A busy agenda is no substitute for assurance
How do Boards and Cabinets know that new housing requirements are being met?
There is no shortage of business for housing Boards and Council Cabinets. Repairs, budgets, building safety, investment in homes and organisational change all need attention. New requirements arrive alongside those pressures, usually with an implementation plan and another report to consider.
Members are told that policies have been updated, training has been arranged and systems are being changed. The programme is on track. But does that give them enough assurance that the organisation will deliver what is required?
In our work with social landlords, we regularly see considerable effort going into preparing for change. The harder task is demonstrating that it has taken hold across the organisation, including the services delivered by contractors. That is where Boards and Cabinets need to focus their challenge.
Compliance, evidence of compliance, confidence in the evidence and a plan to achieve compliance are four different things. A good implementation plan is valuable, but it cannot answer every question about whether an organisation is complying.
Awaab’s Law: will the arrangements work under pressure?
Phase 2 of Awaab’s Law takes effect in England on 30 November 2026, extending the significant hazard requirements beyond damp and mould. Boards and Cabinets should now be looking for evidence that their organisation is ready to deliver, followed by evidence of compliance once the requirements apply.
Consider a resident reporting a serious concern late on a Friday. The person taking the call needs to recognise the potential hazard, understand relevant household circumstances and get the response moving. Information then passes between teams and, often, to a contractor.
Will everyone understand the urgency? Will the records show when the landlord first became aware of the problem? Who checks that the next step happens, and who intervenes if it does not?
These are questions that can be tested before implementation. Following realistic cases through the service can reveal gaps that are difficult to spot in a project update. It also tests whether individual teams’ preparations add up to a workable response for the resident.
After implementation, actual cases should provide the evidence. Members need to see where timescales have been missed, records are incomplete or problems remain unresolved. They also need to know what has been done about those failures. An overall percentage can be useful, but it may tell them very little about the households still waiting for help.
Competence and conduct: what are residents experiencing?
The Competence and Conduct Standard came into force on 1 October 2026. Alongside the applicable qualification requirements, it addresses the skills, knowledge, experience and behaviours needed to deliver good landlord services. It requires a written policy and an embedded code of conduct, and covers learning, performance review, relevant service provider staff and tenant involvement.
There are transition arrangements for qualifications. Those arrangements should not become a reason to put the wider work on competence and conduct to one side.
A Board or Cabinet will reasonably want to see that roles have been assessed, qualification gaps understood and development properly planned and funded. But it should also ask what the organisation knows about the way its people work.
Are staff giving sound advice? Do they recognise when a resident needs additional support? Are concerns listened to and acted upon? Do contractors demonstrate the standards of behaviour the landlord expects?
Complaints, case reviews, supervision and resident feedback can help answer those questions. If residents repeatedly describe dismissive treatment or inconsistent advice, that evidence needs to influence the assessment. A completed training programme will not explain away poor service.
STAIRs: publishing information is only part of the job
For private registered providers, including housing associations, the STAIRs publication requirements took effect on 1 October 2026. The information request requirements follow on 1 April 2027.
Boards need to know whether the required information has been identified and published, whether tenants know how to access it and who is responsible for keeping it current. Those are requirements of the publication scheme, rather than optional improvements to the website.
A practical check is to ask someone to find the information as a tenant would. Can they locate it without knowing the organisation’s structure or terminology? Does it make sense? What happens if they believe information is missing?
The same approach can help with preparation for April. Put a sample information request through the proposed arrangements and see where it goes. Unclear ownership between the contact centre, housing, governance and information teams is better discovered during testing than through a resident having to chase a response.
STAIRs applies to private registered providers. Council residents already have access to information through the Freedom of Information framework, although Cabinets should still take an interest in how well their organisation supports transparency in practice.
Give members an honest picture
We do not expect Boards or Cabinets to inspect every case or become specialists in every new requirement. They should, however, be able to understand the basis of the assurance they receive.
What has been checked? Who checked it? What did they find? What remains unresolved, and what are the consequences?
A report that identifies weaknesses and sets out a credible response can support good governance. It allows members to challenge priorities, consider resources and follow up delivery. A green status without supporting evidence gives them little to work with.
There is also a point at which independent scrutiny is useful. Teams delivering a change programme are close to the work and under pressure to complete it. A separate review can test whether their conclusions are supported and whether anything significant has been overlooked.
Keep asking after implementation
The launch date is an important milestone, but assurance needs to continue. Staff change, workloads increase and contractors encounter difficulties. Boards and Cabinets need to know whether the arrangements remain effective when those pressures arise.
At Integra, we look for a clear connection between the requirement, the way the service operates and the evidence of delivery. Where there are gaps, the improvement plan needs clear ownership, realistic deadlines and a proper test of whether the problem has been resolved.
The resident’s experience must remain part of that judgement. If the report says an action is complete but the resident is still living with the problem, there is more to understand.
A busy agenda makes concise reporting essential. It also makes the quality of that reporting more important. Before accepting that a new requirement has been successfully implemented, Boards and Cabinets should ask:
“What have we tested, what does the evidence tell us, and where are we still exposed?”
Those questions help turn an implementation update into useful assurance. They also give leaders a better chance of addressing weaknesses before residents bear the consequences.
