To break down the inspection process and the role HQN plays in supporting organisations, we talked to HQN’s consumer regulation leads, Lydia Dlaboha and Damian Roche.

 

Can you give us a step-by-step guide to the inspection process, from the first call from the regulator to the publication of the C grading?

Lydia Dlaboha (LD): I’ll try! My understanding is that the organisation gets an email or sometimes a call from the regulator, saying something along the lines of “We’d like to have a meeting with you in the next couple of days about a ‘regulatory matter’”. That’s the terminology they use. It sounds quite urgent, but they don’t actually say it’s about inspection at that point.

During that initial conversation, they make it clear they are coming to inspect you and there’s no escaping. And they then give you a list of the contextual information you need to provide them with within the next seven days. This often puts the organisation into ‘panic mode’.

However, this first information request is the easy part – the tip of the iceberg. A couple of weeks later, organisations are presented with a far more comprehensive list that they have a fortnight to respond to.

Assurance and outcomes, that’s what they are looking for. Evidence of both.

Damian Roche (DR): It’s all about what goes to the governing body, so after that first generic request for information, they receive a scoping document which is cross-referenced against each element of the four standards. You can guarantee that two thirds of the documents requested will be reports to the governing body or senior management. There’s an expectation that basically anything relevant to the consumer standards goes through the governing body.

LD: In terms of advice, organisations really need to set out quite simply their governance structure, how it works and what gets reported where. This is particularly relevant to councils as we see all sorts of complex set ups and a lack of clarity. But it can be complicated to understand what’s reported where for associations as well – especially those that have gone through mergers or with group structures and subsidiaries.

DR: The important thing in terms of the documents, is to give the regulator what they ask for and, if you haven’t got it, explain why (if you can). There may also be additional documentation you want to provide, which is fine, but explain why you’re providing it. Just don’t bombard them with everything including the kitchen sink.

LD: It’s worth stating that, with inspection, it’s on the four consumer standards plus finance and governance for the associations because the regulator is still looking at these areas and high level stuff, like corporate strategy, risk and stress testing. Alistair [McIntosh] makes that point about governance – yes, it’s the consumer standards, but it’s actually governance of the consumer standards that they focus on. So, whilst it’s only the consumer standards that apply to councils, councils still need to think about their business and risk plans and where the money is coming from for compliance in the context of the consumer standards.

Fairly early on in the process, the regulator will also give you an idea about when they expect to be on site, when they want to do the field work. This is for observing meetings and the interviews. They will usually observe a board meeting, a meeting of engaged tenants, and something like a housing services committee meeting.

It can be quite a quick turnaround and, depending on your meetings schedule, it might well be the next board meeting they ask to observe, so you may not get much time to prepare.

“It’s worth saying here, because it was brought up in one of our Residents’ Network meetings, that it’s okay for one or two engaged tenants to attend the feedback meetings. The regulator has confirmed this. I think it’s good that residents get to hear first-hand what the regulator is saying”

DR: In terms of the engaged tenants, they will observe a meeting and hold a focus group. As with most of the meetings, they’re looking for challenge from members, asking the right questions, that sort of thing. Even if they don’t observe a meeting where there has been much challenge, it’s worth providing evidence that there’s challenge in other meetings.

LD: It’s worth saying here, that when the regulator observes meetings, that tends to be virtual. They quite often leave their cameras off. On occasions, people have forgotten that they’re there. Whilst you want the meeting to be as ‘normal’ as possible, there are probably some things you really don’t want the regulator to hear. Don’t get complacent or over-confident.

Depending on whether you’re a council or association, the interviews are usually with the chair of the board, chief executive, leader, portfolio holder, chairs of relevant sub-committees and the executive team. It’s the top people they want to talk to. And they can either be seen individually or in groups. It can be quite flexible.

So, organisations need to think about who they want to field and how. As Damian always points out, it’s not a test of memory so notes or fact sheets are allowed. That can be especially helpful for key facts, or the history/background of the organisation. Also, mission statements, promises to tenants, mergers, geographical spread and what’s happened since your last inspection (for associations). You need to be across the facts.

While they may only interview or speak to a limited number of people during the inspection process, it’s important to understand that everyone in the organisation has a role to play. The consumer standards touch on every interaction with tenants and homes. Success therefore relies on everyone playing their part and doing their job right.

“The residents, especially, can get very nervous. They don’t want to let the organisation down and they will be worried about getting something wrong. They say things like ‘Does it matter that I’ve never spoken to a board member?’”

