One of the most overlooked elements of the Competence and Conduct Standard is the requirement for housing providers to maintain a written policy covering workforce competence, learning, development, appraisal, and performance management.
Much of the sector conversation has understandably focused on qualifications, particularly around Level 4 and Level 5 requirements for senior housing managers and executives. However, the standard goes much further than formal qualifications alone.
The direction issued to the Regulator of Social Housing makes clear that providers are expected to demonstrate structured, organisation-wide approaches to developing, maintaining, and reviewing staff competence across housing services.
For many organisations, this means creating or reviewing a formal competence and development policy for the first time.
Why Is a Competence and Development Policy Important?
The Competence and Conduct Standard reflects a wider shift within the sector towards professionalism, accountability, and resident-focused service delivery.
The standard emerged following years of scrutiny into housing services, including the Grenfell Tower Inquiry, the Social Housing White Paper, and growing concern around complaints handling, resident experience, organisational culture, and professional conduct.
As a result, the standard places greater emphasis on:
- Workforce competence
- Professional behaviours
- Ongoing learning
- Accountability
- Service quality
- Organisational culture
- Resident confidence
The written competence and development policy forms part of the evidence providers may rely upon to demonstrate how these expectations are being embedded operationally across the organisation.
What Does the Standard Actually Require?
The Competence and Conduct Standard requires providers to maintain a written policy setting out how they will:
- Support learning and development
- Appraise staff performance
- Identify competence needs
- Address poor performance
- Maintain workforce capability over time
This means providers should be able to demonstrate not only that staff are qualified where required, but also:
- How competence is assessed
- How learning needs are identified
- How development opportunities are provided
- How performance concerns are managed
- How professionalism is maintained
- How standards are monitored consistently across teams
For many organisations, this will involve bringing together existing processes that may currently sit across HR, operational management, learning and development, and compliance functions into a clearer and more cohesive framework.
What Should a Competence and Development Policy Include?
While every organisation will structure its policy differently, there are several core areas that providers should consider including.
1. Purpose of the Policy
The policy should begin by clearly explaining:
- Why the policy exists
- How it supports the Competence and Conduct Standard
- Who the policy applies to
- The organisation’s commitment to professionalism and resident-focused services
This section should establish that competence is viewed as an ongoing organisational responsibility rather than a one-off qualification exercise.
2. Scope of the Policy
Providers should define:
- Which teams and roles the policy applies to
- Whether contractors or managing agents are included
- How different role types will be assessed
- Which services fall within housing management functions
This is particularly important given that the standard applies differently depending on operational responsibilities and organisational structure.
Many organisations are currently undertaking workforce mapping exercises to identify:
- Roles likely to fall within qualification requirements
- Operational management responsibilities
- Strategic oversight functions
- Outsourced service arrangements
The policy should align with this work.
3. Competence Frameworks
A strong competence and development policy should define what competence means within the organisation.
This may include:
- Technical knowledge
- Professional behaviours
- Communication skills
- Safeguarding awareness
- Resident engagement
- Equality, diversity and inclusion
- Decision-making
- Complaint handling
- Leadership capability
Competence should not be viewed purely through the lens of qualifications. The standard places clear emphasis on behaviours, professionalism, and service quality alongside technical knowledge.
Many providers are now beginning to develop role-specific competency frameworks linked to:
- Job descriptions
- Appraisals
- Progression pathways
- Learning plans
- Supervision arrangements
4. Learning and Development Arrangements
The policy should explain how staff learning and development will be supported in practice.
This may include:
- Formal qualifications
- Housing Apprenticeships
- Internal CPD
- Coaching and mentoring
- Reflective supervision
- E-learning
- Leadership development
- Induction programmes
- Refresher training
Providers should also consider how learning needs will be identified and reviewed over time.
For example:
- Annual appraisals
- Probation reviews
- Supervision meetings
- Service audits
- Complaint trends
- Performance concerns
- Regulatory findings
- Policy changes
The strongest competence and development policies avoid treating learning as a reactive process that only begins when performance concerns arise or complaints are received.
Instead, they position workforce development as an ongoing organisational responsibility linked to service quality, resident experience, professionalism, and continuous improvement.
This means creating structures where learning is built into day-to-day operations through regular supervision, reflective practice, appraisals, coaching, mentoring, CPD, and service review processes rather than relying solely on remedial training after issues have already escalated.
