Submission: Response to the consultation on reformed decent homes standards
11 September 2025
Since 2019, our built environment programme has worked on issues relating to land and housing, identifying key issues and showcasing innovations and opportunities to advance human rights in these areas.
January 2025 saw the launch of our Built Environment Just Transitions Accelerator (BEJTA) in the U.K. Through engagement with front-running businesses, civil society organisations and policymakers, the Accelerator's focus is on advancing practice, shaping policy and strengthening accountability to protect construction workers’ rights and adequate housing rights as we urgently decarbonise to meet critical net zero targets.
Response
We welcome the government’s proposals to reform the Decent Homes Standard (DHS), particularly:
- The extension of the standard to the private rented sector;
- The updated criteria on damp and mould, energy efficiency, and thermal comfort; and
- The ambition to improve safety, comfort, and health in rented homes.
We encourage the government to frame the reformed DHS around the internationally recognised right to adequate housing, defined by seven elements:
- Security of tenure
- Availability of services, materials, and infrastructure
- Affordability
- Habitability
- Accessibility
- Location
- Cultural adequacy
This universally agreed definition, drawn from international law, provides clarity, avoids ambiguity, and offers alignment with existing commitments. Importantly, it enables alignment with international frameworks such as the UN Guiding Principles on Business and Human Rights (UNGPs), which apply to both state and non-state actors. The three UNGP pillars – Protect, Respect, and Remedy – offer a ready-made framework for accountability and enforcement of the DHS.
Key Issues
- Overheating Risks
- Nearly half of the poorest fifth of households, particularly social renters in urban areas such as London, live in homes at risk of overheating.
- Overheating increases health risks (cardiovascular and respiratory) and has caused numerous home-based deaths during heatwaves.
- Design and Habitability Deficits
- Many homes suffer from poor ventilation, inadequate shading, and urban heat island effects, resulting in internal temperatures of 27–35 °C.
- Current regulations focus disproportionately on winter heating rather than summer cooling.
- Equity and Vulnerable Groups
- Ethnic minority and deprived communities are disproportionately exposed to environmental risks, poor housing quality, and inadequate thermal comfort.
- Retrofits and resilience measures must prioritise these communities to uphold the right to adequate housing.
- Potential Supply and Affordability Impacts
- The introduction of these standards could inadvertently reduce the stock of affordable rental units. Financial support (preferably low-interest loans), impact assessments and ongoing monitoring are recommended to mitigate this risk.
- Enforcement and Grievances
- Effective enforcement is crucial, particularly regarding poor conditions.
- Consider clear grievance mechanisms, adequate resources for local authorities, and accountability aligned with rights-holder protections in the UNGPs.
Recommendations
We propose the following recommendations:
1. Frame the DHS in Human Rights Standards
- Explicitly ground the reformed DHS in the seven elements of adequate housing.
- Reference the UNGPs in enforcement provisions, ensuring landlords – particularly those registered as businesses – are held accountable to “Respect” and tenants have access to remedy”
2. Strengthen Habitability: Cooling, Ventilation, Internal Insulation, Lighting, and Space
- Integrate passive cooling and ventilation
- Require cross-ventilation design in new builds.
- Retrofit: support decentralised ventilation (dMVHR), trickle vents, or passive upgrades.
- Mandate external shading (shutters, brise-soleil) and reflective surface materials.
- Where possible, integrate nature-based solutions, such as green roofs and walls for climate resilience and biodiversity net gain.
- Improve acoustic comfort
- In addition to external noise insulation, integrate internal noise insulation measures, particularly in multi-unit dwellings or flats, to reduce sound transmission between rooms or units.
- Support retrofit solutions where feasible, e.g., soundproofing walls, ceilings, or floors, especially in high-density or mixed-use areas.
- Enhance spatial quality
- Consider guidance on minimum room proportions and ceiling heights to reduce overcrowding, particularly for new builds.
- Encourage reconfiguration, extensions, and efficient built-in furniture solutions as part of retrofit best practice.
- Improve daylight and lighting resilience
- Explore guidance on daylight provision standards (e.g., daylight factor or window-to-floor ratio).
- Encourage reflective finishes, mirrors, and light-coloured interiors.
- Promote upgrades to layered LED and smart lighting controls.
- Note: While feasibility varies, these measures can be implemented in both retrofits and new builds, advancing habitability, accessibility, and cultural adequacy.
3. Address Affordability and Avoid Regressive Impacts
- The government should assess, monitor and publicly report on the impact of DHS changes on housing supply, affordability, and tenant costs.
- Provide financial support – particularly low-cost loans – to landlords unable to meet standards, to avoid loss of affordable stock or risk-shifting to tenants.
- Couple with rent regulation to prevent improvements to minimum standards resulting in unaffordable rent increases for private tenants
4. Climate Adaptation Guidance
- Publish best-practice guidance on housing adaptation to climate change, including heat resilience, flood risk management, and green space provision.
- Extend insulation requirements to include internal insulation options where external insulation is not viable.
5. Facilities and Standards Thresholds
- A “decent” dwelling must provide all four core facilities (not just three). Allowing choice risks undermining habitability.
6. Enforcement, Grievance, and Tenant Protection
- Establish clear grievance mechanisms for private sector tenants to report DHS non-compliance by landlords, including considering an ombudsman.
- Provide additional resources for local authorities to adequately handle the volume of cases from rights-holders.
- On exemptions and tenant refusal: these must only be permitted if introduced alongside the abolition of Section 21 “no fault” evictions, to prevent ‘renovictions’.
- With regard to the proposal “to support effective enforcement, we will use secondary legislation to increase the maximum fine level for non-compliance with enforcement action from £30,000 to £40,000”, we would like clarity on where these fines will be directed. Specifically, will the revenue be retained by local authorities to strengthen their enforcement capacity, will it flow into central government budgets, or will some of it be directed to the right-holders (i.e. tenants)?
7. Demolition and Redevelopment Safeguards
- Guard against misuse of demolition and redevelopment exemptions. These can undermine both carbon budgets and tenant security, and risk incentivising displacement.
8. Phased Implementation and Best Practice Guidance
- Support phased adoption, prioritising high-risk areas first – whether from cold-related risks (e.g. poorly insulated rural or northern housing) or overheating (e.g. urban heat islands, densely populated neighbourhoods).
- Phasing should be based on evidence of vulnerability, including income levels, existing health inequalities, and housing conditions.
- Align timelines with 2035/2037 targets but incentivise early adoption, particularly for the less onerous elements of the standards.
- The government should co-develop best practice guidance with civil society and industry; IHRB/BEJTA would welcome the opportunity to contribute expertise.
Additional Proposals
We endorse a) a proposal to introduce best practice guidance to sit alongside the DHS, including information to landlords on some of the ways in which they could choose to go further than the minimum standard set by the DHS. It aligns really well with the work of the Accelerator, and we'd be happy to meet MHCLG (or for you to attend a BEJTA convening), or feed into the guidance.
Conclusion
The reform of the DHS is a critical opportunity to align housing policy with the UK’s human rights obligations and climate goals. By grounding the DHS in the right to adequate housing and strengthening standards for habitability, affordability, and accountability, the government can protect health, reduce inequalities, and future-proof homes against climate risks.
We strongly support the extension of the DHS to the private rented sector, welcome its updated focus on safety, damp and mould, and thermal comfort, and encourage the government to go further by embedding rights-based standards, robust enforcement, and clear guidance for climate adaptation.
These steps will protect the health and dignity of tenants, particularly the most vulnerable, while supporting a just transition that future-proofs homes – existing and new build – against climate risks and upholds everyone’s human rights.
