While more and more housing providers are joining the regulator’s exclusive C1 club, it can be hard to understand the reasons why from the short and succinct judgement reports. As part of HQN’s wider inspection work, we asked Keith Cooper to get under the bonnet of some of the top performing landlords. This is what he found.
The Regulator of Social Housing (RSH) dishes out praise in stock phrases when awarding its top ratings for consumer standards.
Repairs services are “effective and efficient” in these high-scoring landlords, its reports say. Their approach to damp and mould, “proactive”. Evidence of a “respectful, fair and positive culture towards tenants” is another common assessment in these most positive of reports.
But beneath these official expressions of regulatory satisfaction often lies a huge effort by the landlords which have attained the C1 grade. To find out how they’ve been achieved, HQM is quizzing some of these top performers.
Our initial four case studies include the specialist social landlord Golden Lane Housing, the West Midlands association Citizen Housing, Stockport Council, whose homes are managed by its arm’s length management organisation (ALMO), Stockport Homes and Guildford Council.
The road to C1
This piece zooms in on different aspects of each of their journeys to C1.
Citizen Housing highlights the importance of evidence in every step of the inspection process, encapsulated in its own motto: “If it’s not written down, we haven’t done it.” For Golden Lane Housing, its commitment to supporting residents with learning disabilities to take part in the inspection process stands out. Stockport Homes shows how fire safety failings, when quickly tackled, don’t always push a C1 out of reach. And, finally, we examine how Guildford moved up from a C3 and how it tailored its ambition to the very practical limitations of its capacity to improve.
To date, some 70 registered providers have been given this top score, about a third of those inspected so far. This figure includes 50 housing associations, eight for-profit providers and a dozen local authorities.
With so many landlords now hitting the C1 grade, and after more than two years of consumer regulation, the route toward it is now a “well-trodden path”, says HQN chief executive Alistair McIntosh. “The rules are crystal clear. People know what they’ve got to do on governance, asset management, on safety and tenant engagement,” he adds. “We’re also beginning to see that organisations with a C2 or a C3 can move up to C1 through engaging with the regulator and following the requirements. If a landlord wants it, it’s now a question of ‘when’ and not ‘if’.”
HQN director Damian Roche says the key to securing a C1 is a “laser focus” on improvement which continues long after inspectors have left, a “rigorous” approach to data and a positive culture. “While this latter quality of an organisation might seem intangible, it can be seen in how it recruits and treats tenants and staff,” he says. “You can see it in their ethos in terms of recruitment, training and development,” he says. “Who do you ask when you’re recruiting the right people? Do you have tenants on panels for most senior or customer-facing roles?”
What seems clear from these case studies and the numbers of landlords hitting the C1 bar is that these qualities exist in many social landlords – and can be fixed in those where they don’t.
Golden Lane: Get on the front foot and take the regulator with you
Golden Lane Housing’s journey towards its top-notch consumer rating began six years ago in 2020, according to its chief executive John Verge. Back then it agreed to fully demerge from Mencap, the charity which founded this specialist housing provider for people with learning disabilities. “We did a huge amount of work to ensure we were on a strong footing when we did finally demerge in April 2022,” he told HQM.
The Manchester-based association built on this foundation with a governance structure which includes its main board, a 12-strong tenant group, and a board and tenant group working together, made up of a mix of members from each one. “Our work over the last three years to prepare for the consumer standards has had hearing the voice of tenants at its heart,” Mr Verge says. “This gave us confidence that we knew our properties, our tenants, and we also knew where we needed to make improvements,” he adds.
A further crucial step in its journey was a mock inspection, run by HQN.
“Our work over the last three years to prepare for the consumer standards has had hearing the voice of tenants at its heart. This gave us confidence that we knew our properties, our tenants, and we also knew where we needed to make improvements”
John Verge, chief executive, Golden Lane Housing
One of the biggest benefits of the mock was demystifying the process for staff, says Emma Midgley, Golden Lane Housing’s director of business services. “In previous inspections in other organisations I’ve worked for inspections were something very secret. Everyone just got in a room and you didn’t see them for months,” she adds. “But we did an awful lot of colleague awareness and engagement for the mock inspection. We were really open about what the inspection was, how it was assessed, what it would involve, and what it meant for us and our tenants,” she adds.
