The Universities UK/Guild HE Accommodation Code of Practice is a regulatory framework that sets standards for student accommodation managed by higher and further education institutions in England and Wales.
It exists as an alternative to the mandatory licensing regime under the Housing Act 2004, which would otherwise require university-managed accommodation to be licensed as Houses in Multiple Occupation (HMOs).
Universities that comply with the code’s requirements are granted an exemption from the licensing regime, and in England will mean they become exempt from the other protections in the forthcoming Renter’s Rights Act altogether – making the code effectively a self-regulatory system for university accommodation.
There are changes – largely improvements – to the Code that it’s important that SUs get across and check are being implemented in practice.
It’s important to understand that universities actually have a choice between two codes for their institution-managed accommodation:
- The Universities UK/Guild HE Code of Practice (the subject of this analysis)
- The ANUK/Unipol National Code for accommodation owned or managed by educational establishments
Both codes provide the same exemption from other legislation when followed. A third code exists too – the ANUK/Unipol National Code for accommodation NOT owned or managed by educational establishments – which covers purpose-built student accommodation operated by private providers rather than universities. That is being consulted on now.
The new UUK/GuildHE code represents a significant set of changes – from a basic compliance framework to a comprehensive, student-centered approach to accommodation management. It reflects changing expectations of student accommodation as not just shelter but a key component of student wellbeing, academic success, and overall university experience.
What SUs should do now
The new code significantly strengthens the role of students’ unions in accommodation governance and provides multiple opportunities for meaningful intervention. Students’ unions should take several immediate actions:
Operationalise the consultation requirements: Paragraphs 27, 130, 162, and 163 establish specific rights to be involved in accommodation audits, complaints processes, feedback mechanisms, compensation arrangements, and accommodation guarantee shortfalls.
Establish representation in governance structures: Ensure the university is allowing/facilitating student representatives participating in internal accommodation governance committees and are aware of the Code’s requirements.
Verify compliance with new requirements: Conduct a gap analysis between current university practice and the new code requirements, particularly in high-impact areas like sustainability, equality and diversity, and late building provisions.
Support complaints processes: Ensure students are aware of the strengthened complaints processes and their rights under the new code. Establish systems to track accommodation complaints to identify patterns of non-compliance.
Participate in satisfaction surveys: Help shape the design and scope of accommodation satisfaction surveys to ensure they address student priorities, and monitor the publication of results and resulting action plans.
Monitor building standards: Conduct audits of accessibility features, sustainability practices, and amenity standards to verify compliance with the enhanced requirements.
Review accommodation contracts: Scrutinise accommodation contracts to ensure they comply with the new transparency and fairness requirements, and challenge any unfair terms or excessive charges.
Share code knowledge: Raise awareness among students about the strengthened protections under the new code, particularly regarding late building completions, disability accommodations, and internet provision.
Address the rent setting gap: While the code doesn’t specifically mention students’ union involvement in rent setting, students’ unions should advocate for inclusion in these discussions as part of broader consultation on accommodation issues.
What has changed or improved?
1. Protections for late building completions
Why this is important to students: Few situations cause more stress and financial hardship to students than discovering their promised accommodation isn’t ready at the start of term. Students often face unexpected costs, unsuitable temporary housing, and significant disruption to their studies while having little recourse against providers.
The new code introduces a comprehensive section dedicated to late building completions, addressing a critical gap in the previous version. Section Seven (paragraphs 154-163) establishes protections that dramatically improve student rights when accommodation isn’t ready on time.
The most significant change is the requirement for early and honest communication. Providers must inform students “at the earliest opportunity” about delays, giving “realistic terms” about the likely inconvenience, and providing regular updates about further delays. This transparency helps students make informed decisions about their options.
Financial protections have been substantially strengthened. The new code mandates that:
- No rent can be charged until the accommodation is fit for occupation
- Alternative accommodation rent cannot exceed the original rent
- The provider must cover any rent differential if using third-party accommodation
- Equivalent meal provision or catering facilities must be provided
- Laundry costs must be covered if facilities are unavailable for over seven days
- Removal costs must be covered when transferring to permanent accommodation
- Additional travel or other reasonable expenses must be reimbursed
- Equivalent Wi-Fi service must be provided in temporary accommodation
Students now have the explicit right to cancel their contracts without charge if suitable alternative accommodation cannot be provided, or if they remain in temporary accommodation four weeks after the contracted start date. Providers must also consider student and SU representations before finalising any compensation arrangements, creating an opportunity for collective advocacy.
Importantly, the code now requires reasonable adjustments for disabled students in alternative accommodation, addressing a serious gap in the previous version that could leave vulnerable students without proper support during building delays.
2. Enhanced amenity standards and facilities
Why this is important to students: Daily living spaces and essential facilities have a profound impact on student wellbeing, study ability, and quality of life. Inadequate bathroom, laundry, and kitchen facilities are consistently among the top complaints in accommodation surveys.
The new code substantially improves standards for essential amenities that directly impact daily student life. For bathrooms, paragraph 175 now ensures all occupants have “ready access” to toilet, handwashing, and bath/shower facilities, with “sufficient provision” for the number of students. This addresses the common problem of overcrowding and inadequate bathroom access. The code also requires proper separation of en-suite facilities from sleeping areas with adequate ventilation (paragraph 176), improving privacy and preventing mould issues.
Laundry provision, a frequent source of student frustration, receives particular attention in paragraphs 105-106. All occupants must now be provided with appropriate facilities or services for washing and drying clothes, with an “appropriate ratio of facilities to students to prevent excessive waiting times.” This directly addresses the common problem of insufficient machines for the number of residents. Maintenance requirements have been strengthened to ensure facilities remain in “reasonable working order and cleanliness,” with clear repair reporting mechanisms.
For kitchens, paragraph 172 requires “adequate and appropriate facilities for the preparation, cooking and storage of food” designed with “due regard for safety” and proportionate to the number of students using them. The code now explicitly links these requirements to local authority standards, providing an external benchmark for adequacy.
Lift maintenance, critical for accessibility and convenience, now has an entire dedicated section. The code requires regular inspection, maintenance, and prompt repair of lifts with clear timelines. Notably, paragraph 218 requires alternative accessible accommodation to be provided if a lift outage affecting a disabled student exceeds 12 hours, ensuring mobility-impaired students aren’t effectively trapped in inaccessible accommodation.
