NRSA Compliance Guide
Non-Regulated Supported Accommodation
What supported exempt accommodation providers need to know: what is law today, what the draft 2027 licensing regulations propose, and how to get ready.
Updated 22 October 2026. Licensing is not in force yet. The government consultation on the draft regulations runs from 15 October to 10 December 2026.
Written by Sheref Ergun, Founder of MyCareAudit • 20+ years in health & social care compliance
Update 22 October 2026: draft regulations are out for consultation until 10 December 2026. These are proposals, not law. Supported housing licensing is not in force yet. Read the consultation on GOV.UK
1. What Is Non-Regulated Supported Accommodation?
Non-regulated supported accommodation (NRSA) — also known as supported exempt accommodation — provides housing with support for adults who are vulnerable but do not require the level of care that would bring them under CQC or Ofsted regulation. This includes:
- Supported housing for single homeless adults — accommodation with tenancy support, life skills coaching, and resettlement services
- Mental health supported accommodation — housing with wrap-around support for adults with mental health conditions
- Substance misuse recovery housing — structured environments supporting recovery with keyworker access
- Ex-offender accommodation — housing with support for people leaving the criminal justice system
- Domestic abuse refuges and move-on accommodation — safe housing with specialist support services
Key point: Unlike CQC-regulated care homes or Ofsted-registered children's services, NRSA providers are not currently subject to a statutory regulator. "NRSA" describes the type of service; it is not a regulator or an inspection body. The Supported Housing (Regulatory Oversight) Act 2023 gives the government power to bring in licensing, and draft regulations for a nationwide scheme are out for consultation until 10 December 2026. Licensing is not in force yet.
2. Who It Applies To: Law Today vs Proposed
Law today (October 2026)
- • Supported Housing (Regulatory Oversight) Act 2023 is law, but licensing is not in force.
- • Housing Benefit specified/exempt accommodation rules apply as now.
- • HMO licensing and HHSRS apply as now.
- • Personal care needs CQC registration.
- • Supported accommodation for 16–17 year olds needs Ofsted registration.
Proposed (draft 2027 regulations)
- • Nationwide licensing in every local housing authority area.
- • One licence per council district, listing every address, lasting 5 years.
- • Fit and proper person test, including directors.
- • Licence condition to meet the six draft National Supported Housing Standards.
- • Housing Benefit linked to licensing.
You should be working towards NRSA compliance if you provide any of the following:
Supported Exempt Accommodation
Housing where residents receive care, support, or supervision and claim enhanced housing benefit. Must demonstrate genuine support delivery.
Supported Housing for Vulnerable Adults
Accommodation for homeless adults, care leavers (18+), people with learning disabilities, or those with complex needs requiring housing-related support.
Recovery & Rehabilitation Housing
Structured accommodation supporting recovery from substance misuse, mental health conditions, or offending behaviour with keyworker support.
Short-Stay & Move-On Accommodation
Temporary housing with support to help residents develop independent living skills and move on to settled accommodation.
Important: Under the draft regulations, once your council's scheme is running and the 3-month transition ends, operating supported housing without a licence (or an exemption notice) would be an offence, and the government intends to link Housing Benefit to licensing. These are proposals until the regulations are made.
3. Who Regulates What
Non-regulated supported accommodation is guided by several overlapping frameworks. Understanding these is essential for compliance:
Supported Housing (Regulatory Oversight) Act 2023
The Act gives the government power to set National Supported Housing Standards and to require local housing authorities to license supported housing. It is law, but licensing is not in force yet. Draft Supported Housing (Licensing) (England) Regulations 2027 are out for consultation from 15 October to 10 December 2026.
Local housing authorities (councils)
Today councils oversee supported housing through Housing Benefit decisions, HMO licensing and HHSRS enforcement. Under the draft regulations every council would become the licensing authority for its district, set local fees, issue improvement notices and penalties, and keep a public register.
CQC and Ofsted
CQC regulates personal care (under the draft regulations, personal care may only be delivered by a CQC-registered provider). Ofsted regulates supported accommodation for 16–17 year olds. Neither regulates adult non-regulated supported accommodation, and there is no "NRSA inspection".
Local quality schemes (for example SEAQAS in Birmingham)
Some councils use local, voluntary quality schemes. Birmingham’s Supported Exempt Accommodation Quality Assurance Standards (SEAQAS, sometimes written SEAQS) were developed with Birmingham Voluntary Service Council (BVSC) and Birmingham City Council. They are local and voluntary: not a national, statutory or mandatory framework. Check whether your council uses a local scheme alongside the national proposals.
LGA Supported Housing Guidance
The Local Government Association provides guidance to local authorities on oversight, commissioning, and quality assurance of supported housing. This includes recommendations on property standards, support quality, and financial accountability.
