Consultation outcome

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

Updated 28 January 2026

Ministerial foreword

As a government, we are determined to make decisive progress toward a country in which everyone enjoys the security and comfort of a safe, warm and decent home. Our new, modernised Decent Homes Standard (DHS) is integral to that effort.

The DHS has defined baseline expectations of housing quality in the Social Rented Sector (SRS) since 2001. In the quarter of a century since its introduction, millions of social housing tenants have seen their homes upgraded, made safer, and maintained to a good standard. However, the DHS was last updated in 2006 and is now out of date.

Despite the progress made over recent decades, it also remains the case that far too many social and private tenants continue to experience poor quality housing. As of 2023, 21% of homes in the Private Rented Sector (PRS) and 10% of homes in the SRS failed to meet the DHS.

Our new, modernised DHS is designed to meet modern expectations of housing quality. By setting out in plain terms a series of ambitious yet proportionate standards for landlords to adhere to, it will help ensure we continue to drive down rates of non-decency across the country. Importantly, our new DHS will apply to both the SRS and PRS, meaning that all tenants in rented housing will benefit, regardless of who their landlord is.

This important reform is one of a series of changes this government has made to drive a transformational and lasting change in the safety and quality of our housing stock. Our expectations are clear: no tenant should have to live in unsafe conditions for any amount of time, and social and private landlords should act as quickly as possible to ensure their properties are decent.

However, we recognise the significant challenges that landlords are facing as a result of the bold and comprehensive regulatory changes we are enacting. We are also acutely aware that we are asking social landlords to balance the competing demands of improving their existing stock and building more desperately needed social and affordable homes. As such, we have decided that all rented properties will be required to meet the new DHS by 2035 at the latest – an implementation timeline that gives social landlords in particular the time and the certainty they need to boost housing supply as well as drive up the quality of the homes they manage.

I would like to thank all those who took the time to contribute to our consultation on a reformed DHS. Your thoughtful engagement has played an important role in shaping this new standard. I trust it will provide both landlords and tenants with a shared understanding of what a safe, warm and decent home must look like.

Matthew Pennycook MP, Minister for Housing and Planning

Executive summary

1. A new DHS will set out what tenants should be able to expect from their home and make clear the obligations for landlords in providing a home that is safe and warm.

2. A consultation ran from 2 July to 12 September 2025 to seek views on proposals for a new DHS for the social and private rented sectors in England. An interim Impact Assessment was published, to invite views on the estimated costs and benefits of proposals for a new DHS.

3. During the same period, the government ran a separate consultation on introducing a Minimum Energy Efficiency Standard (MEES) in the social rented sector. As part of wider social housing announcements in January 2026 the government confirmed the policy design of MEES. The government also consulted on MEES in private rented homes (PRS) in February 2025 and published a response in January 2026, which can be read here: Improving the energy performance of privately rented homes: 2025 update - GOV.UK

4. Alongside the consultations, we have engaged extensively with landlords and tenants to develop a final proposal for the new standard. As well as setting out the government’s response to the consultation responses, this document sets out the findings of this engagement, the government’s response to the findings, and full details of requirements under a new DHS.

5. We are publishing this government response alongside a policy statement which sets out further detail of the new DHS. As an overview, the new DHS will require:

Criterion A – A home must be free of the most dangerous hazards.

To meet this criterion, properties must be free of ‘category 1’ hazards, as assessed under the Housing Health and Safety Rating System (HHSRS).

Criterion B – A home must be in a reasonable state of repair.

Homes will fail against this criterion if:

• one or more key building components is not in a reasonable state of repair, or
• two or more other building components are not in a reasonable state of repair

Criterion C – A home must provide core facilities and services.

To meet this criterion, flats must provide at least 3 of the following facilities:

• 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

To meet this criterion, houses must provide at least 2 of the following facilities:

• a kitchen with adequate space and layout
• an appropriately located bathroom and WC
• adequate external noise insulation

Homes must also be equipped with child-resistant window restrictors, which can be overridden by an adult, on all windows which present a fall risk for children.

Criterion D – A home must provide thermal comfort.

To meet this criterion, homes must provide a reasonable degree of thermal comfort. This includes ensuring homes meet Minimum Energy Efficiency Standards.

Criterion E – A home should be free of damp and mould.

Homes will be non-decent if a landlord has not remedied damp and mould.

6. The government has introduced landmark changes to transform the experience of private renting. The Renters’ Rights Act 2025 will give renters much greater security and stability, including by ending Section 21 ‘no fault’ evictions from 1 May 2026. The Act will also tackle the blight of poor-quality privately rented homes, including through allowing the DHS to be applied to the private rented sector for the first time. A consultation was published by the previous government on the introduction of the DHS to the PRS. This government published a response in July 2025, which can be read here: Response to the consultation on a Decent Homes Standard in the private rented sector.

7. Compliance with the DHS is already regulated in the social rented sector by the Regulator of Social Housing (RSH) and will be enforced in the PRS by local authority enforcement teams.

8. The Housing Ombudsman will continue to play a role in offering social rented sector (SRS) tenants a route to redress if they are unhappy with how their landlord has dealt with a complaint. Through the Renters’ Rights Act, we have also introduced provisions for a new PRS Landlord Ombudsman Service, which nearly all PRS landlords will need to join. Once established, PRS tenants will be able to access redress through this route, to resolve complaints about their landlords’ actions or behaviours, including complaints about standards and repairs.

9. The new DHS will apply from 2035 in both the social and private rented sectors, at which point regulation and enforcement against these standards by the Regulator of Social Housing and local authority housing teams will begin. This timeframe will allow landlords time to implement other regulatory changes, including Awaab’s Law; new Minimum Energy Efficiency Standards; and other reforms included in the Renters’ Rights Act. Social landlords will also be given the space needed to prioritise the supply of new secure and affordable homes. However, we are clear that landlords should not leave all work to improve homes to the end of the implementation period and will publish guidance to support this.

10. The DHS will apply to supported housing and temporary accommodation, but in recognition of the specific challenges applying the DHS to these tenures may entail, we will bring forward additional guidance in the coming months. We will also provide in guidance more detail on applying the DHS in a fair and proportionate way to rented homes where the landlord is a leaseholder, and to mixed-tenure blocks which include rented properties and owner-occupied leasehold properties.

11. We will publish detailed guidance to accompany this new standard in the coming months.

The consultation: Content and Approach

12. The consultation sought views from social and private rented tenants, landlords, and other interested groups from across the housing sector. The consultation sought views on the following proposals:

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 their condition and their age. The list of key and other building components is 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[footnote 1]. 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 should 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 and mould requirement.	Landlords should ensure their properties are free from damp and mould.

13. The consultation was open for 10 weeks. Respondents could respond via our online survey, email, or by post. The consultation asked 49 questions in total. This included both questions that invited a ‘yes’ or ‘no’ response, as well as questions inviting further views in a free text box.

14. Over the consultation period we engaged with stakeholders representing tenant and landlord groups. We reconvened a panel of experts in the SRS and PRS and delivered online working groups with the National Housing Federation, Local Government Association and Chartered Institute of Housing. We also collaborated with the tenant convening bodies Citizens UK and TPAS on a series of in-person roadshows in London, Liverpool, Manchester and Birmingham.

15. The consultation followed the consultation principles guidance issued by the Cabinet Office. It was accompanied by an interim Impact Assessment. We have now published an updated Impact Assessment, informed by evidence provided to the consultation.

Summary of consultation responses

16. 820 responses were received to this consultation, excluding duplicates.

17. 49 questions were asked, including a total of 100 subsidiary questions. Respondents were not required to answer all the questions in the consultation.

18. To account for the differences in views between groups, the first 10 questions of the consultation asked respondents about their background and the capacity in which they were responding. This data was used to categorise respondents into 11 different groups, as set out below:

Respondent Group	Number of responses	Percentage
Representative organisation (including charities)	152	19%
Private landlord	128	16%
Social landlord – non-local authority (e.g. housing associations or private registered providers (PRPs)	120	15%
Other	102	12%
Social landlord - local authority	102	12%
Tenant in the social rented sector	102	12%
Local authority - other	62	8%
Tenant in the private rented sector	31	4%
Leaseholder	10	1%
Letting agent	7	<1%
Government body	4	<1%

19. All responses received have been considered and are summarised in this document, including where response rates differ between groups. The findings of free text and multiple-choice questions are presented differently:

a. Responses to multiple-choice questions are presented numerically and are accompanied by a narrative description of major differences in responses between groups. Full breakdowns of how each group responded to each multiple-choice question are included at Annex A. Please note that response rates have been rounded to the nearest whole number and so do not always sum to 100%.

b. Responses to free-text questions were analysed to identify common themes and coded by which themes were present in each response. This approach provides a high-level view of the topics raised by different groups, rather than a precise numerical output. Narrative summaries of the findings of this analysis are therefore included in this document, using the following terminology:

• Theme raised by 0 to 19% of respondents - ‘A few’ or ‘A small number of’
• Theme raised by 20 to 39% of respondents - ‘Some’
• Theme raised by 40 to 59% of respondents - ‘Around half’
• Theme raised by 60 to 79% of respondents - ‘Many’ or ‘Most’
• Theme raised by 80+% of respondents - ‘A substantial majority’

20. All responses to the consultation have been considered as part of the government’s policy development. However, some responses are not included in the statistics presented in this document, specifically

• responses submitted by email that did not follow the questions or sections set out in the consultation document and online questionnaire.
• responses from groups to questions specifically targeted at other groups – for example tenant responses to questions marked ‘landlords only’
• responses selecting ‘not applicable’, where this option was available

Proposal 1: Definition of Disrepair (Criterion B)

Question 11: Do you agree that age should be removed from the definition of disrepair?

21. There were 765 responses to this question.

Option	Total	Percentage
Yes	627	82%
No	103	13%
Don’t know	35	5%

22. There was support for this proposal from all respondent groups. 80% of SRS tenants and 77% of PRS tenants responded ‘yes’ to this question, as did 86% of PRS landlords, 80% of LA landlords and 74% of PRPs.

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?

23. There were 752 responses to this question.

Option	Total	Percentage
Yes	677	90%
No	39	5%
Don’t know	36	5%

24. Respondents were supportive of this proposal overall, with 95% and 94% of SRS and PRS tenants responding ‘yes’. 81% of PRS landlords supported the proposal, as well as 88% and 90% of LA landlords and PRPs.

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?

25. There were 742 responses to this question.

Option	Total	Percentage
Yes	448	60%
No	187	25%
Don’t know	107	14%

26. There was overall support for this proposal, though level of support varied across different respondent groups. 55% of SRS tenants and 71% of PRS tenants responded ‘yes’. 54% of PRS landlords, 63% of LA landlords, and 52% of PRPs also responded ‘yes’.

Question 14 (Landlords only): Do you think 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?

27. 330 responses were received from landlords. As the question is directed specifically at landlords, responses from other groups are not summarised here.

Option	Total	Percentage
Yes	141	43%
No	160	48%
Don’t know	29	8%

28. For this question the overall response between PRS landlords and SRS landlords was different. 62% of PRS landlords responded ‘no’ to this question, compared to 37% of LA landlords and 42% of PRPs.

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?

29. There were 733 responses to this question.

Option	Total	Percentage
Yes	611	83%
No	98	13%
Don’t know	24	3%

30. There was overall support for this proposal, with 97% of PRS and SRS tenants agreeing with this proposal. Of the PRS landlords that responded 60% responded ‘yes’, as did 78% and 84% of LA landlords and PRPs.

Question 16a: Do you agree with the proposed list of building components that must be kept in good repair?

31. There were 731 responses to this question.

Option	Total	Percentage
Yes	532	73%
No	155	21%
Don’t know	44	6%

32. When broken down by group, tenants responded very positively to this question, with 95% of SRS tenants and 93% of PRS tenants responding ‘yes’. 60% of PRS landlords selected ‘yes’ and 31% selected ‘no’. LA landlords were supportive with 67% responding ‘yes’ and 28% responding ‘no’, 53% of PRPs selected ‘yes’ and 45% selected ‘no’.

Question 16b:  If you have any views on this specific question you would like to share, please do so here.

33. There was a total of 404 responses to this question.

34. A small number of respondents mentioned component age in their response to this question. SRS landlords highlighted that whilst they understood the rationale for the removal of age, it played an important role in management of their properties and planning processes.

35. Landlords raised concerns about costs associated with the changes to Criterion B, without grant funding for decency as had been provided when the DHS was introduced in 2001.

36. A few respondents also referenced damp and mould and the importance of ventilation in preventing this from occurring, and shared views on proposals for inclusion of external components in the DHS.

Question 17: Do you agree with the proposed ‘key’ components and ‘other’ components as listed?

37. There were 718 responses to this question.

Option	Total	Percentage
Yes	479	67%
No	162	23%
Don’t know	77	11%

38. Overall, both SRS and PRS tenants agreed with the list, with 84% and 80% responding positively. Over half of landlords also agreed - 55% of PRS landlords, 60% of LA landlords, and 57% of PRPs responded ‘yes’.

Question 18: 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?

39. There were 716 responses to this question.

Option	Total	Percentage
Yes	245	34%
No	402	56%
Don’t know	69	10%

40. Most respondents disagreed that additional public realm components should apply only to the social rented sector, including 63% of SRS tenants, 67% of PRS tenants, 71% of LA landlords, and 84% of PRPs. The only group that were supportive of this proposal was PRS landlords, with 73% responding ‘yes’ to this question.

Question 19: If you have any views on these specific questions you would like to share, please do so here.^{[footnote 2]}

41. There were 423 responses to this question.

42. Around half of SRS landlords responded to raise concerns about the addition of public realm responsibilities for SRS landlords only.

43. Although only a small number of tenants responded to this question, many mentioned their support for the universal application of the DHS across rented tenures, suggesting that the standard should be equal across all tenancies. This theme was also raised by around half of SRS landlords, representative organisations, and local authorities not responding as landlords.

44. Respondents shared views about the shift from an age-based requirement to an outcomes-based requirement, welcoming the overall change but highlighting the importance of making sure the changes work effectively to avoid compromising the quality of tenants’ homes.

Government response

Removing age from the definition of disrepair

45. In line with the views of the majority of respondents, the new DHS will remove 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).

46. Respondents agreed that the DHS should focus on the quality of homes, with an obligation on landlords to act when components are broken and negatively affecting tenants’ experience of living in their home. Components should not be left in disrepair simply because they have not reached the end of their life span, and removing age from the definition of disrepair is critical to achieving this.

47. PRS landlords stated that it would be difficult to retain a requirement on the age of components, as they are less likely to have information of when components were installed where this may have occurred before they purchased the property.

