New Decent Homes Standard Faces Criticism Already

The government’s plans for a new Decent Homes Standard appear to have hit a problem with a critical report from an organisation known as the Regulatory Policy Committee. In this post we will look at what has happened and at what might happen next.

Background – the new Decent Homes Standard

The DHS is frequently criticised for being out of date. It has only been updated once since it was originally unveiled in 2000.

Last summer the Ministry of Housing, Communities and Local Government (MHCLG) launched a consultation on updating the DHS, to which all stakeholders were able to respond. Subsequently, in early 2026, they published the outcome and a policy statement outlining the proposed new standard.

You can read our article on what the consultation covered here: Briefing: Consultation on a New Decent Homes Standard

The new DHS is, of course, particularly significant in that it will be introduced in both the social sector and the PRS on equal terms. Current proposals suggest this will happen in 2035 and the current DHS will continue (in the social sector only) until then.

What is new about the new Decent Homes Standard?

The MHCLG have said that the principal aims of a new DHS are both to update the standard and also simplify it. However, it maintains the underlying principle of the original one in that it dictates whether a home meets an acceptable standard or not. The intention is also to improve housing standards by tackling the social costs and health issues attributable to poor housing. The MHCLG have also said that they want to provide landlords with clarity, certainty and time to plan compliance.

The proposed new DHS does not involve scrapping the old standard and introducing a new one. Rather, it is what might be called a substantial ‘tweak’.

Very briefly, the new DHS raises expectations of what a decent home should be. It retains the principle that a decent home must be free of category 1 serious hazards. It updates the components lists. It proposes DHS inspections should focus on condition and outcome rather than just age. It proposes a new approach to assessing core facilities, such as kitchens and bathrooms. It raises standards for thermal comfort and energy efficiency by way of integrating the Minimum Energy Efficiency Standards (MEES). Crucially it also puts a focus on damp and mould by establishing it as a criterion in its own right.

The MHCLG consider that more properties will fail to meet the new DHS as a result of its revision. (Estimated at 45% of social and 48% of PRS properties.)

The role of the Regulatory Policy Committee

As part of the process of introducing a new standard the proposals have been scrutinised by what is known as the Regulatory Policy Committee or RPC.

The RPC is an independent, although government funded, body. Their role is to assess the quality of evidence and analysis used in preparing new regulations to ensure they are sound. They also have a remit of reducing burdens on business and supporting economic growth.

The RPC published their findings in February. Their full report can be found here: RPC opinion: Decent Homes Standard impact assessment

Very importantly, this RPC report is not a review of or comment on the new DHS itself. Rather it is a report on the impact assessment that was undertaken as part of it.

What the RPC report says – not fit for purpose

The overall conclusion of the RPC is that the impact assessment underlying the new DHS is – in their words – not fit for purpose. (Although this does not apply to every aspect of it, as we will explain later.)

Key takeaways are that, while the assessment described the relevant issues and outlined some proposals, it did not adequately compare and contrast the different options – especially with regard to the PRS. The report also called into doubt some of the calculations regarding the costs versus benefits of the new standard.

The RPC recommended shortlisting of options should be done in line with standard procedures for impact assessments as set down in the official government Green Book.

Here is some additional background on their findings:

Rationale

When looking at the rationale behind the impact assessment the report says that this is fit for purpose, giving it what the RPC calls a green rating. However it said that the assessment lacks some detail and would benefit from ‘deeper treatment of tenant choice constraints, concealed defects, and enforcement gaps.’ It went on: ‘The department should add a theory of change.’

Identification of options

This is an area which the RPC gives a red rating to. That is, it is not fit for purpose. It means there are major concerns over the evidence and the analysis of it. These concerns must be addressed if the impact assessment is to be considered adequate.

The impact assessment sets out a number of options: Do nothing, regulatory options, non-regulatory options or some changes to the components of the DHS. The RPC report said that it did not adequately compare the pros and cons of the different options before drawing up a shortlist of the measures that could be taken.

It added that the impact assessment must show how SMART* objectives and critical success factors were used to filter the longlist into a viable shortlist before appraisal.

Interestingly, the assessment does recognise that many PRS landlords are small or micro businesses (the so-called SaMBA) and these may be disproportionately affected by the new standard.

(* A goal-setting tool – specific, measurable, achievable, relevant, time-bound.)

Justification for preferred way forward

This is another area where the RPC say that the impact assessment is not fit for purpose.

The report said that while switching analysis and quantified estimates are provided for a single preferred option these are not contrasted with alternative options. It said that as a result the impact assessment cannot effectively show that it outperforms alternatives for cost effectiveness, compliance, risks or sequencing.

The report recommended the MHCLG must justify its preferred option – the extension of the DHS into the PRS – with a shortlist appraisal process.

Regulatory scorecard

The RPC decided that this aspect of the impact assessment was satisfactory. It provides adequate support for decision making.

It approved of the modelling which compared the costs of the proposed new measures with the benefits of them. However it pointed out that it is not clear whether the unquantified benefits (like health outcomes) have been scaled. It also said that there were difficulties in apportioning costs and benefits to an updated DHS, or to other measures, which would make it hard to assess cost effectiveness. It added that the assessment should identify likely administrative costs to local authorities and landlords more clearly.

Monitoring and evaluation

The RPC says this aspect of the impact assessment is weak and provides inadequate support for decision making.

They said that although the assessment used local authority enforcement data and housing quality monitoring processes it needed more specifics on metrics, ownership, timing and data flows. It advised that the MHCLG should add evaluation questions for local authorities and take on board their feedback.

Conclusions – what happens next

At this stage, and although they have had something of a ‘slap on the wrist’, critics should perhaps not be too harsh on the MHCLG. Updating a 25 year old standard which was designed only for the social sector and extending it to the PRS is no mean feat.

A major criticism of the new DHS – from some politicians and tenants’ rights campaigners particularly – is that it will not come into force quickly enough. ‘Why should tenants have to wait so long for a decent home’ is an often-heard remark. This report from the RPC might help to show them that changing and improving housing standards is not that easy. It cannot be done in a few months or even years. Time needs to be taken to get things right.

It’s important to note that the RPC report does not mean that the proposals to reform the DHS are wrong – or that they will not go ahead broadly in the form proposed. It simply means that the impact assessment was not grounded on sound enough principals.

In strict terms the MHCLG do not have to do anything as a result of this report. Although that would mean the ‘not fit for purpose’ tag would undermine the new standard. It is likely, therefore, that they will revisit and modify their impact assessment. Will this lead to some changes to the new Decent Homes Standard too? Time will tell.

In the meantime everyone in the sector from local authorities, housing enforcement and landlords should keep an eye on what is happening. Although it may still be some time away a new Decent Homes Standard is coming – and we now have a broad idea of what it will be like – but nothing is set in stone yet.