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Decent Homes Standard: Government urged to avoid ‘new layers of legislation’ – London Wallet

Mark Helprin by Mark Helprin
September 12, 2025
in Real Estate
Decent Homes Standard: Government urged to avoid ‘new layers of legislation’ – London Wallet
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Isobel Thomson

safeagent, the UK’s largest not-for-profit accreditation scheme for lettings and management agents, has submitted a comprehensive and constructive response to the government’s consultation on the Decent Homes Standard, which closed on 10 September.

In its submission, safeagent emphasises its commitment to collaborating with government to shape a Decent Homes Standard that is both practical and effective. The organisation advocates for a framework that promotes continuous improvement across the private rented sector (PRS), ensuring standards rise without placing undue burden on responsible agents and landlords.

safeagent’s response highlights the importance of creating a standard that is not only fit for purpose, but also capable of supporting long-term quality and professionalism within the sector.

Isobel Thomson, chief executive of safeagent, commented: “We fully support the principle that all rented homes should provide tenants with safe, warm and decent accommodation.

“While many of the building blocks are already in place, such as the Housing Health and Safety Rating System (HHSRS) and the Minimum Energy Efficiency Standards MEES) – which are both being updated – we urge the Government to publish the HHSRS Review that completed in 2022. This will bring clarity and certainty for the lettings industry about what these changes mean on a practical level.

“The way to drive up decent homes compliance in the private rented sector is not new layers of regulation. The key issue is under-resourcing of local authority housing enforcement and trading standards teams that are tasked with tackling the worst and most prolific offenders. Unless we succeed in tackling under-resourcing, a new Decent Homes Standard could have minimal impact.”

As part of its response, safeagent also encourages government to rethink the overly complex and disjointed nature of DHS Criterion C (facilities, etc) which has led to some oddities. For example, under the proposals every private rented house must be fitted with adequate external noise insulation, but the same does not apply to every private rented flat, and with no indication of how adequacy would be assessed.

Regarding the scourge of damp and mould, while it is entirely right to place a spotlight on this following the tragic death of Awaab Ishak, safeagent questions whether the government has got the regulatory balance right.

Any damp and mould issue can already be enforced under HHSRS, while any disrepair to the structure of the building or deficiencies with the heating and ventilation will be captured by DHS Criterion B.

With the Homes (Fitness for Human Habitation) Act 2018 and Awaab’s Law soon to be rolled out to the PRS, safeagent sees no need to add another layer of damp and mould regulation under proposed DHS Criterion E. This would impose another discretionary power for councils to intervene, duplicating the HHRS and adding no meaningful value.

Likewise, safeagent sees no need to develop a new home security standard for the private rented sector as every property is different, making an appropriate common standard difficult to achieve.

Thomson added: “Overall, there’s a pressing need to simplify and streamline the housing regulatory model, which will benefit all interested parties including landlords, agents, tenants and local authority enforcement officers.”





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