Posted inCoL MAJOR WORKS REPAIRS

decent homes | changing regulations

Housing and Alms-Houses Sub-Committee

26 NOVEMBER 2025

Agenda Item 13 | Housing Matters Update

1. Decent Homes – Current Status and Future Changes

Members are asked to review and comment on the Decent Homes Update

SUMMARY
Decent Homes standards are changing. The UK Government has recently carried out a consultation on revised standards which are forecast to come into effect between 2035 and 2037. These revised standards, although welcome, will increase the compliance burden on landlords and put further pressure on already stressed resources. When assessed against the current standards, 2025 has seen a significant uplift in the non-decency of City of London Housing, with the reported figure rising to a non-decency rate of 17.6%. This is principally due to the delays experienced in three major refurbishment projects where increasing complexity, changing regulations and funding constraints have caused programmes to be substantially revised. These projects, subject to funding and approval, are now set to enter delivery from 2027 but will take a number of years to complete. Other identified works, essential to preventing more of the City’s homes being assessed as non-decent have also been scheduled for delivery over the next 10 years (again subject to funding and approval). The latest stock condition survey, currently underway, may identify further works which will need to be addressed. In the short term at least, the City’s non-decency levels will remain high.

BACKGROUND
The City’s housing is diverse in terms of both age and archetype; our oldest social housing blocks date back to the 1880s, our newest from the 2020s. The Golden Lane Estate is Grade II and II* listed. Properties at Lammas Green, Sydenham Hill and the City of London Almshouses are also Grade II listed. There are also 22 Higher Risk Buildings across our estates.

The City has made significant investment in maintaining its ageing housing with £110 million committed over the past ten years. Of that £110 million, £70m has been spent to date bringing homes up to the required standard.

Works delivered include:

• Replacement of windows, kitchens, bathrooms

• Electrical installation upgrades

• Lift refurbishments

• Heating system replacements

• Fire safety improvements (e.g. modern fire doors, sprinklers in high-rise blocks, compartmentation works)

• Water tank replacements

• Internal and external redecorations

• Roof replacements/upgrades

• Refurbishment of communal play and ball game areas

The remaining £40 million is committed to projects already in delivery or development, with approximately £30 million allocated to the Golden Lane Estate Investment Programme. Despite this investment, buildings continue to age and just as some components are replaced, others approach the end of their lifecycle. To maintain decency, ongoing consistent capital expenditure will be required. Informed by detailed stock data records and the forecast impacts of legislative changes (including the Building Safety Act 2022, Net Zero Targets, Awaab’s Law and the forthcoming revisions to the Decent Homes Standard) a further significant investment has been identified as necessary to meet compliance and new maintenance needs over the next decade for which funding is currently being sought.

CURRENT DECENT HOMES LEGISLATION
The Decent Homes Standard was originally introduced in 2000. It was updated in 2006 to reflect the introduction of the Housing Health and Safety Rating System (HHSRS) under Part 1 of the Housing Act 2004.

The four assessment criteria are set to ensure homes are:

  • Criterion A: Free from serious health and safety hazards (as measured by the 29 HHSRS criteria), such as severe damp, fire risks, or structural instability.
  • Criterion B: In a reasonable state of repair. Key building components (e.g. roofs, windows, heating systems) must not be old and in poor condition, or two or more non-key components must not be simultaneously old and in need of repair.
  • Criterion C: Equipped with modern facilities. Includes reasonably modern kitchens (under 20 years old), bathrooms (under 30 years), and adequate layouts.
  • Criterion D: Thermally comfortable. Must have effective insulation and heating systems to maintain a comfortable indoor temperature.

CALCULATION METHODOLOGY
Stock condition data is held within the Keystone Asset Management software platform. Data is informed by the 2018 Stock Condition Survey (a 100% survey of internal properties, communal and external areas) which is updated on completion of Major Works, VOID works, via interim inspection & remedial action from R&M officers and subsequently applied to these Decent Homes calculations on a monthly basis. While the current stock condition data is now seven years old, the City’s relatively small housing portfolio allows for a reasonably high degree of confidence in its overall condition. The accurate age of building components is known, and their condition is regularly monitored by onsite teams. Feedback from these teams is integrated into planned maintenance programmes. A new 100% Stock Condition Survey is currently underway via Potter Raper, with outcomes once received to be uploaded to Keystone and Decent Homes calculations to be fully refreshed informed by this new data set.