RSH Consumer Standards
The Regulator of Social Housing sets consumer standards that apply to registered providers. While not all NRSA providers are registered with the RSH, the consumer standards (safety, quality, neighbourhood, transparency, engagement, and tenancy) represent good practice for all housing providers.
4. MyCareAudit's 16-Domain NRSA Audit
MyCareAudit's own NRSA master audit organises good practice into 16 domains across three pillars: Organisation & Workforce, Housing & Property, and Support & Safeguarding, with 186 questions. It is our structure, not an official framework, and it is mapped to the six draft National Supported Housing Standards (local voluntary schemes such as Birmingham's SEAQAS can be cross-referenced).
1. Governance & Strategic Management
Organisational leadership, legal compliance, registered provider status, strategic planning, and oversight arrangements. Covers company structure, governance framework, insurance, and regulatory awareness.
- Appropriate legal entity with named licence holder, service manager and nominated individual (proposed licensing roles)
- Clear governance structure with named responsible persons
- Strategic plan demonstrating organisational vision
- Adequate insurance cover (public liability, employer liability, professional indemnity)
- Awareness of and compliance with housing and support legislation
- Regular board / senior management oversight of service quality
1.1. Staff Recruitment & Vetting
Safer recruitment practices including DBS checks, references, right to work verification, interview processes, and pre-employment checks.
- DBS checks at appropriate levels for all staff
- At least two written references obtained before start date
- Right to work documentation verified and retained
- Structured interview process with values-based questions
- Employment history gaps explored and documented
- Recruitment policy reviewed annually
1.2. Staff Policies & Procedures
Written policies covering employment, conduct, disciplinary processes, grievance, whistleblowing, and professional boundaries.
- Employee handbook or policy pack accessible to all staff
- Code of conduct setting professional expectations
- Disciplinary and grievance procedures in place
- Whistleblowing policy with named external contacts
- Professional boundaries policy for staff-resident relationships
- Policies reviewed on a scheduled cycle (at least annually)
1.3. Staff Training & Development
Induction programmes, core training, ongoing professional development, supervision, and competency assessment for all staff.
- Structured induction programme for new starters
- Core training matrix covering safeguarding, anti-social behaviour (draft NSHS), fire safety, first aid, and health & safety
- Specialist training relevant to client group (mental health, substance misuse, etc.)
- Regular supervision (at least monthly) with written records
- Annual appraisal linked to personal development plans
- Training records maintained and up to date
1.4-1.5. Staff Engagement & Wellbeing
Staff consultation, team meetings, wellbeing support, workload management, and creating a positive working culture.
- Regular team meetings with documented minutes and actions
- Staff survey or feedback mechanism in place
- Employee assistance programme or wellbeing support
- Manageable workloads with appropriate staffing ratios
- Recognition and reward processes
- Exit interview process to capture learning
2.1. Housing Management
Tenancy and licence management, allocations, voids, rent collection, housing benefit liaison, arrears management, and tenancy sustainment.
- Clear tenancy or licence agreements for all residents
- Transparent allocation and referral process
- Void management and turnaround procedures
- Rent collection and arrears management policy
- Housing benefit claims supported and monitored
- Tenancy sustainment support for residents at risk
2.2. Property Standards & Safety
Property condition, repairs, fire safety, gas and electrical safety, legionella risk, adaptations, and compliance with the Decent Homes Standard.
- Fire risk assessment current with annual review
- Gas safety certificates renewed annually
- Electrical installation condition report (EICR) within 5 years
- Legionella risk assessment in place
- Responsive repairs process with target timescales
- Properties meeting Decent Homes Standard or equivalent
- Energy Performance Certificates (EPCs) in place
2.3. Data Protection & Confidentiality
GDPR compliance, data processing agreements, information sharing protocols, subject access requests, and records management.
- ICO registration and Data Protection Officer appointed
- Privacy notices provided to residents and staff
- Data processing agreements with third-party processors
- Information sharing protocols with partner agencies
- Subject access request procedure in place
- Secure storage of personal data (physical and digital)
- Data breach reporting procedure
2.4. Quality Assurance & Continuous Improvement
Self-assessment, internal auditing, KPI monitoring, complaints analysis, outcome measurement, and continuous improvement planning.
- Annual self-assessment against the draft National Supported Housing Standards (and any local scheme your council uses)
- Internal audit schedule covering all service areas
- Key performance indicators tracked and reported
- Complaints analysis driving service improvements
- Resident satisfaction surveys conducted regularly
- Service improvement plan with measurable actions and timescales
3.1-3.2. Person-Centred Support Planning
Needs and risk assessment, individual support planning, outcome-focused interventions, review processes, and promoting independence.
