Open consultation

Consultation on a reformed Decent Homes Standard for social and privately rented homes

Published 2 July 2025

Applies to England

Scope of the consultation

This consultation considers decency standards for social and private rented sector housing.

Introduction

• Why is decency important?

Section 1: Policy context and background

• What is the Decent Homes Standard?  
• How is decency measured?  
• The DHS in social housing   
• The DHS in the private rented sector  
• Other existing standards and requirements   
  • Housing Act 2004  
  • Homes (Fitness for Human Habitation) Act 2018  
• Wider housing quality reforms   
  • Awaab’s Law   
  • Minimum Energy Efficiency Standards   
  • The Housing Health and Safety Rating System (HHSRS) Review   
  • Renters’ Rights Bill

Section 2: The Decent Homes Standard Review

• An overview of the findings of the DHS review

Section 3: Proposed changes to the Decent Homes Standard

• Updating the definition of disrepair – removing the age requirement and updating thresholds 
• Revising the list of building components which must be kept in a reasonable state of repair 
• Revising our approach to facilities so that landlords need to provide three out of the four facilities listed in proposal 2  
• Introducing a window restrictor requirement 
• Considering a new home security requirement  
• Considering a requirement for floor coverings for new tenancies   
• Streamlining and updating the thermal comfort requirements.  
• Introducing a new standard for damp and mould.

Section 4: Other Tenures

• The impact of these proposals on leasehold properties, supported housing and temporary accommodation.

Section 5: Best practice guidance and explanatory materials

• What to include in best practice guidance and explanatory material.

Section 6: Implementing the revised Decent Homes Standard

• Implementation timeframes and challenges.

Section 7: Meeting the revised Decent Homes Standard

• How regulatory and enforcing bodies should treat landlords when circumstances mean it will be difficult for their properties to meet the DHS.

Annexes:

• Annex A: glossary of terms used in the consultation   
• Annex B: list of Decent Homes Review core sounding board members 
• Annex C: about this consultation  
• Annex D: privacy notice

Views on the overall proposal: Specifically, this consultation seeks comments on the proposals set out in sections 3, 4, 5, 6, and 7. Following the consultation, responses will be analysed, and a response published in due course.

Geographical Scope: These proposals relate to providers of social housing based in England registered with the Regulator of Social Housing and subject to its regulatory standards and private rented housing in England and subject to local authority enforcement.

Although these proposals will mainly affect tenants of social housing in England (including licensees), we recognise that there are situations where Registered Providers of social housing have stock across England and Wales. We will work with the Welsh Government during the implementation phase to establish a position that works best for providers, tenants, and regulators.

Interim Impact Assessment: sets out the expected impacts of proposals made in this consultation.

Basic information

Body responsible for the consultation: Ministry of Housing, Communities and Local Government

Duration: This consultation will last for 10 weeks from Wednesday 2 July 2025 to 11.45pm on Wednesday 10 September 2025.

Enquiries: For any enquiries about the consultation please email:  DecentHomesReview@communities.gov.uk

When you enquire, it would be useful if you confirm whether you are replying as an individual or submitting an official response on behalf of an organisation and include:

1. your name
2. your position in the organisation (if applicable)
3. the name of your organisation (if applicable)
4. an email address

How to respond: You may respond by completing this online survey on Citizens Space.

We strongly encourage responses via the online survey, particularly from organisations with access to online facilities such as local councils, representative bodies and businesses. Consultations receive a high-level of interest across many sectors. Using the online survey greatly assists our analysis of the responses, enabling more efficient consideration of the issues raised.

Alternatively, you can email your response to the questions in this consultation to: DecentHomesReview@communities.gov.uk

If you are responding in writing, please make it clear which questions you are responding to by stating which question number your response, or each part of your response, relates to.

Written responses should be sent to:

Decent Homes Standard Review Consultation
Social Housing Quality and Residents Division
Ministry of Housing, Communities and Local Government
3rd Floor, Fry Building (Mail point B11)
2 Marsham Street
London
SW1P 4DF

When responding to the consultation, please do not include sensitive personal data such as your name and address within your responses to questions.

Personal concerns about decency issues cannot be resolved through your consultation response. If you have concerns about the decency of your home please email MHCLG at Contact the Ministry of Housing, Communities and Local Government

Demography Questions

1. In which capacity are you completing these questions? (Select all that apply)

• Arms-length management organisation (ALMO) housing provider
• Charity (providing housing but not a registered provider of social housing)
• Charity (providing support services and advice)
• Estate/ Letting agent
• Government body
• Landlord representative group
• Leaseholder
• Leaseholder representative group
• Local authority registered provider
• Local authority not responding in the capacity of a registered provider
• Owner occupier / individual
• Private rented sector landlord operating as an individual or group of individuals (e.g. a couple)
• Private rented sector landlord operating on behalf of an organisation/ company
• Private registered provider of social housing (e.g. housing association)
• Social landlord (but not a registered provider)
• Tenant management organisation (TMO)
• Tenant representative group
• Tenant of the private rented sector (including lodgers)
• Tenant of the social rented sector (including licensees)
• Shared owners
• Other (please specify) [free text]

2. If responding as an individual, where do you live? (Select one)

• East Midlands
• East of England
• London and Greater London
• North East
• North West
• West Midlands
• South East
• South West
• Yorkshire and the Humber
• Other (please specify)
• Prefer not to say
• Not applicable

3. Landlords and estate/letting agents only: Where are the majority of properties you let located? (Select one)

• East Midlands
• East of England
• London and Greater London
• North East
• North West
• West Midlands
• South East
• South West
• Yorkshire and the Humber
• Spread across multiple regions
• Other (please specify)
• Prefer not to say
• Not applicable

4. Landlord only: How many rental properties do you own or manage? (Select one)

• 1
• 2 to 4
• 5 to 9
• 10 to 24
• 25 to100
• 101 to 1000
• 1,001 to 10,000
• 10,001 to 25,000
• 25,001 to 50,000
• 50,000 plus
• Prefer not to say
• Not applicable

5. Landlord only: Which of these options best reflects how you would describe yourself or organisation? (Select one)

• “Accidental” landlord who became a landlord due to external circumstances e.g. inheriting a property (private rented sector)
• Buy-to-let landlord whose properties are an investment (private rented sector)
• Charity who rents out a property or properties on a short- or long-term basis
• Landlord who lives in the property i.e. rents to a lodger (private rented sector)
• Landlord who is a developer/investor/manager of build-to-rent properties (private rented sector)
• Local authority enforcement
• Local authority registered provider (social rented sector)
• Private Registered Provider e.g. housing association (social rented sector)
• Professional landlord making a living from a portfolio of rental properties (private rented sector)
• Short-term landlord who rents out a property or properties only at certain times (private rented sector)
• Other (please provided details)
• Prefer not to say
• Not applicable

6. Landlord only: Do you provide supported housing?

• Yes
• No
• Prefer not to say
• Not applicable

7. Landlord only: Do you provide temporary accommodation?

• Yes
• No
• Prefer not to say
• Not applicable

8. Tenant only: Is anyone living in your property under the age of 5?

• Yes
• No
• Don’t know
• Prefer not to say
• Not applicable

9. Tenant only: Is anyone living in your property over the age of 65?

• Yes
• No
• Don’t know
• Prefer not to say
• Not applicable

10. Tenant only: Do you live in a House in Multiple Occupation (HMO)?

An HMO is a privately rented house or flat occupied by at least three tenants from two or more families who share facilities, e.g. lavatories, kitchens, bathrooms.

• Yes
• No
• Don’t know
• Prefer not to say
• Not applicable

Ministerial foreword

Everyone deserves the security and comfort of a safe, warm and decent home. Yet far too many of those living in social and privately rented homes have to put up with substandard conditions. Today, 10% of homes in the Social Rented Sector (SRS), and a staggering 21% of homes in the Private Rented Sector (PRS) are non-decent.  

Alongside our commitment to delivering the biggest increase in social and affordable housebuilding in a generation, this government is determined to drive a transformational and lasting change in the quality and safety of social housing. 

The last Labour Government introduced the Decent Homes Standard (DHS) to the SRS in 2001. In the nearly of quarter of a century since, millions of social housing tenants have benefited from a programme that saw their homes upgraded, made safer, and maintained to a good standard.  

However, the DHS in its current form no longer reflects the present-day needs of tenants or landlords and it is falling short when it comes to addressing fundamental problems with our social housing stock. For these reasons and more, it needs to be modernised.  

It also needs to be expanded because when it comes to quality and safety, transformational and lasting change cannot be confined only to those in social rented homes. Regardless of who is your landlord, there should be a universally accepted and understood minimum standard of safe and decent housing for all tenants and landlords across the country. That is why our Renters’ Rights Bill extends the DHS to the PRS for the first time.   

The proposals in this consultation are designed to ensure that all tenants feel safe, secure and proud of their homes and that all landlords have a clear understanding of the standards they are expected to uphold. We appreciate fully that the latter want as much certainty as possible in order to plan for the future. That is why we are consulting on these changes at the same time as providing clarity and certainty on future regulation on quality and safety and grant funding support for Registered Providers.  

We know that decent housing helps families and children flourish; supports thriving neighbourhoods; and improves physical and mental health outcomes. We also know that the opposite is true and that the most hazardous conditions can prove fatal. The shameful death of two-year-old Awaab Ishak in December 2020 as a result of prolonged exposure to damp and mould threw into sharp relief the need for renewed action to promptly address hazards in homes. 

That is why, alongside introducing Awaab’s Law to both rented sectors, we are adding a new criterion to the DHS – Criterion E – which sets an ambitious, standalone standard to deal with damp and mould. This will help protect tenants from the serious health risks associated with these hazards and ensure that no other family endures what Awaab and his family suffered.   

We invite tenants, landlords and others to comment on our proposals, both those we believe are essential and those where we have made clear we require more evidence before arriving at a final decision. Please let us have your views, as well as suggestions for improvements and how they can be made.

Matthew Pennycook MP, Minister for Housing and Planning

Executive summary

The government has made it clear that everyone deserves to live in a home that is safe and decent, and all tenants deserve to be treated with respect. Achieving this means delivering the biggest increase in social and affordable housebuilding in a generation, setting clear and proportionate regulations and transforming the experience of private renting, by implementing the Renters’ Rights Bill.

As part of these commitments, reform is needed to the Decent Homes Standard (DHS). The last Labour government introduced the DHS into the social housing sector in 2001. Since then, the DHS has set the minimum standard that social homes must meet and improved the housing conditions of millions of social rented sector tenants.

The DHS was last updated in 2006 and no longer works for our aging housing stock or the modern expectations of tenants. The Deputy Prime Minister committed to consult on an updated DHS across all rented housing (including applying to the private rented sector for the first time following passage of the Renters’ Rights Bill).

Most social and private landlords provide safe and decent homes to their tenants and act quickly to resolve complaints. We appreciate the vital role that landlords play, and we remain committed to working in partnership with them to improve the lived experience for those living in rented housing across the country. 

However, far too many tenants still live in homes that are not well managed or maintained. Around 1.5 million rented homes fail to meet the Decent Homes Standard. The English Housing Survey shows that levels of damp have recently been increasing in prevalence across the rented sectors, and that in 2022-23, 800,000 dependent children lived in a rented non-decent home, and 32% of social renting households were dissatisfied with repair and maintenance. It is imperative that we work together to make all homes safe and decent.  Now is the time for collective action.

Updating the DHS to reflect modern expectations will improve rented homes, support economic growth and improve health outcomes. Through this consultation we are testing a DHS that will:

a) act as a common standard for both private and social rented housing as far as possible that can be used by tenants and landlords alike
b) ensure that focus is placed more on condition of the home rather than arbitrary age profiles for components
c) go further to ensure good quality facilities are provided to tenants
d) ensure window restrictors are installed where windows present a fall hazard to children
e) gather evidence to consider further measures which we could include in the revised DHS, (i) that homes are provided with floor coverings at the start of the tenancy, ii) consider whether new minimum standards on home security should be introduced
f) deal with systemic issues such as damp and mould in a more comprehensive way

The consultation also calls for views on:

a) a proposal to introduce best practice guidance to sit alongside the DHS, including information to landlords on some of the ways in which they could choose to go further than the minimum standard set by the DHS
b) a proposal that the DHS becomes an enforceable requirement in privately rented homes from 2035 or 2037, and a regulatory requirement in social housing from 2035 or 2037
c) proposals for how regulatory and enforcing bodies should engage with landlords who are unable to meet the DHS for reasons relating to the property, their tenants, or the landlords

Table 1 summarises the potential changes to Decent Homes Standard

Criterion	Current DHS	Potential updates for DHS
Criterion A	A dwelling must be free of hazards at the most dangerous ‘category 1’ level	No changes
Criterion B	A property fails if one or more key building components are old and in disrepair; or two or more other building components are old and in disrepair	Failure is based solely on the condition of components, not the condition and their age The lists of key and other building components are expanded
Criterion C	A property fails if it lacks three or more facilities, e.g. adequate kitchen which is less than 20 years old or bathroom which is less than 30 years old	Properties must provide at least three of the core facilities to be decent (see proposal 2). Bathroom and kitchen age is no longer a reason for failure Window restrictors added to list of essential facilities Potential additions: Consider if secure doors and windows be added to the list of essential facilities. Consider if floor coverings should be provided at the start of a tenancy
Criterion D	A dwelling must have both efficient heating and effective insulation	A dwelling must meet relevant Minimum Energy Efficiency Standards and have programmable heating
Criterion E (new)	No specific damp & mould requirement	Landlords should ensure their properties are free from damp and mould.

Introduction

Why is decency important?

All tenants in rented accommodation should expect their home to be safe, secure and good quality. Living in poor housing conditions can have a significant impact on our health, educational outcomes, productivity, career prospects, and the contribution we can make to our communities. The Building Research Establishment (BRE) has estimated that the costs to the NHS, plus the wider societal costs brought on by poor housing (including those relating to long-term care, mental health, and poorer educational outcomes), are £18.5 billion every year^{[footnote 1]}. In 2010, the Marmot Review found housing conditions to be an increasingly significant driver of health inequality^{[footnote 2]}. 

Since the introduction of the DHS by the Labour government in 2001, there has been a reduction in the proportion of social rented sector homes that fail the standard, from 38% in 2001^{[footnote 3]} to 10% in 2023^{[footnote 4]}. In the private rented sector, 21% of homes were classed as non-decent in 2023. Privately rented homes have never been required to meet the decent homes standard and are generally older^{[footnote 5]} than those in the social rented sector. High demand means that there may be limited financial incentive for landlords to improve the quality of their properties.

BRE found that in 2019 almost 1 in every 8 private rented homes, around 619,000 homes, contained a health and safety hazard at the most serious “category 1” level.^{[footnote 6]} It is estimated that the illness or injury posed by these hazards costs the NHS around £290 million per year. In the social rented sector, the equivalent figures are 217,000 (5%) of homes with a serious “category 1” hazard, costing the NHS £65 million per year.^{[footnote 7]}

Health problems caused by poor housing conditions can increase absenteeism and unemployment, as people are left unable to work while they recuperate from illnesses or injuries caused by accidents or hazards in their homes. The recovery time from an illness or injury varies, but analysis indicates that the average loss to the economy per injury from a home hazard was around £1,495 in 2019 prices^{[footnote 8]}.  

It is in this context that we have promised to take action to ensure all homes are safe and decent. Recent evidence from high profile cases, including the coroner’s report into the tragic death of two-year-old Awaab Ishak due to the damp and mould in his home, has highlighted the importance of setting a minimum standard of decency for all rented homes and making sure this is clear, adequately understood, followed and enforced. That is why we are updating the Decent Homes Standard, extending it to the private rented sector, and applying Awaab’s Law to both the social and private rented sector.

Section 1 – Policy Context and Background

What is the Decent Homes Standard?