CURRENT DECENT HOME STATUS
As of the latest assessment, dated 14 October 2025, 338 homes are classified as non-decent, this represents 17.6% of our total tenanted housing, a significant uplift from the figure of 9.6% reported through 2024. To place this figure in a wider industry context, the English Housing Survey 2022 to 2023: Headline Report, published by the Department for Levelling Up, Housing and Communities found that 10% of socially rented dwellings in England failed to meet the Decent Homes Standard (with 9% non-decency rate for London local authorities).

Of the 338 homes currently assessed as non-decent, 336 fail on the Criterion B: Reasonable State of Repair. Major external fabric refurbishment programmes have been delayed at three of our estates (Golden Lane Estate, William Blake Estate and George Elliston & Eric Wilkins Houses on the Avondale Square Estate) due to funding issues and a need to revise scopes of work following regulatory changes which has caused a significant rise from figures reported in the previous financial year. The remaining 2 homes currently assessed as non-decent fail to meet the Criterion A Minimum Standards due to water penetration/damp issues which are considered to be a HHSRS Category 1 Hazard; remedial works are being addressed by the R&M team as a matter of urgency.

A further 293 homes are currently assessed as ‘Potentially non-Decent’. This classification gives an indication of properties which will tip over into non-decency in the short term if identified remedial works are not addressed.

PLANNED WORKS
Major refurbishment projects are being progressed for all three sites where the significant remedial action to address Reasonable State of Repair issues have been identified. Works are dependent on planning approvals (including Listed Building Consent at Golden Lane), Building Safety Regulator approvals, and availability and approval of funding from governance bodies. The Golden Lane Estate Investment Programme is complex with works currently valued at circa £100m scheduled over a ten-year period. It should be noted that non-decency levels will remain high until these works are complete. Furthermore, with new data incoming shortly from the ongoing stock condition survey, the reported non-decency figure is expected to get worse before it gets better. A new 10-year Major Works programme has been produced to ensure ‘Potentially Non-Decent’ homes are addressed in due time. The programme anticipates the impact of forthcoming changes in legislation and will be fully updated pending the outcomes of the ongoing Potter Raper stock condition survey. Delivery of this will be dependent on confirmation of funding and sufficient human resource within the Major Works and wider Housing teams.

FORTHCOMING LEGISLATION – DECENT HOMES 2.0
The UK Government’s consultation on a reformed Decent Homes Standard has recently closed. The consultation proposed to retain and update the four core Decent Homes criteria while introducing a fifth explicitly to address damp and mould. The new standard also proposes extending its mandate to the private rented sector for the first time, anticipated through the Renters’ Rights Act, which is currently progressing through parliament.

The proposed changes can be summarised as follows:

Criterion A: Free of serious hazards (HHSRS)
This criterion is expected to remain unchanged. A home must be free of any Category 1 hazard as defined by the HHSRS.

Criterion B: Reasonable state of repair
Under the proposed standard, building components no longer need to be both old and in disrepair to fail the standard, with age thresholds set to be removed from the definition. Key building components (those that, if in disrepair, could compromise the structure or present major health or safety risks – roofs, external walls, windows, boilers, chimneys, heating systems and electrics etc) must not be in poor condition with the standard of what constitutes disrepair expected to be more clearly defined.

Other building components such as internal doors, flooring, plasterwork, skirting boards and rainwater goods must also be in a reasonable state of repair. Under the revised standards, a property will be considered non-decent if it has either:

• One or more key building components that are not in a reasonable state of repair, or

• Two or more other building components that are not in a reasonable state of repair.

Criterion C: Reasonably modern facilities and services
As before, this criterion focuses on the functionality, safety and usability of facilities. The consultation proposes a shift away from rigid age thresholds towards a condition and layout-based assessment. For example, a home should have a kitchen and bathroom in functional condition, with a safe layout, appropriate storage, lighting and usability. In addition to kitchen and bathroom usability, it is proposed that a decent home must have appropriate window restrictors for safety, a safe and compliant electrical system, effective ventilation and suitable flooring. The consultation also considers introducing minimum security standards and requiring floor coverings to be provided in all rooms when a tenancy starts.

