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BETTESWORTHConstruction

Decent Homes Standard 2035: a joined-up delivery plan for landlords and contractors

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The reformed Decent Homes Standard (DHS) is a ten-year delivery programme, not a deadline-day refurbishment. It will apply across England’s social and private rented homes from 2035, while energy-efficiency milestones arrive in 2030 and 2039. Landlords that start with reliable stock data, resident involvement, safety and damp-and-mould controls, planned repairs, retrofit capacity and documented assurance can spread cost and disruption. Those that wait risk concentrated failures, contractor bottlenecks and enforcement action.

The January 2026 government response says 21% of private rented homes and 10% of social rented homes failed the existing standard on 2023 data. The revised model is more demanding: it initially estimates 45% of social rented homes and 48% of private rented homes would fail. This article explains what changes, which dates matter, and how a construction-led programme can turn the decade into a controlled sequence of work.

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What is the new Decent Homes Standard?

The new DHS is a cross-tenure baseline for rented housing. It replaces a narrow stock-management test with five outcomes: homes must be safe, in reasonable repair, equipped with core facilities, thermally comfortable and free from unresolved damp and mould. The policy applies to both the social rented sector (SRS) and private rented sector (PRS), so the broad quality expectation is the same even though enforcement routes differ.

The government policy statement sets out the criteria below. Detailed implementation guidance and some regulations were still forthcoming, so landlords should treat their asset plans as living documents and refresh them when transition rules are published.

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Criterion What compliance means Construction and maintenance implications
A: safety No Category 1 hazards under the Housing Health and Safety Rating System (HHSRS). Risk-based surveys, urgent make-safe work and evidence that hazards were closed, not merely logged.
B: repair No key building component, or two or more other components, requires replacement or immediate major repair. Component-level condition data, lifecycle planning and programmes for roofs, structure, heating, windows, lifts and mechanical ventilation.
C: facilities and services Flats provide at least three listed facilities; houses at least two. Requirements include an adequately laid-out kitchen, appropriately located bathroom/WC, adequate external noise insulation and, for flats, adequate common entrance areas. Windows presenting a child-fall risk need child-resistant restrictors that an adult can override. Coordinate internal fit-out, common parts, access and window safety; specify products for the actual window type and opening geometry.
D: thermal comfort Reasonable thermal comfort and compliance with applicable Minimum Energy Efficiency Standards (MEES). Sequence fabric, heating, controls and ventilation upgrades around earlier EPC milestones; avoid retrofit measures that worsen condensation.
E: damp and mould Landlords must remedy damp and mould so the home is not non-decent on this criterion. Diagnose moisture sources, repair building defects, provide effective ventilation and record post-work resolution rather than applying cosmetic treatment alone.

The repair test no longer treats a component’s age as an automatic failure. Condition is what matters. The expanded component list brings lifts and mechanical ventilation into the assessment, reflecting accessibility, safety and damp-and-mould risks.

When does the Decent Homes Standard come into force?

The reformed DHS is scheduled to apply from 2035 in both rented sectors. That date is the end of the implementation runway, not permission to defer investment. The government intends landlords to plan alongside Awaab’s Law, Renters’ Rights Act reforms, MEES obligations and social-home supply.

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Energy rules arrive first:

  • 1 April 2030 (social housing): each home must meet EPC C or an equivalent result on one EPC metric, subject to exemptions.
  • 1 October 2030 (private rented housing): homes must meet the dual-metric EPC C-equivalent requirement, with a £10,000 cost cap and specified exemption routes.
  • 1 April 2039 (social housing): a second EPC metric must meet the C-equivalent level, subject to exemptions.
  • 1 April 2035: the Regulator of Social Housing (RSH) is directed to require compliance with the new DHS.

Social landlords remain bound by current repair, fitness-for-habitation and existing DHS duties before 2035. In the PRS, local authorities will enforce the new requirements through housing legislation and regulations made under the Renters’ Rights Act. A programme that only targets 2035 can therefore miss earlier legal exposure.

What are the five Decent Homes Standard criteria in practice?

1. Category 1 hazards

Category 1 HHSRS hazards are the fastest-moving risk. The policy response notes that about 10% of PRS properties currently contain one and says landlords must not wait for 2035. Establish a triage route that escalates serious hazards immediately, records the interim control, assigns an owner and verifies completion.

For contractors, the brief should identify the hazard mechanism, affected occupants, access constraints and the permanent remedy. A temporary repair can protect a resident while a larger structural or services project is designed, but it should not be recorded as a closed risk without a follow-up inspection.

2. Repair and component condition

Use a component schedule rather than a single property score. Capture roofs, walls, windows, doors, heating, electrical systems, lifts, common areas and mechanical ventilation, with condition grade, failure consequence, remaining life, estimated intervention and evidence date. Prioritise defects that can create a Category 1 hazard, cause water ingress or disable heating and ventilation.

