What does a consumer standards inspection actually look like?

Welcome and introductions

Sarah Wilson: Welcome, everyone—this is the Inside a Consumer Standards Inspection webinar. I'll be your host for the next 50 to 55 minutes. Looking at the attendee list yesterday, it's roughly a 50/50 split between people who have already had their inspection and people who are still waiting for theirs, which tells you this is genuinely an ongoing piece of work that never really ends.

Here's how the next hour looks. I'll kick us off with a quick welcome, then hand to Steve, who'll show what a good judgment—and a good inspection—actually looks like, based on the evidence we've pulled together, so you're not treading completely new ground yourself. Then Andrew will walk us through his own inspection: what went well, what didn't, and what he'd tell you to do differently. After that we'll cover what to do next, including a small offer we have for you, and then we'll go into questions.

A bit of housekeeping: we're recording, so you'll get the full recording, the slides, and a follow-up afterwards. Do get your questions into the chat as we go—this webinar actually came about because of the questions people asked after our last one, about what an inspection really looks like day to day. We'll pick out as many as we can live, and we promise to answer anything we don't get to in the follow-up.

Sarah Wilson: Quick introductions. I'm Sarah Wilson—I spend my days speaking to housing associations and local authorities, gathering the questions you want answered, and that's the role I'm playing today. Steve Erdal is back with us again—he's our head of insight and innovation at Wordnerds, which means he does all the genuinely clever analytical work that I then get to report on. And I'm delighted to have Andrew Bryant joining us. Steve and I speak to housing associations all the time, but neither of us has actually been through a regulator inspection ourselves—Andrew has, and he's been really open with us about what that involved, the practical tips that came out of it, and what he'd do differently.

Who are we? We're Wordnerds—we specialise in the analysis of text. One thing I found interesting: yesterday a housing association asked me how many of our customers hold a C1 grade, and the answer is a disproportionate 70%. I don't think that's because we've somehow helped them get there—I think it's more that people who really invest in the power of text, and see the value in the comments behind the scores, tend to be the ones rewarded with a C1. Everything we're talking about today is a learning from our actual customers, not something we've invented ourselves.

Why listening is hard right now

Sarah Wilson: Nobody works in housing because they love filling in evidence logs—you come to this job because you want to do right by your tenants. That should mean an inspection is straightforward: you've been doing the work, so you should be able to show it. But it's genuinely hard, and I think the hardest reason is that the people doing the day-to-day work—reading the reports, reading the tenant comments—usually aren't the people sitting in front of the regulator. We had one housing association tell us their director was asked 52 questions about the consumer standards in one sitting, and of course they hadn't been in the room for any of the underlying work. That's an enormous overwhelm for someone who doesn't do this day in, day out, and the work never really stops—it's a constant cycle of keeping information current and getting it in front of the right people across the organisation.

So what actually works? There are four steps, and you have to go the full distance on all of them. You start with hearing—surveys, panels, social listening. You're already doing that, and most people record it well: it's logged, categorised, filed, and the archive just keeps growing. We never meet anyone who says they don't have enough data—that's genuinely not the problem. The problem comes further along, in the act-and-improve part. That means deciding what to actually act on and where to put your effort, and then—critically—closing the loop: once you've made a change, can you evidence that it worked? Can you show you took tenants' feedback into account and used it to shape the service? That last part is not an easy job, which is exactly what Steve is going to walk us through next.

What 228 regulator judgments reveal

Steve Erdal: Thank you, Sarah. What I want to do now is take you through what, based on the sources we have, actually seems to separate a C1 landlord from a C2, a C2 from a C3, and so on—what the regulator appears to actually be looking for in practice.

First, one thing it clearly doesn't seem to be: awarding a grade based purely on the statistics a landlord provides. Sarah's already mentioned what we call the Wolverhampton paradox. Wolverhampton reported phenomenally positive statistics—95.4% of repairs completed on time, 98.9% of complaints responded to within the timescale set by the ombudsman—figures any housing association would be proud of, and they received a C2. BCP, by contrast, reported a much lower 82% of repairs completed on time, and received a C1. Whatever is happening here, it isn't simply about the operational data a landlord can provide—that alone isn't enough to get a landlord to a C1.

