The Competence and Conduct Standard Consultation sets out the implementation arrangements for the new regulatory standard requiring senior housing managers and executives within social housing to either have, or be working towards, a relevant professional qualification.

Whilst recognising the value relevant professional qualifications in driving up standards in the social rented sector, the CWAG consultation response highlighted concerns around the tight implementation timescales and the potential for these to negatively impact staff recruitment and retention in the short-term. The proposed timescales do not offer sufficient time to implement the necessary organisational and training challenges alongside succession planning.

In addition, the costs associated with introducing these measures are likely to be significantly higher than estimated in the impact assessment. No additional resources have been identified to cover implementation and associated costs which will need to be funded from already stretched Housing Revenue Accounts.

Other issues highlighted include that role descriptions are a poor fit with ALMO clienting arrangements. In addition, organisations using external contractors may face difficult challenges if these roles are deemed in scope of the new regulations.