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Because age is no longer an automatic fail, replacement should be justified by condition, performance and risk. That can prevent unnecessary wholesale renewal, while making poor records harder to defend. Photographs, survey reports, completion certificates and resident-reported defects should be connected to the asset record.

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3. Facilities, access and window safety

Check the required facilities in context: layout and location matter, not just presence. In blocks, common entrance areas are part of the test. For windows with a child fall risk, specify child-resistant window restrictors with adult override where required. Suitability depends on window type, opening size, guarding height and safe installation; a generic product listing is not evidence of compliance.

4. Thermal comfort and energy

MEES and DHS should be designed as one retrofit pathway. Start with fabric condition and moisture risk, then select insulation, airtightness, heating, controls and ventilation as a system. Record the EPC metric used, the baseline, the measure installed, any exemption and the date of reassessment. A measure that lowers heat loss but blocks ventilation can increase mould risk, so design reviews need both energy and building-physics input.

5. Damp and mould

Resolution means finding and correcting the cause: leaks, penetrating or rising damp, cold bridging, failed gutters, plumbing defects, inadequate extraction or occupant-impacting ventilation problems. Cleaning and repainting may be part of reinstatement, but they are not a root-cause remedy. Give residents a clear reporting channel, protect belongings during works, inspect after completion and retain evidence that the problem has not recurred.

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How should landlords build a decade-long delivery programme?

A joined-up plan links six workstreams. Each should have a named accountable lead, a budget profile, measurable outputs and a resident-impact plan.

  1. Build stock intelligence. Reconcile addresses, tenure, component records, hazards, EPC data, repairs history and planned works. Segment failures by component, geography, building type and household vulnerability. Flag missing surveys as uncertainty rather than assuming compliance.
  2. Involve tenants early. Social landlords should give tenants meaningful opportunities to influence and scrutinise investment plans, with fair outcomes across neighbourhoods. Explain sequencing, access arrangements, decant needs, likely disruption and the route for challenging a decision.
  3. Run a safety-and-repairs queue. Separate emergency Category 1 work from planned component renewal. Protect roofs, structure, heating, windows, lifts and ventilation where failure can create wider harm. Keep current legal repairs flowing while capital projects are developed.
  4. Integrate damp, mould and ventilation. Use a diagnostic inspection, moisture readings where appropriate, defect repair, ventilation commissioning and a post-work review. Track recurrence and response times, not just the number of treatments completed.
  5. Sequence energy upgrades. Map every home against the 2030 social and PRS milestones and the 2039 second social metric. Bundle fabric, heating, controls and ventilation where access and scaffolding can be shared, but do not force a measure that creates a health or moisture risk.
  6. Secure capacity and finance. Convert the stock model into annual work volumes, procurement lots, labour requirements, resident-support costs and contingency. Test whether local contractors, specialist surveyors, designers and building-control capacity can deliver the peak years.

Use stage gates: verified data, options appraisal, resident engagement, design sign-off, procurement, site quality checks, commissioning and outcome verification. A dashboard should show homes passing each criterion, open hazards, damp cases, overdue repairs, EPC progress, exemptions and evidence completeness.

How large is the challenge and what might it cost?

The MHCLG and Building Research Establishment modelling estimates that applying the revised DHS to 2023 stock would initially leave 45% of SRS homes and 48% of PRS homes failing. The modelled gross cost to make homes decent is £11.3 billion in the SRS and £26.5 billion in the PRS. The estimated amount above existing obligations is £1.8 billion and £5.4 billion respectively.

These are modelling outputs, not an invoice arriving in one year. They combine assumptions about stock condition, interventions and prices. The useful management distinction is between work landlords already owe under existing law and incremental work created by the reformed standard. That distinction supports realistic budgets, grant bids and rent-impact decisions.

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The wider investment context includes a £39 billion 2026–2036 Social and Affordable Homes Programme, an ambition for around 300,000 social and affordable homes and a target for at least 60% of programme homes to be for Social Rent. New supply, decarbonisation and existing-stock compliance compete for people, materials and capital, so portfolio sequencing matters.

What is different for social landlords and private landlords?

Social landlords operate under RSH consumer standards, proactive inspections, evidence requirements and assurance expectations. They must understand the condition of their homes, maintain them to the required standard and take reasonable steps to protect tenant health and safety. Residents can complain to their landlord and escalate unresolved complaints to the Housing Ombudsman.

Private landlords face local-authority enforcement. Councils may inspect after a complaint or another trigger and require remedial work. Existing Housing Act duties already cover Category 1 hazards; the Renters’ Rights Act provides the wider route for DHS requirements. Private landlords should therefore keep a defensible evidence pack even where no inspection has yet occurred.