These enhanced standards provide students with stronger grounds to challenge inadequate facility provision and ensure their basic living needs are properly met.
3. Health and wellbeing enhancements
Why this is important to students: Student mental health challenges have reached crisis levels, with accommodation often being the first place where issues become apparent. Proper support systems in accommodation can make the difference between successful intervention and tragic outcomes.
The new code dramatically expands health and wellbeing provision, transforming minimal guidance into comprehensive support requirements. Section Three (paragraphs 107-119) creates a structured framework for student wellbeing support that addresses the growing concern about student mental health.
Information accessibility has been substantially improved. Providers must now give accessible information about a comprehensive range of support services including health, financial, housing, harassment, discrimination, sexual misconduct, and disability support. This information must include not just university services but also students’ union and external agency support.
Crisis response capabilities have been strengthened, with paragraph 109 requiring specific information about emergency support both during and outside working hours. Providers must now have clear safeguarding protocols (paragraph 110) specifying when and how to contact relevant departments if a resident is at risk, including guidelines on when to involve external agencies like police or NHS.
The code introduces new data protection provisions specifically tailored to wellbeing support. Providers must now have Student Privacy Notices detailing what personal data can be shared for safeguarding and wellbeing purposes, enabling appropriate information sharing while protecting privacy. For partner accommodation providers, formal information-sharing agreements for student welfare matters are now mandatory.
Staff training requirements have been significantly enhanced. Staff must now have knowledge of mental health conditions and available services, specific training on crisis management, and clear understanding of the boundaries of their responsibility to prevent inappropriate interventions. The training must cover immediate safeguarding actions, assistance for affected students and staff, processes for involving relevant services, and post-incident support.
These wellbeing provisions create a safety net that recognises the unique challenges of student life and ensures appropriate support is available at critical moments.
4. Equality and diversity improvements
Why this is important to students: Students with disabilities or other protected characteristics often face significant barriers in accommodation, from physical accessibility issues to discriminatory practices. Proper accommodation is essential for equal participation in university life.
The new code introduces a dedicated section on equality and diversity (Section Four, paragraphs 120-126), transforming general compliance statements into specific, actionable requirements that create tangible protections for vulnerable students.
For disabled students, several concrete protections have been established. Paragraph 121 explicitly prohibits charging more for adapted rooms than the lowest price for comparable rooms in the same building, addressing the unfair practice of treating accessibility as a premium feature. Priority parking allocation is now required for students with mobility impairments (paragraph 122), improving access to essential transportation.
The code now requires specific policies for the design and adaptation of accommodation for disabled students, accommodation for care workers, provision of auxiliary aids, and personal safety measures for disabled students in emergencies. These targeted policies address the diverse needs of disabled students rather than treating accessibility as a one-size-fits-all issue.
A significant advancement is the requirement for a written “equality access strategy” using an “Equality by Design” approach (paragraph 123). This approach requires equality impact assessments before any changes to accommodation systems, processes, services, or buildings, preventing new barriers from being created. Ongoing improvement is mandated through regular review of impact statements throughout development programs.
Staff training on equality policies is now explicitly required (paragraph 125) to ensure no student is put at “substantial disadvantage” because of a protected characteristic. The code also requires demonstrable skills for resolving disputes involving protected characteristics (paragraph 126), acknowledging the unique sensitivity needed in these situations.
These move beyond minimal legal compliance to create an actively inclusive accommodation environment that recognizes and responds to diverse student needs.
5. Digital infrastructure requirements
Why this is important to students: Reliable internet access is no longer a luxury but an essential utility for academic success. Students need to know exactly what digital infrastructure is available before committing to accommodation, as inadequate service can severely impact their studies.
The new code transforms vague internet disclosure requirements into detailed specifications that reflect the essential nature of digital connectivity for today’s students. Paragraph 53 now requires comprehensive pre-contract information about internet services, addressing a common source of student disappointment and frustration.
Providers must now specify whether internet is included in rent, which locations in and around the accommodation have internet access, and whether connections are wired and/or wireless. Terms of use must be disclosed, including any limits on the number of devices that can be connected simultaneously – a crucial detail for students with multiple internet-connected devices.
Performance transparency has been significantly enhanced. Providers must disclose the average demonstrable speed between peak times (8-10pm) that is achievable by at least 50% of users, preventing marketing claims based on theoretical maximum speeds that are rarely achieved in practice. Service level agreements details must be provided, giving students clear expectations about reliability and support.
The code now requires a warning that internet may be suitable for study but not gaming, acknowledging the different bandwidth requirements for different online activities and preventing unrealistic expectations. This honest disclosure helps students make informed decisions about whether to arrange alternative internet service.
The importance of internet access is further recognised in paragraph 160, which requires equivalent Wi-Fi service in any alternative accommodation provided due to building delays. This prevents the scenario where students in temporary accommodation lose access to this essential utility.
These detailed requirements prevent misleading marketing and ensure students understand exactly what internet service they’re getting – essential information for academic work in the digital age.
6. Student feedback and satisfaction
Why this is important to students: Without formal mechanisms to gather, analyse, and act on student feedback, accommodation providers may miss or ignore important quality issues. Systematic feedback processes ensure student experiences drive continuous improvement.
The new code introduces a dedicated section on occupant satisfaction (Section Five, paragraphs 127-130), creating formal accountability to students through systematic feedback requirements. This represents a significant advancement from the previous code, which had no specific provisions for gathering student input.
Providers are now required to “invite and gather feedback” about how well they are serving student residents, with a recommendation for annual satisfaction surveys. To ensure meaningful year-over-year comparison, the timing of feedback collection must be consistent, allowing trends to be identified and progress measured.
The scope of feedback has been comprehensively defined to cover all aspects of the accommodation experience. Surveys must address staff responsiveness, code awareness, repairs reporting and rectification, mail handling, amenities and facilities, mental health support, safety and security, environment and sustainability, arrival information, expectations fulfilment, and rent levels and value for money. Overall satisfaction must be measured using a Net-Promoter-Score model, providing a standardised metric.
Transparency and improvement requirements have been strengthened. Results must be analyzed and published with key learnings, effectively communicated to students, and used to inform further improvement activities. This creates a feedback loop where student input directly influences service delivery.
