The Path Ahead for Social Housing

Social housing providers face a rapidly evolving regulatory and policy landscape. Two ongoing consultations—the Consultation on a Reformed Decent Homes Standard for Social and Privately Rented Homes and the Consultation on Minimum Energy Efficiency Standards in the Social Rented Sector in England—together with the draft guidance on Awaab’s Law all highlight the government ’s drive to ensure safe, healthy, and energy-efficient homes. In tandem, the Consultation Outcome on Reforming the Right to Buy might also influence how providers choose to invest in and retain refurbished properties.

Below, we set out what each of these consultations entails, why they matter, and how social landlords can respond if the new measures are implemented.

Consultation on a Reformed Decent Homes Standard

The reformed Decent Homes Standard (DHS) consultation (open until 10th September 2025) aims to update the DHS which currently applies to social housing and proposes raising the quality bar for both social and private rented housing.

Key updates include:

• Stricter Requirements on Condition: Moving beyond “age-based” rules for building components such as kitchens/ bathrooms, with a heightened emphasis on condition, structural integrity, thermal comfort, fire safety and damp/mould prevention.
• Aligning with Modern Living: Recognising the link between energy efficiency and health. Properties won’t be considered “decent” if they are prone to damp/mould or deliver poor energy performance.

For social landlords, these proposals suggest an obligation to proactively identify properties in disrepair and upgrade them. As the DHS might dovetail with other energy-focused standards, providers who carefully align investment plans with these broader reforms will see cost efficiencies and reduce future regulatory risks.

Consultation on Minimum Energy Efficiency Standards (MEES) in the Social Rented Sector

Running in parallel, the government is exploring introducing MEES in the Social Rented Sector for the first time (open until 10th September 2025), summarised as requiring an Energy Performance Certificate (EPC) Band C by around 2030.

Key points include:

• DHS: MEES will be included in the thermal comfort proposals in the revised DHS (see above).
• Preferred Target, Not Guaranteed: While 2030 features in the consultation, it remains an indicative date and may change in response to consultation feedback.
• Balancing Costs with Carbon Goals: A proposed per-property spend exemption limit is being considered, acknowledging that some upgrades may prove costly or technically challenging thereby warranting further time for a provider to meet their new obligations.

Registered providers must therefore prepare for enhanced measures around better insulation, modern heating technology, and overall greener housing stock. These improvements—when done right—can also help prevent damp and mould issues and lower tenants’ bills.

Awaab’s Law: Draft Guidance for Social Landlords

Awaab’s Law, named after Awaab Ishak, responds to tragic circumstances in which poor housing conditions contributed to a child’s death from prolonged mould exposure. This will come into force for the social rented sector from 27 October 2025 with further measures to follow. The draft guidance relates to the first phase of the new requirements and is designed to help affordable housing providers understand Awaab’s Law and to ensure compliance.

Core propositions include:

• Enforceable Deadlines: Landlords must rapidly investigate and address damp or mould problems, with potential strict timeframes—even as little as a day if hazards are severe.
• Zero Tolerance for Persistent Disrepair: Recurring complaints about mould or damp will carry heavier scrutiny, placing providers at higher legal, enforcement and reputational risk if they fail to act quickly.

The synergy with a reformed DHS (which also spotlights damp prevention) and tighter energy standards is clear: proactive property care (including improved insulation and ventilation) can simultaneously reduce fuel poverty and create healthier living environments.

Consultation Outcome on Reforming the Right to Buy

Although energy performance and property condition are this article’s main themes, the Consultation Outcome on Reforming the Right to Buy and any related legislation brought forward by the government might subtly shape landlords’ decisions over upgrading or retaining stock.

For instance:

• Protecting Major Upgrades: reforms to “cost-floor” rules or exemption periods may apply to newly built or refurbished homes, which can help ensure providers recoup investment in costly retrofit works.
• Longer-Term Ownership: Retaining ownership of upgraded homes for an extended period can reduce financial risk and incentivise further improvements.

While not primarily about repairs or energy efficiency, right to buy policy might still influence providers’ strategic decisions regarding both routine maintenance and major capital projects.

TLT's opinion 

By tightening expectations around property condition, energy performance, and tenant safety, the government appears to understand the vital role social housing plays in broader health, climate, and housing goals.

Although Awaab’s Law is framed by draft guidance rather than a live consultation, it shares a common purpose with the evolving DHS and likely MEES obligations: better homes and healthier tenants. Social housing providers are already working towards these goals and must be prepared for what is ahead.

Smart planning for capital works, robust complaint-handling procedures, and strategic portfolio management (including properties potentially subject to right to buy) will help sector providers stay on top of these changes. Taking proactive steps now, social landlords can avoid duplicative works, reduce liabilities, and reaffirm their commitment to delivering safe, efficient, and genuinely decent homes.

If you would like further guidance or assistance in planning for these legislative and policy changes, please contact our Housing & Regeneration Team at TLT who can help ensure full preparedness for what lies ahead.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at July 2025. Specific advice should be sought for specific cases. For more information see our terms & conditions.