A proactive approach also allows organisations to identify emerging skills gaps earlier, respond to regulatory or legislative changes more effectively, strengthen succession planning, and support staff confidence and decision-making before problems begin affecting residents or service delivery.
Importantly, this helps shift organisational culture away from viewing learning as a corrective measure and towards seeing professional development as a normal and expected part of delivering high-quality housing services.
5. Qualification Requirements
The policy should clearly explain:
- Which roles are expected to hold qualifications
- Qualification expectations for senior housing managers and executives
- How staff working towards qualifications will be supported
- How compliance will be monitored
- Expectations relating to existing qualifications or top-up learning
Providers should also outline:
- Timescales
- Workforce planning arrangements
- Study support
- Progression expectations
- Arrangements for new starters
This section is likely to evolve over time as further sector guidance develops.
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6. Performance Management
The Competence and Conduct Standard also places emphasis on how organisations identify and address poor performance.
The policy should therefore explain:
- How performance is monitored
- How concerns are escalated
- How support is provided
- How improvement plans are managed
- When formal processes may be required
This should not be framed purely as disciplinary action. A good competence and development policy balances:
- Support
- Accountability
- Learning
- Supervision
- Continuous improvement
The aim should be to create a culture where competence is actively maintained rather than simply enforced.
7. Professional Conduct & Behaviour
Although many organisations already have codes of conduct in place, the competence and development policy should explain how professional behaviours are reinforced operationally.
This may include expectations around:
- Communication with residents
- Professionalism
- Empathy and respect
- Accountability
- Safeguarding
- Equality and inclusion
- Ethical decision-making
- Partnership working
This is particularly important given that the professionalisation agenda emerged partly in response to concerns around resident experience and organisational culture.
8. Tenant Involvement
One of the more significant shifts within the standard is the expectation that tenants should have opportunities to influence and scrutinise competence and conduct approaches. Providers should therefore consider:
- How tenant feedback informs learning
- How complaints trends shape development priorities
- Whether residents contribute to service reviews
- How tenant voice influences organisational standards
This does not mean tenants are expected to manage workforce development directly, but organisations should be able to evidence how resident experience informs continuous improvement. You can read our guide to Tenant Involvement Here.
9. Monitoring, Governance & Review
The policy should explain:
- Who is responsible for oversight
- How compliance will be monitored
- What reporting arrangements exist
- How frequently the policy will be reviewed
Providers may also wish to outline:
- Board oversight arrangements
- Audit processes
- Workforce reporting
- Qualification tracking systems
- Contractor monitoring approaches
The regulator is likely to expect organisations to move beyond informal arrangements and demonstrate more structured governance around competence.
Common Mistakes Organisations Should Avoid
As organisations begin developing competence and development policies, there are several common pitfalls emerging across the sector.
Treating the Policy as a Purely HR Exercise
The standard is operational, cultural, and service-focused. Policies should therefore involve operational leaders, housing teams, compliance functions, and learning and development staff, not HR teams in isolation.
Focusing Only on Qualifications
Qualifications matter, but the standard also focuses heavily on:
- Behaviours
- Professionalism
- Accountability
- Resident experience
- Ongoing competence
A qualification-only approach is unlikely to demonstrate full compliance.
Creating Policies Without Clear Operational Processes
Policies should reflect real organisational arrangements, not aspirational statements unsupported by operational systems. If a policy states competence is regularly reviewed, providers should be able to evidence how this actually happens.
Failing to Consider Contractors and Managing Agents
The standard also creates responsibilities relating to certain outsourced housing management arrangements. Providers should consider how competence expectations are reflected within:
- Procurement processes
- Contract monitoring
- Service specifications
- Partnership arrangements
How to Create a Written Competence and Development Policy for the Competence and Conduct Standard
The Competence and Conduct Standard represents a significant shift in how professionalism within social housing is viewed and regulated.
For providers, the written competence and development policy should not simply be seen as another compliance document. Done properly, it can become a practical framework for strengthening workforce capability, improving resident experience, supporting organisational culture, and evidencing professionalism across housing services.
The organisations likely to be strongest under the new framework will not necessarily be those who respond fastest, but those who take the time to build structured, meaningful, and operationally realistic approaches to workforce competence across the wider organisation.