The code allows for alternative feedback mechanisms if annual surveys aren’t suitable, but these must be developed in consultation with the students’ union and demonstrably effective in gathering, analysing, and communicating occupant satisfaction data to support continuous improvement.
These transform student feedback from an optional courtesy to a mandatory process that drives accommodation quality and responsiveness to student needs.
7. Improved complaints handling
Why this is important to students: When accommodation problems arise, students need clear, accessible complaint processes that deliver timely resolutions. Without effective complaint mechanisms, issues may persist and worsen, significantly impacting quality of life and academic performance.
The new code dramatically strengthens complaints handling provisions, replacing vague guidance with detailed requirements for transparent, effective processes. These changes create multiple layers of protection when accommodation problems arise.
Accessibility and awareness have been significantly improved. Paragraph 33 requires an “appropriate complaints process that is actively publicised to students,” ensuring students know how to raise concerns. Paragraph 47 requires providers to inform residents of complaint processes upon contract signing, during induction, and during occupancy, creating multiple opportunities for awareness.
Persistent issues now receive special attention. Paragraph 34 requires monthly updates on complaints not resolved within three months, preventing complaints from being indefinitely delayed or ignored. Annual reporting of all Stage 2 and Stage 3 complaints (paragraph 35) creates accountability for recurring problems.
External oversight has been enhanced through investigation powers allowing The Code to investigate potential non-compliance from any source (paragraph 36). For further education providers not covered by the Office of the Independent Adjudicator scheme, The Code now has jurisdiction to hear student complaints about code compliance after internal procedures are exhausted (paragraph 37).
Dispute handling procedures have been made more detailed in paragraph 97, which requires accepting contact through any appropriate method, responding reasonably and promptly, confirming proposed actions and timelines, explaining any actions that cannot be taken, recording settlements and honouring them, maintaining proper records, maintaining professional relations throughout disputes, and signposting to independent advice.
Contract clarity about complaint consequences has been improved. Paragraphs 59-60 require contracts to clearly state possible sanctions for non-compliance and ensure these are consistent with Code requirements, preventing disproportionate penalties.
These improvements create a more robust, transparent complaints system with multiple reporting levels, external oversight, and specific procedural requirements that help students resolve accommodation issues effectively.
8. Greater transparency in contracts and marketing
Why this is important to students: Students often make accommodation decisions based on limited or misleading information, committing to significant financial obligations without fully understanding what they’re signing up for. Clear, comprehensive pre-contract information is essential for informed choices.
The new code establishes substantially stronger transparency requirements, ensuring students have accurate, complete information before making accommodation commitments. Section 2 transforms basic information provisions into detailed disclosure requirements covering all aspects of the accommodation offering.
Marketing accuracy has been significantly strengthened. Paragraph 50 requires all promotional material to be “accurate and not misleading,” while paragraph 51 mandates an “appropriate mechanism” to update material when details change, with records kept for 6 years. The code prohibits advertising accommodation not accredited by an approved Code (paragraph 52), preventing providers from claiming standards compliance they haven’t verified.
Pre-contract information requirements have been dramatically expanded. Paragraph 53 now requires detailed information on room numbers by type and location, contract periods, catering arrangements, total contracted amounts and weekly equivalents, clear statements of what is/isn’t included in rent, details of compulsory and optional charges, accessibility adaptations, suitability for families/dependants/carers, staffing and support arrangements, cleaning arrangements, travel information considering different transportation needs, insurance arrangements including limitations, allocation policy and guarantees, payment options and schedules, available bursaries or discounts, application procedures and eligibility, and guidance on specific accommodation needs.
The timing of information provision has been specified. Paragraph 54 requires information to be provided “in the most relevant place at the most relevant time” during the application process, but crucially, before the contract becomes binding. This ensures students can make informed decisions rather than discovering important details after committing.
Contract fairness provisions have been substantially enhanced. Paragraphs 59-65 require accessibility of contracts, prohibition of unfair terms, clear sanctions for non-compliance, the prohibition of contractual fines (only actual losses can be claimed), transparency about consequences of non-compliance, proportionate enforcement, restrictions on academic sanctions for accommodation contract breaches, and prohibition on interrupting essential services to enforce payment.
These requirements help students understand exactly what they’re committing to and protect them from unfair or misleading practices.
A sub note on fines: The code has specific provisions regarding fines in accommodation contracts. In the new code, paragraph 61 explicitly prohibits the use of fines in accommodation contracts:
Members must ensure that accommodation contracts do not purport to impose fines for failure to comply with the contract terms. This does not prevent members from claiming for losses actually suffered and/or expenses reasonably incurred as a result of the occupant’s breach of contract. However, the amounts claimed must not put the member in any better position financially than they would have been in had there been no breach of contract; and claims for payment under the accommodation contract must not be used as a punishment or deterrent or to show disapproval.
This is a significant protection for students that:
- Prohibits punitive financial penalties (fines) in accommodation contracts
- Only allows claims for actual losses suffered or reasonable expenses incurred
- Prevents providers from profiting from contract breaches
- Prohibits using financial claims as punishment, deterrent, or to show disapproval
The code does clarify in paragraph 62 that members may refer incidents to the institution’s central disciplinary function if the action is a disciplinary offence under institutional regulations, which would allow for appropriate disciplinary measures outside the accommodation contract – although if that is a dedicated section of the central disciplinary function that only really covers halls, it’s likely to be an unlawful attempt at evading the protections in the Tenant Fees Act.
9. Sustainability and environmental focus
Why this is important to students: Environmental sustainability is increasingly important to students, both as a matter of personal values and future impact. Accommodation represents a significant portion of a university’s carbon footprint and provides an opportunity for students to live their environmental values.
The new code introduces an entire dedicated section on sustainability (Section Six, paragraphs 131-153), transforming minimal environmental provisions into comprehensive requirements that affect all aspects of accommodation management. This reflects growing student concern about climate issues and sustainability.
Strategic planning requirements have been significantly enhanced. Members must maintain a written environmental sustainability strategy covering all residential accommodation (paragraph 131) and develop specific strategies for new builds/refurbishments (paragraph 132). Environmental impact assessments are now required for all developments or changes to “avoid, minimise or offset” negative impacts (paragraph 133), ensuring sustainability is considered from the planning stage.