DR: We often recommend that our clients invite the regulator out on site visits. It’s not an official part of the inspection process so sometimes they’ll agree to go, other times they’ll decline, but it’s worth making the invitation. There are two reasons – hopefully you can demonstrate you’re maintaining your estates well and you’re keeping your tenants safe. But it also underlines the scale of the challenges you’re facing – whether its inner city or rural areas, it brings to life what you’re doing every day and why it’s important. It helps to tell your story.

LD: Just on telling your story, you’re given 15 minutes to do a presentation to the regulator. And that’s the thing that Alistair is clear about – spend a lot of time on it and get it absolutely spot on. Set the scene, talk about the challenges, what sets you apart and be self-aware. Don’t brag. They will look for the evidence behind everything you say. The aim is to try and write their report for them.

The risk is you put everything in there and, because it’s often written ‘by committee’, nobody wants their bit taken out. So, it’s hard but you really have to focus on what’s important and get one person to check and edit it. Take care – double check things and don’t catch yourself out!

“Our predicted grades are usually spot on. We get it wrong on occasion but that’s very rare and it’s usually where an organisation performs better than we expected them to!”

Once the on-site bit is over, the regulator goes away to consider all the information and evidence they have gathered. They might ask for more documents and ask more questions. They’ll write their report, arrive at their verdict, get it moderated, and arrange for a feedback meeting with you and give you an indicative grading.

It’s worth saying here, because it was brought up in one of our Residents’ Network meetings, that it’s okay for one or two engaged tenants to attend the feedback meetings. The regulator has confirmed this. I think it’s good that residents get to hear first-hand what the regulator is saying. The written reports don’t really give much away.

One other point about the feedback session, is that it’s worth having someone taking notes (who’s not part of the discussion). I think it’s really important as there’s some incredibly valuable information to take from it. It’s basically free consultancy direct from the horse’s mouth!

And just to finish off the process, there’s a bit of a lull, maybe a couple of weeks, while the report and press release are finalised before the final grade is published for the world to see.

Talk us through the inspection support HQN provides

LD: We can provide a variety of support depending on what’s needed or most useful, from a thorough check/third party assurance of compliance against the standards to a practice run or just a light touch review of a self-assessment or improvement plan. It’s never too late to get in touch. Obviously the longer the time before the real inspection, the longer to put things right.

For our practice runs, we have a structured approach, we go through their documents before they submit them and provide an external eye and make suggestions. We flag the things that the regulator is likely to pick up. We do practice interviews with relevant people, including a focus group with residents.

Residents, especially, can get very nervous. They don’t want to let the organisation down and they might be worried about getting something wrong. They say things like “Does it matter that I’ve never spoken to a board member?” Or “I don’t know who our board members are”. It’s often not important stuff, but they can get really stressed about it, which really isn’t the point of the focus groups.

We’re happy to provide coaching and mentoring where needed or if it’s requested by an individual.

“When the regulator observes meetings, that tends to be virtual. They quite often leave their cameras off. On occasions, people have forgotten that they’re there. Whilst you want the meeting to be as ‘normal’ as possible, there are probably some things you really don’t want the regulator to hear”

We can facilitate a group or board discussion about specific issues. We can help with their fact sheets. Something that clients seem to find particularly valuable is our support on the type of quality and safety information that should be monitored and reported on. That standard in particular is very ‘data rich’.

We deal with a lot of ad hoc queries and the key is to try and respond as quickly as possible, which is something Damian is excellent at – the whole team to be fair. That is the expectation we have of all our consultants.

The other thing we do is the full end-to-end mock inspection. Basically, we go through the same process as the regulator but we’re far more supportive. The purpose is to put them through their paces, so they get to practice every part of the process, but we also do that ‘assurance piece’ because we check and validate their self-assessment.

As part of the triangulation, we do go further. We go out on estates ourselves and see things with our own eyes. We pick up on things like safety and compliance.

We sit with the contact centre and listen to first point of contact call handling. We see what that’s like and how well their systems work. We look at the culture and behaviours in different parts of the organisation.

We go and look at voids, review their voids standards, how they’re performing in terms of tenancy sustainment, property condition and health and safety. We look at ASB case files and, of course, complaints.

It’s to give them assurance and us reassurance that what they’re saying is backed up by what they’re actually doing and what the service really looks and feels like on the ground.

DR: We tailor the interviews for the mock inspections. Some want a proper dress rehearsal where we play the role of the regulator, ask lots of tough questions and people get thrown in the deep end. Others want more of a coaching style, so it’s more of a conversation. We ask the same questions, but then we’ll provide immediate feedback on the way they answer, as well as the answer itself.

LD: As part of the process, we’ll give them an indication of their C grading and our evidence for this. And we tell them what we think their priorities should be and advise them if there are any red flags. If we think organisations need to self-refer, then we’ll tell them to do so. Generally, they probably already know but sometimes a nudge from us is needed!