48. Responses from SRS landlords raised concerns that the age of components remains important for management of their homes and for business planning purposes. We are clear that the removal of age from the definition of disrepair should not inhibit landlords from designing repair and maintenance programmes in a way that best supports them to manage their homes and plan ahead for their business. We recognise that this may involve planning based on the age of components. We will use guidance to clarify that there is no barrier to landlords doing this. It is ultimately for landlords to determine how best to manage stock and ongoing maintenance programmes as they comply with the new DHS.

Defining ‘poor condition’ of building components (thresholds)

49. In line with the support received in responses to the consultation, the new DHS will focus on the condition of property by using outcome-based descriptive definitions of disrepair rather than percentage-based thresholds.

50. The new building component list and definitions of disrepair (including examples) are:

Component	Definition of disrepair	Examples (to be developed further in detailed guidance)
Wall structure (key)  including lintels, brickwork, damp proof courses and external wall finish  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.	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, overloaded or slipped lintels due to settlement, bowing of walls and over sailing of walls at Damp Proof Course (DPC) level.
Internal wall and ceiling finish (key)  Does not include decoration.	Plaster requires major repair.	Problems could include: significant crumbling or unbonded plaster; extensive or serious cracking of plaster.
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; water ingress/leaks;  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: significant number of missing, broken or slipped slates or tiles; broken or slipped ridge tiles and hips; missing verges 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; defective 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.	As well as meeting the requirements for an inspection and test of the electrical safety installation at least every five years, 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.
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.	Problems could include: damage that inhibits the user’s ability to read the information, 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.
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	Problems could include: repairs needed to shaft, car, doors, call panel or control panel.

Other building components 

Component	Definition of disrepair for consultation	Examples (to be developed further in detailed guidance)
Rainwater goods (other)	Requires replacement, repair or major unblocking.	Problems could include: cracked or corroded or detached 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)

51. There was clear support for this approach through the consultation. Outcome-based definitions will now be applied to building components. These definitions, supplemented by examples in guidance, will be easier to interpret so all tenants and landlords can more readily assess when a component listed under Criterion B is fit for purpose.

52. In response to concerns raised by landlords that the thresholds must avoid placing a disproportionately high level of repair responsibility on landlords, we will make clear that components that only need minor repairs will not lead to a failure of the DHS.

53. To provide further clarity, we have amended the component list and definitions of disrepair included in the consultation to separate the core definition of disrepair for each component from the illustrative examples of what tenants and landlords can take into consideration when evaluating whether a component is non-decent. For example, a single slipped roof tile may not make a roof non-decent but is an observable fault that may suggest the roof is in disrepair and needs attention.

54. We are committed to continue working with both sectors as we develop detailed guidance to ensure that the new outcomes-based definitions and examples of disrepair are as clear and practical as possible.

Building component list

55. The consultation proposed amending some existing components and making additions. The new DHS will contain additions to the building component list, including bathroom components, and components relating to fire safety, damp and causes of damp, safe access, internal finish and security. It will not include additions relating to shared outdoor spaces (public realm components).

56. Whilst we will work with both sectors to refine definitions and examples of disrepair, building components included in this list are not subject to further change.

57. The proposed additions were supported in the consultation. There were some concerns which are addressed below:

Fire safety

58. A small number of consultation responses raised concerns about possible duplication stemming from the introduction of fire safety components with existing fire safety requirements. We are satisfied that the addition of these components does not create conflicts in regulatory requirements or add additional burdens on landlords and reinforces good fire safety practice. Including fire safety in the DHS will clearly signpost residents to fire safety requirements and emphasises that fire safety is an important part of decency. Therefore, fire safety components listed will form part of the new DHS.

Lifts

59. There were concerns from a few respondents about the potential impact of the inclusion of lifts in the DHS on non-decency rates for blocks of flats, where a broken lift would make all properties in the block non-decent.

60. Whilst we recognise these concerns, there was strong support for this proposal from other respondents and know that a working lift is of key importance to tenants’ experiences, particularly those who are disabled and those with young children.

61. Whilst recognising some of the concerns raised, consultation feedback emphasised that working lifts are fundamental to tenants being able to access and fully enjoy their homes. As such, this proposal will be retained in the new DHS.

Public Realm (SRS only)

62. The consultation proposed the addition of some public realm components to the building components list. Public realm components sit outside of the individual dwelling or building and can include components like external pathways and boundary walls.

63. The consultation also proposed only applying these additions to the social rented sector on the basis that social landlords are more likely to have responsibility for these areas as owners of full blocks of flats rather than only a single dwelling within a block owned by a different freeholder, as can be the case in the PRS.

64. In their responses to the consultation, social landlords raised concerns that the addition of public realm components to the building component list would stretch the scope of the DHS too far beyond the home to include features that are not core property components. There was also concern that these components would be practically challenging to include in Criterion B where the landlord may not be the freeholder, and risk placing additional cost pressures on owner-occupier leaseholders in mixed tenure blocks of flats.

65. Where there was support for the proposal, respondents were mainly concerned by the principle of these components applying only to the social rented sector when the operational challenges would likely be faced by both PRS and SRS landlords, and that this would undermine equal standards between the rented tenures.

66. Responses also highlighted the growth of the ‘build to rent’ market, where a single freeholder owns the entirety of a block of flats for rent in the private rented market. These respondents suggested applying these components only to the SRS would overlook this growing area of the rented housing market.

67. We recognise that outdoor spaces (and the wider public realm) play an important role in how tenants experience their homes and environment.  However, we accept that the inclusion of public realm components within the DHS would create complexities around where accountability lies in outdoor spaces and increase burdens on landlords. There remains an expectation on landlords to consider all aspects of the home and to respond to the needs of tenants, including in outdoor spaces. We will highlight this in guidance.

68. Based on the feedback received, public realm components (boundary walls, curtilage, external pathways and steps, external lighting, bin stores) will not be added to the building component list in the new DHS.

Proposal 2: Facilities and services (Criterion C)

Question 20a: Do you agree that under the new DHS landlords should be required to provide at least three out of the four facilities listed?

69. There were 732 responses to this question.

Option	Total	Percentage
Yes	409	56%
No	282	39%
Don’t know	41	6%

70. This proposal was widely supported by tenants, with 82% of SRS tenants and 77% of PRS tenants agreeing that landlords should have to provide three out of the four listed facilities. Views were more split amongst landlords; the majority of PRS landlords did not support this proposal with 35% responding ‘yes’ and 56% responding ‘no’. For LA landlords, 49% responded ‘yes’ and 45% responded ‘no’. For PRPs, 54% responded ‘yes’ and 40% responded ‘no’.

Question 20b: If you said No, are there any of the facilities that you would prioritise?

71. There were 287 responses to this question. Respondents could choose more than one options, and were not limited to those who responded ‘no’ to question 20a.

Option	Total	Percentage
Kitchens	264	92%
Bathrooms	267	93%
Noise Insulation	89	31%
Communal Areas	78	27%

72. Respondents predominantly suggested that they would prioritise kitchens and bathrooms; 81% of PRS landlords said they would prioritise kitchens, as did 100% of LA landlords and 96% of PRPs. SRS and PRS tenants also prioritised kitchens, 95% and 90% respectively, although a comparatively low number of tenants responded to this question – in part because more tenants supported including multiple facilities.  86% of PRS landlords said they would prioritise bathrooms, as did 98% of LA landlords and 96% of PRPs. Tenants responded in a similar manner, with 90% of both PRS and SRS tenants prioritising bathrooms.

Question 20c: 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?

73. There were 704 responses to this question.

Option	Total	Percentage
Yes	423	60%
No	141	20%
Don’t know	140	20%

74. When broken down by respondent type, views were mixed on whether the multiple-choice nature of Criterion C would have practical implications. For SRS tenants, 45% responded ‘yes’, 23% responded ‘no’, and 32% responded that they did not know. For PRS tenants, 59% selected ‘yes’, 17% responded ‘no’, and 24% responded that they did not know. Overall, there was more agreement amongst SRS landlords that this proposal would have practical implications, with 73% of LA landlords responding ‘yes’, along with 65% of PRPs. 53% of PRS landlords responded yes to this question, 26% responded that they did not know, and 21% selected ‘no’.

Question 20c: If you responded yes to question 20c, please provide supporting detail here.

75. 394 respondents provided additional detail. Responses to this question were not limited to only those who responded ‘yes’ to 20c.

76. Some LA landlords, PRPs and PRS landlords, who responded to this question referenced the limitations in landlord financial capacity as a potential implication for the ‘multiple-choice’ nature of Criterion C. Kitchens and bathrooms were highlighted as being particularly costly.

77. Around half of representative groups who responded to this question mentioned the implications for tenant wellbeing. Respondents suggested that allowing landlords to choose which facilities to prioritise risks other important elements being overlooked.

Question 20d: If there is anything else you would like to add on this specific proposal, please do so here.

78. 285 respondents provided additional detail for this question.

79. Some responses mentioned possible building constraints limiting compliance with Criterion C.

80. Concerns were raised around the practical and financial implications of this proposal. Respondents also raised concerns that if multiple choice is available, landlords may simply choose to provide the cheapest facilities rather than those that are a priority for tenants (kitchens and bathrooms).

81. Further to their prioritisation of kitchens at question 20b, some SRS tenants shared views on the relevance of kitchen adequacy and space.

Government response

82. The government recognises that core facilities and services are central to what makes a home decent.

83. In the consultation, we set out a proposal for a ‘multiple-choice approach’ requiring all dwellings to 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 noise insulation
• adequate size and layout of common entrance areas for blocks of flats

84. Around half of respondents supported this proposal. Therefore, we will be requiring landlords to provide at least 3 of the listed essential facilities for flats to be considered decent. As adequate size and layout of common entrance areas for blocks of flats do not apply to houses, landlords will be required to provide at least 2 of the remaining 3 listed essential facilities for houses to be considered decent. Landlords are encouraged to go further and provide all relevant listed facilities.

85. We acknowledge concerns that the ‘multiple choice’ approach could lead to practical challenges in interpreting the policy for tenants, landlords and enforcement bodies. Respondents suggested that a multiple-choice approach could compromise the application of the new DHS and, in the context of constrained resources, there is a risk that landlords will prioritise lower cost elements which will not meet tenants’ needs.

86. Whilst we accept that there will be variation in implementation, the flexibility of multiple choice allows landlords to make the changes most appropriate to homes. This approach is designed to provide tenants with core facilities whilst retaining flexibility to tailor the approach to individual homes, recognising there are practical considerations and variation needed according to building type. The next section sets out further detail on some of the specific concerns raised through the consultation on modern facilities.

Differentiating between flats and houses

87. Respondents suggested that the ‘multiple choice’ approach would provide flexibility for landlords managing flats. However, they also noted that in practice the current wording provides no ‘multiple choice’ for landlords managing houses.

88. To ensure optionality for all housing types, we are providing clarity in the new DHS by setting out different expectations between houses and flats:

a. To meet this criterion, flats must provide at least 3 of the following facilities:

• 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

b. To meet this criterion, houses must provide at least 2 of the following facilities:

• a kitchen with adequate space and layout
• an appropriately located bathroom and WC
• adequate external noise insulation

Kitchens and bathrooms

89. Consultation responses suggested that a functioning kitchen and bathroom with adequate space and layout are particularly important. Tenants also strongly prioritised kitchens and bathrooms as core facilities they would want within their responses.

90. Kitchens and bathrooms must be provided in homes for them to meet Criterion A of the DHS. Failure to provide a kitchen and bathroom would result in a domestic hygiene health and safety hazard at the ‘category 1’ level, which would mean the property would fail to meet the DHS.  Multiple-choice in Criterion C relates to additional requirements focussed on specific aspects and layouts of a kitchen and bathroom deemed important to a good quality of life and to support accessibility.

91. Kitchens and bathrooms must also be kept in good repair. We have therefore upgraded them to ‘key’ components under Criterion B of the new DHS. This means that if the kitchen and/or bathrooms are in disrepair, the property would fail the new DHS.

Where it is not possible to meet the standard

92. Some respondents raised concerns about homes that cannot meet this part of the standard. For example, one respondent raised concerns about the impacts for listed buildings, buildings within conservation and rural areas, and properties which due to their traditional construction cannot reasonably be retrofitted.

93. Although every effort should be made to meet this criterion where possible, we recognise that individual circumstances may mean it will be prohibitively hard or impossible to meet certain elements of the standard for some homes. In these instances, the new DHS will continue to provide an exemption where physical or planning factors prevent compliance in the SRS. For privately rented homes, we will give guidance to local authorities to help ensure that landlords are not unfairly subject to enforcement if it is not possible for a property to meet this criterion of the DHS.

Proposal 3: Window Restrictors (Criterion C)

Question 21 (Landlords only): Do you currently provide child-resistant window restrictors that can be overridden by an adult on dwellings with windows above ground floor?

94. 326 landlords responded to this question. As the question is directed specifically at landlords, responses from other groups are not summarised here.

Option	Total	Percentage
All dwellings	87	27%
Some dwellings	171	52%
None	53	16%
Don’t know	15	5%

95. 22% of PRS landlords, 34% of LA landlords and 26% of PRPs who responded indicated that they provide window restrictors on all dwellings. 30% of PRS landlords, 63% of LA landlords, and 67% of PRPs reported providing for some dwellings, while 42% of PRS landlords and 1% LA landlords, and 2% of PRPs responded that they do not provide them in any dwellings.

Question 22a: 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)?

96. There were 728 responses to this question.

Option	Total	Percentage
Yes	577	79%
No	118	16%
Don’t know	33	5%

97. This proposal was widely supported by tenants, with 93% of SRS tenants and 83% of PRS tenants agreeing. 89% of LA landlords and 88% of PRPs agreed, whilst 40% of PRS landlords agreed. For PRS landlords, 56% disagreed.

Question 22b: If there is anything else you would like to add on this specific proposal, please do so here.

98. There were 364 responses to this question.

99. Respondents raised some concerns, including the cost implications for landlords and whether the proposal was proportionate. A few respondents highlighted potential impacts on airflow, overheating, and the risk of damp and mould. Others noted possible conflicts with fire safety procedures, as well as practical challenges around implementation.

Government response

100. In line with the views of most consultation respondents, we will require all rented properties to provide child-resistant window restrictors that can be overridden by an adult on all windows which present a fall risk for children.

101. We define windows which present a fall risk to children and therefore unsafe if it meets all of the below criteria:

• where the change in floor level between the inside and outside is more than 600mm
• the window can be opened over 100mm
• the guard height is less than 1100mm above internal floor level
• it does not have a functioning window restrictor in place

102. Restrictors must be installed where all four conditions apply. This could include ground floor windows that present a fall risk. Responses to the consultation raised concerns that serious falls from windows are relatively rare, with some landlords suggesting that they do not justify the cost of installing restrictors across all their homes. However, window restrictors represent a proportionate, low-cost, and unobtrusive safety measure that can significantly reduce the risk of serious injury or death.