Energy efficiency standards have been formalised. Paragraph 136 requires compliance with Minimum Energy Efficiency Standards (MEES) and provision of Energy Performance Certificates (EPCs). Strategies to minimise energy consumption during vacant periods are now mandatory (paragraph 138), addressing wasteful practices during holiday periods. Paragraphs 139-140 require energy-efficient installations and appliances, with specific standards such as “appliances with an energy efficiency rating of C or higher.”
Student engagement has been prioritised through new communication requirements. Providers must give information on efficient heating use within 7 days of occupation, maintain dedicated sustainability areas on noticeboards and portals, and provide pre-departure sustainability guidance 1-2 months before contract end. Paragraph 147 requires promotion of active travel and public transport options, supporting sustainable transportation choices.
For catered accommodation, paragraph 148 mandates policies on sustainable food sourcing and food waste management, extending sustainability principles to dining services. Waste management provisions in paragraphs 149-153 detail requirements for waste disposal plans, recycling facilities, and food waste schemes, supporting responsible waste practices.
Staff integration of sustainability has been strengthened, with paragraph 141 requiring sustainability responsibilities to be included in all accommodation job descriptions. This ensures environmental considerations are embedded in day-to-day operations rather than treated as an optional add-on.
10. Deposits and payment protection
Why this is important to students: Security deposits often represent a significant financial burden for students, and unclear or unfair deposit practices can lead to unexpected charges and disputes at the end of tenancies. Clear rules around deposits and payments protect students’ financial interests.
The new code introduces substantially stronger financial protections around deposits and payments, addressing a common source of student-landlord disputes. These provisions create greater transparency and fairness in financial transactions.
Deposit information requirements have been significantly enhanced. Paragraph 67 now requires clear written information on the amount to be paid, payment deadline, whether the deposit will be protected in an authorised scheme, contact details for deposit queries, specific circumstances when claims may be made against the deposit, the process for disputing deductions, a 28-day refund timeline, and entitlement to deduction statements. This comprehensive information helps students understand their financial obligations and rights.
Deposit amount limitations have been established. Paragraph 68 prohibits deposits exceeding statutory maximums and requires protection in authorized schemes where legally mandated. This prevents excessive deposit demands that can create financial hardship for students.
Payment arrears management has been formalised. Paragraph 69 requires published policies outlining how accommodation payment arrears are managed, including the possibility of debt proceedings. This transparency helps students understand the consequences of payment difficulties.
Contract fairness regarding payments has been significantly strengthened. Paragraph 61 prohibits accommodation contracts from imposing fines for contract breaches, only allowing claims for actual losses suffered or reasonable expenses incurred. This prevents punitive financial penalties that put students in a worse position than if no breach had occurred.
Academic sanctions for accommodation debts have been restricted. Paragraph 63 requires providers to “take particular care if linking academic sanctions to accommodation contracts” and prohibits applying academic sanctions “as a matter of course.” This addresses the unfair practice of withholding academic services for accommodation debts.
Essential services protection has been established. Paragraph 64 prohibits interrupting or withholding services “reasonably necessary for use of accommodation as a residence” as a means of enforcing payment obligations. This prevents practices like cutting off heating or water that could make accommodation uninhabitable.
These create a fairer relationship between students and accommodation providers while preserving legitimate means to address genuine payment issues.
11. Enhanced building security requirements
Why this is important to students: Security concerns significantly impact student wellbeing and peace of mind, particularly for international students, women, and those from minority groups. Effective security measures are essential for creating a safe living environment where students can focus on their studies.
The new code significantly strengthens security requirements in Section 11 (paragraphs 186-208), transforming basic provisions into comprehensive security standards that reflect modern threats and technologies. These enhanced requirements create safer student environments.
Risk assessment scope has been expanded. Paragraph 186 now requires security risk assessments covering not just buildings but “a building’s immediate surrounds and any communal space for residents’ use,” recognising that security extends beyond the building itself. Building entry points have received particular attention, with specific access control requirements for main entrances, flat entrances, bedroom doors, and connecting doors (paragraphs 187-188).
Window security has been strengthened, particularly for vulnerable ground-level rooms. Paragraphs 189-190 require “sound construction” with lockable systems for ground level windows and opening restrictors for upper floors with periodic inspection to prevent tampering. Door security has been enhanced, with paragraph 191 requiring doors and frames to be “well maintained and of strong, solid, safe construction” with secure locking systems.
Modern security technologies are now addressed. Paragraph 192 requires intercom systems to “establish the identity of the caller” and information for students about risks of unknown callers. CCTV requirements (paragraphs 203-207) now include statutory warning signs, compliance with legislation and codes of practice, qualified operators, electronic masking of bedroom windows for privacy, and maintenance of sightlines from foliage.
Staff security procedures have been enhanced. Paragraph 193 requires photographic identification for all personnel and records of room access. Paragraph 194 requires “appropriate due diligence” before allowing personnel access, with particular attention to contact with vulnerable residents. External security personnel must have appropriate training, qualifications, and verified licenses (paragraph 196).
Emergency communications have been formalised. Paragraph 199 requires a “robust method for emergency communication” to issue notifications to residents in crisis situations. Building-specific security plans are now required (paragraph 208), covering security information provision, specific guidance for vulnerable ground-floor residents, monitoring procedures, and occupier security responsibilities.
These enhancements help students feel and be safer in their accommodation, addressing both physical security and privacy concerns.
12. Fire safety improvements
Why this is important to students: Fire safety is a literal life-and-death matter in student accommodation, with tragic consequences when standards fall short. Effective fire safety measures, particularly for vulnerable students, are essential to prevent serious injuries or fatalities.
The new code significantly enhances fire safety requirements, addressing both general standards and the specific risks common in student accommodation. These improvements create safer living environments and better protection for vulnerable residents.
Proactive risk management has been strengthened. Paragraph 251 requires management of common fire risks in student accommodation including covered smoke/heat detectors, false alarms, tampering with fire doors/equipment, cooking negligence, unsafe appliances, smoking, and incense/candles use. This focuses attention on the particular fire risks in student living environments.