The DHS was first implemented in 2001, and last updated in 2006, acting as a technical standard specifying minimum criteria that social landlords must meet to ensure their properties are decent. The DHS is one of several regulatory standards applicable to the social housing sector relating to how landlords govern their organisations and finances and provide services to tenants.

Beyond basic health and safety requirements, the DHS defines the features of a decent rented home, including effective heating and insulation, the facilities that should be available, and the general state of repair. The DHS is structured to provide clear thresholds for social landlords to take action to improve their stock over time, for example by requiring landlords to upgrade kitchens and bathrooms after a stated period to keep facilities up to a reasonably modern standard.

For a dwelling to be considered “decent” under the current DHS it must:

a. be free from health and safety hazards at the most dangerous “category 1” level (as assessed using the Housing Health and Safety Rating System (HHSRS). See more on HHSRS below.
b. be in a reasonable state of repair
c. have reasonably modern facilities and services
d. provide a reasonable degree of thermal comfort

The current DHS guidance (issued in 2006): A decent home: definition and guidance

How is decency measured?

While the DHS currently only applies to social housing, it is the benchmark for decency across all tenures. Data on compliance with the standard is collected by the English Housing Survey (EHS). The EHS is a continuous national survey commissioned yearly by the Ministry of Housing, Communities and Local Government since 1967. It collects information about people’s housing circumstances and the condition and energy efficiency of housing in England. While properties in the private rented sector are not currently required to meet the DHS, data on private rented sector properties along with homeowner properties are also captured by the EHS.

Private registered providers of social housing (e.g. housing associations) are also expected to report on their own compliance to the Regulator of Social Housing (RSH) via the annual Statistical Data Return^{[footnote 9]}, and local authorities self-report their compliance to MHCLG via the annual Local Authority Housing Statistics^{[footnote 10]}. All registered social housing providers must annually publish the proportion of their homes that do not meet the DHS as one of the Tenant Satisfaction Measures^{[footnote 11]}. This information must be made available to tenants in a timely, clear and accessible manner.

The Decent Homes Standard in social housing

In the social rented sector, the RSH regulates the DHS through its Safety and Quality Standard. This requires registered providers of social housing (both local authorities and housing associations) to meet the standard set out in section five of the government’s guidance on DHS. Since 1 April 2024, the RSH proactively seeks evidence and assurances that social housing providers are delivering the outcomes set out in its consumer standards, including meeting the Safety and Quality Standard. Providers are expected to understand the condition of their stock and are subject to programmed inspections. Should the DHS be updated following this consultation, the government will issue a direction to the Regulator of Social Housing to set a new standard requiring social housing providers to meet the new DHS.

In addition, if a tenant in social housing believes their home does not meet the DHS, they can raise a complaint with the Housing Ombudsman Service (HOS) if the landlord has first been given an opportunity to respond to the complaint. This is a free, independent and impartial service set up by law to resolve disputes involving the tenants and leaseholders of registered social housing providers.  

The Decent Homes Standard in the private rented sector

The DHS does not currently apply to privately rented housing. However, landlords must ensure their properties are fit for human habitation and local authorities can take enforcement action against landlords whose properties contain serious hazards (see ‘Other Standards and Requirements’ section).

In 2022, a consultation took place on applying the DHS to the private rented sector (PRS). The proposals received broad support and we are publishing the responses alongside this consultation. We are now legislating to apply the Decent Homes Standard to the PRS through the Renters’ Rights Bill, including expanding the enforcement powers available to local authorities. For further details on how the DHS will be enforced in the PRS see Section 6 – Implementing the Decent Homes Standard.

Once this consultation has concluded, the government will confirm the details of the standard that will apply to the PRS in regulations. Our intention is, as far as possible, to set a common standard across the private and social rented sectors.

Other Existing Standards and Requirements

While the DHS currently only applies to the social rented sector, other legislation and regulation applies to landlords of both tenures. These measures complement and reinforce the DHS.

Housing Act 2004^{[footnote 12]}

Part 1 of the Housing Act 2004 applies to all tenures. Under this legislation, private and social landlords letting out properties containing ‘category 1’ hazards may face enforcement action.

Hazards are assessed using the Housing Health & Safety Rating System (HHSRS). The HHSRS was introduced in 2006 and covers 29 potential hazards found in the home. An assessment under the HHSRS evaluates the risk of harm and uses this to rate the seriousness of any hazard identified. It does not set a minimum standard (i.e. a ‘pass mark’) but instead generates a score that falls into one of ten bands from A to J, with A being the most dangerous and J the least.

Hazards scored at bands A, B or C are ‘category 1’; bands D to J are ‘category 2’. Broadly, a ‘category 1’ hazard means that if the hazard is not removed there will be a need for someone to receive medical attention in the next 12 months.

Homes (Fitness for Human Habitation) Act 2018^{[footnote 13]}

If social and privately rented homes are not ‘fit for human habitation’, tenants of both tenures can take their landlords to court under the Landlord and Tenant Act 1985 (as amended by the Homes (Fitness for Human Habitation) Act 2018). The court can make the landlord carry out repairs or put right health and safety problems and can make the landlord pay compensation to the tenant.

Other requirements

All rented accommodation must meet standards for the testing of gas installations and the provision of smoke and carbon monoxide alarms^{[footnote 14]}. Landlords must also assess risks associated with asbestos^{[footnote 15]} and water safety (legionella)^{[footnote 16]}. Minimum energy efficiency standards^{[footnote 17]} and the testing of electric installations^{[footnote 18]} apply to the private rented sector.

Wider housing quality reforms

Updating the Decent Homes Standard is one of several measures the government is updating or putting in place to improve the quality of homes. Our proposals for the content and implementation of the Decent Homes Standard have considered the interactions between these measures.

Awaab’s Law

Awaab’s Law sets statutory timescales for landlords to respond when tenants report serious hazards in their properties. We laid draft regulations in Parliament on 25 June 2025 to introduce the first phase of Awaab’s Law in the social rented sector. Awaab’s Law is being introduced via a phased approach^{[footnote 19]}:

• From October this year, social landlords will be required to repair all emergency hazards within 24 hours and fix dangerous damp and mould within fixed timescales

• In 2026, requirements will expand to apply to a wider range of hazards. We expect these to include excess cold and heat, falls, structural collapse, fire, electrical hazards and explosions, and hygiene hazards

• In 2027, requirements will expand to apply to the remaining hazards defined by the HHSRS (excluding overcrowding)

This phased approach is intended to allow for a period of testing and learning to ensure Awaab’s Law is being delivered in a way that benefits social housing tenants and secures the lasting legacy for which Awaab Ishak’s family have fought so hard^{[footnote 20]}.

The Renters’ Rights Bill will extend Awaab’s Law to the private rented sector, and we will consult on the approach for giving effect to Awaab’s Law in privately rented homes in due course.

Minimum Energy Efficiency Standards

Energy efficient properties are warmer, providing tenants with homes that are more comfortable and less susceptible to damp and mould. Improving the efficiency of a property also reduces household bills, taking households out of fuel poverty and supporting the transition towards decarbonisation.

Minimum Energy Efficiency Standards (MEES) set a baseline standard of energy efficiency for rented properties. MEES currently only apply to the PRS, where properties are required to reach band E as assessed by the Energy Performance Certificate (EPC) system. A number of reforms to this system are proposed or underway:

• On 4 December 2024, government published a consultation on ‘Reforms to the Energy Performance of Buildings Regime’. The government response will be published in due course. This consultation proposes reforms to enhance the building energy performance regime in 5 areas:

  • updating EPC metrics
  • refining requirements for EPCs and Display Energy Certificates (DECs)
  • improving data management protocols
  • strengthening quality control
  • revising Air Conditioning Inspection Reports (ACIRs)

• a consultation on changes to PRS MEES closed on the 2 May 2025. This proposed a requirement for privately rented homes to reach EPC C or equivalent by 2030, in line with commitments in the Labour manifesto

• alongside this consultation, we are also launching a consultation on requiring all SRS properties to reach EPC C or equivalent by 2030, which will close on 10 September 2025.

• the government also intends to engage with industry on a Home Energy Model (HEM) methodology for producing EPCs in 2025

The outcome of these consultations will affect the elements of the Decent Homes Standard which relate to energy efficiency and thermal comfort (criterion D). See Section 3 for further details.

The Housing Health and Safety Rating System (HHSRS) Review

In 2020 the government of the time commissioned a review of the HHSRS. This focused on making it easier to use and understand. Recommendations included a more intuitive way of making assessments, amalgamation of some hazards, new guidance and a bank of case studies to support inspectors and landlords in assessing risks.

This government is considering the outcomes of the review, but new regulations would be required to bring the review’s conclusions into force. It is important to note that these changes, if brought forward, do not affect landlord’s responsibilities with regards to the standards.

Renters’ Rights Bill

As well as applying the DHS and Awaab’s Law to the private rented sector, the Renters’ Rights Bill will introduce several measures that will help tenants to challenge poor conditions in their homes:

• ending section 21 ‘no-fault’ evictions will provide security for tenants and empower them to challenge poor practice
• the creation of a Private Rented Sector Database will help landlords understand their legal obligations and demonstrate compliance while providing better information to tenants. It will also support local councils target enforcement activity where it is most needed
• the introduction of a new Private Rented Sector Landlord Ombudsman Service will provide fair, impartial, and binding resolutions to many issues, providing an alternative to costly and time-consuming court processes

Section 2 – The Decent Homes Standard Review

A range of stakeholders have contributed to the review. We have considered implications for the social rented sector and the private rented sector. Our engagement included a series of sounding boards, workshops and calls for written evidence.

We heard from stakeholders, including tenants and landlords that issues with the current DHS include:

• the need to update the standard to work in the private rented sector as well as the social rented sector
• the failure of the current standard to adequately protect against unacceptable levels of damp and mould
• criticisms that the current standard fails to prevent serious disrepair
• concerns about tenant safety (e.g. tackling the risk of falls from windows and excess cold)
• the need to amend Criterion D, which sets out requirements on thermal comfort, and is very outdated

Another key theme that emerged was the importance of a common-sense DHS, easy to understand and enforce. Stakeholders, particularly tenants, highlighted the need to limit “jargon” as much as possible so that the standard is understandable to all readers.

The importance of ensuring it is proportionate was raised as the DHS sets out the minimum expected standard for rented properties. Stakeholders suggested that it would be helpful to also have non-statutory guidance on how landlords can go beyond this, but which would not be regulated or enforced against. Aligning the DHS and accompanying guidance with existing and new regulations was also a priority for stakeholders to limit potential confusion and make sure the introduction of the DHS is as smooth as possible.

This feedback has shaped our work to redefine the DHS and to develop the proposals outlined for comment in this consultation.

Section 3 – Proposed changes to the DHS

Changing the DHS

We need to update the DHS. The current version includes information that is out of date (e.g. specifications for insulation are not in line with current requirements). The current DHS was designed for stock management and would not work well for local authorities to enforce against individual properties in the PRS.  

We consider that the basic structure of the current DHS is just as relevant as it was 20 years ago when the DHS was last updated. In our proposals, we set out how we can build on the current DHS to ensure any additional regulation is targeted to support innovation, improve housing quality and critically, make sure that the DHS is widely recognised and understood by tenants and landlords alike.

Specific proposals for an updated DHS

We do not propose changing Criterion A of the DHS.

Criterion A: Homes meet the current statutory minimum standard

• Dwellings which fail to meet this criterion will continue to be those containing one or more hazards at the most dangerous ‘category 1’ level, assessed using the Housing Health and Safety Rating System (HHSRS).
• The government is considering the outcomes of the HHSRS review that concluded in 2022. It is important to note that any changes to the HHSRS following the review, if brought forward, would focus on making the tool more intuitive to use. The review’s recommendations would not change landlords’ responsibilities under criterion A of the DHS.

We are consulting on proposed changes in the following areas with further detail on each proposal set out in the subsequent sections:

Criterion B: Homes meet a reasonable state of repair

There is support for maintaining properties in a good state of repair beyond addressing immediate risks to health and safety. Tackling repairs early will reduce hazards before they arise. This supports landlords to manage their repair programmes, and signals to tenants what they should expect in their home. We propose making some changes to the way that disrepair is defined. Specifically, we propose:

• Proposal 1: Updating the way in which disrepair is measured, removing age requirements, updating the thresholds used to define that a component is in poor condition and updating the list of building components which must be kept in reasonable repair (where present in the building already).

Criterion C: Homes have reasonably modern facilities and services

The current DHS sets out the modern facilities and services that landlords must provide to meet the DHS. These facilities are essential for a basic standard of living with some additions focused primarily on safety and security. We propose:

• Proposal 2: Removing the maximum age requirement for kitchens and bathrooms to align with proposal 1 in criterion B and revising the approach to the list of core facilities that need to be provided before it fails to meet criterion C.  
• Proposal 3: To improve safety and reduce the risk of falls from windows, for example by children, by adding a new requirement for window restrictors to be installed  

We are also considering whether to include new measures regarding security and floor coverings.  Therefore, we propose:  

• Proposal 4: Seeking views on whether we should add a new requirement that suitable floor coverings are provided in all rooms at the start of a tenancy.  
• Proposal 5: Seeking views on whether there should be a new requirement that new doorsets and windows must meet security standards at the point of replacement.

Criterion D: Homes provide a reasonable degree of thermal comfort

Having a home that is warm and cheaper to heat is important to tenants and goes beyond addressing pure safety risks (as included in the HHSRS). These objectives also align with government commitments to reduce fuel poverty and reduce carbon emissions. We propose:

• Proposal 6: Extending existing DHS heating requirements to cover the whole dwelling and remove many of the technical requirements specified in the DHS, instead linking to overall energy efficiency requirements.

Criterion E: Homes should be free of damp and mould (New criterion)

All homes should be free from damp and mould. It affects people’s health, primarily the airways and lungs, but also the eyes and skin. The respiratory effects can cause serious illness and, in the most severe cases, death. Damp and mould can also affect mental health due to worries about its health impacts, unpleasant living conditions, destruction of property and belongings, among other concerns. In this context and in light of significant research in recent years, we propose:

• Proposal 7: To meet the DHS, landlords should ensure their properties are free from damp and mould (supported by the HHSRS to measure compliance and enforcement)

Proposal 1: Updating the definition of disrepair (Criterion B)

Introduction and rationale

The DHS requires properties to be in a reasonable state of repair. We think there continues to be a strong case for maintaining properties in a good state of repair beyond addressing immediate risks to health and safety (e.g. tackling repairs early will reduce the occurrence of hazards). This supports landlords to manage their properties proactively, and signals to tenants what they should expect in their home.

This section sets out how we plan to define disrepair under an updated DHS and the building components that will need to be maintained to a reasonable state of repair to meet this requirement.

How does the current DHS define disrepair?

In the current DHS, the definition for which a dwelling satisfies this criterion is:

• one or more ‘key’ building components are old and, because of their condition need replacing or major repair; or
• two or more ‘other’ building components are old and, because of their condition need replacing or major repair.

At present, a building component can only fail to satisfy this criterion by being both old and requiring replacement or repair. A component cannot fail this criterion based on age or poor condition alone.

Building components are defined in the DHS as structural parts of the dwelling, external elements and internal services and amenities. “Key” building components are those which, if in poor condition, could have an immediate impact on the integrity of the building and currently include walls, roofs, windows, doors and some types of heating. If any of these components are old and need replacing, then the dwelling is not in a reasonable state or repair and remedial action is required.

“Other” building components are those that have a less immediate impact on the integrity of the dwelling and currently include kitchens, bathrooms and the central heating distribution system (the heating system itself is a key component). Their combined effect means a dwelling is not in a reasonable state of repair if two or more are old and need replacing or require immediate major repair.  

Criterion B applies to existing components only. Where a component listed in criterion B of the DHS does not exist in a building, it does not have to be added for the property to meet the standard. For example, chimneys are listed as a key component in criterion B; a house with a chimney that was old and in poor condition would fail to meet criterion B, conversely a house which had never had chimneys (because it was designed not to need them) would not fail to meet criterion B.