103. Some respondents suggested excluding ground floor windows, however even at ground level where there is a change in floor level of more than 600mm between the inside and outside, a fall from a window can cause serious harm to a child. This aligns with building regulations (Approved Document K (Protection from falling, collision and impact) and Approved Document O (Overheating)), which provides a clear and consistent standard to follow.

104. Some respondents also raised concerns that installation of window restrictors could compromise fire safety and contribute to damp and mould and overheating. The fire service does not generally approve of the use of windows as a means of escape unless the window has been designed and installed in line with relevant fire safety regulations for that purpose in the event of a fire. Importantly, restrictors can be manually overridden, allowing windows to be opened more widely, when necessary, which also supports ventilation and cooling in line with building regulations on overheating.

105. Some respondents supported early implementation of this proposal stating that these simple devices are both cheap and easy to install, allow families to open windows safely, and give peace of mind that their children cannot fall from a window. We strongly urge landlords to install restrictors on all windows deemed a risk to child safety as soon as possible.

106. Consultation feedback indicates that many landlords already install window restrictors in some, or all, of their properties. This suggests that the proposal builds on existing practice. We also anticipate that landlords will adopt the most cost-effective approaches, often integrating installation with routine repairs and maintenance.

107. We will make clear in the DHS and supporting guidance that the installation of window restrictors must comply with relevant building and fire safety regulations. The DHS guidance will also set out examples of what constitutes a suitable restrictor to ensure consistent safety standards across the sector.

Proposal 4: Home security measures (Criterion C)

Question 23a: Do you think that home security requirements in relation to external doors and windows are sufficiently covered in the Decent Homes Standard?

108. There were 719 responses to this question.

Option	Total	Percentage
Yes	404	56%
No	217	30%
Don’t know	98	14%

109. SRS landlords agreed that home security requirements are sufficiently covered in the DHS, with 69% of LA landlords responding ‘yes’ as well as 72% of PRPs. 73% of PRS landlords also responded ‘yes’ to this question.

110. Of the SRS tenants who responded to this question 35% selected ‘yes’ compared to 47% who selected ‘no’.  PRS tenants were more evenly split in the views shared, with 47% responding ‘yes’ and 40% responding ‘no’.

Question 23b: 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?

111. We received 335 responses to this question. Respondents who answered ‘no’ to part a) were invited to share additional views on whether additional security requirements for doors and windows should be considered. To note, the consultation did not restrict this question to respondents who responded ‘no’ to Q23a).

Option	Total	Percentage
Yes	221	66%
No	55	16%
Don’t know	59	18%

112. A substantial majority of tenants responded ‘yes’ to this question, with 84% of SRS tenants and 88% of PRS tenants responding ‘yes’. 74% of LA landlords and 72% of PRPs responded ‘yes’ compared to 18% of PRS landlords responding ‘yes’. To note, there was a relatively low number of responses from PRS sector for this question with only 15 PRS tenants and 9 PRS landlords responding.

Question 23c: If you responded Yes to part b), should we consider giving landlords the option to comply with Part Q requirements in Building Regulations?

113. We received 499 responses to this question. Respondents who answered ‘yes’ to part b) were invited to share further views on giving landlords the option to comply with Part Q requirements in Building Regulations. To note, the consultation did not restrict this question to respondents who responded ‘yes’ to Q23b).

Option	Total	Percentage
Yes	272	55%
No	117	23%
Don’t know	110	22%

114. Most SRS landlords were supportive with 70% LA landlords and PRPs responding ‘yes’. 51% of PRS landlords responded ‘yes’ with 17% responding ‘no’ and 32% responding ‘don’t know’. PRS tenant responses were evenly split across all the three options with 35% responding ‘yes’, 35% responding ‘no’, and 30% responding ‘don’t know’.

115. 47% of SRS tenants responded ‘yes’, with 33% and 20% responding ‘no’ and ‘don’t know’ respectively.

Question 23d: 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.

116. We received 354 responses to this question.

117. Landlords across both sectors who responded to this question raised concerns about cost of retrofitting properties and constraints to retrofitting heritage or listed buildings. Tenants and tenant groups raised issues about tenant vulnerability and safety, and the importance of enhanced security for survivors of domestic abuse and older people.

Government response

118. The government has considered the case for inclusion of additional regulatory security requirements beyond what is already in the DHS. Based on consultation responses and the additional protections on home security we have included across other parts of the DHS, we will not be introducing further requirements in this area.

119. Around half of respondents to the consultation felt that home security on external doors and windows was sufficiently covered in the DHS and there was limited consensus on what type of additional requirements should be made to improve home security.

120. The DHS will continue to prioritise and address home security related to external doors and windows. The statutory part of the DHS, Criterion A, states a dwelling will fail the DHS if there is a category 1 hazard present, as assessed under the Housing Health and Safety Rating System (HHSRS). If, for example, an external door cannot be secured or a window can be opened from outside, creating easy access for intruders, this may constitute a category 1 hazard. When assessing a potential hazard, the HHSRS assessment considers factors including the physical and psychological harms to the occupant and whether the dwelling is in a high crime area which would increase the likelihood of a break-in.

121. External doors and windows are listed as ‘key’ components in the new DHS under Criterion B. The new DHS will strengthen this criterion by removing age thresholds, so components are assessed solely on condition. This will mean that broken doors and windows should be replaced or repaired when no longer fit for purpose.

122. As part of our wider DHS response, we will develop supporting guidance to promote best practice. This will include information on how landlords can contribute to crime prevention and help tenants and visitors feel safer.

Proposal 5: Suitable floor coverings (Criterion C)

Question 24a: 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?

123. There were 745 responses to this question.

Option	Total	Percentage
Yes	449	60%
No	229	31%
Don’t know	67	9%

124. There were mixed views on this question, with tenants and PRS landlords being broadly supportive, and SRS landlords generally disagreeing. For SRS and PRS tenants respectively, 79% and 93% responded ‘yes’, as did 60% of PRS landlords. For LA landlords and PRPs, only 33% and 31% responded ‘yes’, compared to 57% and 56% who selected ‘no’.

Question 24b: If you have any views on this specific question you would like to share, please do so here.

125. There were 505 responses to this question.

126. Most SRS landlords referenced financial and operational implications in their response to this question, with many reporting that floor coverings would be challenging to deliver against current broader targets, given the high cost of doing so.

127. Some representative groups referenced health and safety in their responses, highlighting the benefits floor coverings can provide in helping to keep a home warm and the positive impact they have on the wellbeing of tenants.

Question 25a (Landlords only): Do you provide floor coverings in any of your dwellings?

128. 329 responses were received from landlords. Responses from other groups are not summarised here.

Option	Total	Percentage
Yes	296	90%
No	31	9%
Don’t know	2	1%

129. Responses varied slightly between types of landlords with 96% of PRS landlords; 90% of PRPs; and 82% of LA landlords answering ‘yes’.

Question 25b: If you responded Yes to part a) to providing floor coverings, can you provide details of costs here?

130. There were 292 responses from landlords to this question, which we have broken down into those providing the cost of providing floor coverings in a property, a room, or per square metre.

131. Estimates varied significantly, and there were notable differences in figures provided by PRS and SRS landlords. Interpretation has been required where responses were unclear. The average cost for each unit provided by landlords from each tenure was:

Group	Per Property Cost
PRS landlords	£3,300
LA landlords	£1,700
PRPs	£2,300

Question 25c: If you responded Yes to part a), in regard to responsibility of repair and maintenance for floor coverings do you:

• 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

132. 297 responses were received from landlords. Responses from other groups are not summarised here.

Option	Total	Percentage
Carry out or have responsibility for repair and maintenance of flooring as part of, for example, tenancy agreements	138	46%
Gift flooring to tenants and they are responsible for on-going repair and maintenance	102	34%
Other	57	19%

133. 62% of PRS landlords indicated that they repair and maintain floor coverings, carry out or have responsibility for repair and maintenance. For SRS landlords, gifting flooring to tenants was the most commonly reported practice, with 40% of LA landlords and 47% of PRPs selecting this option, followed by 35% and 38% respectively for carrying out or having responsibility for repair and maintenance.

Question 25d: If you answered Yes to part a) to providing floor coverings, in the dwellings you let, which rooms do you currently provide them in?

134. 316 responses were received from landlords. Responses from other groups are not summarised here. Respondents could choose more than one option.

Option	Total	Percentage
All rooms	128	41%
Bedrooms	18	6%
Living room	17	5%
Kitchen	132	42%
Bathroom	133	42%
Other areas (including stairs, hallways)	19	6%
Varies by property	43	14%
Other (e.g. new builds)	30	9%

135. There were significant differences in responses between SRS and PRS landlords. 82% of PRS landlords reported providing floor coverings in all rooms; compared to 7% of LA landlords and 21% of PRPs. SRS landlords reported higher levels of flooring provision in kitchens and bathrooms: for LA landlords 63% selected ‘kitchen’ and 61% selected ‘bathroom’. For PRPs, 67% selected ‘kitchen’ and 67% selected ‘bathroom’.

Question 25d (landlords only): If you responded ‘other’ to part a), please provide additional detail here.

136. 79 responses were received from landlords. Responses from other groups are not summarised here, and responses were not limited to only those who had responded ‘yes’ to part a).

137. Landlords mentioned a mixture of approaches to the provision of floor coverings, including limiting provision to kitchens and bathrooms, gifting floor coverings to tenants, and some respondents who reported providing floor coverings throughout new builds and in specialised housing.

Question 25e: When or if you replace floor coverings in the dwellings you let, do you:

• 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

138. 311 responses were received from landlords. Responses from other groups are not summarised here.

Option	Total	Percentage
Sometimes replace floor coverings	160	51%
Allow tenants to replace floor coverings	24	8%
Always replace floor coverings for new tenancies	8	3%
Never replace floor coverings	12	4%
Provide support for tenants to replace floor coverings	6	2%
Only replace floor coverings if tenants request it	3	1%
Other	98	32%

139. For PRS landlords, 57% reported sometimes replacing floor coverings, with 30% selecting ‘other’. For LA landlords and PRPs, 45% and 50% reported sometimes replacing floor coverings. 33% of LA landlords and 32% of PRPs selected ‘other’.

Question 25e: If you responded ‘other’ when asked about your approach to replacing floor coverings, please provide detail here.

140. 140 responses were received from landlords. Responses from other groups are not summarised here, and responses were not limited to only those who responded ‘other’ to the first part of this question.

141. Around half of respondents reported taking a condition-based approach to the replacement of floor coverings. Other responses highlighted an approach of prioritising the replacement of floor coverings in kitchens and bathrooms.

Question 25f: What proportion of your new lettings do you expect would require new floor coverings (including replacements each year?)

142. 327 responses were received from landlords. Responses from other groups are not summarised here.

Option	Total	Percentage
0 to 25%	127	43%
26% – 50%	36	12%
51% – 75%	49	17%
76% - 100%	81	28%

143. Responses varied significantly between PRS and SRS landlords. 82% of PRS landlords expected that 0 to 25% of their lettings would require new floor coverings each year, compared to 19% of LA landlords and 18% of PRPs. The most common option among SRS Landlords was 76% to 100%, with 45% of LA landlords and 43% of PRPs selecting this option.

Question 25g: What proportion of your new lettings do you expect to reuse and clean existing floor coverings (rather than provide new replacements) each year?

144. 285 responses were received from landlords. Responses from other groups are not summarised here.

Option	Total	Percentage
0 to 25%	135	47%
26% – 50%	50	18%
51% – 75%	33	12%
76% - 100%	67	24%

145. 0 to 25% was the most popular option among SRS landlords with 58% of LA landlords and 54% of PRPS selecting this option. Responses from PRS landlords were more evenly split between 0-25% (34%) and 76 to 100% (41%).

Question 25h: If floor coverings 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?

146. 322 responses were received from landlords. Responses from other groups are not summarised here.

Option	Total	Percentage
Yes	101	31%
No	151	47%
Don’t know	39	12%
Other	31	10%

147. There were varying levels of agreement amongst PRS landlords on this proposal (39% responded ‘yes’ and 42% responded ‘no’). For SRS landlords there were higher levels of disagreement with this proposal, with 54% of LA landlords and 47% of PRPs responding ‘no’.

Question 25h: If you responded ‘other’ to the previous question, please provide detail here.

148. 94 responses were received from landlords. Responses from other groups are not summarised here, and responses were not limited to those who had responded ‘other’ to the previous question.

149. Responses referenced the cost and financial impact of introducing a requirement on floor coverings.

150. Some responses also mentioned the need for a clear definition of ‘suitable’ floor coverings in relation to measuring compliance with the DHS.

151. Responses also mentioned the importance of respecting tenant choice and autonomy to choose floor coverings based on their own preferences.

Government response

152. The government recognises that floor coverings are an important element in making a home feel complete and that the expense is extremely difficult for some tenants to cover.

153. The numbers of people living without adequate floor coverings is particularly high in the social rented sector where it is suggested approximately 756,000 people do not have a suitable floor covering (equivalent to circa 357,000 homes). This compares to approximately 112,000 people in the PRS who do not have a suitable floor covering (equivalent to circa 48,700 homes)^{[footnote 3]}.

154. The consultation sought additional evidence on whether a new DHS should include a requirement that landlords must provide floor coverings (carpets, vinyl etc) at the start of a tenancy. The current DHS does not set any specific standards around the provision of floor coverings.

155. The private rented sector has, on average, shorter tenancies, with greater flexibility, than the SRS. Tenants rightly expect their home will provide basic amenities for the length of their tenancy as they are more likely to live in their property for a shorter period. It is therefore more common for homes to be provided with floor coverings as standard as demonstrated by 82% of PRS landlords responding to question 25d reporting providing floor coverings in all rooms. Given that the sector already provides floor coverings in the vast majority of cases, we do not think further regulation is necessary.

156. In the social rented sector, it is not usual practice for landlords to provide floor coverings in all rooms. Where landlords do provide floor coverings, they tend to focus on providing non-slip flooring in bathrooms and kitchens to prevent falls on wet surfaces in line with HHSRS operating guidance.

157. During the consultation period, we received strong representation and support from tenants and a wide range of groups representing tenants on introducing a new requirement on floor coverings within the DHS. Respondents noted that walking on bare floorboards or concrete floors can be an unsafe environment for children and makes it difficult to heat the home. Respondents also noted that people can get into debt trying to provide floor coverings themselves within their homes, leaving them unable to buy other essentials such as furniture.

158. In their responses, social landlords stated that introducing a new requirement would significantly increase costs and would impact the sector’s ability to deliver the vital shared objective to deliver much needed new social and affordable houses. Their responses noted that some tenants also replace flooring once they move in as they like to have their own choice of furnishings and some suggested that the government had underestimated the costs of introducing a requirement in its interim impact assessment.