Emergency evacuation provisions for disabled students have been significantly improved. Paragraph 249 requires “adequate arrangements” for residents needing alternative alerting methods, assistance leaving buildings safely, documented personal emergency evacuation plans, staff training on evacuation plans, and post-drill evaluation and adjustment of plans. These detailed requirements ensure vulnerable students aren’t overlooked in emergency planning.
Student-centered remediation timing has been established. Paragraph 252 requires “reasonable efforts” to schedule fire safety remediation “at a time that is least likely to disrupt students’ studies,” recognising the impact of maintenance work on academic performance without compromising safety.
Fire door awareness has been enhanced. Paragraph 247 requires informing residents about the function and importance of fire doors, explaining which doors are part of automated systems, how to report suspected malfunctions, and the consequences of tampering with fire safety equipment. This educational approach promotes student cooperation with fire safety measures.
Fire evacuation practice requirements have been maintained but with added evaluation components. After drills or actual emergencies, personal emergency evacuation plans must now be evaluated and necessary adjustments made, creating a continuous improvement process for emergency procedures.
These enhancements address both general safety standards and the specific needs of vulnerable residents, creating a safer living environment for all students.
13. SU consultation
Why this is important to students: Without formal consultation rights, student representatives may be excluded from key decisions about accommodation policies and standards. Structured consultation requirements ensure student voices influence accommodation governance and management.
The new code significantly strengthens the role of student representatives in accommodation governance, transforming a brief mention of student involvement into multiple specific consultation requirements throughout the code. These provisions create formal mechanisms for student influence.
Code compliance consultation has been formalised. Paragraph 27 requires members to “regularly consult their students’ union” and involve them in “audits, complaints and other procedures integral to the functions and administration of this Code.” This creates an ongoing dialogue rather than occasional consultation.
Feedback mechanism development now requires student input. Paragraph 130 requires alternative feedback mechanisms to be “developed in consultation with the member’s students’ union,” ensuring student perspectives shape how feedback is gathered and utilized.
Compensation arrangements now require student representation. Paragraph 162 requires members to “take into account all reasonable representations made by students and the students’ union” before finalising compensation offers for accommodation issues. This creates a formal role for collective advocacy in dispute resolution.
Accommodation guarantee shortfalls must involve student representatives. Paragraph 163 requires members to work with “the students’ union or other student representative body” when addressing situations where guarantees cannot be met, ensuring student interests are considered in contingency planning.
Notification rights have been established. Paragraph 43 requires formal notification of the students’ union if a provider is expelled from The Code, ensuring students’ representatives are informed about significant compliance issues.
These consultation requirements transform student representatives from passive consultees to active participants in accommodation governance, with specific rights to involvement in key processes affecting students.
14. Repairs and maintenance improvements
Why this is important to students: Slow, ineffective repairs and maintenance significantly impact quality of life and can create health and safety risks. Effective repair systems ensure accommodation remains habitable and problems are addressed promptly.
The new code creates much more specific obligations for repairs and maintenance in paragraphs 76-88, replacing basic provisions with detailed requirements that improve service delivery and communication. These changes address a common source of student dissatisfaction.
Inventory and reporting processes have been formalised. Paragraphs 78-79 require provision of inventory reports and clear methods for reporting discrepancies, creating a baseline for condition assessment. This protects students from being charged for pre-existing damage and clarifies reporting responsibilities.
Worker qualifications and conduct have been specified. Paragraph 80 requires repairs by “suitably experienced and competent personnel” with appropriate qualifications, while paragraph 81 mandates management of workers to ensure debris removal and professional conduct. These provisions address concerns about unprofessional or unqualified maintenance staff.
Service transparency has been significantly enhanced. Paragraph 83 requires publishing service level statements with categorised priorities and target response times, giving students clear expectations about repair timelines. Paragraph 84 requires keeping students informed of repair progress, particularly regarding delays, improving communication during the repair process.
Service monitoring and improvement have been formalised. Paragraph 85 requires recording instances where repairs aren’t completed within target times, with annual review and continuous improvement. This creates accountability for service performance and drives ongoing enhancements.
Academic impact consideration has been strengthened. Paragraph 87 requires consideration of exam periods and other sensitive times when scheduling works, while paragraph 88 mandates a calendar identifying sensitive periods where planned works should be avoided. These provisions help prevent disruption to academic work.
Cost transparency for damage repairs has been improved. Paragraph 86 requires notifying residents of claimed costs “as soon as practicably possible” and providing written evidence if requested. This prevents unexpected charges and ensures cost justification.
These repair and maintenance requirements create a more professional, responsive service that better meets student needs and minimises disruption to academic work.
15. Data protection and information sharing
Why this is important to students: Student accommodation holds sensitive personal data that requires proper protection, while effective welfare support sometimes requires appropriate information sharing. Clear data policies balance privacy with necessary disclosure for student wellbeing.
The new code introduces specific data protection and information sharing provisions that were entirely absent from the previous version. These new requirements balance privacy rights with the need for appropriate information sharing to support student wellbeing.
Privacy notice requirements have been established. Paragraph 111 requires Student Privacy Notices detailing what personal data is collected, how it is used, who it can be shared with, and for what purposes. This transparency helps students understand how their personal information is handled.
Welfare data sharing has been explicitly addressed. Privacy notices must cover the use of personal data for safeguarding, wellbeing support, and crisis management, recognising the legitimate need to share certain information in support contexts while maintaining overall privacy.
Regular policy review has been mandated. Paragraph 112 requires periodic review of data processing policies relating to The Code obligations, ensuring practices remain appropriate and compliant with evolving data protection standards.
Partnership agreements have been formalised. Paragraph 113 requires information-sharing agreements with accommodation partners regarding student welfare matters, ensuring consistent data handling across different accommodation providers serving the same institution.
Named contacts for emergencies are now required. Paragraph 113 mandates a named individual within each partner organisation who serves as a contact in the event of a crisis or emergency, facilitating swift information sharing when necessary.
Record security has been strengthened. Paragraph 115 requires secure maintenance of incident/crisis records with sharing only in accordance with data sharing protocols. This protects sensitive information about student welfare incidents.
These data provisions create frameworks for both protecting student privacy and enabling necessary information sharing for welfare purposes, addressing a significant gap in the previous code.