Updating the definition of disrepair

Currently, a building component is in disrepair where the component is both old and in poor condition. However, a broken roof, heating system, or other component has no less of a negative impact on the safety of a property – or on a resident’s experience of living in that property – simply because it has not yet reached the end of its expected lifetime. To address this, we propose removing age from the definition of disrepair so that building components don’t have to be old and broken to be in disrepair, only broken (poor condition).

This would benefit tenants, ensuring that they do not have to live with broken components just because they haven’t reached a certain age. This may lead to tenants living with old components that are replaced less frequently if they are still working but we think this risk is lesser than the risk that tenants have to live with broken components.

Engagement with stakeholders on extending the DHS to the PRS also indicated that it would be difficult to apply requirements on the age of components to this sector as, for example, a PRS landlord may not have information of when building components were installed if this had occurred before they purchased the property. The same argument was raised about the age of kitchens and bathrooms.

Furthermore, stakeholders identified that the age limit for kitchens and bathrooms in criterion B was too prescriptive and did not adequately take into account the functionality or condition of the fittings. They also questioned why the condition of showers is not considered in bathroom repair.

Defining ‘poor condition’ of building components (thresholds)

As set out above, an updated DHS will now focus much more on the condition of a property. Defining “poor condition” for building components must set a clear and reasonable bar for when a component needs to be repaired or replaced.

Currently when considering whether a building component is in poor condition, assessors should have regard to the following definitions set out below in Table 2, taken from Annex A of the DHS. Where a component meets or exceeds the listed criteria (percentage requiring repair and/or replacement), it is considered to be in ‘poor condition’. In 2001, these definitions were consistent with the English Housing Condition Survey (English Housing Survey) definitions. Social landlords are encouraged to use local judgement when considering repair or replacement programmes.   

We think the current approach is overly prescriptive and sets the bar too low. We propose replacing the current definitions for disrepair with a simple descriptive definition of each building component and the signs of poor condition set out below.

Table 2: An extract from the current DHS 2006 guidance (Annex A)

To note: Definition of ‘poor condition’ used in English Housing Condition Survey

Building Component	Definition of ‘poor condition’ used in disrepair criterion b)
Wall structure	Replace 10% or more or repair 30% or more
Wall finish	Replace/repoint/renew 50% or more
Chimneys	1 chimney need partial rebuilding or more
Roof structure	Replace 10% or more or strengthen 30% or more
Roof covering	Replace or isolated repairs to 50% or more
Windows	Replace at least one window or repair/replace sash or member to least two (excluding easing sashes, reglazing painting)
External doors	Replace at least one
Kitchen	Major repair or replace 3 or more times out of the 6 (cold water drinking supply, hot water, sink, cooking provision, cupboards, worktop)
Bathroom	Major repairs or replace 2 or more items (bath, wash hand basin, WC)
Electrical system	Replace or major repair to system
Central heating boiler	Replace or major repair
Central heating distribution	Replace or major repair
Storage heaters	Replace or major repair

Additions to the list of buildings components that must be kept in a good state of repair

In line with our updates to the definition of disrepair, we are expanding the list of building components that must meet this requirement. 

In our engagement, we heard concerns from stakeholders about the current building component list and that it didn’t go far enough. Tenants in particular felt that there were missing elements from the current list of building components that need to be kept in good repair such as communal lifts and fire safety measures.

We considered whether the differentiation between components should be removed completely, with a property failing the DHS if any component is in disrepair whether ‘key’ or ‘other’. However, we want to ensure that the DHS remains proportionate. Given the potential expanded list of building components, removing the “key” / “other” differentiation could lead to a property failing the DHS for something as simple as a blocked gutter. We therefore propose maintaining this differentiation but amending the definition of ‘key’ so that it doesn’t only relate to structural elements. We have set out below which new components would be “key” and which would be “other”.

Proposals

This consultation proposes the following:

Age requirement​

We propose removing the age requirement from the definition of disrepair so that building components don’t have to be old and broken to be in disrepair, only broken. This will help protect tenants having to live with broken components and support landlords in maintaining their stock.

Defining ‘poor condition’

We are seeking views on whether it would be more practical to replace current thresholds for disrepair with a simple descriptive definition of each building component and the signs of poor condition. We have been told that descriptive definitions will enable tenants and landlords to make a simpler and more straightforward assessment of the condition of individual building components.   

This new use of a more descriptive definition of disrepair will ensure that components are structurally sound, free from significant damage or deterioration and fit for their intended use. The tables below set out suggested definitions, which would be a regulatory requirement rather than guidance. We are particularly interested in the views of surveyors and regulatory bodies to ensure that these definitions support sensible judgements of poor condition.

Building Component List

This consultation proposes amending the following components:

• heating technology: Replace the specified types of heating and distribution systems with a general “key” component to cover all types of heating systems
• kitchens and bathrooms: Upgrade to “key” components (meaning that kitchen or bathroom disrepair alone would be enough to fail the DHS)
• kitchens and bathrooms: Remove the maximum age

This consultation proposes adding the following components to the building components list. This would mean that where the component already exists in the property, it would be required to be maintained in a reasonable state of repair (as set out by the revised definition of repair). This is not a requirement that the components listed need to be added to all properties.

• bathroom components: add freestanding showers (key). Please note: a freestanding shower or a bath would be required to be in a reasonable state of repair to meet the DHS, not both
• fire safety: add internal doors, fire alarm systems, sprinkler systems, signage (all key)^{[footnote 21]}
• damp and causes of damp: add damp proof courses to the definition of the wall structure components and add ventilation installations (key), add rainwater goods i.e. all products installed on the exterior of a building to protect it from the rain (other)
• safe access: add lifts (key), add balustrades, handrails and stair-treads (other)
• internal finish: add internal wall and ceiling finish (key)
• security: add door entry systems (other)
• shared outdoor spaces (for social rented sector properties only): add boundary walls, curtilage, pathways and steps, external lighting, bin stores (all other)

We propose shared outdoor space additions apply only to the social rented sector as private rented sector landlords don’t usually have control over these areas, whereas social rented sector landlords tend to be larger and are more likely to be responsible for an entire block of flats or estate. Social landlords would only be expected to maintain areas they are responsible for.

For “key” components, only one needs to be in a state of disrepair for the property to fail the DHS. For “other” components, two or more must be in a state of disrepair for the property to fail the standard.

As outlined above, we plan to update the way in which disrepair is defined for building components. Below (in tables 3, 4a and 4b) are the suggested definitions of disrepair for each of the existing and new components.

Components’ Definitions of Disrepair

Table 3: Proposed updates to definitions for ‘Key” components within the current DHS

Component (all ‘key’ components)	Proposed updated definition of disrepair for reformed DHS
Wall structure (key) - including lintels, brickwork, damp proof courses and external wall finish	Not structurally sound or not weather tight. Problems with the wall structure could include: vertical or diagonal cracking, inadequate expansion joints or inadequate fixings between components, wall tie corrosion, twisted, cracked, overloading or slipped lintels due to settlement, bowing of walls and over sailing of walls at Damp Proof Course (DPC) level. External wall finishes include: pointing to fair faced masonry, brickwork or block work; a coating applied to the wall structure including all renders such as pebble dash and similar proprietary surface treatments; clay or concrete tiles mechanically fixed to wall structure; brick slips or mosaic tiles applied to concrete panels; all forms of plastic, laminates and thin metal sheets.
Internal wall and ceiling finish (key)	Plaster requires major repair. Problems could include: significant crumbling or unbonded plaster; extensive or serious cracking of plaster; walls being structurally unsound.
Chimneys (key)	Not structurally sound or not weather tight. Problems with the chimneys could include: broken, unseated or unsafe pots; leaning stacks; unsafe chimney heads; decayed brick/masonry structure; and defective pointing.
Roof structure (key)	Not structurally sound or not weather tight. Problems with the main roof could include: sagging of roof structure; ponding of water on flat roofs; humping of the roof over internal load bearing walls and/or party walls; and spreading outwards of the roof structure at the eaves.
Roof covering (key)	Not structurally sound or not weather tight. Problems with principal roof covering and roof edges could include: missing, broken or slipped slates or tiles; broken or slipped ridge tiles and hips; and torn or cracked flat roof coverings.
Windows (key)	Not weather tight, unable to make secure / lock, unable to use properly (i.e. open and close). Problems could include: distorted or unseated window frames; rotted sills or sub sills; broken panes of glass; corroded, rusting or rotten ironmongery; and defective, damaged or missing seals or putty where they cause the window to leak or stop it from being secured or locked.
External doors (key)	Not weather tight, unable to make secure / lock, unable to use properly (i.e. open and close). Problems could include: distorted or unseated door frames; rotted sills or sub sills; broken panes of glass; corroded, rusting or rotten ironmongery; and defective, damaged or missing seals or putty where they cause the window to leak or stop it from being secured or locked.
Kitchen (key)	Major repairs required or more than one of the following items need to be replaced: cold water drinking supply; hot water; sink; cooking provision; cupboards and worktop. All components must be in a usable condition.
Bathroom (key)	Major repairs required or more than one of the following items need to be replaced: bath or freestanding shower; wash hand basin; WC. All components must be in a usable condition.
Electrical system (key)	Requires replacement or major repair. The electrical system in the property must not be dangerous to the inhabitant as indicated by: broken casings; damaged power socket boxes; exposed wiring; and other obvious signs of damage, disrepair or unauthorised alterations, especially to the consumer/meter units.
Heating system (key)	Requires replacement or major repair. The heating system in the property must not be dangerous to the inhabitants as indicated by problems such as: wall mounted boilers in danger of detaching; rusted boilers or tanks; leaking oil tanks or pipes; holes in gas flues; balanced gas flues with unsafe guards; balanced gas flues with incorrectly positioned guards; and smell of gas/oil around boiler. The references to gas systems apply to all gas-fired central heating boilers and balanced flue room heaters, as well as conventionally flued gas room heaters and fires, and gas room heaters with back boilers.

Table 4a: List of building components that are proposed to be added to the DHS that must be kept in good repair and compliant with relevant fire safety legislation

New component	Proposed definition of disrepair for reformed DHS
Fire alarm systems (key)	Requires replacement or major repair Problems could include: alarm system visibly tampered with or damaged; alarm failing to sound when tested.
Sprinkler systems (key)	Requires replacement or major repair Problems could include: fixtures visibly tampered with or damaged; fixtures being insecurely fixed; system failing when tested.
Fire Safety Signage (key)	Requires replacement or major repair. Damage that inhibits the user’s ability to read the information. Problems could include: significant signs of wear on signage; signage removed or defaced; emergency light fittings not working.
Internal doors (key)	Requires replacement or major repair Problems could include: distorted or unseated doors and frames; rusting or rotten ironmongery; missing hardware.
Damp proof courses (key)	Included in “wall structure” component definition above
Mechanical ventilation (key)	Requires replacement or major repair Problems could include: ventilation unit being inappropriately or insecurely fixed to the wall; unit not operating despite being switched on.
Lifts (key)	Requires replacement or repair. This could include: repairs to shaft, car, doors, call panel or control panel.
Internal wall and ceiling finish (key)	Plaster requires major repair. Problems could include: significant crumbling or unbonded plaster; extensive or serious cracking of plaster; walls being structurally unsound.
Rainwater goods (other)	Requires replacement, repair or major unblocking. Problems could include: cracked or corroded gutters or downpipes; loose or defective brackets; missing fittings; blockages restricting water drainage.
Balustrades, handrails and stair treads (other)	Requires replacement or repair. Problems could include: insecurely or inappropriately attached components which are unable to withstand reasonable force.
Door entry systems (other)	Requires replacement or repair. Problems could include failure to lock / unlock communal door. Broken elements (entry phone, buzzer, camera, screen) where present.

Table 4b) For social rented sector properties only: A list of building components that are proposed to be added to the DHS that must be kept in good repair and compliant with relevant fire safety legislation

New component	Proposed definition of disrepair for reformed DHS
Boundary walls (other)	Not structurally sound. Problems could include: risk of falling materials from boundary walls; wall unable to withstand reasonable force; loss of structural integrity.
Curtilage (other) Curtilage is the enclosed land immediately surrounding a property, including any closely associated buildings and structures. This includes gardens, bike sheds and bin stores.	Not safe for residents. Problems could include: significant tripping hazards such as uncovered holes or loose steps, risk of falling objects from buildings and structures. For bike sheds and bin stores, problems could include: access doors / gates not functional.
External pathways and steps (other)	Damaged in a manner that restricts residents’ ability to access buildings. Problems could include: obstructions; cracked pathways or loose steps that may cause trips and falls.
External lighting (other)	Requires replacement or repair to 2 or more lights. There must be adequate common or public lighting in the block/outside the property so that tenants are not at risk of falling.
Bin stores (other)	No safe access for residents. Problems could include: access doors / gates not able to be fully opened or closed by users; where the bin store is an enclosed room cracks or gaps are present allowing entry of vermin; bin stores in unsanitary / unhygienic condition; space not adequately lit.

Questions

Question 11:

Do you agree that age should be removed from the definition of disrepair?

Yes/No/Don’t know

Question 12:

Do you agree that the thresholds used to define disrepair for each component should be updated to reflect a more descriptive measure as proposed?

Yes/No/Don’t know

Question 13:

Do you agree that the number of items or components which must require major repairs for the component to be considered in disrepair should be reduced?

Yes/No/Don’t know

Question 14 (Landlords only):

Do you think that that removing age as a consideration from disrepair would lead to less planned maintenance of your properties and more reactive repairs carried out in response to issues raised by tenants?

Yes/No/Don’t know/Not applicable 

Question 15:

Do you agree that kitchens and bathroom components should be considered as “key” i.e. one or more in disrepair would cause a property to fail the DHS?

Yes/No/Don’t know

Question 16:

a) Do you agree with the proposed list of building components that must be kept in good repair?

Yes/No/Don’t know

b) If you have any views on this specific question you would like to share, please do so here

Open Text 

Question 17:

Do you agree with the proposed “key” components and “other” components as listed?

Yes/No/Don’t Know

Question 18:

a) Do you agree that the suggested additional components that relate to the public realm (boundary walls, curtilage, pathways and steps, signage, external lighting, bin stores) should only apply to the social rented sector?

 Yes/No/Don’t know

b) If you have any views on this specific question you would like to share, please do so here

Open text

Question 19:

If you have any views on these specific questions you would like to share, please do so here

Open text

Proposal 2: Facilities and services (Criterion C)

Introduction and rationale

Criterion C of the DHS requires a property to have reasonably modern facilities and services.  

What does the current DHS say about modern facilities?

Section 5, Paragraph 17 of ‘A Decent Home: Definition and guidance for implementation’ ^{[footnote 22]} states that: A dwelling is considered not to meet this criterion if it lacks three or more of the following facilities:

• a kitchen which is 20 years old or less
• a kitchen with adequate space and layout
• a bathroom which is 30 years old or less;
• an appropriately located bathroom and WC
• adequate external noise insulation
• adequate size and layout of common entrance areas for blocks of flats

More specifically, in line with the way the DHS has been measured in the English Housing Survey, this means:  

• A kitchen failing on adequate space and layout would be one that is too small to contain all the required items (sink, cupboards, cooker space, worktops, etc.) appropriate to the size of the dwelling. The kitchen is not required to be a separate room, as long as it has adequate space and layout to function
• An inappropriately located bathroom and WC is one where the main bathroom or WC is located in a bedroom or accessed through a bedroom (unless the bedroom is not used or the dwelling is for a single person or “household”). A dwelling would also fail if the main WC were external or located on a different floor to the nearest wash hand basin, or if a WC without a wash hand basin opens on to a kitchen in an inappropriate area, for example next to the food preparation area
• Inadequate insulation from external airborne noise would be where there are problems with, for example, traffic (rail, road and aeroplanes) or factory noise. Landlords should ensure reasonable insulation from these problems through installation of appropriate acoustic glazing in line with the current Building Regulations. This requirement does not cover insulation to address noise from internal sources, such as insulation between flats
• Inadequate size and layout of common entrance areas for blocks of flats would be one with insufficient room to manoeuvre easily, for example where there are narrow access ways with awkward corners and turnings, steep staircases, inadequate landings, absence of handrails, low headroom, etc

As set out in proposal 1 (above), we propose removing the age requirement for kitchens and bathrooms. This means that the requirements in criterion C regarding kitchens and bathrooms would only relate to its space and layout. We propose strengthening requirements regarding the condition and state of repair of kitchens and bathrooms by making them “key” building components in criterion B, as set out in proposal 1 (above).