159. While there was significant variation in the estimated costs of this requirement, a number of social landlords stated that the average cost of providing floor coverings would be significantly higher than the £1,032 per property estimate put forward in the DHS interim impact assessment^{[footnote 4]}.

160. The average per property cost put forward by PRPs are £2,300, whilst for LA landlords this was £1,700. In the PRS, the average per property cost was £3,300. However, as noted, there was significant variation in responses, with a range for SRS landlords from £900 to £4,000 per property. For PRS, per property costs were quoted between £700 and £7,500. Costs were also provided, and considered, on a per room or area (per square metre) basis. While we would expect variation given landlords operating in different areas of the country, with varying amounts of stock (a proxy for business size, and therefore assumed economies of scale), the variation in responses suggests that there is significant uncertainty in what this requirement might cost, in aggregate.

161. Responses from landlords who were concerned about cost implications assessed that material and labour cost would be higher than estimated in the interim impact assessment. They also noted that some of the costs may be driven by a loss in rental income associated with increased void times, as landlords would typically need to install carpet before new tenants move in. An assumption is also made that a higher number of properties would need new floor coverings at the start of a tenancy (as opposed to retaining floor coverings left by the previous tenant), compared to what was assumed in the interim stage Impact Assessment.

162. In addition to the cost of provision of floor coverings, respondents noted that there would be some practical challenges to implementation such as ongoing maintenance, the monitoring of compliance and tenant choice (e.g. some tenants in a position to buy floor coverings may want to choose their own).

163. Having carefully considered consultation feedback, the Government will not be introducing a mandatory requirement on floor coverings in the DHS. We think this balances the cost implications of improving the quality of existing rented homes with the need to increase affordable and social housing supply and the projected increases in the overall cost of delivering the new DHS. Increasing supply will help move people, including many vulnerable children, out of unsuitable temporary accommodation with the positive behaviours that many landlords are already taking on provision of floor coverings, particularly in the PRS.

164. Whilst many SRS landlords have said they are already providing floor coverings, the government recognises that the situation is not positive across the board. Therefore, we will work rapidly with landlords and tenants to identify cost-effective ways in which landlords can better support tenants who need assistance with floor covering provision. Options we will explore include: 

a. Setting a clear expectation through strong best practice guidance on how social landlords can retain floor coverings which are in good condition between tenancies; and

b. Establishing a working group and pilot with the social housing sector on what more can be done to support tenants who are most in need to access floor coverings and other essential furniture. This pilot will also allow the department to better assess the cost impacts of floor coverings on social housing landlords.

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

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?

165. There were 748 responses to this question.

Option	Total	Percentage
Yes	672	90%
No	59	8%
Don’t know	17	2%

166. Support was particularly high among SRS tenants with 99% responding ‘yes’. 97% of PRS tenants also responded ‘yes’. There was support amongst SRS landlords, with 95% of LA landlords and 94% of PRPs responding ‘yes’. Support was lower among PRS landlords with 71% responding ‘yes’. 26% of PRS landlords responded ‘no’.

Question 27: Are there other thermal comfort requirements that you think should be included in the DHS beyond current MEES proposals?

167. There were 730 responses to this question.

Option	Total	Percentage
Yes	185	25%
No	378	52%
Don’t know	167	23%

168. There was limited overall support for additional thermal comfort requirements. 39% of SRS tenants and 38% of PRS tenants responded ‘yes’ to this question. 79% of PRS landlords responded ‘no’, as well as 62% of LA landlords, and 75% of PRPs all suggesting that thermal comfort requirements should not go beyond what is set out in current MEES proposals. 46% of SRS tenants, 26% of LA respondents and 28% of representative organisations selected ‘don’t know’, indicating some uncertainty around the proposals.

Question 28: If there is anything else you would like to add on this specific topic please do so here.

169. A total of 438 responses were received to this question.

170. Some SRS and PRS landlords, and letting agents, raised affordability, warning that the financial burden of upgrades could fall heavily on landlords and tenants. Some raised the prospect of grants and financial assistance, while others called for clearer guidance and standards to support compliance.

171. Some PRS landlords also raised challenges with achieving EPC C in older or listed buildings, particularly for heritage, rural, or solid wall properties. Respondents noted that these homes are often difficult and costly to retrofit.

172. Some PRPs, representative organisations and local authorities not responding as landlords highlighted the need for clearer definitions of key terms such as ‘whole home’ and ‘thermal comfort’. There was a strong emphasis on practical guidance to support implementation, cost implications, and ensuring that improvements do not compromise safety or comfort.

Government response

173. The government is committed to ensuring that all tenants live in homes that are warm, energy efficient, and affordable to heat. Energy efficiency is a core component of decency, contributing to improved comfort, reduced condensation and mould, lower energy bills, and progress toward net zero.

174. The responses to this consultation showed overall support for aligning DHS and MEES. This alignment will ensure that thermal comfort and energy performance are treated as essential components of housing quality. To deliver on this commitment, the new DHS will include a strengthened Criterion D on thermal comfort.

175. Properties will need to comply with their respective MEES requirements to meet Criterion D of the DHS. The PRS and SRS MEES consultations can be accessed here: Improving the energy performance of privately rented homes: consultation document and here: ​​Improving the Energy Efficiency of Socially Rented Homes in England, which set out more detail in relation to these policies.

176. In addition, in line with support from the consultation feedback, the primary heating system will need to include a distribution system capable of providing heat to the whole home. This will mitigate risks from residents having to resort to portable heaters which can increase fire hazards, raise energy costs, and lead to uneven heating that causes damp and mould.

177. The DHS will also retain the requirement for programmable heating, defined as ‘where the timing and the temperature of the heating can be controlled by the occupants.’ This ensures that tenants can manage their heating efficiently and affordably. Exemptions will continue to apply for supported housing and housing for older people where programmable systems may not be appropriate for health and safety reasons.

178. The DHS guidance will provide clear definitions of key terms such as ‘whole home’ and ‘thermal comfort’ and set out practical examples to support implementation. It will also make clear that any measures taken to meet energy efficiency requirements such as heating system upgrades or insulation must comply with relevant building and fire safety regulations and preserve essential safety features. Guidance will promote best practice in insulation, ventilation, and overheating mitigation to ensure improvements do not inadvertently introduce risks, particularly in hard-to-treat properties such as those with solid walls or located in rural areas.

179. In the DHS, exemptions will apply for SRS properties where compliance is not feasible due to physical or planning constraints, including heritage or hard-to-treat properties. A range of exemptions will also be available for landlords who are unable to comply with MEES requirements in both the PRS and SRS, due to practical constraints or circumstances that make achieving the minimum standard unfeasible.

180. We understand that landlords and tenants raised concerns about the cost of upgrades and the potential risks of landlords exiting the market or increasing rents, and we recognise the financial challenges this may present. However, we believe that thermal comfort and energy efficiency are fundamental to what makes a home decent. These measures not only improve housing quality and living conditions, helping to reduce fuel poverty, but also lower long-term energy costs and contribute to the government’s net zero commitments.

181. For this reason, embedding MEES for both PRS and SRS within the DHS, alongside strengthened requirements for programmable whole-home heating, represents a proportionate and necessary step toward ensuring all homes are warm, safe, and affordable to heat.

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

Question 29a: 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?

182. There were 761 responses to this question.

Option	Total	Percentage
Yes	651	86%
No	78	10%
Don’t Know	32	4%

183. There was strong support for this proposal with 99% of SRS tenants and 97% of PRS tenants responding ‘yes’. 91% of LA landlords and 83% of PRPs also responded ‘yes’. PRS landlords were also supportive, with 67% responding ‘yes’.

Question 29b: 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?

184. There were 740 responses to this question.

Option	Total	Percentage
Yes	592	80%
No	104	14%
Don’t Know	44	6%

185. For PRS landlords, 61% agreed with the proposed approach, as did 86% of LA landlords and 71% of PRPs. Tenants were supportive of the proposed approach, with 95% and 93% of SRS and PRS tenants responding ‘yes’ respectively. There was also support from charities and representative bodies, with 89% responding ‘yes’.

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?

186. There were 733 responses to this question.

Option	Total	Percentage
Yes	492	67%
No	169	23%
Don’t Know	72	10%

187. Tenants from both sectors were supportive of this proposal, with 79% and 76% of SRS and PRS tenants respectively responding ‘yes’. Of all the landlord groups, LA landlords were most supportive with 74% responding yes. PRS landlords and PRPs showed a lower level of support, with 50% and 59% responding ‘yes’ respectively.

Question 31: If there is anything else you would like to add on this specific proposal please do so here.

188. There were 495 responses to this question.

189. A substantial majority of PRS landlords focused on responsibility for damp and mould, in particular pointing to the role of tenants in preventing damp and mould in the home. All of the small number of letting agents who responded  also raised this.

190. Some PRPs raised the importance of clarity in how damp and mould is measured, and around half referred to the risk of duplication with other regimes.

191. Some LA landlords and PRPs highlighted the role that appropriate thresholds will play in the damp and mould standard, emphasising the need for these to be set at the correct level. Local authorities, responding as enforcers as well as landlords, raised concerns about the health impacts of damp and mould and the overlaps with other regulation and enforcement. Other government departments who responded discussed the need for careful measurement techniques.

Government response

192. In December 2020, 2-year-old Awaab Ishak died from a severe respiratory infection caused by prolonged exposure to damp and mould in his home. Following an inquest into Awaab’s death, the Coroner for Manchester North found that, ‘he died as a result of a severe respiratory condition due to prolonged exposure to mould in his home environment. Action to treat and prevent the mould was not taken’. The Coroner also noted that, ‘of particular importance is the fact this is not simply a social housing issue. The same concerns apply as much to the private landlords, where evidence suggests the problem is worse.’

193. The government is clear that damp and mould in rented homes must be addressed. The respiratory effects of damp and mould can cause serious illness and, in the most severe cases, death, but the presence of damp and mould can also impact mental health and quality of life. Everyone is vulnerable to the health impacts of damp and mould, but people with certain health conditions, children and older adults are at greater risk of more severe health impacts. It is right that damp and mould is resolved routinely rather than being addressed when the issue becomes serious or presents significant risks to health.

194. The responses to this consultation show overall support, from all groups, for a new criterion, focused on eliminating damp and mould. We will therefore introduce a new Criterion E to the DHS, requiring that landlords should ensure their properties are free from damp and mould.

195. The new DHS will mean tenants are protected from damp and mould. This will be in addition to Awaab’s Law, which has been introduced in the social rented sector to provide a mechanism for tenants to secure repairs where damp and mould and other hazards are threatening their health and safety. We have also committed to applying Awaab’s Law to privately rented properties. The Renters’ Rights Act includes powers to do this, and we will be consulting on the approach to extending Awaab’s Law to privately rented homes soon.

196. We recognise that some social housing landlords, whilst strongly supporting the proposal, raised concerns that it will be hard to achieve and that substantial time would be spent remedying what they considered was less serious damp and mould. Our analysis shows that disrepair, addressed elsewhere in the standard, is often the cause of damp and mould so other actions to meet the DHS will also help to meet this part of the standard. That is why we recommend landlords should not wait for damp and mould issues to be reported to them by their tenants but should take a proactive approach to prevention, and address damp and mould concerns early.

197. Landlords who meet the new standard will not just be remedying damp and mould problems, but also ensuring issues are addressed before they become more serious. This means they are less likely to reach the stage where action is required under Awaab’s Law, for example.

198. Our guidance: Understanding and addressing the health risks of damp and mould^{[footnote 5]} already sets out actions that can be taken to address and reduce the risk of damp and mould. We will also set out clearly in DHS guidance circumstances where landlords can’t or shouldn’t meet some aspects of the standard and what should happen in these cases. This will be different depending on the tenure, but the standard that must be met remains the same, underpinned by the Housing Health and Safety Rating System (HHSRS), which allows for a close analysis of the risk to health and safety.

199. Social landlords will report to the Regulator of Social Housing where they determine the standard can’t be met. For enforcement in the private rented sector, local authorities will take the specific circumstances into account when they use their discretion to take the most appropriate form of enforcement action. Private landlords will not be expected to carry out HHSRS assessments. In this way, neither private nor social landlords will face enforcement or regulation for minor, unavoidable damp, but will still be required to address problems proactively rather than waiting for them to become severe.

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

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?

200. There were 583 responses to this question.

Option	Total	Percentage
Yes	470	81%
No	39	7%
Don’t know	74	13%

201. There was support for this proposal from tenants, with 79% of SRS tenants and 85% of PRS tenants responding ‘yes’. Landlords also supported this proposal, with 64% of PRS landlords, 78% of LA landlords and 88% of PRPs responding ‘yes’. There was also support from local authorities that aren’t landlords (83%) and representative organisations (89%).

Question 33a: 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?

202. There were 551 responses to this question.

Option	Total	Percentage
Yes	130	24%
No	154	28%
Don’t know	267	48%

203. We had a higher-than-average response from those responding ‘don’t know’ to these questions, which may stem from this question relating to a smaller proportion of housing. For those that did respond ‘yes’ or ‘no’, 46% of LA landlords responded ‘yes’ compared to 35% who responded ‘no’. For PRPs, 19% responded ‘yes’ compared to 48% who responded ‘no’.

Question 33b: If answered yes to Q33a), please give details

204. There were 145 responses to this question. The most raised issue was that the age and design of buildings used as temporary accommodation would make the works required to meet DHS particularly expensive and difficult. Respondents also highlighted that maintenance of temporary accommodation can pose specific challenges and that due to limited availability, households are often placed in accommodation that does not meet minimum space standards.

Question 34: Do you think the proposed DHS requirements will impact temporary accommodation supply?

205. There were 571 responses to this question.

Option	Total	Percentage
Yes	278	49%
No	72	13%
Don’t know	190	33%
Other	31	5%

206. There was agreement on this question amongst landlords who were more likely to respond ‘yes’ to this question, including PRS landlords (51%), LA landlords (58%), and PRPs (49%). Local authorities also agreed that proposed DHS requirements would have an impact on temporary accommodation supply with 67% responding ‘yes’.

Q34i) If you responded as ‘Other’ to question 34), please give details here

207. 126 respondents provided extra detail on their response.

208. Respondents most frequently highlighted that higher standards could result in some landlords withdrawing units from the temporary accommodation market due to cost pressures. A small number reported that with the right approach to implementation, the supply impacts could be managed. Recommendations for implementation included a flexible, phased approach and targeted support for temporary accommodation refurbishment.

Supported Housing

Question 35: Are there any challenges you foresee in applying the outlined DHS proposals in Supported Housing?