Steve Erdal: So what is it looking for, if not that? To answer that, my team looked at two sources. First, what the regulator has told us directly in its own judgments: we're a good way through the process now, which started in April 2024, and to date the regulator has published 228 consumer judgments—closing in on half a million words explaining why each landlord received the grade it did. We looked at all 228. Second, we had an advantage: regular attendees of our webinars will know about the work we've done with Housemark and a group of 18 volunteer housing associations, who gave us the free-text comments that came with their TSM surveys. We categorised and analysed those, which let us look at the C grade each of those associations eventually received and start to see the patterns behind the C1s, C2s and C3s in that data set.

I do have to warn you—I'm a recovering linguist, so the next couple of slides get a little nerdy. The first thing we looked at was the different language used across the different grade groups. Very little of that language was actually about the topics being discussed, which is fairly standard across all of them. What's subtly and interestingly different are the small words—specifically, the pronouns.

We noticed that in C1 judgments, the regulator is far more likely to be talking about what the landlord identified—things the landlord explained to the regulator itself, even where the underlying issue was difficult. Lower-graded housing associations were much more likely to have judgments dominated by discussion of what the regulator identified—the regulator saying, in effect, we noticed this thing that the landlord didn't. There's a real, clean slope in that pattern running from the C1s at the top all the way down to the C4s.

One of the key things to take from that: you are not being graded on whether or not you have problems. Everyone has problems, and it's also not simply about the sheer number of them. What you're often graded on is whether you found them and presented them to the regulator, or whether the regulator found them and effectively handed them back to you. There's almost a race running underneath all of this—the regulator does a great deal of desk research and due diligence before your inspection even starts, so the question becomes whether you can present your own issues to the regulator, or whether you end up being asked about issues the regulator's own research turned up first.

Steve Erdal: The second thing we looked at in those judgments was which words were overrepresented in C1 grades specifically—used by the regulator much more often in C1 judgments than in any other grade. The word that came out clearly on top, used almost twice as often in C1 judgments as in C3 judgments, is "evidence"—as in, a landlord provided evidence that a situation existed, and evidence of what it was doing to address it. It's not necessarily about having a perfect plan, or something that solves every issue you have. It's about showing evidence that you are moving in the right direction—and the crucial word there is evidence: what are you doing to mitigate the challenges your customers are having, and what can you show for it?

Those are the two clearest, most consistent patterns running through the C1s, C2s and C3s, and I think they both map neatly onto the framework Sarah showed you at the start: are you able to find your own issues, and do you have evidence of what you're doing about them next?

Steve Erdal: We also looked at that TSM benchmarking group I mentioned. What's exciting about it for housing associations is that the answers to the question of your likely grade already exist in data you already hold—your TSM surveys, your complaints. If you can categorise that data effectively, it does a lot of the work we've just described: it helps you understand the issues that are likely to surface in an inspection, it gives you the ability to be the one presenting those challenges rather than having them found for you, and it helps you understand more about your customers and their vulnerabilities. That information already exists in the data you have.

What was genuinely interesting about the data from those 18 housing associations is that we could not only see differences between the C1s, C2s and C3s, but present a housing association's own TSM data against that framework and start to understand the relative likelihood of different grades, based on things like attitudes to mental health coming up in the comments, the approach to different communication channels, and—crucially—customers complaining about not being listened to. That moved us from reflective analysis to genuinely predictive analysis.

The thing I'd leave you with is that you already have the information you need. It's very easy to worry about the data you haven't got—nobody has perfect data, and there's always more you can do to reach a wider range of customers—but in the comments and the regular communication you already have with your customers, the information is there to find the issues they're raising and start building a plan to mitigate them. You're in a race the moment you get that inspection notice, to present your own issues to the regulator rather than have it be the other way round, and to get that information out to as wide a range of people in your organisation as possible. Do that, and you'll likely find your inspection goes better than you expected—and, more importantly, that you're in a better position to actually make your customers' lives better, which is what we're all here for.