Criterion D: A reasonable degree of thermal comfort
The proposed changes strengthen expectations around energy efficiency and whole home warmth. It introduces a broader requirement for fixed, efficient heating systems capable of providing adequate warmth throughout the entire home. The revised standard also proposes alignment with other energy-related policies, such as the

Minimum Energy Efficiency Standards (MEES) (itself also under consultation) and the target for all homes to reach EPC Band C by 2030. In addition to heating, the criterion includes adequate insulation and fabric improvements to ensure homes are thermally efficient and are affordable to run.

Criterion E: Free of damp and mould likely to cause harm to health
This new proposed criterion underpins the recent regulatory changes introduced in Awaab’s Law (which came into effect 27 October 2025) which established a clearlegal duty for landlords to act within prescribed timescales to remedy occurrences of mould and damp (24 hours for emergency hazards and within 7 days for more standard repairs). Under the proposed Criterion E, homes are required to be free of:

• Black mould growth (regardless of cause)

• Structural damp penetration or rising damp

• Persistent condensation, typically from poor ventilation or insulation

• Inadequate heating or ventilation systems, or damaged building fabric.

This goes far beyond the existing standards whereby under the current criterion A, only an identified Category 1 (i.e. emergency) damp and mould hazard would be sufficient to trigger non-decency. The suggestion from the current proposals is that more minor occurrences would now be enough.

As with the run up to the launch of the original legislation, there is industry expectation that appropriate time will be allowed for landlords to prepare to meet these proposed changes. Currently floated timescales suggest that the changes will come into effect between 2035 and 2037.

EXPECTED IMPACT
In preparation for the public consultation, the Ministry of Housing, Communities and Local Government (MHCLG) published a briefing (English Housing Survey Briefing: Modelling a Revised Decent Homes Standard (2024)), outlining how the proposed changes to the standards would impact the classification of non-decent homes. The modelling, undertaken by the Building Research Establishment (BRE) uses data from the 2019 English Housing Survey to estimate how the new and updated criteria would affect compliance levels. The model forecast that, for the social housing sector, the proposed new standards would have increased from the 2019 non-decency rate of 12% up to 40% (an increase from 504,000 to 1.6 million homes).

They predict that this would equate to an additional £836m of required expenditure for the sector over and above existing commitments to bring deficient properties up to the current standards. The study notes that there ‘will be significant cost variation at the dwelling level, depending on the current condition of the property and the steps needed to bring it up to standard’ but calculates a median additional compliance cost per property of £3,439.

A significant portion of this new cost burden is expected to fall on responsive repair services due to the need to expedite remedial works ahead of planned works programmes in order to minimise the length of time a given property is classed as non-decent. For example, under the current Criterion B standards, a bathroom, no matter its assessed condition, could only be classed as non-decent if it was more than 40 years old. The City has only a handful of bathrooms of this age (typically where residents have refused works) and therefore reports virtually no non-decent bathrooms. Under the new proposals age is irrelevant. On inspection, a bathroom identified as in need of replacement would immediately cause that property to become non-decent. The next planned bathroom renewal programme for that Estate may be several years away, so that property would either need to sit as non-decent until the programme mobilises or be referred for a reactive renewal where cost efficiencies (via bulk buying and shared site set up expenses for instance) would not be realised.

Watch from 1:19:59

transcript

1:19:59 | Peta Caine, Director of Housing
So, the first section of this report is an update on Decent Homes, about the current status and the proposed future changes and I just wondered if Members had any questions?

I mean in short, in summary, our Decent Homes performance has dropped as a result of not doing the Major Works program works on a number of estates and the longer we don’t do those works the higher the non-decent homes number will rise, and also it’s covered in the report, but we are waiting for the introduction of a new decent homes standard which is going to be quite different to the existing one, which to a large extent I think focused on kitchens and bathrooms. The one that’s coming down the track is likely to be broader and so when we’ve been talking about Major Works and property and spend we’ve been flagging the facts that there’s likely to be more spend required because we’re not quite certain yet, though we’re getting hints, about what the financial implications of the changes might be. So, this is one of those risks that we can’t quite calculate at the moment.