209. There were 554 responses to this question.

Option	Total	Percentage
Yes	169	31%
No	169	31%
Don’t know	216	39%

210. Views were split on this question. For PRS-specific respondents both landlords and tenants most commonly responded ‘don’t know’ at 59% and 65% respectively. For LA landlords ‘yes’ and ‘no’ had relatively even responses with 44% and 43%. 51% of PRPs responded ‘no’ to this question.

Question 35b: If you have any views on this specific question you would like to share, please provide details.

211. 177 respondents provided detail on the challenges that they foresaw.

212. While many respondents support the principle of raising standards, concerns were raised about costs, feasibility, and unintended consequences. Most frequently, respondents raised concerns about the impact the DHS would have on the viability of supported housing. Responses highlighted the challenges that the sector is facing and the complexity of funding models. Some reported that supported housing units are often older or retrofitted buildings which are particularly expensive to bring up to standard. This could result in some landlords leaving the sector, or the cost of provision increasing.

213. Respondents identified specific elements of the DHS that may be challenging to apply in some contexts due to overlap with other regulations or because they may not be in the best interests of vulnerable residents. These included instances where residents have meals provided rather than access to a kitchen, or instances where fixed window restrictors are required in some forms of supported housing. Respondents also highlighted that vulnerable residents may be more likely to find the upheaval of works difficult to cope with and in some cases to refuse to allow works.

214. Respondents emphasised the importance of aligning the introduction of the DHS with the regulatory framework in the sector, including the introduction of the new supported housing licensing regime. A small number of respondents suggested that flexible enforcement was necessary to ensure that the specific residents’ needs in supported housing were recognised, while others suggested additional guidance would be helpful to reflect the heightened vulnerability of residents.

Leasehold and commonhold

Question 36a: Do you agree with the proposed approach to enforcement for rented properties that are leasehold?

215. There were 572 responses to this question.

Option	Total	Percentage
Yes	350	61%
No	48	8%
Don’t know	174	30%

216. There was agreement with the proposed enforcement approach from SRS landlords, with 76% of LA landlords and 70% of PRPs responding ‘yes’.

Question 36b: Do you see any unintended consequences or risks with this approach, including for resident-owned blocks? 

217. 201 respondents provided detail on the unintended consequences or risks.

218. While many supported the principle of applying DHS to leasehold, they emphasised the need for flexibility, and tailored implementation. The most frequent concern was that the leaseholders’ decision to let out properties could result in costs for other leaseholders or the freeholder.

219. Respondents also reported that in some instances obtaining consent from all relevant parties could be difficult or impossible, and disputes between parties could cause delays.

220. Respondents broadly supported the proposal to provide local authorities with flexibility to serve enforcement notices on the person or organisation most responsible for a DHS failure, but a minority warned that it could be challenging for local authorities to enforce compliance, both due to the resource required and the technical complexity of confirming where responsibility for completing work lies. Some pointed to broader challenges within the leasehold sector, including difficulties navigating leasehold disputes.

221. Respondents recommended that clear detailed guidance on applying the DHS to rented leasehold properties and strong guidance for local authority enforcement teams should be provided.

Question 37a: 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?

222. There were 579 responses to this question.

Option	Total	Percentage
Yes	253	44%
No	107	18%
Don’t know	219	38%

223. Responses to this question were mixed. Leaseholders were most likely to respond ‘yes’, with 70% agreeing that the proposed policies would create extra costs for leaseholders. LA landlords and PRPs also agreed (54% and 63% respectively). PRS landlord views were split, with 41% responding ‘yes’ and 44% responding ‘don’t know’. More than half of tenants were unsure, with 53% of SRS tenants and 56% of PRS tenants responding ‘don’t know’.

Question 37b: If you have any views on this specific question you would like to share, please do so here.

224. There were 178 responses to this question.

225. Responses were mixed on whether new costs would arise. A minority reported that most obligations under the DHS should not generate new costs for leaseholders, as freeholders are already expected to maintain common parts under existing lease terms. The majority raised concerns about the cost of specific policies, the costs for some types of buildings, and the way in which costs would be apportioned.

226. Respondents noted that the way in which costs would be apportioned would depend on specific lease terms, but most frequently reported that standards associated with outdoor and shared spaces, thermal comfort, and external noise insulation could increase costs charged to leaseholders. They flagged that the cost of bringing older and high-rise buildings up to the standard could be particularly high.

Government response

227. The government is committed to making sure that everyone lives in a safe and decent home, regardless of tenure, so the DHS will be applied across temporary accommodation, supported housing and leasehold rented properties. The current DHS already applies to temporary accommodation (TA) and supported housing with a social landlord, and to social rented sector homes where the landlord is a leaseholder. For properties in the private rented sector, the DHS will be applied for the first time.

228. We recognise that there is some temporary accommodation and supported housing where applying the DHS is more challenging, however, and will take steps to address this. We will also provide in guidance more detail on applying the DHS in a fair and proportionate way to homes where the landlord who lets the property out to the tenant is a leaseholder and to mixed-tenure blocks which include rented properties and owner-occupied leasehold properties.

Temporary Accommodation

229. A small portion of TA, such as some B&Bs and hotels, does not provide private bathrooms and cooking facilities. While the legislation is clear that local authorities should only use B&Bs as accommodation for homeless families as a last resort, and for a maximum of 6 weeks, we know that local authorities are facing unprecedented demand for temporary accommodation. Requiring that all TA meets DHS requirements on kitchens and bathrooms (as set out in Criterion C), would reduce the supply further.

230. For TA in the PRS that lacks kitchens and cooking facilities and where it is not practical for these to be provided, meaning Criterion C of the standard cannot be met, the local authority will have the discretion to suspend enforcement action for a period of time or use awareness notices that do not require remedial works. This approach was supported by a substantial majority of respondents to the consultation, and we think it balances the need to drive up standards across the sector with the requirement for local authorities to maximise the supply of accommodation to meet local demand.

231. Respondents also highlighted overcrowding as an issue in some types of TA. Local authorities are responsible for considering what constitutes a ‘suitable’ space for a household to live in within the framework for defining overcrowding, considering the current statutory standards and statutory allocations guidance.

232. This is in addition to the Criterion A requirement that properties must be free from health and safety hazards at the category 1 level, assessed using the Housing Health and Safety Rating System (HHSRS). This includes hazardous conditions due to lack of space and crowding. So, a dangerously overcrowded property would not meet the DHS. Local authorities have a duty to take appropriate enforcement action under the Housing Act 2004 if they identify the presence of category 1 hazards.

233. The DHS will be one route to ensure that dangerous overcrowding is addressed. We will work with the sector to understand this issue further and ensure that local authority enforcement guidance calls attention to the issue of overcrowding whilst also recognising the constraints that may lead households to be placed in accommodation that does not meet space standards.

234. To address concerns about the impact of introducing the DHS on the supply of TA, and costs of bringing properties up to the standard, the government has announced, as part of the temporary accommodation package, that it will take steps to increase the supply of good quality, affordable TA for councils, and to improve the physical quality of TA. This will be achieved through continued investment in the Local Authority Housing Fund, improved data and metrics, and the publication of council action plans. We will continue to engage with stakeholders on how best to support them with implementing the DHS and Awaab’s Law to limit impacts on supply whilst protecting residents of TA.

Supported housing             

235. In supported housing, we understand that some parts of the proposed standard may not be suitable in a small number of cases. We agree with consultation respondents that, in rare situations, making sure a property meets residents’ needs and keeps them safe should take priority over strict compliance with the DHS.

236. We do not plan to exempt entire types of supported housing from specific DHS requirements because each case is different, and broad exemptions could create unnecessary gaps. Instead, our guidance for social landlords and local authorities will make clear that if residents have documented needs showing that certain DHS requirements are not in their best interest, those parts of the standard should not apply.

237. We agree with respondents that the DHS must work within the regulatory framework for supported housing. The government is committed to implementing the measures in the Supported Housing (Regulatory Oversight) Act 2023, which will give local authorities the power to challenge rogue landlords and protect residents through a locally led licensing regime and new National Supported Housing Standards for support.

238. The government is not creating new accommodation quality standards for supported housing, but supported housing schemes applying for a licence should meet the accommodation requirements and standards relevant to their housing tenure. In some cases, for example when category 1 HHSRS hazards are present, licences should not be granted. However, if a home does not currently meet other required standards, including the DHS, licensing authorities may still decide to work with the prospective licensee where there is a clear plan for improvements or where it is not appropriate to hold the licensee to those standards.

239. To protect the supply of supported housing and to minimise disruption to residents wherever possible, licensing authorities should take reasonable steps to work with providers to maintain licences, rather than revoking them, unless they have serious concerns about a supported housing scheme. We think that this approach will drive up quality and protect tenants whilst also giving local authorities the flexibility to secure the right services for their residents.

Leasehold

240. We are clear that homes rented out in blocks where there is a freeholder^{[footnote 6]} who is responsible for maintaining the exterior and common parts of the block should comply with all aspects of the standard where possible. This includes leaseholder-owned blocks (whether collectively enfranchised or through share of freehold). At the same time, we recognise that leaseholder–freeholder relationships can be complex, and that delivering works to meet the DHS becomes more challenging when freeholder involvement or agreement is required.

241. Respondents to the consultation raised concerns that the DHS could introduce new obligations for some freeholders, which in turn might lead to higher costs for them and increased charges for leaseholders, including those who do not rent out their homes.

242. Following the consultation, we have made adjustments to the DHS that reduce situations where freeholders would need to be involved in works to meet the standard. For example, we are not adding public realm components or home security measures to Criterion B.

243. However, we acknowledge that some works required to meet the DHS will affect both leaseholders (whether or not they rent out their homes) and freeholders. Clear guidance on how the standard will be applied and enforced, including the respective responsibilities of freeholders and leaseholders and how proportionate enforcement for leasehold properties will work, will be critical to applying the standard in a way that is fair and proportionate.

244. This is a complex area, and we are committed to getting it right. In doing so we also need to take full account of the government’s ongoing reforms to the leasehold system, including our commitment to replace commonhold as the default tenure in future. We consider that further engagement with stakeholders is necessary to understand how the DHS will apply to leasehold homes in a manner which is proportionate, effective, and fair for owner-occupiers and landlord leaseholders, and we will provide further details in due course.

Guidance

Question 38a: What information and/or topics would you like included in the proposed additional best practice guidance for social and private landlords and tenants?

245. There were 680 responses to this question. Respondents were asked to choose topics they would like to see and could select multiple options.

List of topics	Total	Percentage
Accessibility	500	74%
Water Efficiency	448	66%
Adaptations to climate change	438	64%
Additional home security	437	64%
Digital connectivity	414	61%
Electric vehicle charging	375	55%
Furniture provision	347	51%
Other	161	24%

246. For PRS landlords, the areas respondents most commonly reported wanting further guidance on were water efficiency measures (49%), digital connectivity (48%), accessibility (47%) and electric vehicle charging (47%).

247. For LA landlords, the highest priority area was accessibility (93%), followed by climate change adaptations (85%) and water efficiency measures (79%). For PRPs, accessibility was also the highest priority area for further guidance (78%) followed by climate change adaptations (73%) and electric vehicle charging (73%).

248. For SRS tenants, 76% selected additional home security measures, and 72% selected accessibility as the areas they would like included in additional guidance. For PRS tenants, accessibility (83%) and water efficiency measures (73%) were the two most popular selected options.

Question 38b:If you have selected ‘Other’, please say what you would like to be included.

249. We received 198 responses to this question. Respondents were not restricted from answering any of the questions throughout the consultation, so we received more responses to this question than the number of respondents who selected ‘other’ for 38a.

250. tenant engagement and complaint handling. Further information about floor coverings and furniture, ventilation, noise insulation and fire and carbon monoxide safety were also requested.

251. Other suggested topics included guidance for smaller landlords, training and competency requirements for landlords and contractors, and maintenance and inspection protocols.

Question 39: If you have any other views on this specific topic you would like to share, please do so here.

252. We received 207 responses to this question.

253. There was overall consensus that guidance should be tenant focussed and clearly set out what tenants can expect from their landlords through the DHS. There was also a request to clarify how the DHS aligns with existing legislation and standards on decency and quality. Landlords expressed concerns that the guidance could impose additional costs for items beyond statutory or regulatory requirements and create unrealistic expectations among tenants about what landlords should provide or do.

254. Other topics raised for inclusion were the provision of furniture, electrical vehicle charging and climate change adaptations.

Government response

255. The government has committed to publishing guidance to supplement the new DHS.

256. We will provide further information to support landlords and tenants to interpret the DHS, with additional guidance on all the criteria. We recognise that the DHS is a long-term investment in improving existing homes and that it will need to work alongside existing regulations. We will set out how the DHS complements Awaab’s Law and MEES, and how it interacts with existing requirements around the health and safety of homes and their occupants.

257. In addition, we will provide best practice guidance on key areas proposed and selected by respondents including information on electrical vehicle charging, additional security measures, measures to support water efficiency, information about home accessibility and adaptations, best practice on climate change adaptations such as mitigations on overheating and where tenants can access information on furniture provision. Respondents also identified several topics which we will need to consider whether we can include specifically guidance for smaller landlords, information on fire safety, and raising awareness of carbon monoxide risks, among others.

Implementing the Decent Homes Standard

Question 40a: What do you think the implementation date for the DHS should be in the SRS?

258. There were 712 responses to this question. Responses were not restricted to SRS stakeholders.

Option	Total	Percentage
2035	215	30%
2037	169	24%
Other	328	46%

259. Responses varied by demographic groups. SRS tenants and representative organisations, “other” was the most popular response (73% and 65% respectively). SRS landlords favoured 2037 (44% of LAs; 61% of PRPs) over 2035 (42% of LAs; 32% of PRPs).

Question 40b: If Other – What do you think the implementation date should be? 

260. There were 356 responses to this question. Responses were not restricted to SRS stakeholders, or respondents who had selected ‘other’ to the previous question.

Option	Total	Percentage
2027	119	33%
2028	29	8%
2029	12	3%
2030	103	29%
2031	5	1%
2032	5	1%
2033	2	<1%
2034	3	<1%
2036	8	2%
Later	35	10%
Don’t know	35	10%

261. Significantly more SRS tenants and representative organisations responded to this question than SRS landlords, in line with the higher numbers of those groups responding ‘other’ to the previous question. 2027 was the most popular option among SRS tenants (55%), while representative organisations were split between 2027 (26%) and 2030 (35%).

Question 41a: What do you think the implementation date for the DHS should be in the PRS?

262. There were 712 responses to this question. Responses were not limited to PRS stakeholders.

Option	Total	Percentage
2035	202	28%
2037	177	25%
Other	333	47%

263. As in the equivalent question relating to SRS implementation dates, there was a demographic split in responses to this question, with PRS tenants (87%); local authorities not responding in their capacity as landlords (63%) and representative organisations (65%) selecting ‘other’. ‘Other’ was also the most popular option among PRS landlords (39%), but greater numbers of this group also selected 2037 (37%) and 2035 (24%).

