by Graham Oliphant, Managing Director of Harmony Fire’s consultancy business
Nobody can accuse the Regulator of Social Housing (RSH) of lacking clarity in its expectations of registered providers of social housing in England. The recently published Regulatory Casework Review 2026 is an undeniably effective communication, providing simple and straightforward guidance, punctuated by relevant and unambiguous examples of both good and poor practice.
The reason the RSH can produce a document that even hardened members of the ‘Plain English Campaign’ would struggle to find fault with is that its seven key lessons are, fundamentally, common-sense ways for landlords to maximise the impact and value of their investments to existing and future residents.
It’s a guidance document that’s both instructive and also serious about the consequences of failing to act, ignoring problems and declining to engage with the regulator to get things back on track. In its structure, tone and clear articulation of the requirements, the Review poses a clear challenge to the sector. If your life safety investments are more sticking plaster than a cohesive resident-focused asset management masterplan, then you cannot fulfil your duties to current and future residents.
Graham Oliphant, Managing Director of Harmony Fire’s consultancy business.
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The plain-speaking RSH’s list of seven key lessons for registered providers outlines that they should:-
1 Know that tenants are safe in their homes
2 Have an effective risk management culture
3 Use data and insight to drive continuous improvement
4 Demonstrate you deliver strategic value for money
5 Ensure strong governance of financial risks and performance
6 Work with us [regulator] to make improvements
7 Listen to tenants’ views to shape services and inform decision making
These are not abstract concepts without a clear line of sight towards a unifying goal, they are purposefully directed to the ultimate responsibility of every landlord, which is to keep residents safe from harm. The Review explores each of the seven lessons in some detail and then helpfully annotates these core requirements with case studies from across the performance spectrum.
It’s perhaps no coincidence that the word ‘assurance’ appears 34 times in the Review, the word ‘compliance’ just 12 times. This may be a simple linguistic observation, but it reinforces a significant point that satisfying an individual requirement does not mean an organisation has a complete understanding of the risk it is managing. Closing an FRA action is evidence that an intervention has taken place, but it doesn’t provide evidence that the underlying risk is understood, controlled or capable of being assured at board level. Compliance highlights the completion of an action, while assurance provides confidence to the Responsible Person, and to the resident, that the wider system is working effectively and safety is being correctly managed.
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A common thread underpinning every RSH lesson is the effective collection and use of data to inform investment decision making. Read the document carefully and it becomes clear that organisations with a strong focus on understanding their residents’ needs, their building assets and the financial sustainability of their organisation are much better placed to demonstrate effective governance and risk management, while delivering better outcomes for current and future residents.
If collecting and utilising the ‘right’ type of data is one of the central solutions to the RSH’s lessons, then organisational culture represents one of the key challenges today. Demonstrating that investments have assurance value today and legacy value into the future is what the regulator is demanding. Tick boxes won’t cut it any longer, the regulator demands accountability and a financially sustainable approach to managing risk over a long-term horizon. The regulator asks:-
• Do you understand the unique composition of your resident population across your assets, and have you created effective ways to listen to their concerns and ideas?
• Do you have assurance that you understand how your buildings will perform in an emergency, and that prioritised plans are in place to address identified risks?
• Are you confident that your investments are future proofing your assets and providing long-term value and risk assurance to your residents and board?
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The RSH couldn’t be any clearer in this regard that robust organisational knowledge, and the ability to continue to collect and update this information, is intrinsically linked to financially sustainable landlords that are the best run and demonstrate the highest rated consumer standards. The seven lessons are deliberately designed as open-ended and perpetual organisational objectives that work together as a feedback mechanism driving continuous improvement. A lesson can never be closed or ticked off as completed because residents are a dynamic cohort, building assets deteriorate, regulations change and finances are constantly buffeted by competing pressures. Data and insights revealed from each lesson work together to inform processes and investment in a continual feedback loop to iteratively improve overall performance for both landlords and residents in perpetuity.
Despite a significant financial boost to the social housing sector by the government and record recent expenditure on life-safety improvements, decades of underinvestment in our social housing stock has created a perfect storm of competing cost pressures on landlords. The RSH’s fourth and fifth lessons on value for money and financial viability showcase the critical importance the regulator places on the sustainability of a sector that provides a home for one in five households across the UK.
The overwhelming pressure on landlords to confront emerging and unplanned safety compliance issues regularly skews budget forecasting and allocation, and unbalances or halts future new home investment programmes. Calculating the real cost of ad hoc and reactive spending versus investment based on high-quality asset intelligence through conditionality surveys, risk profile and future investment requirements of buildings is what the regulator now demands.
While the relationship between regulator and industry sector is not always frictionless, the RSH has showed itself to be a valuable collaboration and knowledge sharing partner. A focus on early intervention and self-referral showcase the regulator’s commitment to work with partners to mitigate challenges before they further elevate risk to residents. There is a strong focus on highlighting sector best practice to encourage learning, deliver iterative improvements and to ensure investment decisions deliver credible assurance and unlock future housing capacity.
Set piece annual announcements, like the Regulatory Casework Review 2026, mark a core benchmark for all landlords to assess their own performance. If boards cannot actively demonstrate how they respond to each of the seven lessons with evidence not assertion, then there is still more work to do.
www.harmonyfire.com
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