- Comprehensive needs assessment completed at referral/move-in
- Individual support plan co-produced with the resident
- SMART objectives linked to independence outcomes
- Regular reviews (at least quarterly) with resident involvement
- Risk assessments proportionate and regularly updated
- Move-on planning embedded from day one
3.3. Multi-Agency Working
Partnerships with local authorities, health services, probation, substance misuse, mental health, and community organisations to deliver holistic support.
- Active partnerships with local authority commissioning and housing teams
- Referral pathways to health services (GP, mental health, substance misuse)
- Engagement with multi-agency safeguarding arrangements
- Links to education, training, and employment providers
- Information sharing agreements with key partner agencies
- Regular multi-agency reviews for complex cases
3.4. Safeguarding & Risk Management
Safeguarding adults policy, risk assessment, incident reporting, exploitation awareness, modern slavery, and Prevent duty.
- Safeguarding policy aligned with local authority procedures
- All staff trained in safeguarding adults (Level 1 minimum)
- DBS checks at appropriate levels
- Incident recording and reporting procedures
- Exploitation awareness (county lines, cuckooing, modern slavery)
- Prevent duty awareness and training
- Referral pathways to MASH / safeguarding teams
3.5. Complaints & Advocacy
Accessible complaints procedure, advocacy access, feedback mechanisms, and learning from complaints to improve services.
- Written complaints procedure accessible to all residents
- Procedure available in easy-read or alternative formats
- Residents know how to make a complaint
- Independent advocacy signposted and available
- Complaints log maintained with outcomes and learning
- Regular analysis of complaints driving service improvements
3.6. Resident Engagement & Participation
Resident involvement in service design, house meetings, satisfaction surveys, co-production, and community engagement.
- Regular house meetings or resident forums
- Satisfaction surveys conducted at least annually
- Residents involved in policy review and service design
- Community engagement activities supported
- Feedback acted upon with visible outcomes communicated back
- Peer support and mentoring opportunities
FT. Financial Transparency & Housing Benefit
Service charge transparency, housing benefit eligibility, exempt accommodation criteria, value for money, and financial accountability.
- Transparent breakdown of rent and service charges
- Service charges linked to actual services delivered
- Housing benefit claims meet exempt accommodation criteria
- Evidence of care, support, or supervision justifying exempt status
- Financial procedures demonstrating value for money
- Annual accounts or financial statements available
LR. Licensing Readiness (draft 2027 regulations)
Preparation for the proposed licensing scheme under the Supported Housing (Regulatory Oversight) Act 2023: licence roles, fit and proper person tests, the draft National Supported Housing Standards and council oversight.
- Understanding of the draft Supported Housing (Licensing) (England) Regulations 2027
- Licence holder, service manager, nominated individual and directors ready for the fit and proper person test
- Statement of purpose and needs assessments (at move-in or within 4 weeks) in place
- Evidence of working towards the six draft National Supported Housing Standards
- Address list per council district and exemption check completed
- Plans in place to address gaps before your council opens applications
5. The Draft Licensing Scheme (2027)
On 15 October 2026 the government published draft Supported Housing (Licensing) (England) Regulations 2027 under the 2023 Act. The consultation closes on 10 December 2026. Read and respond on GOV.UK. Everything below is proposed and could change.
Nationwide scheme and timeline
Every local housing authority would be designated as a licensing district. Councils would have about 6 months to prepare, followed by a 3-month transition. After that, operating supported housing without a licence or exemption notice would be an offence.
One licence per district
A provider would hold one licence per council district listing every address. Licences would last 5 years. Application and annual fees would be set locally on a cost-recovery basis and are expected to be recoverable through service charges.
Named roles and fit and proper person test
Each licence names a licence holder, a service manager and, for organisations, a nominated individual. The fit and proper person test covers these people and company directors.
Six draft National Supported Housing Standards
Meeting the standards would be a licence condition: (1) Person-centred, (2) Empowerment, (3) Environment, (4) Staff and Safeguarding, including anti-social behaviour training, (5) Local Need, (6) Statement of Purpose. A needs assessment is required at move-in or within 4 weeks. Personal care may only be delivered by a CQC-registered provider. No new property standards: Decent Homes and HHSRS apply.
Enforcement and appeals
Councils could issue improvement notices, financial penalties (up to £7,000 or up to £40,000 depending on the breach) and revoke licences, and would keep a public register. Providers could appeal key decisions to the First-tier Tribunal.
Proposed exemptions
Each still needs an exemption notice: 55+ Registered Provider housing and Extra Care; almshouses; council-provided housing; MoJ/CAS accommodation; council-commissioned under-25 schemes with an Ofsted-registered bed; council-commissioned domestic abuse refuges.
