Decent Homes Standard in the Private Rented Sector: How Landlords Should Prepare for 2035

2035 is a planning horizon, not permission to postpone repairs. The government has

confirmed its policy that a reformed Decent Homes Standard will apply to private and social

rented homes in England from 2035. The detailed private-sector requirements still need to

be implemented through regulations. Meanwhile, existing repair, fitness and safety duties

remain enforceable.

For landlords, the commercial question is not simply whether a property will pass a future

assessment. It is whether the portfolio has a credible plan for maintaining safe homes,

funding renewal and avoiding preventable disruption. A roof, kitchen or heating system

does not wait for legislation before developing a fault.

The Decent Homes Standard in the private rented sector should therefore be treated as

an asset-management issue as well as a compliance issue. Condition records, realistic

budgets and well-timed works put owners in a stronger position than a last-minute

refurbishment programme.

The practical approach: resolve today’s safety issues, understand each property’s condition and build a funded improvement plan around the announced 2030 energy efficiency reforms and 2035 Decent Homes policy.

Decent Homes Standard deadlines: what is law and what is policy?

The Renters’ Rights Act 2025 is now the relevant reform legislation; it is no longer a Bill. Its

first major private-sector tenancy reforms took effect on 1 May 2026, including the abolition

of Section 21 within the new tenancy regime. The Act also provides the framework for

applying additional housing standards to qualifying premises in England. That framework

should not be confused with all five new Decent Homes criteria already being enforceable.

Requirement or milestone Position at 14 October 2026 What landlords should understand

Existing repairs, fitness and Already apply where the Serious defects cannot be left

housing-safety obligations relevant legislation covers until 2035.

the letting

Up to £7,000 for qualifying New power available from Statutory conditions and a

category 1 hazard cases 22 June 2026 formal penalty process apply.

Reformed HHSRS Applies to relevant inspections The framework now covers 21

commenced on or after 23 hazards and uses High, Medium

June 2026 and Low bands.

EPC C or equivalent for Confirmed policy for 1 October Plan for reform, but disting-

inscope private rented 2030, requiring implementing uish it from the current EPC E

homes legislation minimum and registered exemptions.

Reformed Decent Homes Confirmed policy for 2035 Check the final regulations and

Standard guidance rather than assuming

an exact private-sector commencement date.

Awaab’s Law in private Consultation opened on 9 Final requirements and

renting October 2026 commencement remain to be

determined.

These distinctions are based on the government’s policy statement, current statutory

provisions and published implementation guidance. England’s Decent Homes reforms

should not be described as a UK-wide landlord deadline. Housing law differs across the

devolved nations.

Reasonable repair: a broken handle is not automatically a failed home

The new repair test removes the requirement for a component to be both old and in poor

condition. Kitchens and bathrooms become key components, alongside the structure,

roof, windows, external doors, electrics and heating. The expanded list also includes

internal wall and ceiling finishes, internal doors, mechanical ventilation and relevant firesafety

systems where present. Decoration is not included in the internal plaster component.

However, it would be too broad to suggest that any broken cupboard or failed seal

automatically makes the whole home non-decent. Annex A describes kitchen failure in

terms of major repairs, or more than one specified item needing replacement, and requires

the components to be usable. Bathrooms have their own defined threshold. Assessment

must consider the actual defect and the applicable criterion.

That distinction supports proportionate investment. Repair what can be restored reliably.

Renew what has materially deteriorated. Do not use a future standard to justify replacing a serviceable kitchen, and do not use its age to excuse an unsafe one.

Core facilities: the scoring threshold is not a shortcut

For houses, the listed core facilities are an adequately sized and laid-out kitchen, an

appropriately located bathroom and WC, and adequate external noise insulation where

relevant. Flats have an additional common-entrance-area requirement. The new policy also

addresses child-resistant window restrictors that adults can override on windows

presenting a defined fall risk.

The two-of-three and three-of-four thresholds are assessment rules, not permission to

remove essential cooking or sanitary facilities. Separate fitness, safety, HMO and

contractual obligations still matter. Window-safety works should also be considered

alongside ventilation and the fire-safety arrangements, rather than installed without a

suitable assessment.

