The UK Government’s consultation on a reformed Decent Homes Standard (DHS), launched in July 2025, marks another major milestone in the evolution of housing quality regulation in England. The Decent Homes Standard (DHS) has long served as the primary benchmark for housing quality in England’s social rented sector (SRS). However, the government’s 2025 consultation aligns the DHS more closely with modern housing expectations in quality, safety, and energy efficiency standards. The new standard also proposes extending its mandate to the private rented sector (PRS) for the first time, anticipated through the Renters (Reform) Bill, currently progressing through Parliament. 

The Decent Homes Standard was originally introduced in 2000, and updated in 2006 to reflect the introduction of the HHSRS under Part 1 of the Housing Act 2004. The process of review began with the publication of the Social Housing White Paper in November 2020, in which the previous government pledged to review whether the current DHS remained suitable for the social housing sector. This was followed by the Levelling Up White Paper published by the previous government in February 2022, which set a national target to halve the number of non-decent rented homes, both social and private, by 2030. A two-stage review process followed; Stage 1 (2021) focused on the suitability and modernisation of the standard for the social sector; Stage 2 (2022) consulted on its potential extension to the PRS. More recently, in its October 2024 consultation on future social housing rent policy, the government reaffirmed its intention to consult on a reformed DHS. 

The Standard
The current consultation proposes to retain and update the four core DHS criteria while introducing a fifth to explicitly address damp and mould. The government proposes that the DHS will be supported by updated definitions, usability assessments (i.e., based on condition, safety and layout rather than age thresholds), and prescribed ‘building component’ standards. Each criterion is summarised below:

Criterion A: Free from Serious Hazards (HHSRS)
A home must be free from any Category 1 hazard as defined by the Housing Health and Safety Rating System (HHSRS) and associated regulations. The criteria refers to the absence of Category 1 hazards, but does not in itself replace local housing authority HHSRS enforcement powers. This criterion reinforces the importance of the HHSRS, but also highlights the need for joined-up inspection protocols between hazard-based and standard-based enforcement tools. We discuss the interplay between DHS and the HHSRS further in the article below.

Criterion B: Maintains a Reasonable State of Repair
Key building components (e.g., roofs, external walls, windows, boilers, chimneys, heating systems, and electrics) must not be both old and in poor condition. Key building components refer to those which, if in disrepair, could compromise the structure or present major health or safety risks. Other building components such as internal doors, flooring, plasterwork, skirting boards, and rainwater goods must also be in a reasonable state of repair. Under the revised DHS, a property will be considered non-decent if it has either:

• two or more key building components that are both old and in poor condition; or

• three or more other building components that are in poor condition.

Criterion C: Provides Reasonably Modern Facilities and Services
This criterion focuses on the functionality, safety, and usability of facilities. The consultation proposes a shift away from rigid age thresholds (e.g., kitchens <20 years; bathrooms <30 years) towards a condition and layout-based assessment. A home should have a kitchen and bathroom in functional condition, with safe layout, appropriate storage, lighting, and usability. In addition to kitchen and bathroom usability, a decent home must have appropriate window restrictors for safety, a safe and compliant electrical system, effective ventilation to manage moisture and condensation, and safe, suitable flooring, particularly in wet or high-use areas. The consultation also considers introducing minimum security standards and requiring floor coverings to be provided in all rooms at tenancy start. 

Criterion D: Offers a Reasonable Degree of Thermal Comfort
The revised standard strengthens expectations around energy efficiency and whole-home warmth. It replaces the previous requirement for heating in the living room and at least one other room with a broader requirement for fixed, efficient heating systems capable of providing adequate warmth throughout the entire dwelling.

The revised DHS also proposes alignment with other energy-related policies, such as the Minimum Energy Efficiency Standards (MEES) in the PRS and the target for all homes to reach EPC Band C by 2030. In addition to heating, the criterion includes adequate insulation and fabric improvements to ensure homes are thermal efficient and are affordable to run.