It should be noted that this consultation also proposes updates to the list of facilities in criterion C to make sure that it reflects modern expectations of what all homes should provide and measures whether facilities are adequate in the right way. The proposed changes to the list of facilities are set out below in proposals 3 to 5.

Proposal

We propose a dwelling must provide at least 3 of the following facilities to be considered decent:​ 

• a kitchen with adequate space and layout​ 
• an appropriately located bathroom and WC ​ 
• adequate external noise insulation​ 
• adequate size and layout of common entrance areas for blocks of flats 

We are particularly interested in hearing views on what core facilities listed might be challenging for landlords to achieve. We also want to hear from tenants on whether they would prioritise certain facilities over others.

Questions

Question 20:

a) Do you agree that under the new DHS landlords should be required to provide at least three out of the four facilities listed?

Yes/No/Don’t know. If responded No, please provide supporting details.

b) If you said No, are there any of the facilities that you would prioritise?

(Please select all that apply) Kitchens / Bathrooms / Noise Insulation / Communal Areas

c) Do you believe that the “multiple choice” nature of Criterion C (i.e. landlords must provide at least three out of the four facilities listed) could lead to any practical implications for tenants, landlords and/or organisations responsible for regulating/enforcing the standard?

Yes/No/Don’t know If you responded Yes, please provide supporting details.

d) If there is anything else you would like to add on this specific proposal, please do so here

Open text

Proposal 3: Window restrictors (Criterion C)

Introduction and rationale

We want all tenants to feel safe in their homes. In 2023/24, there were around 3,500 hospital episodes due to falls from or out of buildings and structures in England, including 614 children under 15.^{[footnote 23]} Several studies have found falls from windows to be the most frequent fall related incidents.^{[footnote 24][footnote 25]} A review of children admitted to a trauma centre in North West England with neurological injuries found that the most common cause of injury was falls, including 19% from open windows. Of the 25 children they treated after falls from windows in the years 2015-2020, three died, and half were left with permanent disabilities.^{[footnote 26]} The average treatment cost for their time in hospital was £9,300, not including the costs of longer-term physiotherapy/occupational therapy or other care required to manage resulting disabilities.^{[footnote 27]}

The current DHS requires that homes are free from health and safety hazards at the most dangerous ‘category 1’ level, and this includes “falls between levels” hazards. The HHSRS operating guidance^{[footnote 28]} recommends that where windows above ground floor level poses a danger to a child being able to open a window unsupervised that catches which restrict the opening to 100mm should be fitted to reduce the possibility of an accident. However, no specific requirements in the current DHS are made to address issues relating to window safety in relation to falls.

Given the evidence set out above, we consider there is a case to go beyond the existing baseline of being free of a Category 1 level “falls between levels” hazard by adding a window safety requirement in the DHS.

What do building regulations say about window safety? 

For new dwellings, building regulations require that building designs factor in the risk of falls from windows. For example, Approved Document K (Protection from falling, collision and impact)^{[footnote 29]} provides guidance on guarding to give barrier protection. Where there is a change in level of over 600mm in and around a dwelling, pedestrian guarding should be provided to the edges of floors, stairs, landings and ramps. This includes the edge below an opening window. The guidance states that guarding should be provided to a minimum height of 800mm from finished floor level. The guidance also notes that where a person may fall through a window above ground level, the provision of suitable window limiters to restrain the window should be considered to prevent falls.

However, a recent study published by HSE ^{[footnote 30]} recommends raising the minimum guarding height in building regulations guidance to 1100mm to protect nearly all adults, compared to 800mm which protects less than 1% of the adult population. All Approved documents are currently being reviewed as part of a wider fundamental review of building safety regulations guidance announced last year by the government.^{[footnote 31]}

Approved Document O (Overheating)^{[footnote 32]} already recommends a guarding height of 1100mm for windows that can be opened wider than 100mm and the change in floor level between the inside and the outside is more than 600mm. In line with Part O and HSE’s recently published study on guarding heights, this consultation is proposing a guarding height of 1100mm where window restrictors are to be fitted and would welcome respondents’ views on this recommendation.

As most rented properties were built before the current building regulations were introduced, it is unreasonable to expect that windows in all existing rented properties meet modern safety standards regarding guard heights or other design features. Where windows in existing properties are easily accessible, wide opening, and at a dangerous height above the ground, window restrictors (also called latches or catches) are a safety feature that can be added to limit the size of the opening and prevent children or vulnerable persons from falling. Window restrictors are largely supported as a cheap and easy method of reducing this risk. The Royal Society for the Prevention of Accidents (RoSPA)^{[footnote 33]} and The Child Accident Prevention Trust (CAPT)^{[footnote 34]} amongst others recommend the use of restrictors to prevent children from falling from buildings. Additionally, we heard from stakeholders that installing window restrictors could also provide an additional benefit in reducing anxiety for parents and carers living in high rise properties.

We also heard concerns about some risks associated with window restrictors. In particular, that restrictors may restrict air flow into a property, risking overheating in hot weather, or that they could help compound any existing problems in the property with damp and mould due to restrictions on ventilating a room. There were also concerns raised that any policy on the installation of window restrictors could compromise fire safety.

We acknowledge these concerns and have engaged with the National Fire Chiefs Council, Home Office and the Health and Safety Executive on the issues raised to ensure that any introduction of this requirement could be done safely. During these discussions it was identified that the fire service do not generally approve of the use of windows as a means of escape unless the window(s) has been designed and installed in line with relevant fire safety regulations for that purpose in the event of a fire.

Our proposal is to require window restrictors that are child resistant which can be overridden by an adult, where required. The ability to manually override the restrictor will also allow for wider opening of the window for the purposes of cooling the property when necessary. We would also set out in the DHS and any guidance supporting the Standard that any works such as the installation of window restrictors in dwellings should align with relevant building regulations and relevant fire safety regulations and that fire risk assessments should be updated to reflect any relevant changes made to dwellings. Guidance would also set out that landlords should adequately inform adults/responsible occupants how to override the window restrictors.

Proposal

Require that all rented properties must provide child-resistant window restrictors, which can be overridden by an adult, on all windows which present a fall risk for children.

We define windows which present a fall risk to children (as stated in building regulations) as:

• where the change in floor level between the inside and outside is more than 600mm
• the window can be opened over 100mm; and
• the guard height is less than 1100mm above internal floor level

This requirement would work in tandem with the existing requirement that properties must be free from Category 1 hazards to meet Criterion A of the DHS. The window restrictor policy sets a hard and fast rule to make sure the windows which are most likely to be a fall risk (because of their height and how easily they can be accessed) are made safer. The HHSRS assessment tool provides a more holistic assessment of the risk of ‘falls between levels’ which considers a broader range of factors, such as the type of surface an occupant would land on if they fell, for example, a hard concrete surface or onto spiked railings. This will act as a ‘backstop’ for any windows that would not be covered by the proposed policy to mandate window restrictors but where there is still a risk of serious injury as the result of falls. In these instances, landlords would still be required to take steps to make the window safe – either through installing window restrictors or other suitable measures.

Questions

Question 21 (Landlord only):

Do you currently provide child-resistant window restrictors that can be overridden by an adult on dwellings with windows above ground floor?

All/some/none/don’t know/not applicable (select one please)

Question 22:

a) Do you agree with the proposal that all rented properties must provide child-resistant window restrictors that can be overridden by an adult on all windows which present a fall risk for children (as defined above including a recommended guarding height of 1100mm)?

Yes/No/Don’t know

b) If there is anything else you would like to add on this specific proposal, please do so here

Open text   

Proposal 4: Home security measures (Criterion C)

Introduction and rationale

We have heard through our engagement that home security reduces the risk of crime and allows tenants to feel safe in their homes. In this consultation we are seeking further evidence to determine whether to include additional requirements in a revised DHS in this area.

Home security is currently covered in the DHS by requiring that a home be free from health and safety hazards at the most dangerous ‘category 1’ level including “entry by intruders” hazards. Criterion B of the DHS also requires landlords ensure windows and external doors must be kept in good repair. We know that safety and security is a concern for tenants and as part of this consultation we are seeking views if we should consider additional home security requirements.

There is evidence to show that renters are currently more likely to experience burglary than owner occupiers. Research from Nottingham Trent University found that private renters experienced 63%^{[footnote 35]} higher burglary risk than owner-occupiers and that social renters experienced around 40%^{[footnote 36]} more burglaries and household thefts than owner-occupiers.

Proposal

We are seeking your views on whether we should consider additional requirements to the DHS on doors and windows as part of planned programme of works to replace. This requirement under consideration would apply to all easily accessible^{[footnote 37]} doors or windows that provide access into a dwelling from outside, into a building containing flats from outside, or into a flat from the common parts of a building.

Such a requirement would typically consider measures such as the ability to lock windows, and the presence of double locks and chains on door. Additionally, we would like respondents to consider whether as part of any programme of works or planned replacement of new doorsets^{[footnote 38]} and windows that they should comply with the higher standards in Approved Document Part Q^{[footnote 39]} of the Building Regulations. To note, compliance with Part Q is required for new dwellings but not when doors or windows are replaced in existing homes.

Questions 

Question 23:

The following questions relate to additional home security requirements in the DHS:

a) Do you think that home security requirements in relation to external doors and windows are sufficiently covered in the Decent Homes Standard? Yes/No/Don’t know

b) If you responded No to part a), should we consider additional security requirements in relation to external doors and windows in the Decent Homes Standard? Yes/No/Don’t know

c) If you responded Yes to part b), should we consider giving landlords the option to comply with Part Q requirements in Building Regulations?  Yes/No/Don’t Know

d) If there is anything else you would like to add about the impact of introducing additional home security measures (such as challenges, costs), please provide detail here Open text

Proposal 5: Suitable floor coverings (Criterion C)

Introduction and rationale

Currently there is no specific legal requirement for landlords to provide floor coverings in their properties.  We recognise that the cost of acquiring floor coverings can be a big expense for tenants and for those who simply cannot afford to install floor coverings, resulting in a home being harder to keep warm, less safe and more likely to cause noise issues for other tenants. Most private rented properties are let with floor coverings, however in the social rented sector, external evidence^{[footnote 40]} suggests a large portion of properties are let with bare floors. In this consultation we are seeking further evidence to determine whether to include additional requirements for floor coverings in a revised DHS. 

The rationale that homes in the social rented sector do not provide floor coverings varies including that social housing is considered a more secure tenure than private rented and therefore landlords choose to let properties unfurnished and without floor coverings to allow social housing tenants a choice on what floor coverings they want in their homes. Additionally, some social housing landlords have said that, unlike private landlords, they do not receive secure tenancy deposits and therefore they are unable to recoup some or all of the cost of floorings if they are damaged.

According to 2023 to 2024 data^{[footnote 41]} on social housing lettings, 261,000 households received a new let. Of these new lets, some social landlords will have removed usable floor coverings left by a previous tenant, including in cases where the new tenant asked if they could keep it. We have heard from some landlords that they do this because of concerns around the cleanliness of the flooring or safety issues, and about who may be liable if there were any problems with the flooring left in place.

Landlords have expressed concerns about the overall costs of providing, repairing and maintaining floor coverings and who those costs would fall to. However, there are examples of landlords retaining floor coverings which are in good enough condition and gifting these items to the new tenant if they wish to keep them and this practice is something we would urge landlords to consider more. We have heard too that some landlords run schemes which provide new floor coverings when properties are re-let to a small number of tenants who are in most need. In the private rented sector, tenancies are on average shorter and there are higher expectations around provision of floor coverings. As a result, even when tenancies are offered unfurnished, floor coverings tend to be included. However, there are still cases of properties being let privately without floor coverings. 

Proposal

We are seeking views on whether a new requirement should be added to criterion C of the DHS.  The requirement we are exploring is whether landlords should provide suitable floor coverings in all rooms at the start of every tenancy. For this requirement only, landlords would not be held accountable for providing floor coverings for all new tenancies until 2035 at the earliest (in line with our proposals on implementation in Section 6), resulting in negligible costs for landlords in the interim.  

We want to know more about the provision of floor coverings and the practical challenges of applying this requirement in DHS. To do this, we would like to hear if we should add this new requirement to the DHS. To help us better assess the impact on landlords we have asked a number of questions specifically for landlords to respond to on costs and current practice.  

As previously noted, we would encourage landlords to consider using floor coverings from a previous tenancy if they are clean, free from hazards and in a reasonable state of repair at the start of the tenancy. Best practice guidance on this matter could be provided as part of the DHS. 

We think “suitable” floor coverings would include carpet, linoleum, tiling and, where they are appropriately finished to be left uncovered, floorboards. Exposed subfloors, such as those made of concrete, plywood, laminated or Oriented Strand Board (OSB) would not be considered suitable. For measurement and assessment purposes, we propose that once DHS is in force a dwelling will fail the DHS in relation to floor coverings if the tenancy is less than 1 year old and suitable floor coverings, as defined above, are not present.    

Questions

Question 24:

a) Do you think that landlords should provide suitable floor coverings in all rooms at the start of every new tenancy from an agreed implementation date?

Yes/No/Don’t know

b) If you have any views on this specific question you would like to share, please do so here Open text

Questions 25 (Landlords only): To help us better assess the impact and know more about the detail of how you currently operate in the relation to providing floor coverings, we are interested in the following:

a) Do you provide floor coverings in any of your dwellings? Yes/No/Don’t know/Not applicable

b) If you responded Yes to part a) to providing floor coverings, can you provide details of costs here?

c) If you responded Yes to part a), in regard to responsibility of repair and maintenance for floor coverings do you: (please select one)

• Gift flooring to tenants and they are responsible for on-going repair and maintenance
• Carry out or have responsibility for repair and maintenance of flooring as part of, for example, tenancy agreements
• Other (please provide details)
• Not applicable

d) If you answered Yes to part a) to providing floor coverings, in the dwellings you let, which rooms do you currently provide them in? (select all that apply)

• All rooms
• Bedrooms
• Living room
• Kitchen
• Bathroom
• Other areas (including stairs, hallways)
• Varies by property
• Other e.g. new builds (please provide details)
• Not applicable

e) When or if you replace floor coverings in the dwellings you let, do you? (select one)

• Always replace floor coverings for new tenancies
• Sometimes replace floor coverings for new tenancies
• Only replace floor coverings if tenants request it
• Allow tenants to replace floor coverings themselves
• Provide support for tenants to replace floor coverings themselves
• Never replace floor coverings
• Other (please provide details)
• Not applicable

f) What proportion of your new lettings do you expect would require new floor coverings (including replacements) each year?

• 0% to 25%
• 26% to 50%
• 51% to75%
• 76% to 100%
• Not applicable

g) What proportion of your new lettings do you expect to reuse and clean existing floor coverings (rather than provide new replacements) each year?

• 0% to 25%
• 26% to 50%
• 51% to75%
• 76% to 100%
• Not applicable

h)If floor covering were to form part of the DHS, do you agree with the proposed measurement approach for whether a dwelling passes or fails the suitable floor coverings element of the standard?