DR: I’m not sure anyone’s declined to self-refer when we’ve recommended that they do.

LD: We do help them with the self-referral in order to get the message right, to make sure that they’ve actually uncovered everything and to make sure they’ve got a plan in place. It’s just helping them through that process really.

Are you able to predict what C grade an organisation is going to get before it’s published?

DR: Yes, generally we have a pretty good record, and our predicted grades are usually spot on. We get it wrong on occasion but that’s very rare and it’s usually where an organisation performs better than we expected them to!

LD: We place a lot of emphasis on safety and quality. We have specialists working on that one area specifically. Wayne [Hughes], Chris [Poulton] and Kevin [Bentley] have been doing compliance, health and safety for years. They know where the skeletons are and they have a really clear focus. We know this is an area that drives the lower grading – C3 and C4.

They really scrutinise the data, look at stock condition, Decent Homes compliance. Are clients defining things properly? They drill into all of that.

“The other thing we do is the full end-to-end mock inspection…As part of the triangulation, we do go further. We go out on estates ourselves and see things with our own eyes. We pick up on things like safety and compliance. We sit with the contact centre and listen to first point of contact call handling. We see what that’s like and how well their systems work. We look at the culture and behaviours in different parts of the organisation”

Damian or Suzanne [Hemingway] cover the other three standards and governance. And, if we’re looking at finance and viability we call in Ian [Parker].  Everyone on the team has done the ‘day job’ themselves so know where the skeletons are. Suzanne is particularly good at understanding councils as she’s spent a lot of her time working for them.

One of the big things we do is review improvement plans and the actions they need to take forward. Damian now sits on a number of improvement boards after initially doing a review of the progress that they’ve made.

We also put organisations in touch with each other, if they’re dealing with a similar issue or we’re particularly impressed with what one organisation is doing and want to share their work. HQN’s networks help with this as well.

Basically, we just act as a ‘critical friend’. They can call and ask us for advice at any stage of the process and we’re there for them.

We’re very friendly and approachable! Even though sometimes we do deliver tough messages.

DR: We build up a lot of knowledge through working with all these different organisations, with different demographics, specialisms and structures all over the country.

LD: And then we’ll draw on all that knowledge to create our toolkits, checklists and briefings that we share with members.

I just want to finish by giving a shout out to Anna [Pattison] and Tasha [Thompson]. They are the glue that holds the consultancy team together. It means there’s always someone in the office for clients to talk to. They provide outstanding support, not only to our own team but the organisations as well.

 

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The inspection process at a glance

Timescales
Day zero	The call/email – asking to speak to the CEO about a “regulatory matter”
ASAP (within days)	Meeting to talk through the process, the timings and set up further meetings Confirm meetings to observe – depends on your scheduled dates Request the first batch of information – the context with a week to submit
Weeks 2/3	Submit the first batch of information
Weeks 3/4	Document request list provided – two weeks to submit
Weeks 5/6	Second batch of documents submitted
Weeks 7/8/9	Liaison – follow up queries, sorting out the meeting schedule
Weeks 10/11/12 (approx.)	On site work – meetings with key people, usually over two or three consecutive days, including focus group with residents
Post on site work	Follow-up requests
Approx 10 weeks after on site work	Feedback meeting
Approx two weeks after feedback	Report issued with statements and comms

 

Being inspection-ready

• Get everyone on board with consumer regulation – set the tone and the culture
• Self-assess against the consumer standards and develop an action plan to address any gaps
  • Position statements – eg, for each element of each standard
• Be vigilant – horizon scan:
  • Keep track of inspections, findings and key themes
  • Network with others – including RPs who have been through inspection
  • Check what’s being said about you in the public domain – website, press, social media, HOS determinations. Could anything trigger the call?
• A plan of action – for when you get the call
• Appoint your inspection support team – and team leader
• Documents/evidence base – in a well-referenced folder
  • Start it now and regularly review/refresh – don’t wait for the call
  • Be ready for a final polish
  • An outline of your context document
• Key facts and information – for a shared understanding
• Governance structure – on one sheet of paper
• 15-minute introductory presentation.

 

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Case studies

 

“Strengthening compliance with HQN’s support”

Annette Brandwood, Director of Governance and Assurance, Cobalt Housing

“We’d already lined up support from HQN as part of our commitment to strengthening compliance with the Regulator of Social Housing’s consumer standards – so when we were notified of our inspection, the timing couldn’t have been better.

“HQN came in as a critical friend, helping us take a step back and reflect. They didn’t just review documents – they spent time understanding our services, visited void properties, listened in to customer calls, and explored how we manage complaints, antisocial behaviour, and our homes and communities. Their ‘reality checks’ brought an extra layer of perspective.