Ms Midgley says the mock also helped confirm the association’s strengths and weak spots, and validated the improvement plans it had in place to address them. “We’re going through a huge period of change and have got an awful lot of projects underway for improvements. Some are at the very start of the journey but we could show where we were and where we were going. We had a great story to tell.”
Golden Lane Housing approached its actual inspection as a way of helping the RSH understand its business. “We didn’t want to just throw 200 documents at the regulator,” says Ms Midgley. “We spent a lot of time preparing overviews of everything that we provided and how it supported the evidence they were after,” she adds. “The inspection team were also really engaging. They talked to us about how it was going to work, where they were going to focus, and gave us an opportunity to ask questions. This meant that we were able to plan and everybody knew what their role was.”
Its next shrewd move was its handling of an assurance gap meeting with the RSH, where it gathers the information which its inspectors have not yet seen. Golden Lane Housing’s “top tip” for these meetings is to “take the lead” in them. “People might think, this is a regulator meeting, they’re going to lead it. But we took the opposite approach,” says Ms Midgley. “We thought, hang on, they’ve sent us a letter with a couple of queries, we’ll present to them and that’s what we did,” she adds. “We got minimal questions off the back of that presentation. We did a great job of being able to tell the story.”
Mr Verge’s advice to other associations after Golden Lane Housing’s experience of inspection is to “get on the front foot” and “don’t be defensive”. “The RSH was very clear that one of their roles is to support providers to get the evidence,” he says. “If you can’t provide it or can’t provide assurance that clearly won’t land well in terms of your rating, but they’re not there to trip you over.”
Golden Lane Housing even found the RSH was willing to learn a thing or two about the inspection process from them. “Normally, when inspectors talk to engaged tenants they won’t give them any advanced notification of what they’re going to talk about,” says Paul Knight, director of housing and tenant experience at the association. “We told them, okay, that’s fine but we need to facilitate that. If they wanted to get the best out of our tenants they needed to work with us, give them advanced sight of the questions, so we could present them in an easy-to-read format, give them an opportunity to think about them, and then contribute in a more meaningful way.”
Stockport Council: Turning bad news into good
Stockport Council and its ALMO Stockport Homes had begun preparing for the consumer standards months before their introduction in April 2024. But then they hit a snag. That December, the ALMO had to refer itself to the RSH after uncovering some overdue fire safety remedial actions. But this didn’t stop the Greater Manchester landlord from getting a C1. In fact, the RSH judgement praised it for acting quickly to mitigate risks and put “clear plans” in place for the completion of the works.
“The response we had was in line with the behaviour of a C1 landlord – to be honest, transparent and put in place mitigation measures as soon as possible,” says Stockport Homes chief executive Carmel Chambers. “The introduction of the new consumer standards was a welcome process, and an opportunity to build upon the strengths already in place, whilst acknowledging there’s always room for improvement,” she told HQM.
Its preparation for the consumer standards had begun the previous summer. “We created a specific project team when the draft consumer standards were released…and undertook a gap analysis,” Ms Chambers adds. “This identified areas for improvement, and an action plan.”
This team reported to a regulation project board which met regularly to ensure the standards were met and it had evidence to prove it. Its progress was reported back to Stockport Homes executive, board and the authority.
“Everything has to be evidence based…I was sent pictures of smoke detectors on ceilings, which was meant to be demonstrating compliance. But there’s no way I’m sending those to the regulator because it doesn’t tell me anything. It could be a picture of my ceiling for all they know”
Katie Finch, director of assurance and business services, Citizen Housing
The authority and ALMO also kept itself up to speed on the development of consumer regulation by scouring any new judgement and arranged a mock inspection by HQN.
Stockport thought it was on track for a C2 “as a minimum” but knew the diversity of an ageing stock, which includes 25 high-rises, would make assurances on safety a particular challenge. The inspection, however, found that all of its buildings had up-to-date fire risk assessments and that it was managing the risks within its tall buildings with remedial work and “appropriate remediations”.
Despite being “incredibly proud” of its top rating, Stockport Homes and its parent authority doesn’t see its C1 rating as meaning it’s achieved “perfection”.