In both sectors, keep records of surveys, decisions, exemptions, notices, contractor competence, completion checks and resident outcomes. “Work ordered” is not the same as “standard met.”

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How do supported housing, temporary accommodation and mixed-tenure blocks fit?

The DHS covers supported housing and temporary accommodation, but the government recognises that a requirement may conflict with a scheme’s purpose or a documented resident need. Additional guidance is promised, and broad blanket exemptions are not planned. Record the specific need, the assessment, the alternative control and the review date.

Mixed-tenure blocks and rented leasehold homes need an early responsibility map. External walls, roofs, lifts and common parts may be controlled by a freeholder or another party. Identify who can authorise access, fund the work, serve notices and provide evidence; then build those dependencies into the programme rather than discovering them after a failure.

What should a contractor-ready DHS evidence pack contain?

For each home or block, assemble:

  • a current stock and component record with survey dates and confidence levels;
  • HHSRS assessments and closure evidence for Category 1 hazards;
  • repair orders, photographs, specifications, certificates and post-completion inspections;
  • facility and accessibility checks, including window-restrictor specifications where relevant;
  • EPCs, retrofit designs, commissioning records, ventilation checks and recorded exemptions;
  • damp-and-mould investigations showing cause, remedy, drying or reinstatement and follow-up outcome;
  • resident communications, access attempts, decant or safeguarding arrangements and complaints;
  • procurement, competence, quality-assurance and health-and-safety records.

Use consistent status definitions such as “surveyed,” “failure confirmed,” “remedy designed,” “in delivery,” “completed—awaiting verification” and “compliant with evidence.” This prevents a dashboard from overstating progress.

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What can go wrong, and how can the programme recover?

Inaccurate stock data: sample-check records against current surveys and repairs history; quarantine homes with missing evidence and budget for validation.

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Cosmetic damp treatment: reopen cases where mould returns, investigate moisture and ventilation, and require a post-work inspection.

Retrofit that creates condensation: pause the affected design, review ventilation and thermal bridges, and commission the installation before reinstatement.

Contractor capacity collapse: phase tenders, pre-qualify specialist trades, use realistic productivity assumptions and avoid concentrating every project in the same year.

Resident access failure: offer appointment choices, interpreters or support where needed, document attempts and coordinate multiple works in one visit.

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Unclear block responsibility: escalate the freeholder or leaseholder interface early, obtain written consents and maintain a risk register for dependencies.

Waiting for final guidance: comply with current legal duties now, design to the published five criteria, and schedule a formal policy refresh when transition mechanisms and detailed regulations are issued.

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How will compliance be enforced and demonstrated?

The policy approach is staged: urgent safety action now, planned investment through the decade and formal DHS compliance from 2035. Social providers should expect regulator scrutiny of outcomes and assurance, not just policy statements. Private landlords should assume that a complaint, inspection or hazard report can require rapid evidence and remedial action.

Set board or senior-management reporting around resident risk and verified outcomes: open Category 1 hazards, unresolved damp, homes without reliable condition data, overdue statutory repairs, EPC milestone exposure, expenditure against plan and repeat failures. That is the information needed to decide whether to repair, renew, retrofit, acquire, dispose or seek an exemption.

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The central construction lesson is sequencing. A roof replacement, ventilation upgrade, window-safety measure and insulation project can be cheaper and less disruptive when designed together, but only if the underlying defect and resident needs are understood first. A decade is long enough to plan well; it is not long enough to postpone every difficult building.

Frequently Asked Questions

Will every rented home need an EPC rating of C by 2035?

No. The DHS includes thermal comfort and applicable MEES requirements, but the energy deadlines are staged and use EPC C-equivalent metrics. Social housing has a first metric by 1 April 2030 and a second by 1 April 2039; private rented homes have a dual-metric requirement by 1 October 2030, with exemptions described in the policy.

Can a landlord claim a blanket exemption for supported housing?

No. The government does not plan broad blanket exemptions. A rare exception may be considered where a documented resident need or the purpose of a scheme conflicts with a specific requirement, supported by forthcoming guidance and evidence.

What should tenants do if damp and mould keeps returning?

Report recurrence in writing, keep copies of photographs and dates, and ask for the cause investigation rather than another surface clean. Social tenants can use their landlord’s complaints process and escalate unresolved cases to the Housing Ombudsman; private tenants can contact their local authority.

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Does replacing an old component automatically make a home compliant?

Not necessarily. The revised repair test focuses on condition and immediate major-repair need, while other criteria cover safety, facilities, thermal comfort and damp and mould. Completion evidence and an outcome check are needed to show that the relevant failure was actually resolved.

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