Criterion E (Proposed): Free from Damp and Mould Likely to Cause Harm to Health
This new criterion reflects the lessons of the Awaab Ishak inquest and underpins Awaab’s Law, which establishes statutory timeframes for landlords to investigate and remedy hazards like damp and mould. The inquest into Awaab’s tragic death in 2020 highlighted systemic failures in landlord response, communication, and accountability. As a result, Awaab’s Law introduces a clear legal duty to act within 24 hours for emergency hazards and within 7 days for repairs. The proposed Criterion E directly aligns with these requirements. It proposes a legal requirement for homes to be free from:

• Black mould growth (regardless of cause).

• Structural damp penetration or rising damp.

• Persistent condensation, typically from poor ventilation or insulation.

• Inadequate heating or ventilation systems, or damaged building fabric.

The consultation also calls for views on:

• Introducing best practice guidance to sit alongside the DHS, including information to landlords on how they might voluntarily exceed the minimum requirements.

• Making compliance with the DHS an enforceable requirement in the private rented sector by 2035 or 2037, and a regulatory requirement in social housing over the same timescales.

• How regulators and enforcement authorities should respond where landlords are unable to meet the standard due to limitations associated with the building, the tenant, or the landlord’s own capacity.

Modelling its impact
In preparation for the public consultation, the Ministry of Housing, Communities and Local Government (MHCLG) published a technical EHS modelling briefing (English Housing Survey Briefing: Modelling a Revised Decent Homes Standard (2024), outlining how changes to the DHS would impact the classification of non-decent homes. The modelling uses the 2022 English Housing Survey to estimate how the new and updated criteria would shift compliance levels across both sectors. Based on the most recent data, the proportion of non-decent dwellings in England was 15%, based on the current standard. However, when applying the new standards:

• In the social rented sector, non-decency would rise from 12% to 40%, affecting 1.6 million homes.

• In the private rented sector, it would jump from 23% to 47%, impacting 2.2 million homes.

This increase is driven largely by updated disrepair and thermal comfort requirements, as well as the introduction of Criterion E, focused on damp and mould. The modelling also found that 81% of non-decent social homes and 71% of non-decent PRS homes would fail only one DHS criterion. This suggests that while the overall number of homes classified as non-decent under the revised standard will increase substantially, the majority of interventions may be targeted to address just one major failing, such as inadequate insulation, outdated heating systems, or visible damp and mould. In practice, this might enable local authorities and landlords to prioritise resources, addressing the most common and critical deficiencies without requiring wholesale refurbishment in many cases. 

Importantly, the scale of impact is significant with over 9 million individuals estimated to reside in homes, across both the PRS and SRS, that would require to be brought up to standard through this reform. These individuals include vulnerable residents, such as older adults, families with children, and those with pre-existing health conditions, who stand to benefit most from improved housing safety, thermal comfort, and moisture control. The additional compliance costs associated with moving to a new, higher standard are estimated in 2019 prices, at £836 million for the SRS, and £2.4 billion in the PRS, assuming all currently non-decent homes are brought up to the proposed standard without grant or phased implementation.

DHS and the Housing Health and Safety Rating System (HHSRS)
The HHSRS remains the statutory framework for hazard assessment under the Housing Act 2004, enforced by local authorities. The DHS complements rather than replaces the HHSRS. Criterion A (hazards) and Criterion E (damp and mould) are particularly linked. However, a home may still fail DHS while being HHSRS-compliant, or vice versa. In parallel with the DHS reform, the Government has also concluded its review of the HHSRS, delivered by ourselves at RHE Global. The review’s headline outcomes, published by Government in September 2023, include:

• Reviewed and updated HHSRS operating and enforcement guidance.

• Reviewed and updated guidance for landlords and property-related professionals and the introduction of new guidance for tenants.

• A Simpler means of banding the results of HHSRS assessments

• Amalgamation of existing hazard profiles, reducing the number of hazards from 29 to 21.

• Creating a new set of baseline indicators (or minimum standards) for key hazard areas (e.g. excess cold, damp, fire safety).