“It means that, overall, we’re delivering the outcomes of the consumer standards, but we never stand still,” says Ms Chambers. “We have a detailed improvement plan following the inspection, which includes, amongst other things, ensuring the unfiltered customer voice is heard, and that our systems and data journey remains focussed,” she adds. “We know that some customers aren’t satisfied with what we are delivering often because they’re living in a home that no longer meets their needs.”
With more than 700 staff, Stockport Homes is also ensuring that their competence and conduct is at the heart of it service delivery and that “all of our staff understand the expectation of excellent customer services and accountability,” Ms Chambers says.
Evidencing excellence: The Citizen Housing experience
It’s not good enough to just be a great landlord if you want to secure the top rung consumer rating. You must also prove it. This is the key lesson from West Midlands association Citizen Housing, which was awarded a C1 in 2025. And this kind of proof doesn’t come easy, its director of assurance and business services, Katie Finch, told HQM. “I liken the process to a big sausage machine – everything gets fed into it. It was huge… trying to get hundreds of documents read, understood, signed off and then over to the regulator is quite a feat in itself,” Ms Finch adds.
“The rules are crystal clear. People know what they’ve got to do on governance, asset management, on safety and tenant engagement. We’re also beginning to see that organisations with a C2 or a C3 can move up to C1 through engaging with the regulator and following the requirements”
Alistair McIntosh, chief executive, HQN
Like other providers we spoke to, the volume of documents required by the regulator is substantial. Citizen had sent more than 300 documents to the RSH by the end of its inspection process. As many landlords will know, the generation of detailed and convincing evidence for a regulatory requirement is hugely time intensive. “Everything has to be evidence-based,” says Ms Finch. “It’s all well and good saying we’ve done that but if you can’t pull a piece of paper out to evidence it, it’s not really worth anything. It became a kind of motto: “If it’s not written down, we haven’t done it.”
The quality of the evidence was also crucial, says Ms Finch. “This can be a bit painful at times. For example, I was sent pictures of smoke detectors on ceilings, which was meant to be demonstrating compliance. But there’s no way I’m sending those to the regulator because it doesn’t tell me anything. It could be a picture of my ceiling for all they know.”
From serious failings to top rating: Guildford’s road back
Guildford Council is the only authority to climb to the highest consumer rating after being found to have “serious failings” by the RSH.
The Surrey authority was upgraded to a C1 in March after major shortcomings were found in its repairs services, compliance with the health and safety standard, and its tenant satisfaction measures in 2024.
So, just how did the authority turn itself around?
Annalisa Howson, Guildford and Waverley’s assistant director of housing, admits the service was at a “low point” and had a “lot of holes” when she joined it in the months before the initial inspection. One of its first steps to recovery was the creation of a housing improvement plan, a document familiar to many social landlords in a similarly non-compliant position.
“This aimed to address the weaknesses [we] had identified and the failings that had been identified in the regulatory judgement,” Ms Howson told HQN’s ‘From C3 to C1: A journey of change, challenge and pride’ event last month. “One of the main aims of the improvement plan was to build trust, pride and excellence. We really needed to build trust not only with our tenants, but with our members and our staff as well.”
Such plans can be crucial to the recovery of a landlord from regulatory failure. At Guildford, it was treated as “dynamic” and changed as its investigations uncovered other shortfalls but remained realistic as the scale of its problems emerged. “You don’t have to stick diligently to the plan,” Ms Howson says. “You need to let it evolve and flex as different priorities and different situations occur. There’s no point in having something that’s overly ambitious.”
Like many councils which have been subject to years of cost cutting, Guildford has lost many of the staff in its housing services which supported improvement.
Julian Higson, strategic director of housing, communities and environment at Waverley and Guildford Council, said it was also important for everyone to work from a single unified plan instead of multiple ones for each service area. “I’ve worked for some organisations who seem to have an awful lot of improvement plans. This isn’t a good thing,” he adds. “How on earth do you manage to keep track of them all?” he asked the HQN event. “How on earth are you going to do the governance around them? You need one clear plan.”
Another crucial element in its recovery was the use of external advice, initially from the Society of Local Authority Chief Executives (SOLACE), and later, HQN. “I’ve seen other organisations who say, it’s okay. We’ll do our own self-assessments,” Mr Higson says. “It’s very difficult to be self-critical of your colleagues and self-critical of yourself.”