“They helped us test whether our evidence really stood up to scrutiny – not just whether it existed, but whether it told the story it needed to. Their findings more or less echoed what the regulator later picked up, which gave us real assurance that we were asking ourselves the right questions.

“What made the biggest impact was the way they helped us open up conversations internally. It wasn’t about a one-off check – it was about building something more lasting. Their involvement gave us a clearer picture of where we’re doing well and where we can sharpen up, with a focus on embedding a stronger, more confident compliance culture.

“Working with HQN helped us move from ‘what do we need to prove?’ to ‘how do we keep doing this better?’”

 

“You have to prepare well”

Katie Finch, Director of Assurance and Business Services, Citizen Housing

“The first thing to say is that inspection is a marathon not a sprint. It’ll be over seven months from the first call we received to when our judgement is public.

“One of our key priorities leading up to our inspection was to prepare through a mock process. We commissioned HQN to carry out as much of the process that the regulator would do, which included document requests, interviews and observations of our boards and committees.

“We submitted up to 100 documents as part of the evidence gathering. The key from our point of view was to highlight any potential gaps, which has helped us to articulate ourselves better when the regulator asked questions.

“Confidence was a big thing – for the board and committee members as well as the engaged tenants. They hadn’t been through an inspection before so to understand the process and what was expected of them was quite valuable.

“You do really have to prepare well. Inspections are fundamentally different to IDAs, particularly with the consumer regulations, which touch on every single part of the organisation.

“It’s also quite demanding – inspections are time demanding and require the right level of resource, but you also have to make sure it’s business as usual, as delivering for customers remains the top priority.

“Damian [Roche] was brilliant. We really valued his support, especially his work on the consumer standards and working with our engaged customers.”

 

“A critical friend”

Darren Knight, Deputy Chief Executive, Warwick District Council

“Progress is the activity of today and the assurance of tomorrow – the key word is assurance; the new regulatory framework for social housing puts the need to demonstrate assurance front and centre.

“Demonstrating effective assurance provides certainty and gives confidence to stakeholders that tenants are being kept safe, and data and insight is driving continuous improvement.

“A key ingredient for achieving certainty is independent advice, check and challenge, which is where HQN are playing a key role in supporting Warwick District Council’s improvement journey through professional advice, being a critical friend and a valuable sounding board.”

 

“The whole thing was tailored to what we needed”

Jess Hyland, Corporate Head of Governance, Lincolnshire Housing Partnership

“We started working with HQN in 2024 after using their consumer standards toolkit to help with our self-assessment. Damian [Roche] initially came in to do a desktop review, followed by a spot reality check where he spoke to colleagues and went out with them on visits.

“On the back of this, HQN made recommendations on how we could improve, which we found really useful. The relationship then continued into preparing for the inspection, advising on the documents we needed to submit to the regulator, providing templates, signposting us to other organisations we could talk to.

“They also helped us to rehearse for the conversations with the regulator, running through the types of questions that might be asked. Damian and Ian [Parker] were so good at playing the role of the regulator and put our executive team and board members through their paces.

“Feedback was provided throughout, letting us know what we were doing well and not so well.

“HQN supported our involved customers through the inspection process. Damian did a presentation to customers to help them understand the process, what to expect and generally helped to improve their confidence.

“All went very much to plan. It was totally different to the in-depth assessments (IDAs), which I had been through before. The regulation team was very friendly and approachable – the conversations were looking for assurance that we were doing what we should be doing. The IDAs always felt like we were under test conditions.

“Dare I say it, but it was a semi-pleasant experience!

“We were very happy with HQN’s support. The whole thing was tailored to what we needed and never felt off the peg. Damian and Ian were so helpful and responsive. If we had any queries, we knew we were going to get a response the same day.

“We thought our gradings from the regulator were fair – G1/V2/C2. We knew when we self-assessed that there were areas that needed improvement. We’ve used all this feedback to create our two-year change programme to achieve C1 – ‘Everyday Better’.”

 

“Instrumental in strengthening our approach”

Jane Martin, Acting Corporate Director of Housing, London Borough of Waltham Forest

“In 2023, we commissioned HQN to support our preparations for the new regulatory regime and to guide our self-assessment against the new consumer standards.

“With HQN’s expert input, we developed a comprehensive Social Housing Regulation Action Plan that addressed the key gaps identified through our self-assessment. A summary of this plan was submitted as a key piece of evidence ahead of our inspection in November 2024.

“The external challenge and scrutiny provided by HQN were instrumental in strengthening our approach to comply with the new consumer standards. Their insights ensured we were inspection-ready and helped us amplify the positive outcomes of our transformation work.”