Question 41b: If Other – What do you think the implementation date should be? 

264. There were 357 responses to this question. Responses were not restricted to PRS stakeholders, or respondents who had selected ‘other’ to the previous question.

Option	Total	Percentage
2027	106	30%
2028	23	6%
2029	18	5%
2030	110	31%
2031	10	3%
2032	4	1%
2033	1	<1%
2034	0	0%
2036	5	1%
Later	51	14%
Don’t know	29	8%

265. PRS tenants favoured a 2027 implementation date with 61% selecting this option, while 58% of PRS landlords selected ‘later’. 2030 was the most popular option among local authorities not responding as landlords (55%) and representative organisations (42%), although some representative organisations (25%) also selected 2027.

Question 42a: Do you support phasing in some elements of the new Decent Homes Standard ahead of the proposed full implementation dates (2035/2037)?

266. There were 731 responses to this question.

Option	Total	Percentage
Yes	389	53%
No	255	35%
Don’t know	87	12%

267. Responses to this question showed strong support for phasing among tenants with 74% of PRS tenants and 59% of SRS tenants responding ‘yes’. 64% of local authorities not responding as landlords, and 66% of representative organisations also responded ‘yes’. ‘Yes’ was also the most popular option among LA landlords (52%), although greater numbers also selected ‘no’ (35%). PRPs were evenly split between ‘yes’ and ‘no’ with 48% and 49% selecting these options respectively, while ‘no’ was the most popular option among PRS landlords (53%) and letting agents (71%).

Question 42b: If Yes – Which elements of the new DHS do you think should be introduced ahead of the proposed full implementation dates (2035/2037)?

268. There were 346 responses to this question. Criterion E, requiring that properties be free from damp and mould, was the most common response across all groups with significant numbers of responses, including around half of local authority landlords. Some respondents also supported bringing in energy efficiency, safety, and window restrictor requirements ahead of the final implementation date.

Question 43a: SRS LANDLORDS ONLY: Are you confident in your ability to deliver works to meet the new Decent Homes Standard by the proposed implementation dates (2035/2037) within current income forecasts in the SRS?

269. 204 SRS landlords responded to this question. Responses from other groups have not been summarised here.

Option	Total	Percentage
Yes	49	24%
No	86	42%
Don’t know	69	34%

270. 24% of both LA Landlords and PRPs responded ‘yes’ to this question, compared to 49% and 36% who responded ‘no’. 26% of LA landlords and 40% of PRPs responded ‘don’t know’.

Question 43b: Are you confident in your ability to deliver works to meet the new Decent Homes Standard by the proposed implementation dates (2035/2037) alongside other regulatory requirements including Awaab’s Law and MEES? (All landlords)

271. 316 landlords responded to this question. Responses from other groups have not been summarised here.

Option	Total	Percentage
Yes	101	32%
No	127	40%
Don’t know	88	28%

272. There was a difference in how landlords of different types recorded their confidence in their ability to meet the DHS by the proposed implementation date. PRS landlords were evenly split between ‘yes’ (41%) and ‘no’ (37%); LA landlords favoured ‘no’ (48%) and PRPs were evenly split between ‘don’t know’ (36%) and ‘no’ (38%)

Question 43c: Please give supporting details.

273. 256 landlords responded to this question. Most SRS landlords raised concerns about the cost of the reforms, along with some PRS landlords. Some landlords of all types were concerned about implementing the DHS alongside MEES and other changes within the Renters’ Rights Act for private landlords. Some PRPs and local authority landlords raised the prospect of government funding.

Question 44a: Considering the need to meet both Minimum Energy Efficiency Standards and the Decent Homes Standard, do you plan to deliver savings by prioritising measures which will both improve a property’s energy efficiency and help meet the DHS? (SRS and PRS landlords only)

274. 318 landlords responded to this question. Responses from other groups are not summarised here.

Option	Total	Percentage
Yes	179	56%
No	52	16%
Don’t know	87	27%

275. 70% of LA landlords and 57% of PRPs responded ‘yes’ to this question compared to 35% of PRS landlords who responded ‘yes’. For PRS landlords there was a more even split between the three response options, with 31% responding ‘no’ and 34% responding ‘don’t know’.

Question 44b: Considering the need to meet both Minimum Energy Efficiency Standards and the Decent Homes Standard, do you plan to deliver savings by reducing overhead costs by programming combined works to meet both standards? (SRS and PRS landlords only)

276. 313 landlords responded to this question. As the question is directed specifically at SRS landlords and PRS landlords, responses from other groups are not summarised here.

Option	Total	Percentage
Yes	161	51%
No	53	17%
Don’t know	99	32%

277. 70% of LA landlords and 61% of PRPs responded ‘yes’ to this question, compared to 27% of PRS landlords who selected ‘yes’. 36% of PRS landlords responded ‘no’, and 37% responded ‘don’t know’.

Question 44c: Please give supporting details.

278. There were 191 responses from landlords to this question. Responses from other groups are not included in this summary.

279. While some landlords agreed that combining MEES upgrades with DHS improvements is a sensible approach to reduce costs and disruption, including around half of LA landlords, others expressed concern about financial constraints and affordability. Local authority social landlords were less likely to express these concerns. Some social landlords also discussed their strategic approach to asset management.

Question 45a: Will achieving the new Decent Homes Standard by the proposed implementation dates (2035/2037) only be achievable by reducing discretionary spending compared to your current plans? (SRS landlords only)

280. 191 SRS landlords responded to this question. Responses from other groups are not summarised here.

Option	Total	Percentage
Yes	96	50%
No	19	10%
Partly	48	25%
Other	28	15%

281. For LA landlords and PRPs the most common response was ‘yes’ with (51% and 50% respectively). 21% of LA landlords and 28% of PRPs selected ‘partly’, 16% and 13% said ‘other’, and 12% and 8% responded ‘no’.

Question 45b: Please provide supporting detail.

282. There were 149 responses from SRS landlords to this question, largely highlighting their difficult financial positions. Some mentioned cutting back on new stock, while others – particularly LA landlords – highlighted that they have no discretionary spend available to cut back. Some landlords advocated for government funding to deliver the new DHS.

Question 46a: Do you agree that only criterion A should be a Type 1 DHS requirement? (PRS landlords and tenants only)

283. 146 PRS landlords and tenants responded to this question. Responses from other groups are not summarised here.

Option	Total	Percentage
Yes	74	51%
No	21	14%
Don’t know	51	35%

284. 65 out of the 73 responses to this question came from PRS landlords, with 54% agreeing that only criterion A should be a Type 1 DHS requirement. From the small number of responses from PRS tenants, 36% selected ‘yes’, and 32% selected both ‘no’ and ‘don’t know’.

Question 46b: If No – which other criteria do you think should be a Type 1 DHS requirement? (PRS landlords and tenants only)

285. 19 PRS landlords and tenants responded to this question. Respondents could choose more than one option and responses from other groups are not summarised here.

Option	Total	Percentage
Criterion B	12	63%
Criterion C	7	37%
Criterion D	7	37%
Criterion E	7	37%
Other	4	21%

Question 46c: Please give supporting details (PRS landlords and tenants only).

286. 14 responses from PRS landlords and tenants were received to this question. Due to the low response rate, no further analysis is presented here.

Question 47: If there is anything else you would like to add on this specific section? If so, please do so here.

287. 136 responses were received to this question, most of which came from landlords or representative organisations. Few tenants responded to this question.

288. Some social landlords, as well as around half of representative organisations and local authorities not responding as landlords raised concerns about the timelines for implementation. Some landlords also raised concerns about financial pressures and the funding available to meet the new DHS.

Government response

289. The DHS is one of several measures that will improve the quality of rented housing, including Awaab’s Law, new Minimum Energy Efficiency Standards, and measures in the Renters Rights’ Act including the end of Section 21 ‘no fault’ evictions and the new Private Rented Sector Database.

290. The government’s aim in implementing these measures is to achieve quick improvements on safety and energy efficiency, while allowing sufficient time for landlords to sustainably deliver their new obligations.

291. The responses received to this consultation support the conclusion that the best way to achieve this aim is to implement the DHS in 2035.

292. The new DHS will drive a long-term improvement in housing quality. While we expect landlords in each tenure to begin taking action now to ensure their properties meet the DHS and other new requirements, we recognise that it will take time to plan and deliver works sustainably. Social landlords must also balance the cost and speed of quality improvements with their role in tackling the housing crisis by delivering a new generation of homes.

293. Responses from landlords in both tenures cited concerns about the ability to deliver the DHS alongside new Minimum Energy Efficiency Standards. We have considered the timelines for MEES in each tenure when deciding the final implementation date and believe a 2035 implementation will allow landlords in each tenure sufficient time to plan and undertake necessary works to meet both standards while continuing to deliver new supply in the SRS and managing pressure on rents in the PRS. This timeline is comparable to the implementation period allowed when the DHS was first published in 2001.

294. We recognise that tenants responding to the consultation strongly favoured a shorter implementation period and are clear that people renting non-decent homes should not have to wait until 2035 to see improvements. In the social rented sector, we expect to see a steady improvement in conditions now that the new DHS has been published, as social landlords generally have large portfolios and are likely to make use of the full implementation period to sustainably deliver the required works. While private landlords mostly have smaller portfolios, they should not delay action until the end of the implementation period. By publishing the standard now we are providing a clear framework for landlords to be able to do this, and we will begin monitoring rates of compliance with the new DHS ahead of the final deadline.

295. While we have set a long-term implementation period to allow landlords the space and flexibility to deliver the DHS sustainably, we are taking a stricter approach to safety. This is particularly relevant in the private rented sector, where an unacceptable 10% of properties currently contain category 1 hazards. Rapid improvements are needed and so we will consult on the approach to extending Awaab’s Law to the PRS in the near future, having already applied it to the social rented sector. In addition, the Renters’ Rights Act will strengthen enforcement in relation to hazards in privately rented homes by giving local authorities a new power to issue financial penalties of up to £7,000 to landlords who have failed to take reasonably practicable steps to keep their properties free of category 1 hazards. As set out in the Renters’ Rights Act implementation roadmap, we intend to commence this new financial penalty by summer 2026.

296. We have also considered whether to phase in some DHS criteria ahead of the final implementation deadline, in line with the support expressed for this proposal by some consultation respondents. A degree of phasing is already implied by the structure of the DHS, because:

a. Criterion A requires homes meet the current statutory minimum standard, which is to be free from category 1 hazards assessed using the Housing Health & Safety Rating System (HHSRS). All landlords, private and social, must therefore already meet this standard and private landlords who do not take reasonably practical steps to do so will face new on the spot fines from 2026. The HHSRS is currently under review, but this will not change how a category 1 hazard is defined or change landlords’ responsibilities under criterion A of the DHS.

b. Criterion D requires that properties meet the relevant Minimum Energy Efficiency Standards (MEES). New MEES will apply for all rented properties from 2030.

297. In line with the most popular response to question 42b, we considered whether it would also be appropriate to introduce criterion E – relating to damp and mould. However, as we expect Awaab’s Law, MEES, and new fines for private landlords whose properties contain category 1 hazards all to have an impact on damp and mould, we do not believe it would be proportionate to also bring forward the requirement for rented properties to be entirely free from damp and mould.

Meeting the standard

Question 48 (SRS-only)

Question 48a: Do you agree that providers should be given flexibility from meeting the DHS where tenants refuse access?

298. There were 554 responses to this question.

Option	Total	Percentage
Yes	416	75%
No	94	17%
Don’t Know	44	8%

299. There was support for this proposal from landlords, with 82% of PRS landlords, 94% of LA landlords and 98% of PRPs responding ‘yes’. 64% of Representative organisations also agreed with the proposal. There was less support among tenants, with 50% of SRS tenants and 39% of PRS tenants supporting the proposal.

Question 48b: Do you agree that there should be additional guidance issued by the government to provide more detail on tenant refusals?

300. There were 555 responses to this question.

Option	Total	Percentage
Yes	504	91%
No	18	3%
Don’t Know	33	6%

301. There was strong overall support for this proposal across all respondent groups. 83% of SRS tenants responded ‘yes’ to this question, as did 98% of LA landlords and 97% of PRPs. 87% of representative organisations also supported the proposal.

Question 48c:  Do you agree that providers should be given flexibility from meeting the DHS where there are physical or planning factors preventing compliance?

302. There were 546 responses to this question.

Option	Total	Percentage
Yes	418	77%
No	74	14%
Don’t Know	54	10%

303. There was a difference in response to this question between tenants and landlords. 97% of LA landlords and 99% of PRPs responded ‘yes’ to this question, compared to 51% of SRS tenants who agreed. 69% of representative organisations also responded ‘yes’ to this question.

Question 48d: 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?

304. There were 539 responses to this question.

Option	Total	Percentage
Yes	387	72%
No	95	18%
Don’t Know	57	11%

305. For both LA landlords and PRPs, 96% of respondents agreed with the proposal. SRS tenants showed more mixed views, with 47% responding ‘yes’, 34% responding ‘no’, and 19% responding ‘don’t know’. 61% of representative organisations also responded ‘yes’.

Question 48e:  If there is anything else you would like to add on this specific question please do so here.

306. There were 224 responses to this question.

307. Around half of SRS landlords highlighted their views that tenant refusal of access would be a barrier to their compliance with the new DHS. Some also provided further detail on concerns around possible planning constraints preventing landlords from meeting the new DHS.

308. Some respondents shared concerns around any leniency in the standard being exploited by landlords, or the possibility of landlords pressuring tenants into declining access.

309. SRS landlords also raised the need for comprehensive guidance to accompany any future exemptions to the DHS.

Question 49a (PRS-only): 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?

310. There were 462 responses to this question.

Option	Total	Percentage
Yes	354	77%
No	55	12%
Don’t Know	53	11%

311. There was agreement to this proposal from all landlords, including 94% of PRS landlords and 91% of LA landlords. LAs not responding as landlords also agreed, with 65% responding ‘yes’. 46% of PRS tenants responded ‘yes’ to this question, although a limited number of PRS tenants answered this question (13).

Question 49b: Should statutory enforcement guidance specify that local authorities exercise discretion on enforcement in situations of tenant refusal?

312. There were 453 responses to this question.

Option	Total	Percentage
Yes	347	77%
No	60	13%
Don’t Know	46	10%

313. Landlords agreed with this proposal, with 94% of PRS landlords and 91% of LA landlords responding ‘yes’. LAs responding in their capacity as enforcers also agreed with this proposal, with 88% responding ‘yes’.

Question 49c: If there is anything else you would like to add on this specific question please do so here.