Andrew Bryant: Wolverhampton's inspection story

Andrew Bryant: Thank you, Sarah and Steve. Just to be clear up front, I'm by no means suggesting I'm an expert on everything to do with Regulator of Social Housing inspections—this is largely about our own experience in Wolverhampton. That experience was broadly positive; it felt co-regulatory. We had a lot of engagement with the regulator before, during and after the process, and we continue to engage with them now, because anyone who receives anything other than a C1 has a protracted period of engagement following their judgment.

A bit of background on Wolverhampton. We're a relatively large stock-owning authority—we own just over 21,000 council properties in the city, but we don't directly manage any of them. Like a lot of councils, 20 to 25 years ago we set up an arms-length management organisation, Wolverhampton Homes, to deliver the Decent Homes programme; it manages 19,000 of those properties, with three small tenant management organisations managing around 10% of the stock between them. So we have no direct involvement in day-to-day service delivery, but strategic oversight and clienting of those organisations. As the responsible body, it's us the regulator engages with and issues a judgment on, regardless of who delivers the service on the ground.

The lead-up to the Social Housing Act was a seismic shift for us, because we hadn't directly managed housing services for over 20 years. Our preparation really started back in 2019, following the social housing green paper and then the white paper, and from around 2021 we began getting external views on our ability to meet the expectations of the consumer standards. Things really ramped up in 2023 and 2024: we restructured the team, and I built a landlord services team within the council with officers dedicated to compliance, assurance, performance, inspection and improvement—horizon-scanning our performance against other councils and housing associations, and periodically bringing in external advice on where we stood. We were trying to be as self-aware as possible about what we did well and where we genuinely needed to improve—and, as Steve said earlier, trying to be the ones finding things rather than having things found for us.

Andrew Bryant: We self-referred to the regulator in June 2025, after talking about it internally for a significant period beforehand. With hindsight, I think our instinct on that was right. For anyone who works in a council, you'll know that officers lead the work, but we then rely on escalating our concerns and getting senior leadership—people not necessarily close to housing day to day—on board with it. The regulator genuinely wants self-referral and encourages you to come forward if you find problems, because it's a co-regulatory approach. We took external advice on our self-assessment, gained political buy-in, and self-referred around four key areas, two of which were more concerning than the others.

The first was our stock condition programme, which began in early 2023 and wasn't progressing as expected—at the point of self-referral we had only 22% in-person stock condition assessments across our roughly 21,000 properties. We had plenty of information from other sources, so we felt we understood the general condition of our stock, but we didn't have that in-person assessment of every property, and we still don't today. The second was a dip in fire risk assessment performance, caused by some ambiguity around the Building Safety Act's requirements for duplex-style properties with no communal areas—we'd fallen behind there and had already flagged it with the regulator. Less materially, we felt we could demonstrate good tenant engagement, influence and transparency, but weren't good at evidencing the outcomes of that engagement. And, like a lot of large organisations, we had concerns about data quality and assurance, still relying on manual data collection in places rather than being as technologically savvy as we wanted to be. We raised all four issues in the self-referral.

We'll never know for certain whether the self-referral itself triggered the inspection or whether we were already on the programme, but a brief period of regulatory engagement followed, and on 4 August 2025—the day I got back from leave along with the Deputy Director of Housing and our Executive Director—we got the call. The very next day, 5 August, we had a roughly hour-long meeting with the regulator, our chief executive and myself, giving a brief overview of the inspection process, the timeframe, when they intended to be on site, and what we needed to start providing immediately. A formal letter followed confirming we were now subject to an inspection—the moment you get that call, you're effectively already being inspected. We then had seven days to provide context information about council housing services in our city.

