Making the Competence and Conduct Standard work for us: our advice for smaller housing associations

Christina Friedenthal, 29 June 2026

In this blog, Christina Friedenthal, Corporate Services Director at CDS, explains how they’re implementing the Competence and Conduct Standard as a smaller housing association. 

When the Competence and Conduct Standard was first introduced, my initial reaction was probably the same as many others working for smaller housing associations. It felt like another requirement to absorb and a risk that we would end up creating processes that added more burden than value.

My initial reaction was to figure out how we could comply as quickly and easily as possible, but after spending just a little time getting to understand the standard, I changed my focus to how we could comply in a way that was proportionate to our size and would actually improve how we operate.

What did we do first?

Our first step was a basic gap analysis against the Regulator’s expectations. This showed that we already had strong foundations in place, including policies covering training and development, capability and disciplinary processes, regular appraisals and one-to-ones, and written role profiles.

Fortunately, the analysis determined we just needed to add clarity to the foundations we already had in place, including refining some parts of our existing policies. The one big gap we found, though, was that – whilst we talked about competence regularly – we had never clearly defined what competence looked like for each role.

What challenges did we encounter?

We had long known that we had several challenges in the business, but it wasn’t until carrying out this exercise that we realised they all stemmed from not having written competence expectations. These challenges included performance expectations not always being explicit, assessments of competence could be subjective and managers did not always have a consistent framework to support performance conversations. This made it harder than it should have been to evidence decisions about competence clearly and fairly.

To resolve this problem and improve compliance with the standard, we developed a competence framework made up of role-based standards, team-level competence maps and an organisation-wide competence architecture that shows how expectations scale from front-line delivery through to strategic leadership. For each role, we set out the knowledge, skills, experience and behaviours required, along with how competence is maintained and assessed.

We ensured the format of each document was consistent, with the same core themes run through every role, but with different expectations depending on responsibility. Doing this created a golden thread that runs between operational work and organisational strategy.

What has the impact been?

One of the most immediate benefits has been how this supports decision-making. Shortly after we introduced the framework, a manager and a director were working together on a change within a service area. They had different views on the best approach, and there was some uncertainty about who should make the final call.

By referring to the competence framework, it became clear that directors are responsible for cross-organisational strategy, whilst managers are responsible for functional strategy. In this case, the responsibility sat with the manager. That clarity meant the issue could be resolved quickly, without unnecessarily escalating it. I have since seen several similar situations where having clearly defined responsibilities has made a real difference.

I knew creating the competence framework would help us meet the requirements of the standard, but I had not anticipated quite how directly it would improve our corporate governance. Conversations about performance are now more grounded, accountability is clearer, and we have a more consistent approach across the business.

How did we introduce the framework with our staff?

We were conscious that new processes could easily feel imposed and burdensome if not handled carefully. To avoid that, we introduced the framework through an all-staff session and involved teams in refining their own competence standards whilst keeping them based on the existing role profiles. We also linked the competence standard for each staff member to their annual objectives and one-to-one meetings. Staff were broadly supportive of the creation of the framework but embedding it properly does take ongoing effort. We are continuing to reinforce its use through appraisals and one-to-one meetings, and we are doing some light-touch checking in on how it is being applied in practice.

Our advice for other smaller housing associations

For other smaller housing associations, my advice would be to start with what you already have and don’t panic about the additional regulation. If you have role profiles and basic people management processes in place, you are starting from a stronger position than you might think. The real value comes from making expectations explicit and ensuring they can be evidenced, rather than introducing entirely new systems.

Implementing the Competence and Conduct Standard does not have to be a burdensome exercise. Approached in a proportionate way, it can become a practical tool that supports better decision-making, clearer accountability and more consistent performance management. That has certainly been the case for us, and it is work that is already making a noticeable difference to how we run the organisation.