The new Decent Homes Standard, and the damp and mould criterion

The Decent Homes Standard has been the same document since 2006. On 28 January 2026 the government published its response to the reform consultation, along with a policy statement and a final impact assessment, and the standard that replaces it is a materially different test.

Two changes matter more than the rest. There is a new criterion for damp and mould, and the standard now applies to the private rented sector as well as social housing.

The five criteria

The new standard is built on five criteria rather than four.

Criterion A, a home must be free of the most dangerous hazards. Criterion B, a home must be in a reasonable state of repair. Criterion C, a home must provide core facilities and services. Criterion D, a home must provide thermal comfort. Criterion E is the new one: a home should be free of damp and mould.

Criterion E fails where a damp and mould hazard is assessed within bands A to H of the Housing Health and Safety Rating System. The wording of the policy statement is worth reading closely, because it asks for two different things. Landlords have to respond when a problem is reported, and they have to take preventative action so the problem does not arise. A property that is repeatedly treated and repeatedly recurs is not a property that has been kept free of damp and mould.

That sits alongside Awaab's Law rather than replacing it. Phase 1 of Awaab's Law came into force in social housing in October 2025 and sets fixed timescales for investigating and fixing damp, mould and emergency hazards once a tenant reports them. The Decent Homes criterion is the standing condition test. Awaab's Law is the clock that starts when somebody complains. You can comply with the clock and still fail the standard.

Who it applies to, and from when

For the first time the standard covers both the social rented sector and the private rented sector in England. The private rented sector application arrives through the Renters' Rights Act framework, and it is the larger practical change, because the sector has never had a decency test before.

The compliance date is 1 April 2035. The existing standard continues to apply until then.

Nine years reads like a long runway. It is worth being honest about why it is not.

The scale of the gap

The modelling published with the consultation, using English Housing Survey data from 2018-19 and 2019-20, gives the clearest picture of the distance involved. Under the current standard, 12% of social rented homes and 23% of private rented homes are non-decent. Under the revised standard as consulted on, those figures were modelled at 40% and 47%, which is roughly 1.6 million social homes and 2.2 million private rented homes.

Those numbers are consultation-stage modelling against the proposed standard, not a measurement of the final one, and the 2019 base year is the last in which full physical surveys were completed before the pandemic interrupted fieldwork. Treat them as an order of magnitude rather than a target. Even discounted, they say that something close to half of privately rented stock in England has work to do, and that the work is not evenly spread.

Why 2035 is not far away

Three things compress the runway.

The first is that Criterion E is not a defect you can survey once and fix. Damp and mould is seasonal, it is behavioural as much as structural, and it returns. Demonstrating that a home is free of it means holding a record across winters, not a single certificate. If the evidence starts in 2034 there is one heating season in it.

The second is that the failures are concentrated in the stock that is hardest to plan. Thermal comfort and damp failures cluster in older solid-wall properties, converted houses and homes with no effective mechanical ventilation. Those are fabric interventions with lead times, planning constraints where the building is listed or in a conservation area, and disruption that has to be scheduled around occupation.

The third is capacity. A deadline that applies to two sectors at once, on the same date, means every landlord in England is buying the same trades in the same decade. The organisations that survey early get quotes. The ones that survey in 2033 get a queue.

What is worth doing now

The useful first move is not remediation. It is finding out where you stand.

Survey against the new criteria, not the old ones. A stock condition survey run to the 2006 definition will tell you very little about Criterion E, because damp and mould was previously picked up only where it reached category 1 hazard severity under Criterion A. Ask for the HHSRS damp and mould band explicitly, property by property.

Record ventilation as an asset, not an observation. Extract fans, trickle vents, passive stack systems and mechanical ventilation with heat recovery are the things that decide whether a property recurs. They need a location, a specification, a service history and a test result, in the same way a fire door does.

Log every report and every response with dates. The preventative limb of Criterion E is the hard one to evidence after the fact. A tenant report, the inspection that followed, what was found, what was done and what was found on the return visit is a chain that has to be written as it happens.

Keep photographs against the room, not the job. Damp arguments are won and lost on whether you can show the same wall in February 2027 and February 2030.

Where this sits in SAMRISK

Damp and mould is a condition that lives across several records, which is exactly why it goes missing.

The hazard assessment belongs in risk assessments, scored and dated, so the HHSRS band for each property is a field rather than a paragraph in a PDF. Ventilation equipment, extract fans and MVHR units are assets in items with their own service intervals, and the servicing runs as recurring work in maintenance, chained through the compliance calendar so the next inspection is created when the last one is signed off.

A tenant report becomes a dated record in incidents with a remedial task that has an owner and a due date, so the Awaab's Law timescales are measured rather than estimated. Survey reports, contractor certificates and moisture readings sit in documents, the annual condition sweep runs as an audit, and photographs attach to the room in building plans so the same wall can be compared across years.

The point

The reformed standard does not ask for anything a competent landlord would argue with. Homes should be free of damp and mould, and somebody should be able to show that they are.

The difficulty is the word show. A condition standard measured across a decade is an evidence problem before it is a building problem, and the evidence has to be gathered while the condition is happening rather than assembled in the year of the deadline.

Survey against the new criteria, put ventilation on the asset register, and date everything. Nine years is enough time if the record starts now, and not much time at all if it does not.

Sources: Ministry of Housing, Communities and Local Government, Consultation on a reformed Decent Homes Standard for social and privately rented homes: government response, and The New Decent Homes Standard: policy statement, both published 28 January 2026, GOV.UK; MHCLG, EHS Briefing: Modelling a revised Decent Homes Standard for consultation, English Housing Survey 2018-19 and 2019-20; Housing Health and Safety Rating System, Housing Act 2004; Awaab's Law, Social Housing (Regulation) Act 2023, Phase 1 in force October 2025.