Andrew Bryant: We'd actually started building an evidence base around 12 months before that call—looking at board papers, cabinet reports, anything that would demonstrate we met the expectations of the consumer standards, because unlike housing associations, councils don't typically publish much at all about their housing services. So we put together a context document: welcome to Wolverhampton, the challenges the city faces, how many properties we own, who our tenants are, who manages the stock, the housing revenue account pressures, new build and regeneration. A lot of our stock is genuinely old—some of it built over a hundred years ago, right after council housing itself began—alongside newer builds, so we have a complex, non-traditional, ageing stock profile, and all of that went into the context document, along with our management agreements and tenant profile data.

We were told a scoping framework would follow imminently, but it didn't actually arrive until 1 September—so there was a gap where we were somewhat in limbo, not entirely sure what they were asking for yet. What the scoping framework asks for—and, just as tellingly, what it doesn't ask for—says a lot. For us, as a council, safety and quality, and transparency, influence and accountability, were clearly going to be the focus; they asked for comparatively little evidence on the tenancy standard. We had 14 days to complete the scoping framework, and submitted 118 documents through NROSH initially—with a similar number submitted during and after the inspection, so in the region of 200 pieces of evidence in total, which is genuinely resource-intensive to index and get right.

In the run-up to the on-site days, the regulator also silently observed several meetings—our ALMO board, our scrutiny board, and a couple of tenant group meetings, including our in-house tenants group and the ALMO's customer involvement panel. They were then on site for two days, 15 and 16 October: a kickoff meeting with the chief executive, the council leader, cabinet members, the deputy leader, the portfolio holder for housing, and senior leadership of both the council and the ALMO, followed by four consumer-standard focus groups, a tenants' meeting, and initial feedback at the end. You could tell from the agenda they sent ahead of time roughly how the two days would be weighted—several hours on safety and quality and on transparency, influence and accountability, against about an hour each on the tenancy standard and on neighbourhood and community standards—so we knew where the real focus would land before we even walked in.

Andrew Bryant: One thing I'd say to anyone who hasn't been through this yet: we did a lot of work briefing leadership beforehand. A council chief executive is responsible for everything the council does—adult and children's social care, education, the lot—so there's an expectation they'll have a grasp of the strategic vision for housing, how tenants feel about services, and what needs to improve. We put a lot of effort into briefing senior leadership, the cabinet member and the council leader ahead of the on-site engagement, because what the regulator is really gauging when they speak to your strategic leadership and politicians is whether what they say matches what operational staff are actually doing and delivering—whether there's symmetry between the two.

If you're part of that interview process, and you don't know the answer to something, don't try to talk around it or go off on a tangent—tell the inspection team you don't know but will go away and check. We had a lot of people based here at the Civic Centre throughout, tracking actions and questions as we went through each workshop so we could debrief and identify what we'd missed or what additional information was being asked for. The regulator was completely comfortable with us not knowing everything on the spot, but your leadership does need to know most things—if they can't answer, or don't understand where you're at, that's genuinely problematic.

By 18 December 2025 we were told we'd be graded C2—weaknesses in delivering the consumer standards, requiring improvement. Back in January 2025 we'd honestly thought we might be looking at a C3, given the stock condition and fire risk assessment issues, and while it isn't a universally shared view across the council, colleagues in my team believe the self-referral is what got us to a C2 rather than a C3, because we'd already identified those issues ourselves. We then had to wait until 28 January 2026 before that judgment could be made public—over five weeks of embargo, which is genuinely difficult to manage internally, especially once it became tangled up with our HRA business plan going to Cabinet on the same day, and the political opposition making the most of it, as they often do.

Andrew Bryant: We met the inspection team again last week—we're now part of what they call the provider improvement process. They've told us directly, and I'll quote this: "standing at C2 is not acceptable," and the improvements have to be addressed across all our areas of weakness, quickly, given how narrow that area of weakness actually is for us. Our priorities include getting to a much fuller understanding of our stock condition—we're currently just south of 60% in-person assessments against a route map to 100% by March 2027—better tenant profile data, which came as a bit of a surprise to us, stronger governance, oversight and assurance frameworks, better data quality and validation, more meaningful tenant engagement and influence, and clearer accountability and evidence of compliance. None of that was hugely surprising to us; we knew where our gaps were.