1:21:21 | Sarah Gillinson (Cripplegate)
I mean I think honestly you’ve just pointed to it and I’m after, I think I’m after, a quantification that you probably can’t give, but I understand that the places where we’re not meeting the decency standards now are largely around the state of the repairs. So Major works will make a big contribution to that, fantastic. But along with the kind of kitchens and bathroom piece, the damp and mould piece in the future standards looks really significant and it looks like the implication is that’s a place that we drive on decency. So, my question is what kind of work will it require to really get on top of that? Is that covered in the Major Works? What are the implications of that going forward?

1:22:08 | Sandra Jenner (Aldersgate, Labour)
You say that there’s going to be a new standard. Does that mean that actually our numbers are going to be even worse? Because as far as I can see we’ve got, if you add together the potentially non-decent to those that are, we’ve got 600 homes, which is a very large percentage of our stock. Is that going to get worse when we have a new standard?

1:22:35 | Deputy Helen Fentiman (Aldersgate, Labour)
I think this is a really important point because what we consistently say is that our improvement programs are orientated to bringing all homes up to Decent standard. And I think whilst we need to understand the impact of the lack of repairs and maintenance to date, and the impact of Decent Home Standards, I think that given that we are, I hope, in the final stages of being able to secure a very major capital investment, that capital investment through that Major Works program is going to address what we anticipate is coming our way. And if there’s any question of challenge to that, we need to know that understand that very clearly.

1:23:30 | Deputy Ceri Wilkins (Cripplegate)
I’m just intrigued, how do we get the figures of knowing how many homes are or aren’t decent homes, because obviously at the moment there’s a stock condition survey taking place but it’s not been completed. So, if we could just get an update on that please.

1:23:47 | Peta Caine, Director of Housing
So, what work will be required, we think that what’s required, is what we’re planning to do for the Major Works program, but also what Rachel has just talked about in terms of it bringing in CAS [Climate Action Strategy] funding as well, which is why we’re trying to dovetail the major works program with CAS funding, but because of the delivery of the Major Works program being largely post 2027, we can’t be definitive yet because then that coincides with the new program, the new CAS program being announced. But we are talking to CAS about this so that they know this is coming down the track. We’ve been doing lots of work, and Rachel’s been doing lots of work, on actually assessing homes. The EPC’s [Energy Performance Certificates] that are being carried out as well will help with that too. So, we’re doing the preparatory work hoping that we can get CAS funding, and as Helen has said being hopefully close to securing the funding for the Major Works program as well.

But there are other sort of less hungry money intensive issues which are being identified by the new standard such as flooring – when you turn over a home, include making sure that there’s flooring left there. At the moment if there’s flooring found we usually take it out and give leave people without any. That sort of thing is being covered in the new Decent Homes Standard. So, it straddles from sort of quite expensive things to changing the way we do things with our empty properties, for example. So, you know, it’s actually quite interesting but it will be, it could be costly, but we are bearing that in mind and Bev [Beverley Andrews, Head of Repairs] has already made some estimates about what she thinks the financial impact might be for the repairs budget, which is part of the revenue ask that we’re making, and will be part of the budget setting process. So, we’re trying to look at it from all angles.

Sandra – will get things get worse with the new standard? It’s forecast to come into action 2035/37. So, they realise the impact of this because they’ve been talking to people for years about it. So, we’ve got some time to get our act together, look at the results of the stock condition survey and see exactly what it means for us.

And Ceri – where do we get the information from? You’re right, the last full stock condition survey was in 2018. Luckily, we did an 80% coverage, which is unusual but very positive. So, we’re using some of that data because it’s property data, we’ve also included the information that we get from responsive repairs and planned works as well. So, at the moment we’ve made a calculation, which we’ve shared with the regulator and other bodies as our best guesstimate, as to where we’re at. But what has happened with the stock condition surveys that are been carried out so far, it hasn’t been way off. So, it is not a bad working assumption but that’s how we’ve been doing it to date.

1:27:23 | Leyla Boulton (Bassishaw)
When do you hope to know if you’ve secured the necessary funding for the Major Works program?

Steve Goodman (Aldersgate, Labour) – Chair
Well, that’s a question that will be coming to Court in a couple of weeks’ time. So, if we all can vote for that in Court, we would secure.

– (auto-generated transcript provided by YouTube, with minor corrections and tidying up)

press

26 NOVEMBER Percentage of ‘non-decent’ homes managed by City almost doubled in the last year
MyLondon | Ben Lynch