16. Accommodation for families and care workers
Why this is important to students: The traditional model of single undergraduate accommodation excludes students with families, dependents, or care needs. Inclusive accommodation policies ensure all students can access suitable housing regardless of their family or care circumstances.
The new code introduces specific provisions for families and care workers across several sections, acknowledging the diverse needs of the student population beyond the traditional young single undergraduate model. These provisions support inclusion and accessibility.
Marketing information requirements have been expanded. Paragraph 53 now requires information about accommodation “suitable for families or students with dependants or with carers” before contract signing. This helps students with these needs identify appropriate options early in their accommodation search.
Equality policy requirements have been enhanced. Paragraph 120 requires specific policies for “accommodation for care workers,” recognizing the essential role these individuals play in supporting disabled students. These policies should address the particular needs of care workers in the accommodation environment.
Security arrangements have been made more flexible. Paragraph 188 acknowledges potential exceptions to standard locking arrangements for “a student and their carer sharing adjoining connected rooms,” ensuring security measures don’t create barriers to necessary care provision.
These recognise that today’s student population is diverse, with needs that extend beyond traditional student accommodation models.
17. Management and governance improvements
Why this is important to students: Without proper governance and management systems, even the best accommodation standards may not be consistently delivered. Strong governance ensures accountability and continuous improvement in accommodation quality.
The new code establishes much more rigorous governance requirements in the “Ensuring Ongoing Compliance” section (paragraphs 12-32), replacing basic audit provisions with comprehensive management standards. These improvements create stronger accountability for accommodation quality.
Continuous compliance monitoring has been formalised. Paragraph 13 requires all accredited buildings to “continuously” meet Code standards with notification if they cease to be compliant. This shifts from periodic to ongoing compliance responsibility.
Regular self-assessment has been introduced. Paragraph 16 requires annual self-audits against Code requirements, complementing the three-year external audit cycle. This ensures more frequent review of standards compliance.
Independent audit requirements have been strengthened. Paragraphs 18-19 mandate at least one on-site visit during triennial audits, with auditor discretion on which buildings to visit and consideration of independence, objectivity, and materiality. This creates more thorough external verification.
Governance oversight has been enhanced. Paragraphs 20-21 require adequate resources for audits and follow-up, full audit reports (not just summaries) to Audit Committees, and minutes of review meetings submitted to governors. These requirements elevate accommodation governance to appropriate institutional levels.
Action planning has been formalised. Paragraph 22 requires specific, time-bounded action plans with identified personnel responsible for implementation. Paragraph 24 mandates updates on progress implementing recommendations from previous audits. These requirements ensure identified issues are actually addressed.
Institutional responsibility has been clarified. Paragraph 25 requires members to “embrace this Code as an institutional (rather than departmental) compliance responsibility,” with a recommended senior person having overall responsibility. This prevents accommodation standards being treated as a peripheral concern.
Emergency reporting has been strengthened. Paragraph 31 requires notification to The Code “at the earliest opportunity” if accommodation becomes unfit for habitation, with updates on progress and remediation. This creates external oversight of serious accommodation failures.
These improvements ensure accommodation standards receive appropriate institutional attention and create multiple layers of accountability for service quality.
18. References and housing transitions
Why this is important to students: Transitioning between university accommodation and the private rental sector can be challenging, particularly for first-time renters. References and transition guidance help students navigate housing changes successfully.
The new code introduces specific provisions to support students transitioning between different accommodation, addressing the particular challenges faced when moving into the private rental sector. These provisions help students navigate housing transitions successfully.
Reference provision has been formalised. Paragraphs 101-102 establish an obligation to provide references within 3 weeks free of charge, with requirements for factual references relating to contract performance. This helps students secure future accommodation by demonstrating their reliability as tenants.
Reference content has been clarified. References must be factual and relate to the individual’s performance of their contractual obligations, with permission to state whether the provider would be willing to house the student again. This balanced approach provides useful information while avoiding unfair subjective judgments.
End-of-tenancy guidance has been established. Paragraph 146 requires providing information 1-2 months before contract end on rights as renters in the Private Rented Sector, the role of EPCs in the Private Rented Sector, and reducing waste through donations/recycling. This helps students prepare for their next accommodation move.
Mail forwarding information has been strengthened. Paragraph 103 requires students to be advised of arrangements for forwarding or redirecting mail after they’ve vacated, addressing a common practical concern during transitions.
These recognize that student accommodation is often temporary, and students need support transitioning between university accommodation and other housing options. The guidance and references help students navigate these transitions successfully.
19. Lift safety and accessibility
Why this is important to students: For students with mobility impairments, functioning lifts are not a convenience but a necessity. Without reliable lift access, disabled students may be effectively trapped in inaccessible accommodation or unable to attend classes.
The new code introduces a comprehensive section on lift safety and accessibility (Section 12, paragraphs 209-218) that was entirely absent from the previous version. These provisions address a critical accessibility feature with detailed requirements.
Inspection and maintenance requirements have been established. Paragraphs 209-211 require risk assessments, statutory examinations by competent persons, and maintenance of examination records. These ensure lifts remain safe and functional through proper oversight.
Defect remediation timelines have been formalised. Paragraph 213 requires addressing defects “as soon as reasonably practicable” and within any timescale specified by inspectors, with prohibition on use after deadline unless defects are remedied. This prevents continued operation of unsafe lifts.
Downtime monitoring has been mandated. Paragraph 215 requires logging all instances when lifts are non-operational and the reasons why, allowing analysis of performance patterns and identification of problematic lifts requiring intervention.
Firefighting and evacuation lift requirements have been specified. Paragraph 216 requires inspection at least as often as legally required, with defect reporting to fire and rescue services and maintenance of inspection records.
Emergency procedures have been strengthened. Paragraph 217 requires clear communication to trapped persons, staff understanding of their role in responding to entrapments, and a system for swift release. This addresses the distressing scenario of being trapped in a malfunctioning lift.
Accessibility accommodations have been formalised. Paragraph 218 requires alternative access arrangements when lift failures affect disabled students’ access to their rooms, including alternative accessible accommodation if outages exceed 12 hours. This prevents disabled students being effectively trapped by lift failures.
These lift provisions address both safety concerns and the particular needs of disabled students who depend on lifts for basic accommodation access.