They want us to show a clear understanding across the organisation of why we got a C2 and the root causes behind it, to address those causes sooner rather than later to reduce any risk to tenants, and to publish an improvement strategy with an action plan—something we probably should have done already. Engagement with the regulator continues until every weakness is addressed, there's an expectation we'll eventually request a regrade, and—genuinely news to me only last week—if we don't make timely progress, we can be downgraded further rather than simply left at C2.

Andrew Bryant: To wrap up: get a clear commitment across leadership and teams to the improvements required, promote a genuine no-surprises culture so bad news travels up the chain as readily as good news, and be realistic—don't over-promise. Our stock condition route map says we'll hit 100% by March 2027, and the regulator asks us regularly whether we're on track. You need to identify capacity and resourcing issues honestly; regulatory compliance is only one part of my role, alongside running the service day to day. And keep sight of where you are making progress and what tenants are actually telling you—because if inspection doesn't ultimately produce a better outcome for tenants, it's just box-ticking.

What's next: the provider improvement process

Sarah Wilson: That was a genuinely fascinating story, and I think the no-surprises point is one I'll take away myself. What Andrew, Steve and everyone's contributions show is that this is very much a standing job—it doesn't end, it's not a one-off piece of work, it's a moment in time, and the audit trail is really a set of daily behaviours you build into the organisation.

To recap: the answers are already in your data. You don't need to collect more of it—pay attention to the text and comments you already have and prioritise them in the organisation. Pulling that together is a genuinely big job: lots of different sources, formats and legacy systems, and it has to hold up not just today but next quarter and next year. If that sounds like where you're at, we do this work for other providers too. We're offering an improvement plan—Steve and the team taking the sources you already have and giving you a structured, categorised analysis, similar to the work Steve described on the regulator judgments, but specific to you: what to do next, where your problems are, root-cause analysis, and then how to evidence the changes and their impact. If that's of interest, register and we'll set up a conversation.

Q&A

Sarah Wilson: First question, probably for you, Steve: what are your recommendations for the best way to share evidence and track progress? We get asked this a lot—should it be an action tracker, a BI dashboard, a login, a written report?

Steve Erdal: It needs to be a mixture, and the key question is: do the right people have the right information? If you have a data-savvy team, BI dashboards are great—they let people interrogate the data and follow their own curiosity. For other groups you need more of a written report, and increasingly people are also using chatbots to interrogate the data directly, which is great, but it can lead to different people reaching different conclusions from the same underlying data if it isn't structured consistently—so structuring that data well becomes the insight team's job, to make sure everyone is working from something reliable.

The key is tailoring the information to the audience—the people actually doing the improvement work need something different from the people with oversight of the whole process, and tenants themselves need something different again. And every action needs a named owner with a date and a checkpoint for when it's done; the best organisations we see do that really consistently.

Sarah Wilson: And one for you, Andrew—what does it look like now with the regulator? How often are you meeting, and what's the engagement like?

Andrew Bryant: About six weeks after the regulatory judgment, so around early-to-mid March, we had our first provider improvement meeting, and initially we were meeting roughly every six weeks. We met in July, had a break over the summer, and met again last week in September—so around two months without a meeting that time—though there's a standing expectation that any changes get uploaded to NROSH and the regulator notified in between. There was also a meeting with our chief executive and cabinet member for housing in October, originally framed as a midpoint review, though that framing assumed we'd be halfway through all the required improvements—which the regulator has since made clear isn't quite how it works. The provider improvement process will run for as long as it takes to make the improvements, not to a fixed timetable, and it needs to be complete before we'd be back in line to be inspected again. But as I said at the start, it does feel genuinely co-regulatory and open—no stone is left unturned, and the people leading our inspection are experienced housing professionals asking exactly the level of question you'd expect them to.

Sarah Wilson: Thank you both so much—Steve for the analysis, and Andrew for being so open about your experience. We'll be following along to see where you go next. Stay tuned for the next webinar; we're back on that monthly track again. You'll get an email from us with the recording later today. Thanks so much, everyone.