Yes/No/Don’t know/Other (please provide details)/Not applicable

Proposal 6: Streamline and update thermal comfort requirements (Criterion D)

Introduction and rationale

Energy efficiency provides a wide range of benefits for tenants and is an important part of what makes homes decent. Evidence shows that living in a cold home can seriously affect tenants’ health and wellbeing, increasing the risk of circulatory diseases, respiratory problems and mental ill-health. Children in cold homes are twice as likely to suffer from respiratory problems such as asthma and bronchitis, and children made sick by damp and cold conditions at home miss more days of school than their peers. The rise in energy prices since 2020 has impacted the ability of many households to heat their homes adequately, disproportionately affecting fuel-poor households.

This can be addressed through making homes more energy efficient. Energy efficient homes are warmer and drier, making them more comfortable to live in. They will have less condensation, preventing damp and mould. They are cheaper to run which deals with fuel poverty as well lowering the carbon emissions of the home.

To meet the current DHS, a social rented sector dwelling must “provide a reasonable degree of thermal comfort”. Thermal comfort is currently defined in the DHS as a dwelling having efficient heating, effective insulation and a Standard Assessment Procedure (SAP) rating of 35 or above, equivalent to EPC F rating. The primary heating system must have a distribution system sufficient to provide heat to two or more rooms of the home.  

Homes are also required to meet the statutory minimum standard for housing, as defined by the Housing Health and Safety Rating System. This includes addressing category 1 damp, cold and/or heat hazards, which remain even if the current thermal comfort criterion is met. 

While the statutory minimum standard for housing acts as a backstop, the existing DHS requirements for a “reasonable degree of thermal comfort” are outdated and prescriptive about insulation and heating, and do not necessarily make a home more energy efficient or improve comfort levels for tenants. For example, properties where the primary heating system only covers two rooms, fulfilling the requirement set in criterion D currently, may be more difficult or more expensive to heat as tenants rely on secondary heating systems, such as electric heaters to keep additional rooms warm.

Proposal

All rented properties

The main component of the new criterion will be new minimum energy efficiency standards (MEES), which are the subject of separate consultations for social and private rented homes. Properties will need to meet these set standards in both the private and social rented sectors to be DHS compliant.

MEES by themselves are not sufficient to ensure tenants can adequately heat all parts of their homes. We therefore propose updating the heating requirement within criterion D to require the primary heating system to have a distribution system sufficient to provide heat to the whole home.

We would retain the existing definition of programmable heating as “where the timing and the temperature of the heating can be controlled by the occupants”.

For the requirement that the primary heating system is programmable, we would also continue to exclude supported housing and housing for older persons where it is necessary for health and safety reasons for landlords to ensure adequate levels of heating are maintained. We are also exploring the feasibility of this requirement for some forms of heat network and how this should be reflected in the enforcement of the DHS.

Private rented sector

The private rented sector is already subject to a minimum energy efficiency standard (MEES), currently set at EPC E. This is set and enforced elsewhere in legislation^{[footnote 42]} and we do not propose introducing any new requirement for energy efficiency in the private rented sector within the DHS regulations. The 2025 PRS MEES consultation, led by Department for Energy, Security and Net Zero (DESNZ), outlined proposed future requirements, that by 2030 all private landlords may be required to meet a higher EPC C standard. The proposal is for a dual metric approach to replace the current Energy Efficiency Rating (EER) system.

This will assess properties based on:

• fabric performance: This could include cavity wall insulation, solid wall insulation, loft insulation and double glazing for windows

In addition to the fabric performance standard, landlords must choose to improve one of the following:

• smart readiness: This could include solar panels, batteries and other load shifting appliances, and smart meters to enable tenants to access smart tariffs and services
• heating system: This would incentivise energy efficient low-carbon options, such as heat pumps, over direct electric heating and carbon-intensive fossil fuel systems.

The consultation closed on 2 May 2025, and a response will be published in due course. More details on the proposals can be accessed via the consultation document at: Improving the energy performance of privately rented homes: 2025 update

Social rented sector

Unlike the private rented sector (PRS), there are currently no MEES that applies to the social rented sector (SRS).

We are consulting on energy efficiency measures in the social rented sector in a separate consultation which was published 2 July 2025.

Within this separate consultation, we propose to introduce a standard for the first time, replacing the thermal comfort criterion of the DHS using post reform Energy Performance Certificates (EPC), setting the standard at EPC C or equivalent, using post EPC reform metrics, by 2030.

The proposal is for MEES to use a dual metric approach. This will assess properties based on:

• fabric performance: This could include cavity wall insulation, solid wall insulation, loft insulation and double glazing for windows

Once the fabric performance standard is met, landlords must choose to improve one of the following:

• smart readiness: This could include solar panels, batteries and other load shifting appliances, and smart meters to enable tenants to access smart tariffs and services
• heating system: This would incentivise energy efficient low-carbon options, such as heat pumps, over direct electric heating and carbon-intensive fossil fuel systems.

Questions

Question 26:

Do you agree with the proposal that the primary heating system must have a distribution system sufficient to provide heat to the whole home?

Yes/No/Don’t Know

Question 27:

Are there other thermal comfort requirements that you think should be included in the DHS beyond current MEES proposals?

Yes/No/Don’t Know

Question 28:

If there is anything else you would like to add on this specific topic please do so here

Open text

Proposal 7: Properties should be free from damp and mould (Criterion E)

Introduction and rationale

All homes should be free from damp and mould, which affect people’s health, primarily the airways and lungs, but also the eyes and skin. The respiratory effects can cause serious illness and, in the most severe cases, death. Damp and mould can also affect mental health due to worries about its negative health impacts, unpleasant living conditions, destruction of property and belongings, among other concerns.

The tragic death of two-year-old Awaab Ishak was the result of a severe respiratory condition caused by prolonged exposure to mould. Mould grows in damp environments, which was the case in Awaab’s family’s rented home. In her report following Awaab’s death, the Coroner for Manchester North raised concerns that the DHS does not give due concern to damp and mould, and this contributed to her opinion that, unless government takes action, future deaths will occur.

Everyone is vulnerable to damp and mould, and people with certain health conditions, children, and older adults are at greater risk of severe health impacts. BRE estimated that if dangerous damp and mould in people’s homes were fixed it could save the NHS an estimated £38 million every year.^{[footnote 43]} The 2023-24 English Housing Survey^{[footnote 44]} showed that damp and mould are increasing in all tenures, but also that people who lived in rented homes are more likely to suffer from damp and mould than those who own their home (9% of the private rented sector and 7% of social housing had damp and mould, compared to 4% of owner-occupied homes).

The root causes of damp and mould are deficiencies in buildings. These may include, but are not limited to, inadequate ventilation and heating, poor energy efficiency, defective damp proof courses, or damaged pipes and gutters. Everyday tasks such as cooking, bathing and drying laundry will create moisture in the home, but a home should be able to cope with this without resulting in dangerous and unpleasant damp and mould.

The government is introducing ‘Awaab’s Law’, which will provide a mechanism for tenants to secure repairs where damp and mould, and other hazards, are threatening their health and safety. But damp and mould should not be allowed to get to the stage where action is required under Awaab’s Law. Raising minimum energy efficiency standards for rented homes, will help reduce some of the conditions that make damp and mould worse and should minimise the need for tenants to rely on Awaab’s Law. But minimum energy efficiency standards will not, on their own, address all damp and mould.

We agree with the Coroner for Manchester North that the DHS should be more preventative, robust and explicit when it comes to damp and mould. Landlords, tenants and experts in housing enforcement, when asked in early engagement for the DHS Review, agreed that a minimum standard would be helpful. Landlords, in particular, desired an achievable standard that offers clarity and simplicity.

Proposal

Our expectation is that, to meet the DHS, landlords should ensure their properties are free from damp and mould. This will be set out in a newly established Criterion E.

How would this be regulated?

An HHSRS assessment of damp and mould generates a score that falls into one of ten bands, from A to J, with A the most dangerous and J the safest. Hazards scored at bands A, B or C are ‘category 1’, everything else is ‘category 2’ and there is no ‘category 3’. Criterion E will be failed if a damp and mould hazard is assessed to be anywhere from bands A to H, excluding only the mildest category 2 hazards. Local authorities will take this into account when assessing if a private landlord meets the DHS, social landlords will assess this through, for example, stock condition surveys.

What is the expectation on landlords?

Landlords should address damp and mould when reported to them by their tenants, as well as taking a proactive approach to prevention. The expectation is not that landlords should need to complete an HHSRS assessment if they become aware of damp and mould, it is that they should act. If the mould is creating a significant risk of harm, landlords should take action within the timescales set out under Awaab’s Law.

Government guidance on understanding and addressing the health risks of damp and mould in the home^{[footnote 45]} already sets out clear actions that can be taken by social and private landlords to address and reduce the risk of damp and mould in their homes. We will provide further practical guidance including photographic case studies.

What is the expectation on tenants?

It is not reasonable to blame tenants’ ‘lifestyle choices’ for damp and mould. This is set out in our damp and mould guidance and confirmed by the Housing Ombudsman in his spotlight report on damp and mould^{[footnote 46]}. Tenants cannot be expected to reduce moisture levels if their home does not enable them to do so.

However, landlords may wish to work with tenants to help them to understand what reasonable adjustments to their behaviour, if appropriate, can be made to reduce their damp and mould risk. It is essential that working with tenants must sit alongside - and not be a substitute for - tackling the root causes of the issue, such as building deficiencies, inadequate ventilation or low indoor air temperature.

Questions

Question 29:

a) Our expectation is that, to meet the DHS, landlords should ensure their properties are free from damp and mould. Do you agree with this approach?

Yes/No/Don’t Know

b) Criterion E will be in addition to the requirements under Awaab’s Law as it aims to prevent damp and mould reaching a level that is hazardous. If, however, damp and mould in a property were to become severe enough to cause ‘significant harm’, landlords would have to comply with Awaab’s Law to ensure prompt remediation and, if they do not, tenants will be able to take action in the courts. The damp and mould standard in the DHS should however help to prevent damp and mould getting that severe. Do you agree with this approach?

Yes/No/Don’t Know

Question 30:

To ensure the standard is met, regulators and enforcers will consider whether the home is free from damp and mould at bands A to H of the HHSRS, excluding only the mildest damp and mould hazards? Do you agree with this approach?

Yes/No/Don’t Know

Question 31:

If there is anything else you would like to add on this specific proposal please do so here. Open text

Section 4 – Application of the DHS to temporary accommodation and supported housing and implications for leasehold and commonhold tenants and landlords

Temporary accommodation

The government announced in February this year that subject to consultation it plans to extend the DHS to temporary accommodation (TA) alongside measures to apply Awaab’s Law also to the sector.

TA is provided by the local authority to certain households who are statutorily homeless – preventing families and vulnerable individuals from rough sleeping. Local councils are legally required to provide TA where an eligible applicant is homeless through no fault of their own and in priority need, for example, where the household includes a child. TA can be shared or self-contained, and can come in various forms, including private and social rented sector accommodation, B&Bs, hotels, hostels and refuges. Around half of TA is in the social rented sector and is therefore already subject to the current DHS, with the remaining half in the private rented sector including a small proportion of B&Bs and hotels.

Currently, local authorities are legally required to ensure TA is suitable for the household. TA is rented accommodation so housing authorities should, as a minimum, ensure that all TA is free of hazardous conditions at the most dangerous “category 1” level, as assessed using the HHSRS.

Most TA is self-contained where households have their own private bathroom and cooking facilities. However, not all TA has these facilities, for example B&B accommodation which may require households to share important amenities such as cooking and bathroom facilities or lack kitchen facilities. The legislation is clear that local authorities should avoid using B&B accommodation as accommodation for homeless families unless there is no other accommodation available. Local authorities should, therefore, use B&B accommodation with shared facilities or that lacks cooking facilities as TA for families only as a last resort and only for a maximum of 6 weeks.

Application of the DHS to TA (Criteria A, B, D and E)

The consultation on applying the DHS to the private rented sector asked whether the DHS should apply to TA. The consultation response sets out that 84% of responses agreed, in principle, to apply the standard to TA. It is the government’s intention that the DHS should apply to TA, as far as possible, but we recognise that there are concerns around how the standard is applied to this specialist sector that require careful consideration.  

We expect that all TA should comply with the requirements regarding state of repair as set out in criterion B, and covered here under proposals 1.  This means that, where building components exist (including the required facilities set out for kitchens and bathrooms), they must be kept in a good state of repair and free from damp and mould. This would apply both to TA with a kitchen and to TA which does not contain a kitchen but does contain cooking facilities, for example, a fridge, or a cooking hob.  

The majority of TA will contain a kitchen and bathroom and, where these facilities are present (including shared facilities), we propose the requirements around kitchens and bathrooms in DHS (as set out in criterion C) will apply in full.    

Application of DHS to TA (Criterion C)

Where it is feasible, some accommodation which has basic cooking facilities but lacks all the elements to be considered a kitchen (as set out in criterion C) will need upgrading to meet the standard, for example, if there is no worktop for food preparation or cupboard for food storage. There will be cases where it is not practical for kitchens or cooking facilities to be provided in TA (for example where B&Bs or hotels are being used). In these circumstances the enforcing authority will be the local authority, who would have the discretion to consider whether it is appropriate to suspend enforcement action for a period of time or use awareness notices that do not require remedial works.  

This will only apply to criterion C of the DHS in relation to TA. Therefore, for TA that lacks kitchens and cooking facilities and where it is not practical for these to be provided and therefore criterion C of the standard cannot be met, all the other requirements of the DHS must be in place. 

This aligns with proposals around meeting the standard set out in Section 7 below. This is considered proportionate as it enables local authorities to use hotel and B&B accommodation as TA as a last resort when nothing else is available, while ensuring that households temporarily accommodated in hotels and B&Bs benefit from the other elements of the DHS. The alternative, which we do not believe is appropriate, would be to exempt these forms of TA from the DHS entirely. 

Supported housing

Supported housing is accommodation that has been designed or designated to be provided alongside support or care, to enable people who need additional help to live as independently as possible in the community. The supported housing sector is diverse and includes registered providers of social housing, charities, voluntary bodies and private providers. This means that supported housing is split across the social and private rented sectors, so some is already subject to the current DHS. There are many providers doing excellent work to provide good quality homes and support for their tenants who include some of the most vulnerable in society. 

We are committed to making sure that supported housing tenants receive the good quality accommodation and support they deserve. The government recognises the very serious issues and consequences of a minority of landlords who are exploiting vulnerable people and the Housing Benefit system, by providing little or no support to their tenants whilst charging excessive rents for poor-quality housing.

We have recently consulted on the proposed implementation of measures in the Supported Housing (Regulatory Oversight) Act 2023,^{[footnote 47]} which enables the government to introduce a licensing regime, forcing new National Supported Housing Standards to regulate the quality of support provided in supported housing. The licensing regime may also require licensees to make sure that their properties meet the DHS where the DHS is applicable to supported housing, and that their properties are free from category 1 hazards. The government will publish its response to feedback on the consultation in due course.

We do not believe that any of the proposed changes to the DHS will have an additional impact on supported housing.

For the requirement that the primary heating system is programmable, we would continue to exclude supported housing and housing for older persons where it is necessary for health and safety reasons for landlords to ensure adequate levels of heating are maintained.

Leasehold and commonhold

Given that the terms of individual leases vary significantly, we would like to understand better the cost implications of meeting the DHS for leaseholders in mixed tenure blocks. We believe that, in most cases, any costs of meeting the DHS would be no more than the costs that leaseholders would already expect to pay under the terms of their leases to ensure such areas are maintained and kept in the appropriate state of repair. We welcome views on this position, and whether there are any of the proposed new standards which might be regarded as an improvement and risk unanticipated and significant additional costs to leaseholders.   

For conciseness, we will generally just refer to leaseholders and freeholders for the rest of this section, but please note that these proposals will also apply to their commonhold equivalents: unit owners and commonhold associations. Full definitions in glossary (annex A).