20. Business continuity requirements
Why this is important to students: Major incidents like fires, floods, or infrastructure failures can severely disrupt student accommodation. Without proper contingency planning, these disruptions can lead to extended displacement or inadequate alternative arrangements.
The new code introduces specific business continuity requirements in paragraph 170, creating a structured approach to emergency preparedness that was only briefly mentioned in the previous version. These provisions ensure accommodation providers can respond effectively to major incidents.
Comprehensive planning is now required. Paragraph 170 mandates business continuity plans for all managed/controlled accommodation, ensuring every building has appropriate emergency response procedures in place.
Regular testing and review have been established. The plans must be reviewed annually and stress tested, ensuring they remain current and effective. The review must consider newly emerging risks, allowing plans to adapt to changing circumstances and threats.
Accessibility requirements have been formalised. Plans must be freely available as part of site policies and procedures, ensuring they can be quickly accessed during emergencies rather than stored in inaccessible locations.
Staff awareness has been prioritised. Appropriate staff must be made and kept aware of their responsibilities under the plan, ensuring everyone understands their role during emergencies. Clear guidelines must specify how, where, and when the plan should be activated, preventing confusion during crisis situations.
These create more resilient accommodation services that can effectively respond to major incidents, minimizing disruption to students during emergencies and ensuring swift restoration of normal operations.
21. Electrical safety improvements
Why this is important to students: Electrical faults represent a serious safety hazard in student accommodation, with potential for fires, shocks, or electrocution. Rigorous electrical safety standards protect students from these potentially fatal risks.
The new code significantly strengthens electrical safety requirements, replacing basic provisions with comprehensive standards that reflect current best practices. These enhanced requirements create safer electrical systems in student accommodation.
Current standards compliance has been specified. Paragraph 226 explicitly references the latest edition of electrical safety standards (“BS 7671:2018+A2:2022”), ensuring alignment with modern safety requirements rather than outdated standards.
Testing regimes have been formalised. Paragraph 227 requires inspection and testing by qualified persons at least every 5 years, with proper Electrical Installation Condition Reports (EICR) that must be made available to future inspectors. Inspections must follow the timeline set in previous EICRs, ensuring regular verification of electrical safety.
Remedial work timelines have been established. Paragraph 228 requires completing remedial work within 28 days of receiving an EICR, or sooner if specified in the report. This ensures prompt addressing of identified electrical safety issues.
Portable equipment testing has been strengthened. Paragraphs 229-230 require a Portable Appliance Testing (PAT) policy ensuring that all member-supplied electrical equipment with injury potential is maintained in safe condition. Instructions for safe use of electrical appliances must be provided to occupants.
Student equipment safety has been addressed. Paragraph 231 requires making students aware of PAT policies and any arrangements for testing students’ personal equipment. Paragraph 232 mandates procedures for dealing with potentially hazardous personal electrical equipment, with student awareness of these procedures.
These electrical safety provisions create multiple layers of protection against electrical hazards, with clear standards, regular testing, prompt remediation of issues, and management of both institutional and student-owned equipment.
22. Information on pests and infestations
Why this is important to students: Pest infestations can make accommodation uninhabitable and pose health risks. Clear pest management procedures help prevent infestations and ensure swift remediation when they occur.
The new code significantly enhances pest management provisions in paragraph 184, replacing a brief mention with detailed requirements that address prevention, reporting, and response. These improvements help maintain healthy living environments.
Preventative management has been formalised. Paragraph 184 requires a demonstrable management plan for pest prevention, shifting focus from reactive treatment to proactive prevention. Property maintenance requirements to deter potential infestations address environmental factors that attract pests.
Reporting procedures have been clarified. The code now requires clear information for occupants on how to report suspected infestations, ensuring swift identification of developing problems. This educational component helps students recognize and report issues promptly.
Response expectations have been established. Providers must now give anticipated response times for different types of infestations, creating accountability for timely remediation. This prevents situations where pest problems persist due to delayed responses.
These pest management provisions help prevent infestations through proper maintenance and ensure effective response when issues arise, maintaining healthy living environments for students.
23. Code compliance penalties and enforcement
Why this is important to students: Without meaningful enforcement, code requirements may be ignored or deprioritised. Robust compliance mechanisms ensure accommodation providers actually deliver the standards promised to students.
The new code establishes a much stronger enforcement regime with clearer consequences for non-compliance. These provisions create real accountability for accommodation standards.
Non-compliance examples have been specified. The new code identifies specific examples of non-compliance including administrative failures, audit findings indicating persistent management failures, and improperly addressed complaints showing serious/persistent issues. This clarity helps providers understand their obligations.
Enforcement options have been expanded. Paragraph 42 establishes “a range of sanctions and penalties” beyond just suspension/expulsion, creating a more nuanced approach to addressing different levels of non-compliance.
Public accountability has been strengthened. Paragraph 43 requires publishing details of expulsion decisions on The Code website, creating transparency about serious compliance failures. Formal notification requirements to the member, students’ union, and local authority ensure all stakeholders are informed.
Appeal rights have been formalised. Paragraph 45 establishes a formal appeal process for expelled members, balancing enforcement with procedural fairness. The member remains excluded pending appeal outcome, maintaining standards protection during the appeal process.
Misrepresentation penalties have been established. Paragraph 48 enables The Code to “take such action as it sees fit” against institutions falsely claiming membership, preventing misleading claims about standards compliance.
These create a more robust compliance system with clear consequences for standards failures, protecting students from persistent poor accommodation management.
24. Rights information and induction
Why this is important to students: Students often lack knowledge about their housing rights and may not realise they are protected by a formal code of practice. Without proper information at move-in, students may endure poor conditions, unfair treatment, or safety issues without knowing they can challenge these problems.
The new code places much stronger emphasis on ensuring students understand their rights and the protections afforded by the code from the moment they move into accommodation. This creates greater awareness and empowers students to advocate for proper standards.