Damp and mould: deal with the cause, not the photograph

The separate damp and mould criterion is intended to address problems below the

category 1 threshold. Landlords should not wait until a defect becomes severe before

responding. The January policy statement used the former HHSRS lettered bands; the June

2026 reforms now use High, Medium and Low. Final implementation guidance should be

checked for how the new damp criterion is assessed under the revised framework.

A useful response involves recording the report, assessing urgency, investigating leaks,

moisture sources, ventilation and heating, then arranging suitable works and follow-up.

Cleaning or redecorating can form part of the response, but it is not a complete solution

where the underlying cause remains. Do not assume that tenant behaviour explains a

problem without investigating the property.

Decent Homes Standard fines: understand the current enforcement risk

Since 22 June 2026, councils have had a power to impose a financial penalty of up to

£7,000 in qualifying category 1 hazard cases. The statutory test includes whether it would

have been reasonably practicable for the responsible person to secure the hazard’s

removal. It is not an automatic charge for every defect or every complaint. The particular

section 6A penalty excludes the common parts of a building containing flats, although other

enforcement powers remain relevant.

The process includes a notice of intent, an opportunity to make representations, a final

notice and a right of appeal to the First-tier Tribunal. The representation period is 28 days beginning the day after the notice of intent is given. Calling this an informal “on-the-spot

fine” would conceal important safeguards.

For relevant housing offences, including failure to comply with an improvement notice, the

maximum civil penalty increased to £40,000 from 1 May 2026. A civil penalty can be used

as an alternative to prosecution for the same offence; it should not be described as the

maximum penalty a court could ever impose. The full future Decent Homes enforcement

arrangements must be read alongside the eventual regulations.

The management lesson is straightforward: keep evidence of inspections, reports, access

requests, decisions, works and follow-up. Good records support accountability, but they do

not replace effective repairs or guarantee protection against enforcement.

EPC C by 2030: plan for the policy without misstating today’s rules

Under current legislation, in-scope domestic private rented properties in England and

Wales generally need EPC E or above, unless a valid exemption is registered. The current

improvement-cost framework includes a £3,500 cap, including VAT, subject to its detailed

rules. EPC C is not today’s general legal minimum.

The government’s January 2026 response confirms a policy of EPC C or equivalent by 1

October 2030. It envisages a fabric-performance standard first, followed by either the

heating-system or smart-readiness metric. It also announces a £10,000 cost cap and a tenyear cost-cap exemption, subject to the implementing legislation.

The response includes a property-value-adjustment exemption for homes valued below

£100,000, based on 10% of value. It also provides for qualifying current EPC C-or-better

certificates issued before 1 October 2029 to be recognised until they expire or are replaced.

These are announced transitional and exemption arrangements, not automatic

permissions to ignore today’s duties.

The energy-efficiency cost cap is not a general cap on landlord repairs or Decent

Homes spending. A property may require roof repairs, electrical remedials or damp works

independently of the energy programme.

Sequence works around the building, not a single certificate

Consider weather-tightness, moisture, ventilation, insulation and heating together. For

older solid-wall homes, an unsuitable retrofit can create further problems. Obtain propertyspecific technical advice before committing to significant works, especially where planning, listed-building, leasehold or building-control requirements may affect the specification. An integrated programme can reduce duplicated access and making-good costs. It should not delay urgent remedials merely because another project is scheduled later.

Awaab’s Law, HMOs and supported accommodation: keep the regimes separate

Awaab’s Law is related to housing condition, but it is not the same as the Decent Homes

Standard. It focuses on processes and timescales for addressing specified hazards. Phase 1

has applied to relevant social housing tenancies since 27 October 2025. The government

states that Phase 2 will extend significant-hazard coverage from 30 November 2026.

For private renting, the consultation opened on 9 October 2026 and closes on 18

December 2026. It considers private tenancies and certain accommodation occupied

under licence, including supported, temporary and care-leaver accommodation. Privatesector timescales and commencement have not yet been finalised. Do not import socialhousing deadlines into a private landlord’s current duties as though the extension has

already commenced.

HMO licensing is not replaced by the new standard

Mandatory HMO licensing in England generally covers qualifying properties occupied by

five or more people forming two or more households and sharing facilities, subject to the

statutory definitions and exceptions. Additional licensing can cover further HMOs locally.

