Decent Homes Standard for Private Rentals: Council Preparation Guide

The Decent Homes Standard has applied to social housing since 2000, requiring properties to meet four criteria: freedom from Category 1 hazards under the HHSRS; reasonable repair; reasonably modern facilities and services; and reasonable thermal comfort. The Renters' Rights Act 2025 extends this standard to the private rented sector for the first time, meaning all 4.6 million PRS households in England will eventually need to meet the same baseline. This is a transformative change. While the Housing Act 2004 already allowed councils to enforce against Category 1 hazards via the HHSRS, the Decent Homes Standard adds requirements around repair, facilities, and thermal comfort that go beyond hazard-based enforcement. Detailed implementation timelines and secondary legislation are expected in 2026, with enforcement anticipated from 2027.

Criterion A requires the property to be free from any Category 1 hazard as assessed under the HHSRS. This is already enforceable under the Housing Act 2004, so councils have existing powers and experience here. Criterion B requires the property to be in a reasonable state of repair, meaning key building components (roof, walls, windows, heating, plumbing) should not be old and in poor condition. Criterion C requires reasonably modern facilities, including a kitchen installed within the last 20 years, a bathroom within the last 30 years, and adequate insulation. Criterion D requires a reasonable degree of thermal comfort, which in practice means an efficient heating system and effective insulation. For the PRS, the thermal comfort criterion aligns with the existing minimum EPC E rating requirement, though the government may set a higher bar through secondary legislation.

Extending the Decent Homes Standard to 4.6 million properties will require a significant increase in inspection capacity across local authorities. Most councils currently operate with 3 to 5 enforcement officers responsible for 10,000 or more PRS properties. Inspecting even a fraction of the PRS stock for Decent Homes compliance will require more staff, better training, or more efficient inspection methods. Options include: recruiting additional qualified HHSRS inspectors; training existing environmental health officers in the specific requirements of the Decent Homes criteria; using risk-based targeting to prioritise inspections (older properties, lower EPC ratings, areas with higher complaint rates); leveraging PRS Database data to pre-screen properties likely to fail; and using desktop assessments where possible before committing to a full site visit. The £18.2 million enforcement funding for 2025/26 can be used to begin building this capacity now.

Enforcement of the Decent Homes Standard in the PRS will follow the existing framework of improvement notices and civil penalties. Where a property fails to meet the standard, councils will be able to serve an improvement notice requiring the landlord to carry out specified works within a set timescale. Failure to comply with the improvement notice will be an offence attracting civil penalties. The government has indicated that Decent Homes enforcement will align with the new penalty framework, with maximum fines of up to £7,000 for minor failures and £40,000 for serious or repeat breaches. Councils should update their enforcement policies to include the Decent Homes criteria, develop inspection checklists tailored to the four criteria, and establish clear escalation paths from initial identification through to penalty imposition.

Rather than attempting to inspect every PRS property, councils should use data to identify those most likely to fail the Decent Homes Standard. Key indicators include: EPC ratings of E or below (suggesting poor thermal comfort); properties built before 1919 (higher likelihood of disrepair and outdated facilities); properties with a history of HHSRS complaints or enforcement action; properties in areas with high deprivation indices; and landlords with previous compliance failures. Cross-referencing EPC data, council tax records, and the PRS Database will allow teams to create a risk-scored list of properties for targeted inspection. This approach maximises the impact of limited inspection resources by focusing on properties where the greatest improvements in living conditions can be achieved.

Tenants are often the first to identify properties that fail the Decent Homes Standard, but many do not know what standards their home should meet. Councils should develop tenant-facing communications explaining the Decent Homes criteria in plain English, with clear guidance on how to report concerns. Online reporting tools that allow tenants to describe issues and upload photographs can help triage complaints and identify potential Decent Homes failures before a physical inspection. Some councils have had success with targeted campaigns in areas with known concentrations of poor-quality PRS stock, using leaflet drops, social media, and partnerships with local advice agencies to reach tenants who might otherwise not report issues.