Are You Ready for the New Decent Homes Standard?

By David Guy · 15 July 2025

Time to Think Differently About Housing Quality, Compliance and Delivery Models

The Government has launched a bold and far-reaching consultation on a new Decent Homes Standard (DHS). For the first time, the same standard will apply across social and private rented homes, with an emphasis on condition, safety, energy efficiency and tenant health.

What’s Changing?

The proposals aim to set out a clear, enforceable, and modernised standard of decency that reflects the expectations of today’s tenants and the operational reality for landlords.

These are not just minor technical updates but significant reforms that require both strategic realignment and operational readiness across the sector.

The new Decent Homes Standard seeks to:

• Mandate legal duties to address serious hazards such as damp and mould, with new enforcement powers coming into effect from October 2025 (Awaab’s Law).
• Reframe how disrepair is assessed, moving away from age-based rules to focus on the actual condition, functionality, and safety of building components.
• Establish core minimum facilities for all rented homes: this includes functioning and safe electrical systems, whole-home heating, kitchens, and bathrooms.
• Introduce expectations for thermal comfort, requiring energy-efficient heating systems, whole-home heat distribution, and potentially insulation upgrades aligned to long-term net-zero goals.
• Require landlords to install safety features where necessary, including window restrictors to prevent falls, adequate door and window locks, and proper floor coverings at the start of a tenancy.
• Strengthen enforcement capabilities for local authorities, enabling higher penalties of up to £40,000 and empowering councils to act more quickly and decisively against non-compliant landlords.
• Apply the same standard across social and private rented sectors, creating consistency of housing quality regardless of tenure and removing previous disparities in expectations.

These changes will require landlords to:

• Reassess their asset management strategies and planned programmes
• Adapt procurement frameworks and contract terms
• Upskill trades teams, surveyors, and contractors
• Strengthen customer communications and complaint triage
• Rebuild risk frameworks and board assurance mechanisms around statutory duties

The DHS consultation doesn’t exist in isolation. It’s designed to work together with Awaab’s Law and new Minimum Energy Efficiency Standards (MEES) as a complete framework.

Awaab’s Law requires social landlords to investigate and fix hazards like damp and mould within strict legal deadlines. This directly supports the updated Decent Homes Standard, which now treats damp and mould as a standalone requirement rather than just another health risk.

The MEES consultation wants all social housing to meet EPC Band C by 2030. This energy efficiency requirement will become part of the revised Decent Homes Standard under “thermal comfort” rules. Put simply, if your property fails MEES, it may also fail the Decent Homes Standard.

Why Your Data Strategy Matters

Good data isn’t just helpful, it’s essential for meeting these new requirements. Landlords need to move beyond fixing problems as they arise and start using data to prevent them.

You’ll need better stock condition data that’s more detailed and regularly updated. The revised Decent Homes Standard includes new components like window restrictors, floor coverings, and security features that may require fresh surveys and updated asset registers.

Customer data becomes crucial for tailoring services, identifying vulnerable tenants, and ensuring proper engagement. Under Awaab’s Law, responding quickly to tenant-reported hazards is now a legal duty.

Energy data from EPCs, smart meters, or retrofit assessments will be vital for planning and tracking progress toward the 2030 EPC C target. Without accurate energy performance data, you risk falling behind on compliance.

Key Risks

The proposals bring new pressures, and new responsibilities, that will require significant operational and strategic adjustment. How housing providers prepare now, will determine their ability to meet future standards, respond to enforcement, and maintain tenant trust.

For those with in-house contracting teams/DLOs, there is likely to be more flexibility and control, but also a need for sustained investment in skills, materials, and scheduling.

For providers using contractors, successful compliance will depend on how well contracts are written, monitored, and adapted to the new requirements.

From a regulatory perspective, failing to meet the new legal duties (particularly under Awaab’s Law) may lead to enforcement notices, regulatory downgrades, and increased scrutiny. All of which could undermine investor confidence and organisational credibility.

Legally, providers could face increases in disrepair claims, health and safety prosecutions, or even judicial reviews if hazards such as damp and mould are not addressed within the required timescales.

Financially, the costs of non-compliance can escalate quickly. Landlords may incur fines of up to £40,000, be forced into reactive emergency works, and face rising contractor prices due to unplanned demand or delayed mobilisation. Complaints and compensation claims and reputational damage can add further pressure on budgets and reserves.