Housing Benefit link
The government intends to link Housing Benefit to licensing. Statutory guidance has not yet been published.
Our advice: Don't wait for licensing to go live. Self-assess against the six draft standards now, prepare your statement of purpose and needs-assessment process, check your service charges, and respond to the consultation by 10 December 2026.
6. NRSA Compliance Checklist
Use this interactive checklist to assess your organisation's readiness against current law and the draft licensing requirements. Enter your details to unlock tracking.
Unlock the NRSA Compliance Checklist
Enter your name and email to access the full interactive checklist with progress tracking.
7. Common Compliance Gaps & How to Fix Them
Based on our experience auditing supported accommodation providers across England, these are the most frequent compliance gaps we find — and how to address them:
Weak governance and oversight
Establish a clear governance framework with named responsible persons, regular board meetings, and documented decision-making. Conduct an annual governance self-assessment.
Insufficient evidence of support delivery
Maintain detailed support plans with SMART objectives. Record all interactions, reviews, and outcomes. Housing benefit claims for exempt accommodation depend on demonstrating genuine support.
Inadequate property safety compliance
Create a property compliance tracker covering fire, gas, electrical, legionella, and repairs. Set calendar reminders for renewal dates. Use a traffic-light system for visibility.
Missing or outdated staff training
Implement a training matrix with expiry date tracking. Ensure all staff complete induction within first week and core training within first month. Schedule refreshers automatically.
No formal quality assurance process
Conduct annual self-assessments against the six draft National Supported Housing Standards. Schedule internal audits across all 16 MyCareAudit domains. Track actions to completion and evidence improvements.
Service charges not linked to services
Ensure every service charge component maps to an actual, documented service. Keep a clear breakdown showing what each charge covers. This is critical for housing benefit eligibility.
Poor complaints handling
Make the complaints process accessible (including easy-read versions). Log all complaints, track outcomes, and analyse trends to drive service improvements.
No licensing preparation
Read the draft 2027 regulations, list every address by council district, check whether any exemption applies, run a gap analysis against the six draft standards, and make sure your licence holder, service manager, nominated individual and directors can pass the fit and proper person test.
8. NRSA vs Regulated Accommodation
Understanding the differences between non-regulated supported accommodation and regulated services is essential for providers, commissioners, and referral agencies.
| Aspect | NRSA (Non-Regulated) | CQC Regulated | Ofsted Regulated (SA) |
|---|---|---|---|
| Client group | Vulnerable adults (18+) | Adults needing personal care | Young people 16–17 |
| Regulator | None today; council licensing proposed (draft 2027 regulations) | CQC | Ofsted |
| Framework | 2023 Act; draft National Supported Housing Standards | Single Assessment Framework | 4 Quality Standards |
| Service type | Housing + support (not personal care) | Personal care + accommodation | Accommodation + support (not care) |
| HB type | Enhanced (exempt accommodation) | Standard HB / self-funded | Standard HB / LA funded |
| Inspection | Council oversight (HB, HMO, HHSRS); licensing proposed | CQC inspection | Ofsted inspection |
| Audit tools | MyCareAudit NRSA audit: 186 questions / 16 domains | CQC KLOEs / SAF | SCCIF / SA Quality Standards |
MyCareAudit supports all three frameworks with dedicated audit templates. Read our CQC Compliance Guide or Ofsted Compliance Guide for the regulated frameworks.
9. Top Tips for Licensing Readiness
Start with a full self-assessment
Use MyCareAudit's NRSA master audit tool to assess your service against all 186 questions across 16 domains. This gives you a clear baseline and identifies priority gaps.
Evidence your support delivery
The biggest risk for exempt accommodation providers is failing to demonstrate genuine support. Keep detailed support plans, case notes, and outcome records for every resident.
Get your property compliance right
Fire, gas, electrical, and legionella — these are non-negotiable. Create a property compliance tracker and never let a certificate lapse.
Invest in staff training and supervision
Well-trained, well-supervised staff deliver better outcomes. Ensure induction, core training (including safeguarding and anti-social behaviour), and regular supervision are embedded in your culture.
Build multi-agency partnerships
Strong relationships with local authorities, health services, and specialist agencies demonstrate effective service delivery and improve outcomes for residents.
Prepare for licensing now
Don't wait for the final regulations. Work towards the six draft standards, list your addresses by council district, check exemptions, and prepare your licence holder, service manager, nominated individual and directors for the fit and proper person test.
Make quality assurance continuous
Annual self-assessments, internal audits, resident surveys, and complaints analysis should be routine — not one-off events before an inspection.
Keep financial transparency front and centre
Service charges must be transparent and linked to actual services. Housing benefit claims must clearly evidence the care, support, or supervision being provided.
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