Leaseholders and unit owners who are landlords

For some rented homes, the landlord who lets the property out to the tenant will be a leaseholder, with a different person or organisation owning the freehold of the property and the land on which the building is situated. Arrangements can also be more complex, with intermediate lessors in between the owner of the freehold and the leaseholder who lets out the property to the tenants – for example, when there is a ‘head lessor’ of the building. A leaseholder will typically have the right to sublet their flat under an assured shorthold tenancy agreement or equivalent. In cases where a leaseholder sublets their flat under a short tenancy, they will be required to comply with DHS.   

Arrangements around leasehold will have a greater impact on the application of the DHS to the PRS, as this ownership model is more prevalent in this tenure – 37% of PRS properties (1.82 million) are owned on a leasehold basis. In the SRS, it will be more common for a registered provider or local authority to own and manage the wider building or estate as well as the individual dwellings. However, there will also be some SRS properties in which the immediate landlord is a leaseholder, 7% of SRS properties (0.30 million) are owned on a leasehold basis.

For leasehold properties that are privately or socially rented, the leaseholder landlord will generally be responsible for maintaining and repairing their flat (as defined in their lease), while the freeholder will be responsible for all other parts of the building that have not been demised (e.g. common areas and external building fabric). The cost of the freeholder performing their obligations will usually be passed onto the leaseholders through the service charge fund. The lease will clearly state what costs can and cannot be recovered from the service charge fund, and these costs must be reasonable. The cost of the leaseholder performing their obligations will usually be paid for by the leaseholder privately. In some cases, the leaseholder must obtain a superior landlord’s prior consent before carrying out the works. These respective responsibilities are set out in the individual lease and will vary. We will shortly publish a consultation which includes proposed reforms to the major works process under Section 20 of the Landlord and Tenant Act 1985 (“the 1985 Act”) that leaseholders must go through when the landlord wants to carry out “major works” funded by a service charge. It also includes proposals to implement measures in the Leasehold and Freehold Reform Act 2024 aimed at driving up the transparency of service charge costs. These measures will help leaseholders better scrutinise and challenge costs if they consider them to be unreasonable.

For commonhold properties, the arrangements are governed by the Commonhold Community Statement, which sets out who is responsible for what and the financial arrangements. Similar to leasehold, the commonhold owner will typically be responsible for the maintenance and repair of the commonhold unit, with the Commonhold Association being responsible for the maintenance and repair of the communal commonhold. The Commonhold Association can charge the costs for this from the commonhold owners. The Commonhold Community Statement is often less rigid than a lease and can also be amended without the rigidity of leasehold, if required.  

The Renters’ Rights Bill requires, by default, that enforcement action in relation to DHS failures is taken against the immediate PRS landlord. However, the Bill will also give flexibility to serve DHS enforcement notices on any superior landlord if the local authority considers that they are the person who ought to take the action specified in the notice. This will ensure the DHS can be applied and enforced effectively for leasehold properties in the PRS by ensuring that leaseholder landlords, superior landlords, or freeholders can be subject to enforcement action if they are responsible for a DHS failure. If there is a dispute as to who is responsible, the local authority could request a copy of the lease to clarify this. To support local authorities in dealing with such issues, we intend to address the approach to enforcement of the DHS in relation to leasehold properties in statutory guidance.   

For situations in which a leaseholder landlord requires permission from a superior landlord to carry out works required to meet the DHS, we expect that the leaseholder should take all reasonable steps to obtain such consent. However, if they could not obtain permission despite taking such steps, we do not think it appropriate that the leaseholder landlord should be penalised as a result. We also plan to address these circumstances in statutory enforcement guidance for local authority enforcement bodies.

Resident leaseholders and commonhold owners

The DHS does not apply to owner-occupied leasehold properties (i.e. where the properties are not privately let), however there may be circumstances where owner-occupied leasehold properties in mixed-tenure blocks may be impacted by wider works to the building that are required for social or private rented sector properties to meet the DHS, for example, in communal areas or to the fabric of the building.

The proposed updates to the DHS could incur additional costs for resident leaseholders: 

• Applying the DHS to the PRS for the first time will bring buildings containing a mixture of owner-occupied, PRS properties and SRS properties either sold under Right to Buy or have been since been sold and now privately let within scope of the standard for the first time. We envisage that the requirements under criteria A and B in relation to hazards and disrepair would not place significant new obligations in respect of mixed-tenure blocks that would result in additional costs but, as set out below, there are potential costs arising from criterion C and Criterion D. 

• The addition of building components (proposal 1) and the changes to the requirements on what facilities must to be missing before a property fails to meet criterion C (proposal 2) have the potential to result in additional costs in some circumstances because these changes relate to communal areas. For building components (proposal 1) this relates to requirements to maintain in good repair rainwater goods, lifts, stairways (balustrades, handrails and stair-treads), door entry systems, and in the SRS only, boundary walls, curtilage, pathways and steps, external lighting, and bin stores. For core facilities (proposal 2) this relates to adequate size and layout of common areas for blocks of flats and the external noise insulation requirement and the fact that we now propose that a property is required to provide at least three of four facilities to meet the DHS (rather than the current approach of a property failing to meet the standard if it lacks three or more of six facilities). 

• Streamlining and updating thermal comfort requirements (proposal 6) may affect some leaseholders with a social landlord where, in order to meet any new requirement, registered providers need to carry out work to buildings that contain both social rented and leasehold homes. 

Leaseholder responsibilities, and their liability to contribute towards the overall cost of meeting the standard via the service charge fund, will depend on the terms of individual leases – and these do vary. Where leaseholders are liable to pay, landlords may need to carry out a consultation under Section 20 of the 1985 Act, to ensure that leaseholders have sufficient input into how their money is spent. We would like to better understand the existing landscape and how we can or should implement any new regulatory requirement in a manner which is proportionate, effective, and fair to owner-occupied leaseholders. 

We would also like to better understand if the proposed DHS will add new obligations, given that freeholders (and/or superior landlords) are already required to maintain and repair the building. We are keen to understand if, in practice, DHS will require considerable additional work, and therefore cost, or if buildings will on the whole already be compliant, or if freeholders (or superior landlords) should be doing works anyway to comply with basic lease terms.  

In addition, we also intend to use statutory enforcement guidance to support local authorities to take a proportionate approach to enforcement that considers the potential for costs on resident leaseholders. For example, this guidance could encourage local authorities to take enforcement action if a freeholder failed to fix a leaking roof that was causing damp and mould problems, but not for a minor failure relating to the layout of the common areas of a building that would be disproportionately costly and disruptive to fix and may impact on leaseholder rights under the lease.

Questions

 Temporary accommodation 

Question 32:

Do you agree all other aspects of the DHS in relation to bathrooms and facilities should still apply to temporary accommodation which lacks kitchen and cooking facilities and/or separate bathroom facilities?

Yes/No/Don’t know/Not applicable

Question 33:

a) Are there any other elements of the DHS which have not already been identified which are likely to be challenging to apply to temporary accommodation?

Yes/No/Don’t Know/Not applicable

b) If answered yes to Q33a), please give details Open Text

Question 34:

Do you think the proposed DHS requirements will impact temporary accommodation supply?

Yes/No/Don’t Know / Other (please specify)/Not applicable

Supported housing

Question 35:

a) Are there any challenges you foresee in applying the outlined DHS proposals in Supported Housing?

Yes/No/Don’t Know/Not applicable

b) If you have any views on this specific question you would like to share, please provide details Open text

Leasehold and commonhold

Question 36:

a) Do you agree with the proposed approach to enforcement for rented properties that are leasehold?

Yes/No/Don’t Know/Not applicable

b) Do you see any unintended consequences or risks with this approach, including for resident-owned blocks? Open text

Question 37:

a) Do you feel that any of the proposed policies create costs for leaseholders (including owner occupiers who live in mixed-tenure buildings) that go beyond what they would expect to cover currently in terms of repair and maintenance liabilities?

Yes/No/Don’t Know/Not applicable

b) If you have any views on this specific question you would like to share, please do so here Open text

Section 5 – Guidance

We will issue guidance on the DHS. This is important because it will help landlords, tenants, the Regulator and enforcement agencies to understand the standard and their obligations.

We recognise that the Decent Homes Standard is one of several new and updated measures aimed at improving housing quality, including Awaab’s Law and MEES, and that landlords are also subject to other existing requirements, for example around accessibility. While we are consulting separately on each new measure, we will consider how guidance can help landlords understand all their regulatory requirements and deliver works as efficiently as possible.

Additional best practice guidance

The DHS sets a minimum standard for rented accommodation. However, we recognise that there is an opportunity to use guidance to encourage and support landlords to go further in improving quality.

We are considering producing a further piece of guidance to accompany the DHS, with examples of best practice across tenures on several topics which we have set out in Table 5. Subsequent guidance will specify where it is tenure specific. Following this guidance will be voluntary (unlike statutory guidance for local authorities). Proposed topics to include within this additional best practice guidance listed below have been informed by previous sounding boards conducted.

Table 5 List of proposed topics for best practice guidance

Proposed topic	Details on how the guidance could go further
Accessibility	Guidance on improving the accessibility of homes for older people and those with additional needs.
Home security	Additional home security measures beyond the measures we are considering in proposal 4, such as external lighting and use of CCTV.
Adaptations to climate change	Information on adaptations to climate that landlords may want to consider e.g. what could be done to adapt for extreme weather events such as increased temperatures.
Water efficiency	Information on the benefits of water efficient devices, including a reduction in energy and water bills and the support provided by local water companies.
Furniture provision	Information and sharing of best practice on schemes some organisations have created for providing furniture such as white goods and bed frames.
Digital Connectivity	Guidance on how to improve a property’s digital connectivity, to improve national coverage and help fix digital exclusion. Such as via access to better broadband.
Electrical Vehicle Charging	Information and best practice for installing electric vehicle charging facilities that landlords should consider. EV chargers will encourage tenants to switch to electric vehicles through improving the accessibility and convenience of charging and providing lower cost energy to power their vehicle.

Questions

Question 38:

a) What information and/or topics would you like included in the proposed additional best practice guidance for social and private landlords and tenants? (Select all that apply)

Please select what you would like to include:

• Accessibility
• Additional home security measures e.g. external lighting and CCTV
• Adaptations to climate change
• Digital connectivity
• Electrical Vehicle Charging
• Furniture provision
• Water efficiency measures
• Other

b) If you have selected ‘Other’, please say what you would like to be included

Question 39:

If you have any other views on this specific topic you would like to share, please do so here

Open text

Section 6 – Implementing the Decent Homes Standard

Introduction

Updating the DHS and applying it to the private rented sector for the first time will drive up standards for all tenants in rented accommodation. We want to see progress as soon as possible and are clear that nobody should have to live in an unsafe home for any amount of time. However, we also recognise that landlords and tenants in both the social and private rented sectors have faced financial challenges in recent years, and that SRS landlords are also responsible for delivering much needed new supply.

We are therefore proposing an approach which prioritises safety in the short-term, while allowing a longer implementation period for landlords to meet the full Decent Homes Standard. This period will begin at the point we confirm the details of the new DHS and publish accompanying guidance for both the PRS and SRS.

Implementation timeframes

The DHS is one of several new measures that will apply to rental properties in the near future. Awaab’s Law will apply to the social rented sector in phases from October 2025. We also intend to consult on extending its application to the private rented sector. In parallel, we are consulting on requiring all rented properties to meet EPC C by 2030.

Together, these reforms are expected to deliver meaningful improvements in safety and energy efficiency for tenants across both sectors. However, they will also place significant new obligations on landlords. In this context, we are proposing that the updated DHS be brought into force in each tenure in either 2035 or 2037. This timeline broadly aligns with the nine-year implementation period that accompanied the original introduction of the DHS in the social rented sector in 2001.

While we are proposing a long-term deadline, our expectation is that landlords should commence works earlier wherever feasible. We are seeking views through this consultation on whether phasing in elements of the DHS ahead of the final implementation deadline will help achieve this. In addition, once the Renters’ Rights Bill receives Royal Assent, we intend to commence a new power enabling local authorities to impose financial penalties on landlords who have failed to take reasonably practicable steps to keep their properties free of serious hazards.

By providing landlords and tenants in each sector with clarity on the long-term future of regulation we aim to deliver a decade of sustained improvements in housing quality. These reforms prioritise safety and energy efficiency, while giving landlords the certainty and time needed to plan how best to meet their new commitments. For social landlords, this includes the rapid building of new social homes that we so urgently need.

Further detail on our approach to implementation in each tenure is set out below.

Figure 1: Timeline of quality measures to apply to the SRS and PRS.  We will consult separately on applying Awaab’s Law to the PRS.

Implementation of the DHS in Social Housing

The existing DHS is already a requirement in the social rented sector and will remain so until the new standard comes into force. This means that social landlords must continue to ensure current standards are maintained during the implementation period, while also protecting tenants from the most serious hazards under the HHSRS and Awaab’s Law (from October 2025).

Compliance with the DHS is regulated by the Regulator of Social Housing (RSH), following a direction from the Secretary of State for Housing, Communities and Local Government to include the DHS within its regulatory standards. Following the passage of the Social Housing (Regulation) Act 2023 (SHRA), the RSH launched a consultation on its revised consumer standards over summer 2023. The revised standards57 were published on 29 February 2024 and came into effect on 1 April 2024.

The Regulator of Social Housing’s Safety and Quality Standard^{[footnote 48]} sets out the required outcomes and specific expectations, including in relation to quality of accommodation, which include that registered providers must:

a) have an accurate, up to date and evidenced understanding of the condition of their homes that reliably informs their provision of good quality, well maintained and safe homes for tenants
b) ensure that tenants’ homes meet the standard set out in section five of the government’s Decent Homes guidance and continue to maintain their homes to at least this standard unless exempted by the Regulator for Social Housing
c) when acting as landlords, take all reasonable steps to ensure the health and safety of tenants in their homes and associated communal areas

The new Safety and Quality Standard is accompanied by broader changes to the RSH’s approach to regulating the consumer standards. On 1 April 2024, the RSH launched a new proactive consumer regulation regime. In the new regime, the RSH is proactively seeking evidence and assurances from registered providers that they are delivering the outcomes in the revised consumer standards. There are also new routine inspections for large providers. As part of these inspections, the RSH seeks assurances that providers are delivering outcomes relating to stock quality, repairs and maintenance, and health and safety compliance. These changes will ensure the RSH is equipped to hold landlords to account for delivering the outcomes set by the consumer standards.

When the implementation period begins, we will publish a direction to the RSH that it must set a standard requiring registered providers to comply with the new DHS from the agreed date and set out more details of our expectations of landlords during the implementation period.

We are not proposing any further changes to the way that the DHS is implemented in the social rented sector. The updated standard will continue to be regulated by RSH through its consumer standards.

Implementation of the DHS in the Private Rented Sector

There is currently no comprehensive standard of decency in the private rented sector. However, private landlords are required to ensure that their homes are fit for human habitation including being free from category 1 hazards as defined by the Housing Health & Safety Rating System (HHSRS).

The Renters’ Rights Bill amends the Housing Act 2004 to introduce a power for the Secretary of State to apply a Decent Homes Standard to the private rented sector and places a legal duty on private landlords to ensure their property meets the standard. Following this consultation, the details of the standard and the timeframes for implementation will be set out in regulations.

The Bill also amends the Housing Act 2004 to allow local authorities to apply their existing enforcement powers for hazards to the DHS and places a duty on local authorities to, if appropriate, inspect properties to determine whether there are DHS failures. This could be following a tenant complaint, for example. If a council identifies failures to comply with DHS requirements, it will be able to take enforcement action, including requiring landlords to remedy failures. Non-compliance with council enforcement notices or orders will be a criminal offence, meaning landlords who fail to comply can be prosecuted or fined.