• Review of the ‘Fire Safety Hazard’ to ensure the risk of fire in tall buildings can be assessed effectively.

• A new and updated suite of case studies (‘worked examples’) across all prescribed hazards and based on the recommended changes.

• Recommendations for introducing a digital assessment tool for consistent enforcement and training competency requirements.

The revised DHS will operate as a condition-based benchmark that defines a decent home, while the HHSRS will remain the legal tool for risk-based enforcement under the Housing Act 2004. The government is seeking feedback on how these frameworks can best align in practice, and acknowledges the need for clear guidance to avoid duplication, overlap, or inconsistency in enforcement.

For local authorities, this reinforces the need to integrate DHS assessments within existing housing inspection processes, and to develop robust protocols for when a dwelling may fail the DHS but not meet the threshold for HHSRS enforcement. The consultation seeks views on how to clarify this dual operation in practice, including how local authorities can apply both frameworks effectively without duplication or legal conflict.

Regulatory and Legal Implications
The consultation proposes two potential implementation dates by which compliance with the Decent Homes Standard would become a statutory requirement across both sectors, April 2035 or April 2037. These timelines would make the DHS an enforceable duty for landlords in the PRS and a regulatory obligation for providers in the social housing sector. The government is seeking views on which option allows sufficient time for landlords, local authorities, and the Regulator of Social Housing to prepare for the necessary infrastructure, guidance, and enforcement frameworks. Until then, voluntary adoption and best practice will be encouraged, supported by enhanced inspection protocols, digital compliance tools, and performance monitoring. 

The proposed Decent Homes Standard (DHS) will have important implications for both the social and private rented sectors. In the SRS, the DHS is expected to become a tenant-facing compliance obligation. Landlords would be required to publish data on their compliance with DHS criteria, inform tenants about how their home meets each of the five DHS criteria and involve tenants in inspection and remedial planning processes. These proposals reflect the wider tenant empowerment and an accountability agenda set out in the Social Housing (Regulation) Act 2023.

In the PRS, the DHS would be enforceable by local housing authorities using their powers under the Housing Act 2004. The consultation indicates that:

• DHS compliance could be monitored through the PRS Property Portal.

• Landlords may be required to complete self-assessments and submit evidence.

• Local authorities would be expected to implement risk-based inspection strategies using both DHS and HHSRS frameworks.

The consultation acknowledges that the proposed dual-framework, combining the HHSRS (risk-based hazard assessments) with the reformed DHS (standard-based compliance system) presents several operational challenges. The DHS will set enforceable minimum standards for housing decency, while the HHSRS will remain the legal tool for assessing serious health risks. A home might fail the DHS without triggering enforcement under the HHSRS (e.g., a kitchen that is outdated but not hazardous). DHS breaches, such as ‘functional’ facilities or insufficient insulation, may not always meet the thresholds for hazard-based action. Clear statutory guidance will be needed to support consistent enforcement.

In social housing, non-compliance may be actionable through the Housing Ombudsman or the Regulator of Social Housing. In the PRS, the consultation proposes that DHS compliance could be linked to future redress schemes, offering tenants an alternative enforcement route beyond local authorities. Local authorities will play a key role in monitoring compliance and taking enforcement action. The consultation recognises the resource implications and proposes operational support which may include standardised guidance, training and centralised compliance database, potentially integrated with other PRS systems.

Final Thoughts
The reformed Decent Homes Standard has the potential to raise the bar for housing quality across both the social and private rented sectors. When combined with Awaab’s Law, MEES and the proposed updates to the Housing Health and Safety Rating System (HHSRS) as examples. However, the success of this new framework will depend on legal clarity (including how the DHS and other regulations including the HHSRS operate in tandem), the operational capacity of housing providers and enforcing authorities to implement those changes, and achieving consistency in the delivery of improvements across tenures. 

The government rightly notes that an effective standard must be clear, practical, and enforceable. Whether you are a tenant, landlord, agent, housing provider, or local authority officer, now is the time to give your views and help shape these proposals to deliver a system capable of delivering a reformed system which is best placed to achieve its aims.