Selective licensing is a separate scheme for privately rented housing in designated areas,

not another name for HMO licensing.

HMO amenity standards must be checked against the current consolidated regulations,

rather than an outdated universal bathroom-to-occupier ratio. Current Schedule 3 requires

an adequate number of bathrooms, toilets and wash-hand basins for those sharing them,

together with suitable kitchen provision. Council amenity standards, the licence and the

building’s configuration must be checked.

For HMO owners, a kitchen replacement is therefore a capacity, durability and safety

decision. A layout suitable for one household may not support several residents cooking at

the same time. Inspect shared facilities at intervals appropriate to use and document both

routine maintenance and recurring faults.

Supported housing needs a resident-led operating plan

The reform framework includes supported exempt accommodation, while registered social

housing providers remain subject to the social-housing regulatory route. The government

recognises that some supported and temporary settings require tailored implementation

guidance. For example, there may be justified health-and-safety reasons not to provide individual heating controls in particular settings. These are not blanket exemptions for all

supported accommodation.

For owners and operators, property condition should be considered alongside residents’

needs, safeguarding procedures, access arrangements and the allocation of responsibilities

between landlord, managing agent and support provider. A Decent Homes assessment

does not determine Housing Benefit entitlement or establish exempt-accommodation

status. Those matters require separate assessment.

Does the Decent Homes Standard cover serviced accommodation?

Do not assume that every property marketed as “serviced”, “mid-stay” or a “company

let” has the same legal status. The relevant arrangement, actual occupation and statutory

definitions matter. Genuine holiday use and residential occupation should not be treated as

interchangeable; obtain advice on the specific model before claiming that a property is

outside the housing-standards framework.

The published energy-policy response states that short-term lets will not be included within

the announced PRS MEES scope. That does not remove separate safety obligations or

resolve planning, licensing, registration or tax questions for a short-stay business.

For Stay & Co’s short-stay and mid-stay audience, the operational message remains

relevant: maintain reliable heating, ventilation, safe facilities and a recorded renewal plan.

However, residential and hospitality compliance should have separate checklists. A shortstay

label is not a compliance strategy.

Decent Homes Standard component lifetimes: useful context, not replacement deadlines

The 2006 guidance included component lifetimes for assessing disrepair and planning

stock renewal. The figures below are historical assessment assumptions, not guarantees

of modern service life or statutory replacement intervals for private landlords.

Component Houses and bungalows Flats in blocks below six

storeys

Wall structure 80 years 80 years

Roof structure and roof 50 years 30 years

covering, each

Chimney 50 years 50 years

Windows and external doors, 40 years 30 years

each

Kitchen 30 years 30 years

Bathroom 40 years 40 years

Central-heating gas boiler 15 years 15 years

Heating distribution system 40 years 40 years

Other heating 30 years 30 years

Electrical systems 30 years 30 years

The historical modern-facilities test separately referred to kitchens of 20 years or less and

bathrooms of 30 years or less. Those ages should not be confused with the disrepair

lifetimes in the table. Under the announced new standard, age alone will not cause failure.

A component register should therefore record condition, estimated remaining life and

repair history, not simply installation dates. An electrical installation does not need

rewiring solely because it reaches a particular age; inspection findings and competent

technical assessment are more relevant.

Build a landlord sinking fund around remaining life

A sinking fund is a reserve for planned renewal. Its value is not the label on the account; it is

whether the money available matches the likely timing and cost of the work.

For a newly installed component, replacement cost divided by its planning life gives a

simple annual allowance. For an existing component, subtract the reserve already allocated

to it and divide the unfunded balance by its estimated remaining life. Urgent work requires

funding now, not a multi-year saving formula.

An illustrative replacement budget

The following figures are assumptions for demonstrating the calculation, not contractor

quotations, market averages or a recommended contribution for every property. They

assume new components, no existing reserves and no inflation.

