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Compliance is not enough

By Ian Hembrow
April 2, 2024

Senior Consultant Ian Hembrow assesses the Housing Ombudsman’s updated Complaint Handling Code, plus early learning from a collaborative project about complaints. Just complying with the Code is no longer enough he says – customers have a right to expect more.

From 1 April 2024, registered housing providers have to up their game when it comes to handling customer complaints. The new Complaint Handling Code issued by the Housing Ombudsman Service now has statutory force, and it ratchets up the pressure on organisations to respond properly and positively when things go wrong.


What’s new

The 2024 Code isn’t hugely different to its 2022 predecessor, but there are some important amendments designed to empower both residents and staff to achieve better outcomes and greater satisfaction. Headline changes (enacted as part of the Social Housing [Regulation] Act 2023) include:

  • Common targets and time limits for all providers to respond to both initial complaints and ‘Stage 2’ appeals, or explain why they can’t
  • A requirement for organisations to have someone at board level with specific responsibility for overseeing performance on complaints (the ‘Member Responsible for Complaints’, MRC)
  • New obligations to monitor and report on the numbers, types and outcomes of complaints, and how organisations learn from them.

More interesting (and possibly far-reaching) though are some of the subtler tweaks to the Code’s language and expectations. The foreword proclaims:

‘This Code considers complaints to be more than transactions.’

This is a welcome recognition that when there’s a problem in or around your home, it’s not just a service that’s failed, an inconvenience or the source of discomfort. Difficulties indoors or on the doorstep go to the very heart of what it means to have a decent home. Housing complaints are about people’s lives, and how safe, secure and happy they feel.

There’s another nice change tucked away in the guidance for what happens if a customer isn’t satisfied by their provider’s response to a complaint. It says:

‘Residents must not be required to explain their reasons for requesting a stage 2 consideration. Landlords are expected to make reasonable efforts to understand why a resident remains unhappy as part of its stage 2 response.’

In other words, the onus mustn’t simply fall back on the customer if the organisation comes up with a sub-standard response. There’s an overarching expectation that landlords will be proactive in trying to do the right thing(s) when problems arise.

Launch of the updated Code coincides with strengthened consumer regulation, including new standards for Safety and Quality, Transparency, Influence and Accountability, Neighbourhood and Community Standard, and Tenancy. These will also see a return to regulatory inspections of registered housing providers.

More process than people

The Ombudsman has rightly highlighted the importance of sensitivity and appropriate communication in its wider work (for example, the Spotlight report on Attitudes, respect and rights). But this customer-centric promise doesn’t really follow through into the updated Code. The document’s focus is firmly on process, with little or no reference to how complaints affect people emotionally and psychologically. This in turn downplays the massive and lasting reputational damage that poor complaints handling can cause.

At just over 8,000 words, the new Code is shorter than the 2022 version (9,361 words). But professionals looking for guidance on how to take a more human and holistic view of complaints will be disappointed. Words like ‘people’, ‘feeling’, ‘emotion’, ‘anger’, ‘upset’, ‘frustration’, ‘distress’, ‘empathy’ and ‘compassion’ are nowhere to be found – as if complaints don’t concern individuals (be they customers or staff) at all.

The three big questions that linger after digesting the new Code are:

  1. Whether it’s what customers really need and want
  2.  If following it will boost people’s satisfaction with how complaints are handled, and
  3. How these standards match up to what people experience from other industries and parts of daily life.

Experiments to improve

Complaints Lab logo






Since autumn 2023, Creative Bridge has been working with a group of five housing associations to challenge traditional approaches to complaints and explore some different paths to greater success. This collaboration – the Complaints LAB – has pinpointed the need to aim high, and treat every complaint as a unique and personal situation.

We’ve taken inspiration from a ranking published some years ago in the International Customer Service Survey. It shows what matters most to customers when something goes wrong. From highest importance to lowest, the list is:

  1. Speed
  2. Apology
  3. Treatment
  4. Acknowledgement
  5. Explanation
  6. Assurance
  7. Product or service fixed/replaced
  8. Anger
  9. Money back
  10. Compensation
  11. Revenge

At first sight, it seems counterintuitive that putting the problem right ranks at number seven. But think for a moment about your own reactions to frustrating problems, or do some self-watching next time you experience below-par service. The clear message is that fixing things alone doesn’t make people content – it’s how providers communicate, engage and make them feel that matters. This ranking also counters the oft-expressed belief that residents complain simply to get compensation.

The Complaints LAB has encouraged its members to be creative and ambitious – responding not just transactionally to resolve complaints, but actively rebuilding trust, relationships and reputation through the way they do it. In the workshops we ran with staff and customers, it was clear that most people don’t want to complain or be seen as someone who does. They just want things to go well, with quick, friendly and respectful action when they don’t.

The first five Complaints LAB members are busy trialling different aspects of this approach, with particular emphasis on the tone of how they communicate. We’ve also encouraged organisations to apply some simple behavioural psychology – working with the grain of human instinct rather than against it.

By definition, when something goes wrong, it’s gone off script. So complaints are the worst possible place for turgid, standardised templates full of generic platitudes. Yet too often this is what people receive. A customer who’s taken the time and trouble to complain deserves a response that’s completely bespoke to them, their circumstances and the situation.

Don’t just comply, do better

Housing providers don’t have a choice about following the new Complaint Handling Code, they have to comply. But that doesn’t mean it’s all they should do. And there’s no law or rule against doing better. On its own, compliance risks trapping organisations in dull, process-heavy methods that evidently don’t work for many customers. We’ll be pursuing this theme when the next Complaints LAB cohort begins in the summer.

Alongside the 2024 Code, the Housing Ombudsman has opened a new, online Centre for Learning and Landlord Learning Hub. As lessons from the Complaints LAB trials emerge, we’ll submit these as evidence of what works.

We hope there will be plenty of other reports and best practice advice from the brighter and braver world that exists beyond compliance.

Complaints Lab logo

To join or find out more about the next Complaints LAB group, please contact or 07912 273010.

Ian Hembrow FCIH is the housing, engagement and copywriting lead at Creative Bridge.