To support effective enforcement, we will use secondary legislation to increase the maximum fine level for non-compliance with enforcement action from £30,000 to £40,000. For serious failures, such as category 1 hazards, local councils will also have a new power to issue immediate civil penalties of up to £7,000 if the landlord has failed to take reasonably practicable steps to address the issue. Subject to secondary legislation, our intention is for this new power to come into force ahead of the full DHS.

The Bill will give local authorities flexibility to take enforcement action in respect of DHS failures against a superior landlord in relation to a private rented sector property when appropriate (for example, the freeholder of a building containing a leasehold flat if the failures relate to common parts of the building).

We will produce statutory guidance to support local authorities in enforcing the DHS.

Classifying DHS requirements in the private rented sector

The detail of the DHS requirements that must be met by privately rented homes will be set out in Regulations. The DHS requirements will be divided into two categories: type 1 requirements that a local housing authority has a duty to enforce; and type 2 requirements that a local housing authority has a power to enforce. Local councils will have greater powers to issue fines and take emergency action, as well as a duty to take enforcement action, when type 1 failures are identified. As there are existing statutory powers for local councils in relation to DHS criterion A (being free from category 1 hazards), these new DHS regulations will set out the new requirements for private rented sector properties in relation to DHS criteria B, C, D and E. 

Table 6: Enforcement approach for type 1 and type 2 DHS failures in the PRS

Requirement	Enforcement approach
Type 1	- In line with the current approach for category 1 hazards - Councils have a duty to take enforcement action - Councils able to undertake emergency enforcement action and issue on the spot civil penalties, as well as improvement notices, awareness notices and prohibition orders
Type 2	- In line with the current approach for category 2 hazards - Councils have a power to take enforcement action - Councils able to issue improvement notices, awareness notices and prohibition orders

We have taken this approach to allow for flexibility in enforcement, recognising that some DHS requirements pose more serious risks than others in the private rented sector. This will allow local authorities to prioritise the most serious cases and mirrors the way in which Part 1 of the Housing Act 2004 is enforced in relation to hazards.

As DHS failures against criterion A (presence of category 1 hazards) present serious and immediate risks to a person’s health and safety, failures of DHS criteria B, C, D and E will, by definition, be less serious. We therefore consider that most, or all, criteria B, C, D and E DHS requirements should be type 2, unless there is a strong rationale for making a certain part of the DHS (other than category 1 hazards) subject to enhanced enforcement. Getting this right will be important as setting the bar for type 1 issues too low could hamper local councils’ ability to effectively prioritise enforcing against the most serious risks to health.

We would welcome views on whether any parts of the DHS other than category 1 hazards are sufficiently serious to justify being classed as type 1 requirements for the purposes of enforcement in the private rented sector.

Monitoring the DHS

We will seek to measure and report on the prevalence of dwellings which pass or fail the updated DHS as soon as feasible, using existing data collections, to monitor improvements ahead of the compliance date.

Questions

Question 40 (All):

a) What do you think the implementation date for the DHS should be in the SRS?

2035 / 2037 / Other (Please select one)

b) If Other – What do you think the implementation date should be? (Please select one)

2027 / 2028 / 2029 / 2030 / 2031 / 2032 / 2033 / 2034 / 2036 / Later/Don’t know

Question 41 (All):

a) What do you think the implementation date for the DHS should be in the PRS? (Please select one)

2035 / 2037 / Other

b) If Other – What do you think the implementation date should be? (Please select one)

2027 / 2028 / 2029 / 2030 / 2031 / 2032/ 2033 / 2034 / 2036 / Later/Don’t know

Question 42 (All):

a) Do you support phasing in some elements of the new Decent Homes Standard ahead of the proposed full implementation dates (2035/2037)?

Yes / No / Don’t Know

b) If Yes – Which elements of the new DHS do you think should be introduced ahead of the proposed full implementation dates (2035/2037)?

Open Text

Question 43 (For SRS and PRS landlords only):

Are you confident in your ability to deliver works to meet the updated Decent Homes Standard by the proposed implementation dates (2035/2037)?

a) For Social Housing Landlords only: Within current income forecasts in the SRS?

Yes/No/Don’t Know/Not applicable

b) For all Landlords: Alongside other regulatory requirements including Awaab’s Law and MEES?

Yes/No/Don’t Know/Not applicable

c) Please give supporting details?

Question 44 (For SRS and PRS landlords only): 

Considering the need to meet both Minimum Energy Efficiency Standards and the Decent Homes Standard, do you plan to deliver savings by:

a) Prioritising measures which will both improve a property’s energy efficiency and help meet the DHS?

Yes/No/Don’t Know/Not applicable

b) Reducing overhead costs by programming combined works to meet both standards?

Yes/No/Don’t Know/Not applicable

c) Please give supporting details Open text

Question 45 (SRS landlords only)

Will achieving the updated Decent Homes Standard by the proposed implementation dates (2035/2037) only be achievable by reducing discretionary spending compared to your current plans? (Select one)

a) Yes/No/Partly/Other/Not applicable

b) Please providing supporting detail

Question 46 (For PRS landlords and tenants):  

a) Do you agree that only criterion A should be a Type 1 DHS requirement?

Yes/No/Don’t Know/Not applicable (Select one)

b) If No – which other criteria do you think should be a Type 1 DHS requirement?

Criterion B / Criterion C / Criterion D / Criterion E/ Other/ Not applicable (Select all that apply)

c) Please give supporting details

Open text

Question 47: (For All)

If there is anything else you would like to add on this specific section? If so, please do so here Open Text

Section 7 – Meeting the Standard

Introduction and rationale

It will be possible for most properties to meet the DHS. For some properties, however, individual circumstances mean it will be prohibitively hard or impossible to meet certain elements of the standard – for example, if planning restrictions prevent the landlord from making changes to the layout of the property in line with requirements under criterion C. While we want all tenants to benefit from the DHS, the systems for managing compliance with the DHS should provide some flexibility to account for such circumstances.   

Current position

The current DHS sets out circumstances when it is acceptable for individual social housing dwellings not to meet the standard - these are sometimes referred to as ‘exemptions’. Large private registered providers of social housing declare annually to the Regulator of Social Housing the number of their properties which do not meet the DHS and the number of their properties which they assess are exempt from meeting the DHS requirements.

There are two types of exemption in the current DHS:

Absolute – exemptions that do not need to be agreed with the RSH to be applied by the landlord. These include:

• paragraph 6.11: Where an individual tenant does not want work carried out on their home, the home can remain below the standard until the property is vacated. (This does not apply where works are required to maintain the structural integrity of the property, to prevent other components from deteriorating or where a health and safety hazard at the most dangerous ‘category 1’ level is present)
• paragraph 5.20 of the DHS: If it is impossible to make required improvements due to physical or planning reasons
• paragraphs 2.20 and 5.5: If practical steps cannot be taken to remedy category 1 hazards without disproportionate expense or disruption, the existence of these hazards is not a trigger for remedial action

Implementation – an exemption that is applied and granted by the RSH on a case-by-case basis and can be time limited. These include:

• paragraph 5.21: If demolition and new build are more appropriate, it may not be necessary to make homes decent
• paragraph 6.13: Packages of work or cycles of major repairs where, during the cycle of a major repairs programme, properties enter or fall out of decency for periods of time

Proposal

The current system introduced in 2006 was designed for the social rented sector and while there is diversity in registered providers of social housing, the position of registered providers is different to that of most landlords in the private rented sector, who often own one or two properties.

In addition, the mechanisms for ensuring that properties comply with the DHS are different for the two tenures. For social housing, the Regulator of Social Housing regulates the DHS through its consumer standards while, for privately rented homes, local authorities will have enforcement powers in respect of properties that fail to meet DHS requirements.

The approach to managing situations where there is a legitimate reason why a rented home cannot meet parts of the DHS must therefore reflect the differences between the tenures and how the standard will be applied.

We propose the following approach for managing circumstances in which it may not be possible for a property to not meet the standard:

In the Social Rented Sector

Tenant refusal of access (with enhanced guidance)

There will be some situations where access to properties may pose issues, however, exempting landlords from meeting the DHS where tenants refuse access for remedial works is a complex issue that requires careful consideration.

Providers must be able to carry out necessary repairs and improvements to ensure properties meet safety and quality standards. However, it is equally important to recognise the rights and concerns of tenants, particularly those who may be vulnerable or have legitimate reasons for refusing access.

Landlords are encouraged to engage proactively with tenants, addressing their concerns and working to find mutually agreeable solutions. Detailed guidance will be provided to ensure that providers understand the steps they should take to engage with tenants who refuse access.

Physical or planning factors preventing compliance

We propose that providers should be exempted from meeting the DHS when physical or planning factors prevent compliance. In certain cases, structural limitations or planning restrictions may make it impractical or impossible to carry out necessary improvements. For instance, heritage buildings may be subject to listing constraints that restrict the extent of possible works.

However, it remains important that providers maintain safe and habitable conditions for tenants. We expect that category 1 hazards are addressed by providers.

Exemptions for non-compliance due to sale, demolition, or planned regeneration of properties

We propose that providers would have reasonable grounds to not meet the DHS when properties are in the sales process; due for demolition; or there are planned regeneration works.

In such scenarios, investing in extensive repairs or upgrades may be impractical and economically challenging, and we acknowledge the reality that resources are better allocated towards long-term solutions rather than temporary fixes.

However, it is essential that providers ensure tenants’ safety and wellbeing during the transition period, maintaining habitable conditions until planned changes are implemented, with no presence of category 1 hazards. More detail will be provided in guidance accompanying the standard. We expect that large private registered providers will continue to be asked to report aggregate numbers of exemptions to RSH.

MEES specific exemptions

Alongside this consultation, we have also published a consultation on introducing a minimum energy efficiency standard (MEES) in the social rented sector as part of Criterion D of the DHS. There are specific reasons for not meeting energy efficiency standards that will not apply to the rest of the DHS, for example we are proposing a specific exemption that would apply to meeting MEES only. Please visit our consultation to answer questions on the suitability of this.

In the Private Rented Sector:

The government recently consulted on improving energy performance in the private rented sector. The outcome of this consultation will be published in due course. The consultation proposed exemptions to minimum energy efficiency standard (MEES) for private rented properties to ensure that landlords are not unduly burdened when it’s not feasible or reasonable to meet the new energy efficiency standards. Although MEES will be referenced as part of criterion D of the DHS, the exemptions for MEES will not be part of DHS regulations but will instead be governed through a separate MEES regulation for the PRS. Please visit the consultation link here for further details of the proposed PRS MEES exemptions: Improving the energy performance of privately rented homes: 2025 update - GOV.UK.

Local authorities will enforce the DHS for individual private rented sector properties. While there may be legitimate reasons why some privately rented homes cannot meet certain parts of the DHS, we do not consider that a formal exemptions process is the appropriate way to manage this. Feedback from local authorities and landlords has indicated that such a system would be burdensome. 

Instead, local authorities will be able to use discretion in determining how to enforce in such circumstances. For example, if a local authority enforcement officer identifies a DHS failure in a privately rented home but determined that there were good reasons why the landlord could not be expected to remedy the failure, they will be able to serve an awareness notice. This notice would ensure that the landlord and tenants were aware of the failure and could take steps to manage any risks that it presented but would not mandate that the landlord take remedial action. 

We will support local authorities to use this discretion through statutory enforcement guidance that will set out some reasons for non-compliance that local authorities can consider. This aligns with current local authority enforcement of hazards through the Housing Act 2004.

We propose that this private rented sector statutory enforcement guidance does not directly mirror the social housing exemption circumstances described above due to differences between the two tenures. The two situations that we are considering including in the private rented sector guidance are:

Physical or planning factors preventing compliance

We propose that local authorities should not take enforcement measures requiring that landlords undertake remedial action when physical or planning factors prevent compliance in respect of one of the requirements of the DHS. In certain cases, structural limitations or planning restrictions may make it impractical or impossible to carry out necessary improvements. For instance, heritage buildings may be subject to listing building constraints that restrict the extent of possible works.

Tenant refusals

There is an argument for addressing in statutory enforcement guidance situations in which tenants do not want remedial works undertaken in respect of a DHS failure – for example, if these would cause significant disruption and the tenants were not concerned about the issue. However, we are concerned that specifying in statutory guidance that local authorities should not take enforcement measures requiring remedial action in such circumstances might prompt some unscrupulous landlords to attempt to coerce tenants into refusing works. In addition, as local authorities will generally inspect properties for compliance with the DHS after being contacted by a tenant about poor conditions in their home, we do not envisage that genuine cases of tenant refusal will arise frequently in practice. We would therefore welcome views on whether it would be appropriate to include such circumstances in statutory enforcement guidance.

In both tenures:

Leasehold and commonhold   

In addition, we propose to address in this statutory enforcement guidance specific issues relating to the enforcement of the DHS in respect of privately rented leasehold and commonhold properties – for example, dealing with situations where a leaseholder landlord has been refused permission to carry out the works required to meet the DHS or where requiring a DHS failure in respect of the common parts of a building to be remedied may result in disproportionate costs falling on resident leaseholders living in the building. These issues are addressed above in Section 4. 

Questions

Social Rented Sector

Question 48:

a) Do you agree that providers should be given flexibility from meeting the DHS where tenants refuse access? Yes/No/Don’t Know/Not applicable

b) Do you agree that there should be additional guidance issued by the government to provide more detail on tenant refusals? Yes/No/Don’t Know/Not applicable

c) Do you agree that providers should be given flexibility from meeting the DHS where there are physical or planning factors preventing compliance? Yes/No/Don’t Know/Not applicable

d) Do you agree that providers should be given flexibility from meeting the DHS for non-compliance due to sale, demolition, or planned regeneration of properties? Yes/No/Don’t Know/Not applicable

e) If there is anything else you would like to add on this specific question please do so here. Open text

Private Rented Sector 

Question 49:

a) Do you agree that statutory enforcement guidance should specify that local authorities should exercise discretion on enforcement when physical or planning factors prevent compliance with a DHS requirement? Yes/No/Don’t know/not applicable

b) Should statutory enforcement guidance specify that local authorities exercise discretion on enforcement in situations of tenant refusal? Yes/No/Don’t Know/not applicable

c) If there is anything else you would like to add on this specific question please do so here. Open text

Annexes

Annex A: Glossary 

Approved Document: Documents providing practical guidance on how to meet the requirements of building regulations. They set out what, in ordinary circumstances, may be accepted as reasonable provision for compliance with the relevant requirements.

Approved Document K: Document providing guidance for compliance with the building regulations for protection from falling, collision and impact.

Approved Document O: Document providing guidance for compliance with the building regulations for overheating mitigation.

Approved Document Q: Document providing guidance for compliance with the building regulations requirements for security in dwellings.

Building Regulations: A set of standards for the design, construction and extension of buildings to ensure the safety and health for people in or about those buildings. They also include requirements to ensure that fuel and power are conserved and facilities are provided for people, including those with disabilities, to access and move around inside buildings.

Category 1 hazard: See Housing Health and Safety Rating System (HHSRS). A health and safety hazard at the “category 1” level is, broadly, one which is likely to result in harm over a 12-month period that requires some form of medical attention.

Commonhold: An alternative to leasehold under which individual flats are owned on a freehold basis. Each unit owner is a member of the commonhold association, which owns and manages the common parts of the building or estate.

Decent Homes Standard Review: A review of the Decent Homes Standard to ensure it is in line with modern demands and expected standards in the social rented sector. It was committed to in the social housing white paper, published on 17 November 2020.

Decent Homes Standard (DHS): The Decent Homes Standard has played a key role in setting the minimum standards that social homes are required to meet since 2001. The standard sets out four criteria for evaluating decency – it requires that homes are free of serious hazards, are in a reasonable state of repair, have reasonably modern facilities and services such as kitchens and bathrooms, and have efficient heating and effective insulation. The Decent Homes guidance COVER

English Housing Survey (EHS): A continuous national survey commissioned by the Ministry for Housing, Communities and Local Government (MHCLG). It collects information about people’s housing circumstances and the condition and energy efficiency of housing in England.