314. There were 166 respondents to this question.

315. Many LA landlords raised the issue of tenant refusal and planning constraints as barriers to the completion of works needed to comply with the DHS. Some PRS landlords also raised the issue of planning constraints, with responses highlighting the need for clear exemptions where upgrades are not feasible. Other responses raised that landlord attempts to engage tenants and access properties must be clearly documented.

316. Responses also referred to challenges in LA enforcement capacity.

Government response

317. Some rented properties will fail to meet the new DHS. The government recognises that this is unavoidable. It is important, therefore, to have a strategy in place that recognises the difference between cases where landlords won’t comply with the standard (wilful non-compliance, or failures of delivery, systems or governance that will result in regulation or enforcement), and where landlords either can’t or shouldn’t comply with the standard.

318. This section of the government response to the consultation does not cover non-compliance with MEES. Please see the section above on Criterion D and the government response to the consultation on introducing MEES in the social rented sector and on improving energy performance in the private rented sector.

Cases where landlords do not comply with the standard

319. Action will be taken where landlords do not comply with the requirements to meet the standard but where there is no reason why they can’t or shouldn’t.

320. In the social rented sector, the Regulator of Social Housing will regulate the new DHS through its standards and will monitor and assess landlords’ compliance. Tenants in social housing who believe their home does not meet the new DHS, and who have already raised the issue with their landlord, will also be able to raise a complaint with the Housing Ombudsman Service.

321. In the private rented sector, compliance with the standard will be enforced by local authorities. Supported by the new private rented sector database, they will have strong powers to issue penalties for non-compliance and will be expected to take the most appropriate form of enforcement. PRS tenants will also be able to escalate complaints about their landlords’ actions or behaviours, including complaints about standards and repairs, to the new PRS Landlord Ombudsman.

Cases where landlords can’t comply with the standard

322. There will be some cases, however, where individual circumstances mean it will be prohibitively hard or impossible to meet certain elements of the standard, for example due to planning restrictions. There may also be circumstances where it is not appropriate to meet an aspect of the standard, for example in certain types of temporary accommodation.

323. We have set out how these circumstances will be addressed, in the private and the social rented sector below. We will provide further detail in upcoming guidance.

Social landlords

324. Large PRPs report to the regulator aggregate numbers of properties where the standard is not met in these circumstances. We will keep this system in place as follows:

a. There will be cases where tenants do not allow the landlord access to their homes to carry out works to comply with the standard. Guidance will set out clearly steps providers should take to engage with tenants in these circumstances, in order to find mutually agreeable solutions. There will be cases, however, where this means the standard cannot be met.

b. Physical or planning factors may prevent the landlord from complying with the standard. Guidance in these cases will make it clear that the most dangerous category 1 hazards must still be addressed.

c. Landlords may have plans to sell, demolish or regenerate properties and estates and this would make compliance with the standard impractical or economically challenging. Guidance will set out our expectation, however, that tenant safety and wellbeing in these cases should still be the landlord’s priority.

325. There was widespread support for this proposal from most respondents to the consultation. Tenants, while generally supportive, expressed some concerns about cases where tenant access restricts compliance. We accept that it is very important tenants feel secure in their homes and there will be circumstances where they do not feel comfortable allowing landlords or their contractors in to carry out works. We also understand that this means landlords can find it challenging to meet the requirements of the DHS in some cases. We will address these circumstances, along with the other cases where compliance isn’t possible, in comprehensive guidance.

Private landlords

326. Currently, part 1 of the Housing Act 2004 sets out local authorities’ duties and powers to take action on identifying health and safety hazards in homes. It also sets out a range of potential enforcement action and gives local authorities discretion in determining which is most appropriate for the circumstance.

327. We will introduce a similar approach to enforcement of the DHS in the private rented sector. Local authorities will be able to use discretion in determining how to enforce the DHS, which may involve requiring remedial works or, in circumstances where works are not possible, the service of an ‘awareness notice’. We will support local authorities to use this discretion through statutory enforcement guidance that will set out the following circumstances:

a. There will be cases where tenants do not allow the landlord access to their homes to carry out works to comply with the standard. Guidance will set out clearly steps landlords should take to engage with tenants in these circumstances, in order to find mutually agreeable solutions. There will be cases, however, where this means the standard cannot be met. There are already legal requirements landlords must follow when they wish to enter the property and tenants who feel harassed can go to their local authority tenancy relations service. Guidance for landlords will set out clearly how cases around tenant access should be managed and we will work closely with local authorities to ensure they are confident when they make their decisions around enforcement, based on the merits of each individual case. In particular, local authorities will need to be aware of cases where a landlord may be using difficulties around tenant access as a reason to avoid carrying out essential works.

b. Physical or planning factors may prevent the landlord from complying with the standard, and these will be taken into consideration in the guidance issued to local authorities to inform their approach to enforcement. There was support for this proposal from respondents to the consultation, but again some reticence from tenants, particularly around the issue of tenant refusal of access. As with social tenants, private tenants should feel safe and secure in their homes not under pressure to allow landlords or the contractors access.

Cases where landlords shouldn’t comply with the standard

328. There will be some very specific tenure types where compliance with the standard may directly pull against the purpose of this accommodation. For example, temporary housing, supported housing or sheltered accommodation for people with specific needs where cooking facilities are not provided. The systems set out above for the regulation of social housing and enforcement in the private rented sector will also apply in these circumstances. Guidance specific to these tenures will cover this in detail, including the need to work with tenants.

329. Temporary housing and supported housing can be found in both rented sectors and there are specific challenges associated with these tenures when they are found in the private rented sector.

330. For temporary accommodation in privately rented homes, where properties lack kitchens and cooking facilities and where it is not practical for these to be provided, the local authority will have the discretion to suspend enforcement action for a period of time or use awareness notices that do not require remedial works. This is designed to balance the need to drive up standards with the requirement for local authorities to maximise the supply of accommodation to meet local demand.

331. Entire types of temporary accommodation in social housing will not be exempted from specific DHS requirements because each case is different and broad exemptions could create unnecessary gaps. Instead, guidance for social landlords and local authorities will make clear that if residents have documented needs showing that certain DHS requirements are not in their best interest, those parts of the DHS should not apply.

Annex A: Responses to multiple-choice questions by demographic group

Purpose

This annex provides a complete breakdown of responses to each multiple-choice question by demographic group. Questions where respondents could enter free text are now included, and ‘not applicable’ responses have been excluded.

Proposal 1: Updating the Definition of Disrepair (Criterion B)

Question 11: Do you agree that age should be removed from the definition of disrepair?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	627	80	24	108	81	86	55	112	5	4	9	63
No	103	10	5	14	15	28	4	11	2	0	1	13
Don’t Know	35	10	2	4	5	3	1	5	0	0	0	5
Total	765	100	31	126	101	117	60	128	7	4	10	81

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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	677	95	29	103	88	104	54	113	6	4	10	71
No	39	2	0	13	7	10	2	2	1	0	0	2
Don’t Know	36	3	2	11	5	1	2	7	0	0	0	5
Total	752	100	31	127	100	115	58	122	7	4	10	78

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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	448	55	22	68	62	59	46	77	2	4	7	46
No	187	30	7	34	28	40	10	16	4	0	2	16
Don’t Know	107	15	2	24	8	14	4	24	1	0	1	14
Total	742	100	31	126	98	113	60	117	7	4	10	76

Question 14 (Landlords only): Do you think 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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	157	0	2	33	49	59	1	6	1	0	1	5
No	177	0	0	78	35	47	1	7	3	0	0	6
Don’t Know	30	0	0	14	10	5	0	0	0	0	0	1
Total	364	0	2	125	94	111	2	13	4	0	1	12

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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	611	90	29	76	79	96	55	110	3	3	7	63
No	98	1	1	42	18	18	3	3	3	0	3	6
Don’t Know	24	2	0	9	4	0	1	3	1	0	0	4
Total	733	93	30	127	101	114	59	116	7	3	10	73

Question 16a: Do you agree with the proposed list of building components that must be kept in good repair?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	532	86	28	75	67	62	52	85	5	3	7	62
No	155	1	0	39	28	52	4	16	2	0	2	11
Don’t Know	44	4	2	12	5	2	3	11	0	0	1	4
Total	731	91	30	126	100	116	59	112	7	3	10	77

Question 17: Do you agree with the proposed ‘key’ components and ‘other’ components as listed?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	479	76	24	69	60	64	39	80	4	3	5	55
No	162	2	3	39	32	45	11	9	3	0	3	15
Don’t Know	77	11	3	18	7	3	7	18	0	0	2	8
Total	718	89	30	126	99	112	57	107	7	3	10	78

Question 18a: Do you agree with the proposed ‘key’ components and ‘other’ components as listed?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	245	28	7	92	22	14	17	29	6	1	5	24
No	402	57	20	27	71	95	35	52	1	2	5	37
Don’t Know	69	6	3	7	7	4	5	26	0	0	0	11
Total	716	91	30	126	100	113	57	107	7	3	10	72

Proposal 2: Facilities and services (Criterion C)

Question 20a: Do you agree with the proposed ‘key’ components and ‘other’ components as listed?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	409	80	23	45	49	61	25	69	2	1	4	50
No	282	15	6	72	45	46	31	36	4	3	6	18
Don’t Know	41	3	1	11	6	7	2	7	1	0	0	3
Total	732	98	30	128	100	114	58	112	7	4	10	71

Question 20b: If you said No, are there any of the facilities that you would prioritise? Select all that apply

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Kitchens	264	19	9	56	46	47	26	32	3	1	6	19
Bathrooms	267	18	9	59	45	47	27	33	3	1	6	19
Noise Insulation	89	16	9	8	13	8	9	14	0	1	1	10
Communal Areas	78	14	6	5	12	7	9	13	1	2	2	7
Total*	287	20	10	69	46	49	27	34	3	2	6	21

Question 20c: 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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	423	43	17	66	72	73	44	65	5	3	6	29
No	141	22	5	26	19	30	7	13	1	0	3	15
Don’t Know	140	30	7	32	7	10	3	26	1	0	1	23
Total	704	95	29	124	98	113	54	104	7	3	10	67

Proposal 3: Window Restrictors (Criterion C)

Question 21 (Landlords only): Do you currently provide child-resistant window restrictors that can be overridden by an adult on dwellings with windows above ground floor?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
All dwellings	95	0	1	26	32	29	1	3	2	0	0	1
Some dwellings	187	0	1	36	60	75	2	9	0	0	0	4
None	56	0	1	50	1	2	1	0	0	0	0	1
Don’t know	18	0	0	7	2	6	1	1	0	0	0	1
Total	356	0	3	119	95	112	5	13	2	0	0	7

Question 22a: 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)?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	577	84	25	51	90	101	55	96	6	4	3	62
No	118	4	3	71	8	12	3	6	1	0	4	6
Don’t know	33	2	2	5	3	2	2	9	0	0	2	6
Total	728	90	30	127	101	115	60	111	7	4	9	74

Proposal 4: Home Security Measures (Criterion C)

Question 23a: Do you think that home security requirements in relation to external doors and windows are sufficiently covered in the Decent Homes Standard?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	404	34	14	92	68	83	37	35	7	1	5	28
No	217	46	12	13	27	31	16	45	0	1	2	24
Don’t know	98	18	4	21	4	2	3	26	0	1	3	16
Total	719	98	30	126	99	116	56	106	7	3	10	68

Question 23b: Do you think that home security requirements in relation to external doors and windows are sufficiently covered in the Decent Homes Standard?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	221	47	15	9	28	31	18	45	0	1	2	25
No	55	2	2	28	5	9	3	3	1	0	0	2
Don’t Know	59	7	0	13	5	3	4	19	0	0	1	7
Total	335	56	17	50	38	43	25	67	1	1	3	34

Question 23c: If you responded Yes to part b), should we consider giving landlords the option to comply with Part Q requirements in Building Regulations?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	272	36	7	45	47	52	19	35	3	1	3	24
No	117	25	7	15	9	16	12	18	0	0	1	14
Don’t Know	110	15	6	28	11	6	7	26	1	0	2	8
Total	499	76	20	88	67	74	38	79	4	1	6	46

Proposal 5: Suitable floor coverings (Criterion C)

Question 24a: 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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	449	79	28	76	34	36	39	86	5	3	4	59
No	229	16	0	41	58	64	15	18	2	0	5	10
Don’t Know	67	5	2	9	10	15	5	17	0	0	0	4
Total	745	100	30	126	102	115	59	121	7	3	9	73

Question 25a: (Landlords only) Do you provide floor coverings in any of your dwellings?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	321	1	3	121	77	98	2	10	3	0	0	6
No	32	0	0	5	16	10	0	1	0	0	0	0
Don’t Know	3	0	0	0	1	1	0	0	0	0	0	1
Total	356	1	3	126	94	109	2	11	3	0	0	7

Question 25c: (Landlords only) If you responded Yes to part a), in regard to responsibility of repair and maintenance for floor coverings do you:

• 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)

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Carry out or have responsibility for repair and maintenance of flooring as part of, for example, tenancy agreements	154	0	1	72	27	39	1	6	3	0	0	5
Gift flooring to tenants and they are responsible for on-going repair and maintenance	107	1	1	23	31	48	0	1	0	0	0	2
Other	62	0	0	21	20	16	1	3	0	0	0	1
Total	323	1	2	116	78	103	2	10	3	0	0	8

Question 25D: (Landlords only) 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

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
All rooms	142	0	1	100	6	22	1	4	3	0	0	5
Bedrooms	19	0	1	14	2	2	0	0	0	0	0	0
Living room	18	0	1	9	4	4	0	0	0	0	0	0
Kitchen	142	1	1	5	55	72	1	5	0	0	0	2
Bathroom	143	1	1	8	53	72	1	5	0	0	0	2
Other areas (including stairs, hallways)	21	0	1	14	1	4	0	1	0	0	0	0
Varies by property	47	0	0	12	17	14	0	3	0	0	0	1
Other e.g. new builds	32	0	0	0	19	11	0	2	0	0	0	0
Total	434	6	7	122	87	107	26	49	4	1	3	22

Question 25E: (Landlords only) 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

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Sometimes replace floor coverings for new tenancies	166	0	1	69	37	54	1	3	0	0	0	1
Allow tenants to replace floor coverings themselves	27	0	0	4	9	11	0	0	1	0	0	2
Always replace floor coverings for new tenancies	10	0	1	4	2	2	0	1	0	0	0	0
Never replace floor coverings	14	0	0	5	4	3	0	1	0	0	0	1
Provide support for tenants to replace floor coverings themselves	7	0	0	1	3	2	0	1	0	0	0	0
Only replace floor coverings if tenants request it	4	0	0	2	0	1	0	0	0	0	0	1
Other	106	0	0	37	27	34	0	5	2	0	0	1
Total	334	0	2	122	82	107	1	11	3	0	0	6

Question 25f: (Landlords only) What proportion of your new lettings do you expect would require new floor coverings (including replacements each year?)