Old Code (2019):
- Brief reference in Section 5.8 to an “induction briefing” that must “advise students that their accommodation is covered by this Code”
- Limited detail on specific rights information that must be provided
New Code:
- Comprehensive “Information For Students at Start of Occupancy” section (paragraphs 98-100) with detailed requirements:
- Multiple information formats: Paragraph 99 allows flexibility in providing information through “an induction, briefing, e-induction process or the provision of pre-arrival welcome literature,” ensuring accessibility for different student preferences
- Comprehensive content requirements: Paragraph 100 requires detailed information covering:
- All core contractual matters
- Where to find the Code and its purpose
- Essential contact details
- Health and safety guidance
- Security information
- Conduct and behavior expectations
- Communal living guidance
- Complaints procedures – critical for exercising rights
- Practical information such as mail arrangements
- Sources of advice within the university, students’ union, and external agencies
- Multiple notification points: Paragraph 47 requires providing information about the Code and complaints processes “upon the signing of their accommodation contract, at induction talks and during occupancy,” creating multiple opportunities to learn about rights
- Contract reference requirement: Paragraph 57 requires the accommodation contract to include “a reference to the establishment’s membership of this Code,” ensuring formal acknowledgment of code protections
- Complaint rights awareness: Specific requirement to inform residents of “the process for making complaints if they believe their accommodation does not comply with The Code”
These information requirements ensure students are aware of their rights, know how to exercise them, and understand the standards their accommodation should meet.
Cheat sheet – a summary of students rights
As a student living in university-managed accommodation, you have specific rights protected by the Universities UK/Guild HE Accommodation Code of Practice. This guide outlines what you can expect and how to assert your rights if problems arise.
Your Basic Rights
Safe, well-maintained accommodation: Your accommodation must meet health and safety standards with no serious hazards. This includes proper fire safety systems, secure doors and windows, safe electrical and gas installations, adequate heating, and protection from pests.
Clear, fair contracts: Your contract must be written in clear language without unfair terms. You must receive a copy before occupation begins, and the university must explain any terms if requested.
No punitive fines: Universities cannot impose arbitrary fines in your contract. They can only claim for actual losses or expenses resulting from contract breaches – not as punishment or deterrent.
Reasonable rent collection: Universities must have clear payment policies but cannot interrupt essential services (heating, water, etc.) to enforce payment or unfairly link academic sanctions to accommodation debts.
Protected deposit: If you pay a deposit, the university must clearly explain how much you’re paying, when you’ll get it back, and the circumstances where deductions might be made. They must return deposits (minus legitimate deductions) within 28 days of your tenancy ending.
Reasonable repairs: The university must have a published system for reporting repairs with defined response times for different urgency levels. They must keep you informed about repair progress and avoid scheduling disruptive works during exam periods.
Privacy: Staff must give appropriate notice (typically 48 hours) before entering your room except in emergencies. All staff accessing accommodation must have identification.
Complaint procedures: The university must have a clear complaint procedure that’s been publicized to students, with defined stages and reasonable response times.
If Your Building Isn’t Ready On Time
If your accommodation isn’t ready when promised, you have strong protections:
- The university must inform you early and honestly about delays
- They must offer you suitable alternative accommodation or a delayed start date
- If alternative accommodation lacks facilities from your original booking (like catering or laundry), the university must compensate you
- You can cancel your contract without charge if:
- The university can’t provide suitable alternative accommodation
- You’ve been in temporary accommodation for more than four weeks
Internet and Services
- You should have clear information about internet service, including what’s covered by your rent, connection speeds, and usage limits
- Laundry facilities must be available with an appropriate number of machines to prevent excessive waiting times
- Mail and parcel collection systems must be in place with clear arrangements
Equality and Accessibility
- The university cannot charge more for rooms adapted for disabled students than comparable standard rooms
- If you have a disability, the university must make reasonable adjustments to accommodate your needs
- If you need accessible accommodation, the university should have policies for:
- Design and adaptation of rooms for disabled students
- Accommodation for care workers
- Personal emergency evacuation plans
Safety and Security
- Your accommodation must be securable against intrusion with functioning locks on doors and ground-floor windows
- The university must have security plans, including proper arrangements for visitor access
- CCTV, if installed, must comply with data protection laws, including privacy protections for bedroom windows
- Fire safety systems must be regularly tested, with fire drills at least once per year
Health and Wellbeing
- You should receive information about local healthcare services and be encouraged to register with a GP
- The university should provide information about mental health support services
- The university must have procedures to assist students experiencing health or wellbeing crises
When You Move Out
- The university must provide references if requested by future landlords
- Before your contract ends, you should receive guidance on the private rental sector and waste reduction
How to Assert Your Rights
1. Know the Code
Understand that your university must follow the UUK/Guild HE Code of Practice. You can find the full code at www.acop.ac.uk.
2. Report Problems Promptly
Use the university’s reporting system for maintenance issues, security concerns, or other problems. Keep records of all reports, including dates and reference numbers.
3. Follow the Complaints Procedure
If issues aren’t resolved:
- Start with the accommodation office (Stage 1)
- If unsatisfactory, escalate to the next level in the university (Stage 2)
- If still unresolved, consider external options like the Office of the Independent Adjudicator (Stage 3)
4. Gather Evidence
Document problems with photos, videos, emails, and written records of conversations. Save all communication with university staff.
5. Seek Support
Contact your students’ union for advice and advocacy. They can often help navigate complaint processes and may be aware of similar issues affecting other students.
6. Know External Options
If your university fails to meet Code standards:
- Contact your local authority’s housing department if conditions are hazardous
- Complain to the Code administrators if the university systematically fails to follow the Code
Red Flags
Be alert to these issues that violate the Code:
- Fines for rule violations (rather than charges for actual costs incurred)
- Refusing repairs or blaming you for problems without evidence
- Entering your room without proper notice outside emergencies
- Not providing information about the Code or complaint procedures
- Accommodation that is unsafe or has serious hazards
- Preventing you from having visitors without reasonable cause
- Not addressing harassment or anti-social behavior from other residents
Remember:
Your university has committed to following this Code. If they don’t meet these standards, you have the right to hold them accountable. Living in university accommodation shouldn’t mean accepting substandard conditions or unfair treatment. The Code exists to ensure your housing is safe, well-maintained, and properly managed.
Your students’ union can provide advice specific to your university and may be aware of ongoing accommodation issues. They should be your first stop for support if you’re having trouble resolving problems through regular channels.
Read more
UUK/GuildHE Accommodation Code of Practice
The ANUK / National Code for accommodation owned or managed by non educational establishments
The ANUK / National Code for accommodation owned or managed by educational establishments
How to respond to the consultation on standards and rights in privately-run halls