Component Assumed future Illustrative planning Annual allowance

replacement cost life

Kitchen £6,000 20 years £300

Bathroom £4,500 25 years £180

Gas boiler £2,700 15 years £180

Heating pipework £3,200 40 years £80

and radiators

Electrical rewire £4,800 30 years £160

and consumer unit

Windows and £6,000 40 years £150

external doors

Roof covering £9,000 50 years £180

Total £36,200 — £1,230

That produces £102.50 a month. On an illustrative rent of £750 a month, it represents

approximately 13.7% of gross rent. It excludes routine repairs, management charges,

finance costs, insurance, voids, compliance visits and additional contingencies. It is not a

profit calculation.

The catch-up position is different. A £2,700 boiler with four years remaining and no

allocated reserve requires £675 a year on these assumptions. A £6,000 kitchen with two

years remaining requires £3,000 a year. Together, those two components require £3,675 a

year until renewed. Existing reserves would reduce the unfunded amount.

Review costs and timing annually. Obtain local quotations that state what is included,

including any VAT, access, disposal, certification and making-good costs. A contribution to a

reserve does not itself establish tax deductibility; ask an independent accountant about the

treatment of actual expenditure.

Frequently asked questions about the Decent Homes Standard in the private rented sector

When will the Decent Homes Standard apply to private landlords in England?

The government has confirmed its policy that the reformed standard will apply from 2035.

Detailed private-sector requirements and commencement must be implemented through

regulations. Existing repair, fitness and safety obligations already apply; 2035 is not a grace

period for dangerous conditions.

What are the five criteria of the new Decent Homes Standard?

The five announced criteria cover freedom from category 1 hazards, reasonable repair, core

facilities and services, thermal comfort, and damp and mould. The policy sets out the

intended tests, but landlords should also check the final implementing regulations and

guidance.

Do landlords have to replace a kitchen after 20 years?

Not simply because it reaches that age. The announced standard removes age-based failure

and makes the kitchen a key component. Its condition, usability and the defined repair

thresholds matter. An isolated cosmetic defect does not automatically require a full

replacement, but safety issues and disrepair still need appropriate action.

What is the fine for failing the Decent Homes Standard?

There is no single automatic fine for every future failure. Since 22 June 2026, a penalty of up

to £7,000 can apply in qualifying category 1 hazard cases under statutory conditions. Relevant housing offences can attract a civil penalty of up to £40,000 instead of

prosecution. Notice and appeal safeguards apply, and the wider new standard still requires

implementation.

Is EPC C already compulsory for private rented homes?

No. The current general minimum for in-scope domestic private rented properties is EPC E,

unless a valid exemption is registered. The government has announced EPC C or equivalent

for 1 October 2030, with implementing legislation and detailed transitional and exemption

arrangements required.

Does Awaab’s Law already apply to private landlords?

Its private-sector extension has not yet commenced. The consultation opened on 9 October

2026 and closes on 18 December 2026. Final requirements and commencement remain to

be set. Existing duties to address disrepair, unfitness and hazards continue independently.

Does the Decent Homes Standard apply to HMOs and supported housing?

The reform framework includes qualifying HMOs and supported exempt accommodation.

Registered social housing providers are regulated through the social-housing framework.

The government recognises that supported and temporary settings may need tailored

guidance. HMO licensing and management requirements remain separate obligations.

Are the historical component lifetimes legal replacement deadlines?

No. The 2006 figures were assessment and planning assumptions, including 15 years for a

gas boiler, 30 for a kitchen and 40 for a bathroom. The announced new standard removes

age from the repair test. Use condition, competent advice and estimated remaining life to

plan expenditure.

How much should a landlord put into a sinking fund?

There is no universal amount. Estimate each component’s replacement cost, deduct the

reserve already allocated and divide the unfunded balance by its remaining life. The

worked example gives £1,230 a year only under its stated assumptions. An older property

with near-term replacements may need substantially more.

Will the new Decent Homes Standard require carpets?

The government decided not to introduce a general mandatory floor-covering requirement

within the new standard. Flooring that is provided must still be considered under

applicable safety, fitness and repair obligations; damaged surfaces can create hazards.

Can a serviced-accommodation operator assume the property is exempt?

No. The legal arrangement and actual use must be assessed, rather than relying on the

marketing label. The announced PRS energy-policy response excludes short-term lets from

that reform, but separate safety, planning, licensing and tax issues still require

consideration.