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
0 to 25%	142	0	1	94	15	18	2	4	3	0	0	5
26% to 50%	44	3	2	11	12	13	0	2	0	0	0	1
51% to 75%	59	6	1	7	15	27	0	2	1	0	0	0
76% to 100%	99	6	1	3	35	43	1	6	1	0	0	3
Total	344	15	5	115	77	101	3	14	5	0	0	9

Question 25g: (Landlords only) What proportion of your new lettings do you expect would require new floor coverings (including replacements each year?)

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
0 to 25%	144	1	0	38	42	55	1	5	0	0	0	2
26% to 50%	55	1	0	17	11	22	0	3	0	0	0	1
51% to 75%	41	3	1	11	10	12	0	1	2	0	0	1
76% to 100%	93	10	3	45	9	13	1	4	3	0	0	5
Total	333	15	4	111	72	102	2	13	5	0	0	9

Question 25h: (Landlords only) What proportion of your new lettings do you expect would require new floor coverings (including replacements each year?)

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	118	0	1	48	19	34	2	8	1	0	0	5
No	159	1	0	52	49	50	0	4	2	0	0	1
Don’t Know	42	0	1	16	13	10	0	1	0	0	0	1
Other	33	0	0	8	10	13	0	2	0	0	0	0
Total	352	1	2	124	91	107	2	15	3	0	0	7

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

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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	672	99	29	91	96	107	56	109	6	3	7	69
No	59	0	1	33	4	6	2	5	1	0	3	4
Don’t Know	17	1	0	4	1	1	2	6	0	0	0	2
Total	748	100	30	128	101	114	60	120	7	3	10	75

Question 27: Are there other thermal comfort requirements that you think should be included in the DHS beyond current MEES proposals?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	185	38	11	12	24	15	14	38	0	2	1	30
No	378	15	11	100	62	83	28	44	6	1	6	22
Don’t Know	167	45	7	14	14	13	15	32	1	0	3	23
Total	730	98	29	126	100	111	57	114	7	3	10	75

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

Question 29a: 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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	651	100	29	84	92	94	43	120	4	3	6	76
No	78	1	0	32	6	14	8	6	3	0	3	5
Don’t Know	32	0	1	10	3	5	8	3	0	0	1	1
Total	761	101	30	126	101	113	59	129	7	3	10	82

Question 29b: 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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	592	94	28	77	85	80	41	108	3	3	6	67
No	104	4	1	38	9	26	7	8	3	0	3	5
Don’t Know	44	1	1	12	5	6	9	5	1	0	1	3
Total	740	99	30	127	99	112	57	121	7	3	10	75

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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	492	78	22	63	73	67	36	88	3	2	6	54
No	169	13	4	45	21	36	15	16	3	0	3	13
Don’t Know	72	8	3	18	5	10	7	13	1	0	1	6
Total	733	99	29	126	99	113	58	117	7	2	10	73

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

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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	470	65	22	48	77	76	38	82	2	1	5	54
No	39	4	0	8	11	4	4	2	1	0	3	2
Don’t know	74	13	4	19	11	6	4	8	2	0	2	5
Total	583	82	26	75	99	86	46	92	5	1	10	61

Question 33a: 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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	130	8	4	8	44	16	14	21	1	1	1	12
No	154	16	2	21	34	40	10	17	0	0	2	12
Don’t know	267	52	18	45	18	28	22	40	4	1	6	33
Total	551	76	24	74	96	84	46	78	5	2	9	57

Question 34: Do you think the proposed DHS requirements will impact temporary accommodation supply?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	278	33	14	39	57	42	31	31	2	0	4	25
No	72	12	2	6	17	11	3	12	0	0	1	8
Don’t know	190	36	8	32	15	28	8	32	3	1	5	22
Other	31	1	2	0	10	4	4	8	0	0	0	2
Total	571	82	26	77	99	85	46	83	5	1	10	57

Question 35: Are there any challenges you foresee in applying the outlined DHS proposals in Supported Housing?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	169	10	5	18	38	31	15	28	1	0	2	21
No	169	23	4	11	37	46	15	19	0	2	1	11
Don’t know	216	47	17	41	11	13	17	32	4	1	6	27
Total	554	80	26	70	86	90	47	79	5	3	9	59

Question 36a: Do you agree with the proposed approach to enforcement for rented properties that are leasehold?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	350	42	14	26	67	64	38	55	1	0	4	39
No	48	1	2	21	3	13	0	3	1	0	2	2
Don’t know	174	33	9	37	18	14	10	27	3	1	4	18
Total	572	76	25	84	88	91	48	85	5	1	10	59

Question 37a: 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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	253	25	7	36	50	61	17	26	2	1	7	21
No	107	11	4	13	21	20	15	14	0	0	0	9
Don’t know	219	41	14	38	21	16	18	39	3	1	3	25
Total	579	77	25	87	92	97	50	79	5	2	10	55

Guidance

Question 38a: 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

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Accessibility	500	72	25	42	91	84	41	89	1	2	3	49
Additional home security measures	437	76	21	33	73	71	38	76	1	3	4	41
Adaptations to climate change	438	51	20	38	83	79	39	81	1	2	2	42
Digital connectivity	414	54	19	43	73	76	34	69	1	2	3	40
Electric vehicle charging	375	42	9	42	73	79	31	60	1	2	2	34
Furniture provision	347	42	15	22	60	55	36	77	0	2	3	35
Water efficiency measures	448	69	22	44	77	77	36	76	1	2	3	41
Other	161	12	3	25	11	21	16	46	2	2	1	22
Total	680	100	30	90	98	108	52	120	3	4	5	70

Implementing the Decent Homes Standard

Question 40a: What do you think the implementation date for the DHS should be in the SRS?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
2035	215	19	6	39	37	38	17	29	4	1	0	25
2037	169	9	1	27	38	51	5	22	0	0	4	12
Other	328	70	24	56	21	17	30	62	3	1	5	39
Total	712	98	31	122	96	106	52	113	7	2	9	76

Question 40b: If Other - What do you think the implementation date for the DHS should be in the SRS?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
2027	119	42	15	12	1	2	5	19	2	0	1	20
2028	29	11	2	3	0	0	1	4	0	0	1	7
2029	12	5	0	2	0	0	0	4	0	0	0	1
2030	103	16	7	15	3	4	19	25	0	1	2	11
2031	5	0	0	1	0	0	2	2	0	0	0	0
2032	5	0	0	0	1	0	1	3	0	0	0	0
2033	2	0	0	0	1	0	0	1	0	0	0	0
2034	3	0	0	1	0	0	0	0	0	0	0	2
2036	8	0	0	1	2	1	1	3	0	0	0	0
Later	35	1	0	17	3	7	1	1	1	0	3	1
Don’t know	35	1	1	9	5	1	5	10	0	1	0	2
Total	356	76	25	61	16	15	35	72	3	2	7	44

Question 41a: What do you think the implementation date for the DHS should be in the PRS?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
2035	202	22	3	29	43	34	19	26	2	0	1	23
2037	177	8	1	46	36	63	3	9	3	0	1	7
Other	333	68	27	48	20	13	37	66	2	3	7	42
Total	712	98	31	123	99	110	59	101	7	3	9	72

Question 41b: If Other - What do you think the implementation date for the DHS should be in the PRS?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
2027	106	37	17	5	2	2	4	18	1	0	1	19
2028	23	6	2	2	0	0	3	5	0	0	1	4
2029	18	9	0	1	0	0	0	6	0	0	0	2
2030	110	15	8	9	8	6	21	30	0	1	2	10
2031	10	1	0	3	0	0	2	3	0	0	0	1
2032	4	1	0	0	0	0	1	1	0	0	0	1
2033	1	0	0	0	1	0	0	0	0	0	0	0
2034	0	0	0	0	0	0	0	0	0	0	0	0
2036	5	0	0	1	1	1	1	0	0	0	0	1
Later	51	1	1	33	2	4	3	0	1	0	3	3
Don’t know	29	1	0	3	6	3	3	8	0	1	1	3
Total	357	71	28	57	20	16	38	71	2	2	8	44

Question 42a: Do you support phasing in some elements of the new Decent Homes Standard ahead of the proposed full implementation dates (2035/2037)?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	389	58	23	40	51	54	38	74	1	1	6	43
No	255	18	7	68	35	55	18	24	5	1	3	21
Don’t know	87	23	1	20	13	3	3	14	1	0	1	8
Total	731	99	31	128	99	112	59	112	7	2	10	72

Question 43a: (SRS Landlords) Are you confident in your ability to deliver works to meet the new Decent Homes Standard by the proposed implementation dates (2035/2037) within current income forecasts in the SRS?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	60	1	1	3	23	26	1	4	0	0	0	1
No	99	0	0	6	47	39	0	1	1	0	0	5
Don’t know	79	0	1	3	25	44	1	4	0	0	0	1
Total	238	1	2	12	95	109	2	9	1	0	0	7

Question 43b: (Landlords) Are you confident in your ability to deliver works to meet the new Decent Homes Standard by the proposed implementation dates (2035/2037) alongside other regulatory requirements including Awaab’s Law and MEES?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	112	0	1	51	24	26	2	6	1	0	0	1
No	138	0	0	46	45	36	0	2	2	0	0	7
Don’t know	93	0	1	26	24	38	1	2	0	0	0	1
Total	343	0	2	123	93	100	3	10	3	0	0	9

Question 44a: (Landlords) Considering the need to meet both Minimum Energy Efficiency Standards and the Decent Homes Standard, do you plan to deliver savings by prioritising measures which will both improve a property’s energy efficiency and help meet the DHS?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	192	0	1	41	65	73	1	7	1	0	0	3
No	56	0	0	36	8	8	1	0	1	0	0	2
Don’t know	96	0	1	39	20	28	1	2	1	0	0	4
Total	344	0	2	116	93	109	3	9	3	0	0	9

Question 44b: (Landlords) Considering the need to meet both Minimum Energy Efficiency Standards and the Decent Homes Standard, do you plan to deliver savings by Reducing overhead costs by programming combined works to meet both standards??

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	172	0	0	31	66	64	1	7	0	0	0	3
No	57	0	0	41	5	7	1	0	1	0	0	2
Don’t know	110	0	2	43	22	34	1	2	2	0	0	4
Total	339	0	2	115	93	105	3	9	3	0	0	9

Question 45a: (SRS Landlords) Will achieving the new Decent Homes Standard by the proposed implementation dates (2035/2037) only be achievable by reducing discretionary spending compared to your current plans?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	109	0	1	6	43	53	0	3	1	0	0	2
No	23	0	0	1	10	9	1	2	0	0	0	0
Partly	56	0	0	2	18	30	0	3	0	0	0	3
Other	31	1	0	0	14	14	0	2	0	0	0	0
Total	219	1	1	9	85	106	1	10	1	0	0	5

Question 46a: (PRS Landlords and Tenants) Do you agree that only criterion A should be a Type 1 DHS requirement?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	107	5	9	65	5	10	1	9	1	0	0	2
No	37	5	8	13	1	2	0	3	1	0	1	3
Don’t know	67	5	8	43	3	2	0	2	1	0	0	3
Total	211	15	25	121	9	14	1	14	3	0	1	8

Question 46b: (PRS Landlords and Tenants) If No – which other criteria do you think should be a Type 1 DHS requirement? Select all that apply

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Criterion B	21	3	7	5	0	1	0	3	0	0	0	2
Criterion C	13	3	4	3	0	0	0	2	0	0	0	1
Criterion D	16	3	4	3	0	3	0	2	0	0	0	1
Criterion E	5	3	4	3	0	3	0	2	0	0	0	1
Other	9	1	1	3	0	0	0	0	2	0	1	0
Total	38	3	9	10	1	3	0	4	2	0	1	3

Meeting the standard

Question 48a: (SRS) Do you agree that providers should be given flexibility from meeting the DHS where tenants refuse access?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	416	48	7	28	91	109	24	64	4	0	7	34
No	94	33	9	4	5	1	5	23	0	1	1	12
Don’t Know	44	15	2	2	1	1	2	13	0	0	0	8
Total	554	96	18	34	97	111	31	100	4	1	8	54

Question 48b: (SRS) Do you agree that there should be additional guidance issued by the government to provide more detail on tenant refusals?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	504	82	15	24	95	108	30	87	3	1	8	51
No	18	5	3	5	2	1	0	1	1	0	0	0
Don’t Know	33	12	0	2	0	2	0	12	0	0	0	5
Total	555	99	18	31	97	111	30	100	4	1	8	56

Question 48c: (SRS) Do you agree that providers should be given flexibility from meeting the DHS where there are physical or planning factors preventing compliance?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	418	49	6	26	94	110	25	68	4	2	5	29
No	74	27	8	2	2	0	3	16	0	0	3	13
Don’t Know	54	21	3	2	1	1	2	14	0	0	0	10
Total	546	97	17	30	97	111	30	98	4	2	8	52

Question 48d: (SRS) 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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	387	46	5	22	90	107	22	59	4	0	6	26
No	95	33	9	4	3	3	7	18	0	1	1	16
Don’t Know	57	19	3	4	1	1	1	19	0	0	0	9
Total	539	98	17	30	94	111	30	96	4	1	7	51

Question 49a: (PRS) 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?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	354	25	13	117	48	17	45	46	7	1	5	30
No	55	10	9	3	3	1	2	11	0	0	1	15
Don’t Know	53	7	6	5	2	2	4	14	0	0	2	11
Total	462	42	28	125	53	20	51	71	7	1	8	56

Question 49b: (PRS) Should statutory enforcement guidance specify that local authorities exercise discretion on enforcement in situations of tenant refusal?

Answer	Totals	SRS Tenant	PRS Tenant	PRS Landlord	LA Landlord	PRP	LA – Other	Rep. Org	Letting Agent	Gov. Body	Lease- holder	Other
Yes	347	23	14	113	45	17	45	42	6	1	5	36
No	60	10	12	5	4	1	4	12	1	0	1	10
Don’t Know	46	6	3	6	3	1	2	13	0	0	2	10

1. (1) A kitchen with adequate space and layout; (2) An appropriately located bathroom and WC; (3) Adequate external noise insulation; and (4) Adequate size and layout of common entrance areas for blocks of flats. ↩

2. The published consultation document included a duplicate of question 19, numbered 18b, that was not present in the online questionnaire. No data was collected for this question. ↩

3. The-Extent-of-Furniture-Poverty-in-the-UK-final-3.pdf ↩

4. Decent Homes Standard Interim Impact Assessment ↩

5. GOV.UK:Understanding and addressing the health risks of damp and mould ↩

6. For conciseness, we will generally just refer to leaseholders and freeholders in this section, but please note that these proposals will also apply to their commonhold equivalents: unit owners and commonhold associations. ↩