
• Adding a new specific expectation requiring that RPs must ensure that their reported tenant satisfaction measure information is an accurate reliable, valid, and transparent reflection of their performance against the tenant satisfaction measures prescribed by the Regulator.

The consultation asks whether respondents agree with these proposed changes to the TI&A Standard for TSMs.

Part 2: Proposed changes to the Consumer Standards Code of Practice

The Code provides statutory guidance to landlords to understand what is expected and how they might deliver the required outcomes in the consumer standards. The Regulator is proposing to make a small number of updates to the Code in relation to STAIRs, competence and conduct requirements, and the TSM-related requirements where it considers further amplification to be helpful. The consultation seeks views on whether the proposed changes to the Code accurately reflect the Directions from the Government.

Proposed STAIRs revisions to the Code

The proposed changes require that:

• Private RPs must publish certain information and respond to tenant requests unless withholding is reasonable;
• Communication must be clear, accessible, timely, and appropriate to tenants’ diverse needs; and
• Decisions to withhold information should align with protections under the Freedom of Information Act and Data Protection Act

Proposed competence and conduct revisions to the Code

• Landlords must ensure staff and service providers have the skills, knowledge, and behaviours needed for quality services;
• They should maintain a robust approach to staff development, performance review, and qualifications compliance; and
• Tenants must have meaningful opportunities to influence and scrutinise policies and codes of conduct

Proposed TSM revisions to the Code

• Providers must comply with the regulator’s TSM Direction to ensure accurate, reliable, and transparent reporting;
• Systems and processes should support robust data collection and reporting; and
• Providers are encouraged to publish TSM data at a more granular level (e.g by property type or region) following tenant engagement, to support effective tenant scrutiny

Part 3: Electrical safety checks (Tenant Satisfaction Measure)

The Government has introduced a legislative change in the form of The Electrical Safety Standards in the Private Rented Sector (England) (Amendment) (Extension to the Social Rented Sector) Regulations 2025, which extends mandatory electrical safety checks to the social rented sector. The Regulator is therefore proposing to introduce an electrical safety checks TSM to help provide tenants with greater transparency and provide the Regulator with information on RPs meeting their obligation.

Under the proposal, RPs will need to report the proportion of homes where all required electrical safety checks have been completed and recorded as at year-end. These checks cover electrical installations and equipment within the dwelling, as well as communal areas serving the property. The calculation will be based on the number of compliant homes divided by the total homes requiring checks, expressed as a percentage.

The new TSM will align with existing building safety measures for gas, fire, asbestos, water, and lifts, and is expected to apply from the 2026/27 reporting year. Whilst the measure does not track remedial actions identified during checks, RPs must still ensure these are carried out promptly.

The Regulator seeks views on whether the proposed TSM will provide an appropriate level of information about RP performance in carrying out required electrical safety checks.

Timeline for implementation

The consultation closes on 3 March 2026, with the decision statements expected in summer 2026. The revised TI&A Standard and Code would come into force on 1 October 2026, with the electrical safety checks TSM reporting beginning from 2026/2027 reporting year.

RPs have the opportunity to provide feedback on the changes as proposed by the Regulator.

RPs should also use this as an opportunity to familiarise themselves with what will be required of them in light of these changes, and ensure they have the structures in place to be able to meet the requirements of the TI&A Standard and the Code. We expect that new consumer standards on STAIR and competency and conduct will be forthcoming in 2026 and RPs should also be prepared for their implementation.

With regard to the TSMs, it should be noted that other than the proposed introduction of an electrical safety checks TSM, the changes do not alter the TSMs themselves or the technical and tenant survey requirements and so will not change what RPs need to do to meet them.

Darren Hooker is a Partner and Georgia Moon is an Associate at Capsticks.