Fire and Rescue Incident Statistics: National statistics on fires, casualties, false alarms and non-fire incidents attended by the fire and rescue services in England.

Health and Safety Executive (HSE): Government agency that aims to reduce work-related death, injury and ill health.

Housing Act 2004: Part 1 of the Housing Act 2004 covers enforcement of housing standards and the use of the Housing Health and Safety Rating System (HHSRS).

Housing Association (HA): Non-profit organisation set up to provide affordable homes for those in need.

Housing Health and Safety Rating System (HHSRS): A risk-based assessment tool used to assess hazards in residential premises. Criterion A of the DHS says that to be decent, a dwelling should be free from hazards assessed at the ‘category 1’ level, using the HHSRS. In addition, if a local council carries out an HHSRS assessment and identifies hazardous conditions at the most dangerous category 1 level, they must take enforcement action under the Housing Act 2004.

House in Multiple Occupation (HMOs): A privately rented house or flat occupied by at least three tenants from two or more families who share facilities, e.g. lavatories, kitchens, bathrooms. HMOs with five or more tenants must be licensed by the local council, who also have the power to decide smaller HMOs require licensing. Social housing cannot be an HMO.

The Housing Ombudsman Service (HOS): The Housing Ombudsman Service (HOS) is set up by law to look at complaints about the housing organisations that are registered with them. The service is free, independent, and impartial. The HOS resolves disputes involving the tenants and leaseholders of social landlords (housing associations and local councils) and a small number of voluntary members (private landlords and letting agents).

Impact Assessment (IA): An evidence-based procedure that assesses the impact of a policy proposal. Impact is measured through several metrics, including impact on the environment, health, and justice.

Owner-Occupier Leaseholders: An owner-occupier leaseholder is a person who owns the property in which they live on a leasehold basis.

Leasehold: Leasehold is a form of property ownership, typically used for flats and occasionally for houses, in which the leaseholder has a long-term tenancy granting the right to occupy and use the property for a specified period – known as the ‘term’ of the lease. This generally means a period of over 21 years and the lease can be bought and sold during this term. The term is fixed at the beginning and decreases year by year, until the property returns to the freeholder or intermediate landlord (although the leaseholder may be entitled to an assured tenancy on expiry of the long lease).

Leaseholder: A person who buys a leasehold property on a long lease.

Minimum Energy Efficiency Standards (MEES): A baseline energy efficiency standard that properties have to meet to be let. The standard is measured using Energy Performance Certificates and is currently only applied to the private rented sector. It stipulates that all properties must meet, at a minimum, EPC Band E. The Decent Homes Standard review includes provisions for extending MEES to social housing. If properties do not meet MEES, they will not be considered decent.

Private Registered Provider: A registered provider of social housing that is not a local council. Most are housing associations.

Private rented sector: The housing tenure consisting of properties owned by private landlords and rented to tenants.

Regulator of Social Housing (RSH): The independent body regulating registered providers of social housing (such as local authority landlords and private registered providers (such as not for profit housing associations, co-operatives and for-profit organisations) in England. More information on the Regulator’s role Our role and approach to regulating landlords - GOV.UK

Social housing green paper (SHGP): The social housing green paper was published in August 2018. Following the Grenfell Tower tragedy, it aimed to rebalance the relationship between landlords and tenants, deal with stigma and ensure social housing is safe and decent.

Social housing white paper (SHWP): The social housing white paper was published in November 2020, based on evidence and views gathered through the social housing green paper. It sets out the actions the government will take to ensure that tenants in social housing are safe, are listened to, live in good quality homes, and have access to redress when things go wrong. It included a commitment to review the Decent Homes Standard and consult on electrical safety.

Social Housing (Regulation) Act 2023 (SHRA): An Act that became law on 20 July 2023 and that makes provisions for the Regulator of Social Housing to take a new, proactive approach to hold social housing registered landlords to account to deliver outcome of their consumer standards. It additionally provides the Housing Ombudsman Service with the power to issue good practice guidance, and to order social landlords to complete a self-assessment against that guidance when a complaint is received, as well as extending the power to make electrical safety standards regulations to social housing.

Social Landlord: A local council landlord or private registered provider of social housing (such as a housing association).

Social Rented Sector: Homes for rent that are owned by social housing registered providers such as local authority landlords and private registered providers (such as not for profit housing associations, co-operatives and for-profit organisations). This includes general needs, affordable rent and self-contained supported housing. This does not include shared ownership homes, rent to buy, or similar schemes. It also does not include other types of housing which have their own safety standards such as Houses in Multiple Occupation (HMOs), care homes, student halls of residence, hostels, hospices and other accommodation relating to healthcare provision.

Sounding board: Convened by government to support and advise on the Decent Homes Standard Review; made up of key stakeholders from social sector and private rented sector (tenant and landlord representatives and technical experts).

Supported Housing: Accommodation where tenants receive care, support or supervision.

Temporary Accommodation: Temporary housing for people who are statutorily homeless and have priority need. It includes private rented sector accommodation, local council or housing association stock, B&Bs, hotels, hostels and refuges.

White paper: Policy document produced by the government that sets out proposals for future legislation.

Annex B: List of Decent Homes Review Core Sounding Board Members

• Academics (Cardiff Metropolitan & Greenwich University)
• Acorn
• Association of Chief Environmental Health Officers
• Association of Retained Council Housing (ARCH)
• Bristol Council
• British Property Federation
• Building Research Establishment (BRE)
• Chartered Institute of Housing (CIH)
• Chartered Institute of Environmental Health (CIEH)
• Confederation of Cooperative Housing
• Councils with ALMOs Group (CWAG)
• Crisis
• Derby Council
• East Suffolk Council
• English Rural Housing Association
• G15
• G320
• Gateshead Council
• Generation Rent
• Housing Ombudsman Service
• Justice for Residents
• Local Government Association (LGA)
• London Councils
• National Federation of Arms-Length Management Organisations (ALMOs)
• National Federation of Tenant Management Organisations
• National Housing Federation (NHF)
• Northern Housing Consortium
• National Residential Landlord Association (NRLA)
• Propertymark
• Regulator of Social Housing
• RH Environmental
• Safer Renting
• Shelter
• TAROE
• Tenant Participation Advisory Service (TPAS)
• Waltham Forest Council
• West Northamptonshire Council

Annex C: About this consultation

This consultation document and consultation process have been planned to adhere to the Consultation Principles issued by the Cabinet Office.

Representative groups are asked to give a summary of the people and organisations they represent, and where relevant who else they have consulted in reaching their conclusions when they respond.

Information provided in response to this consultation may be published or disclosed in accordance with the access to information regimes (these are primarily the Freedom of Information Act 2000 (FOIA), the Environmental Information Regulations 2004 and UK data protection legislation. In certain circumstances this may therefore include personal data when required by law.

If you want the information that you provide to be treated as confidential, please be aware that, as a public authority, MHCLG is bound by the information access regimes and may therefore be obliged to disclose all or some of the information you provide. In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on MHCLG.

The Ministry of Housing, Communities and Local Government will at all times process your personal data in accordance with UK data protection legislation and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties. A full privacy notice is included below.

Individual responses will not be acknowledged unless specifically requested.

Your opinions are valuable to us. Thank you for taking the time to read this document and respond.

Are you satisfied that this consultation has followed the Consultation Principles? If not or you have any other observations about how we can improve the process please contact us via the complaints procedure.

Annex D: Personal data

The following is to explain your rights and give you the information you are entitled to under UK data protection legislation.

Note that this section only refers to personal data (your name, contact details and any other information that relates to you or another identified or identifiable individual personally) not the content otherwise of your response to the consultation.

The identity of the data controller and contact details of our Data Protection Officer  

The Ministry of Housing, Communities and Local Government (MHCLG) is the data controller. The Data Protection Officer can be contacted at

dataprotection@communities.gov.uk or by writing to the following address:

Data Protection Officer
Ministry of Housing, Communities and Local Government
Fry Building
2 Marsham Street
London
SW1P 4DF

Why we are collecting your personal data 

Your personal data is being collected as an essential part of the consultation process, so that we can contact you regarding your response and for statistical purposes. We may also use it to contact you about related matters.

We will collect your IP address if you complete a consultation online. We may use this to ensure that each person only completes a survey once. We will not use this data for any other purpose.

Sensitive types of personal data

Please do not share special category personal data or criminal offence data  if we have not asked for this unless absolutely necessary for the purposes of your consultation response. By ‘special category personal data’, we mean information about a living individual’s:

• race
• ethnic origin
• political opinions
• religious or philosophical beliefs
• trade union membership
• genetics
• biometrics
• health (including disability-related information)
• sex life; or
• sexual orientation.

By ‘criminal offence data’, we mean information relating to a living individual’s criminal convictions or offences or related security measures.

Our legal basis for processing your personal data

The collection of your personal data is lawful under article 6(1)(e) of the UK General Data Protection Regulation as it is necessary for the performance by DLUHC of a task in the public interest/in the exercise of official authority vested in the data controller.  Section 8(d) of the Data Protection Act 2018 states that this will include processing of personal data that is necessary for the exercise of a function of the Crown, a Minister of the Crown or a government department i.e. in this case a consultation.

With whom we will be sharing your personal data

MHCLG may appoint a ‘data processor’, acting on behalf of the department and under our instruction, to help analyse the responses to this consultation.  Where we do we will ensure that the processing of your personal data remains in strict accordance with the requirements of the data protection legislation.

For how long we will keep your personal data, or criteria used to determine the retention period

Your personal data will be held for 2 years from the closure of the consultation, unless we identify that its continued retention is unnecessary before that point.

Your rights, e.g. access, rectification, restriction, objection

The data we are collecting is your personal data, and you have considerable say over what happens to it. You have the right:

a. to see what data we have about you

b. to ask us to stop using your data, but keep it on record

c. to ask to have your data corrected if it is incorrect or incomplete

d. to object to our use of your personal data in certain circumstances

e. to lodge a complaint with the independent Information Commissioner (ICO) if you think we are not handling your data fairly or in accordance with the law.  You can contact the ICO at https://ico.org.uk/ or telephone 0303 123 1113.

Please contact us at the following address if you wish to exercise the rights listed above, except the right to lodge a complaint with the ICO: dataprotection@communities.gov.uk or

Knowledge and Information Access Team
Ministry of Housing, Communities and Local Government
Fry Building
2 Marsham Street
London
SW1P 4DF

Your personal data will not be sent overseas

Your personal data will not be used for any automated decision making

Your personal data will be stored in a secure government IT system

We use a third-party system, Citizen Space, to collect consultation responses. In the first instance your personal data will be stored on their secure UK-based server. Your personal data will be transferred to our secure government IT system as soon as possible, and it will be stored there for 2 years before it is deleted.

1. BRE report, The cost of poor housing (2021) ↩

2. The Health Foundation, Health Equity in England: The Marmot Review 10 Years On (2020) ↩

3. English House Condition Survey 2001 (p2) ↩

4. English Housing Survey 2023 to 2024: headline findings on housing quality and energy efficiency - GOV.UK ↩

5. English Housing Survey 2022 to 2023: rented sectors - GOV.UK Annex Table 4.4 ↩

6. Assessed using the Housing Health and Safety Rating System (HHSRS) ↩

7. BRE, cost of poor housing tenure analysis (2023) ↩

8. Transport Research Laboratory, Re-valuation of Home Accidents (2009) ↩

9. Statistics at RSH - Regulator of Social Housing - GOV.UK (www.gov.uk) ↩

10. Local authority housing data - GOV.UK (www.gov.uk) ↩

11. https://www.gov.uk/government/collections/tenant-satisfaction-measures ↩

12. https://www.gov.uk/government/publications/rogue-landlord-enforcement-guidance-for-local-authorities ↩

13. https://www.gov.uk/government/publications/homes-fitness-for-human-habitation-act-2018 ↩

14. https://www.gov.uk/government/publications/smoke-and-carbon-monoxide-alarms-explanatory-booklet-for-landlords ↩

15. https://www.hse.gov.uk/asbestos/duty/check.htm ↩

16. https://www.hse.gov.uk/legionnaires/legionella-landlords-responsibilities.htm ↩

17. https://www.gov.uk/guidance/domestic-private-rented-property-minimum-energy-efficiency-standard-landlord-guidance ↩

18. https://www.gov.uk/government/publications/electrical-safety-standards-in-the-private-rented-sector-guidance-for-landlords-tenants-and-local-authorities ↩

19. Written statements - Written questions, answers and statements - UK Parliament ↩

20. Awaab’s Law: Consultation on timescales for repairs in the social rented sector - GOV.UK ↩

21. Landlords will continue to be required to meet all fire safety requirements as set out in fire safety regulations. Where fire safety components listed in Criterion B have been installed to comply with fire safety regulations, the DHS requirements that components are kept in reasonable repair does not place any new burden on landlords. ↩

22. Ibid ↩

23. NHS Digital, Hospital Admitted Patient Care Activity (2023-24) ↩

24. Keogh S, Gray JS, Kirk CJ, et al, Children falling from a height in London. Injury Prevention 1996;2:188-191. ↩

25. Apostolopoulou K, Setia V, Pettorini B, Parks C, Ellenbogen J, Dawes W, Mallucci C, Mehta B, Sinha A. Secure windows for child safety: a retrospective study of window falls in children, aiming to raise prevention awareness. Childs Nerv Syst. 2023 Apr 24:1–11 ↩

26. Ibid ↩

27. Ibid ↩

28. HHSRS Operating guidance ↩

29. Approved Document K (Building Regulations) ↩

30. RR1219: A study of the effectiveness of guarding to prevent falls through window openings - HSE ↩

31. Grenfell Tower Inquiry - Hansard - UK Parliament 2 December 2024 Grenfell Tower Inquiry debate ↩

32. Overheating: Approved Document O - GOV.UK (www.gov.uk) ↩

33. RoSPA- Keeping Kids Safe - Preventing falls and injuries ↩

34. Falls from open windows, Child Accident Prevention Trust ↩

35. Should-you-accept-63-more-risk-in-private-rented-housing.pdf ↩

36. Should-you-accept-40-more-risk-in-social-housing.pdf (ntu.ac.uk) ↩

37. An easily accessible doorway is one where any part is within 2m vertically of an accessible level surface such as a ground or basement level, or an access balcony. An easily accessible window is one where any part is within 2m vertically of an accessible level surface such as a ground or basement level, or an access balcony; or within 2m vertically of a flat or sloping roof (with a pitch of less than 30°) that is within 3.5m of ground level. ↩

38. Doorsets are a complete door assembly, including the door frame, door leaf or leaves, essential hardware and any integral side panel or fanlight (but excluding windows are supplied as separate self-contained frames and fixed together onsite). They can be assembled on site or delivered as a completed assembly. ↩

39. Building regulations guidance: Approved document Part Q Security in dwellings: Approved Document Q ↩

40. altairltd.co.uk/wp-content/uploads/2024/05/Final-Report-Longleigh-Flooring-final.pdf ↩

41. Social housing lettings in England, tenants: April 2023 to March 2024 - GOV.UK ↩

42. https://www.legislation.gov.uk/uksi/2019/595/note/made ↩

43. https://bregroup.com/news/bre-report-finds-poor-housing-is-costing-nhs-1.4bn-a-year#:~:text=BRE%27s%20findings%20indicate%20the%20cost,%C2%A318.5%20billion%20per%20year. ↩

44. https://www.gov.uk/government/collections/english-housing-survey ↩

45. www.gov.uk/government/publications/damp-and-mould-understanding-and-addressing-the-health-risks-for-rented-housing-providers ↩

46. www.housing-ombudsman.org.uk/reports/spotlight-reports/spotlight-on-damp-and-mould/ ↩

47. Supported Housing (Regulatory Oversight) Act 2023 (legislation.gov.uk) ↩

48. ​Safety and Quality Standard - GOV.UK ↩