Reputationally, the risk is severe. Failing to meet tenant expectations — especially in light of public cases like Awaab Ishak — could result in sustained media scrutiny, loss of trust, and permanent reputational harm. Tenants, politicians, and regulators alike will expect proactive, transparent action.

In short, these risks cut across the entire governance framework — and leadership teams must act now to assess their exposure, strengthen assurance, and plan for safe, timely compliance.

Key Questions

Either way, if you are responsible for your assets, you will need to rethink:

How you manage quality control: Will your current inspections and supervision systems stand up to heightened scrutiny?

Whether your contracts are fit for purpose: Do existing responsive repair, cyclical programmes and major works contracts include enforceable expectations around issues like mould, heating, and thermal comfort?

Workforce capability and training: Do your teams, regardless as to if in-house or outsourced, understand how to identify and resolve damp, mould, disrepair, and safety hazards in line with Awaab’s Law and the new standard?

Pace and agility of delivery: Can your teams respond quickly enough to complaints, inspections, or enforcement notices under the tighter legal deadlines?

Supply chain and retrofit delivery: Are you ready for the scale and complexity of future works involving insulation, heating upgrades, or structural repair?

These challenges should trigger immediate debate and forward planning, and leadership teams may wish to reflect on the following prompts:

• What risks are we carrying now that may escalate under the new regime?
• Do our board or cabinet members have a clear line of sight on compliance gaps?
• Are we over-reliant on lifecycle data, or do we have live condition data to base decisions on?
• How do we ensure our technical teams focus on the condition of a property, instead of sometimes hiding behind remaining lifecycle to justify decisions?
• Are our repair and capital teams aligned – or operating in silos?
• What needs to change in our contractor relationships or internal governance to ensure consistent, high-quality outcomes?

From a governance and risk perspective, board and cabinet members will need to ask themselves:

• How many of our homes would fail the new DHS if assessed today?
• Are our repair and investment programmes driven by condition or component age?
• Can our contractors or internal teams spot and resolve DHS risks confidently?
• Do our contracts include KPIs for issues like mould, floor coverings, and heating controls?
• Are we confident in how we would respond to new enforcement powers?
• How will we fund and schedule DHS compliance across a 10-year horizon?

This Is More Than Compliance

This is about leadership. The new Decent Homes Standard will define your organisation’s ability to:

• Protect tenants from harm
• Deliver trust and transparency
• Sustain asset value
• Avoid reputational risk

Now is the time to take stock. To act early. To influence the conversation.

Your Feedback Is Important

By feeding into the consultation before 10 September 2025, you can help shape a system that works for both residents and providers. You might want to consider providing Government with your own thoughts on:

• How to assess what’s “in poor condition”
• Support available for tackling damp and mould
• The need for time, funding and capacity for retrofitting homes
• Clarification of expectations for safety and security measures
• Achieving fair and consistent enforcement via councils
• Implementation and phasing of the standard in practice
• The need for simple reporting tools to help with record-keeping and monitoring
• How to manage tenant refusals or complex needs to avoid penalising landlords trying to do the right thing

How ARK can help

Strategic Asset Management: We help you move from lifecycle-based planning to condition-based, risk-prioritised strategies that align with the new DHS. Whether you need an updated Asset Management Strategy, decency investment forecast, or board-level decency risk assessment.

Operational Readiness and Delivery: We work with both in-house teams and contracted services to develop pragmatic delivery models, clear repair and inspection workflows, and targeted operational improvements. We can determine your current state, assess skills and capability, and help you redesign services to be DHS-compliant.

Retrofit and Thermal Comfort: Our energy and retrofit experts work with landlords to deliver costed, funded, and achievable pathways to meet MEES and thermal comfort standards. From SHDF bids to EPC modelling, PAS 2035 readiness and supply chain mobilisation, we bring end-to-end capability.

Resident Engagement and Consultation: Tenants are at the heart of the new standard. We facilitate resident feedback, deliver co-design workshops, and ensure tenant voices shape decisions. We also help landlords manage access challenges and embed clear, accessible communications.

Compliance and Board Assurance: We help you turn regulation into action. From compliance reviews to internal audits, governance reports to regulator preparation, ARK helps you build confidence in your DHS response from the boardroom or council chamber to the frontline.

Whatever stage you’re at – strategy, mobilisation, recovery or response – ARK can help you.