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Elmhurst responds to Decent Homes Standard Consultation


Elmhurst has issued a response to the government’s consultation, which proposes to introduce a legally binding Decent Homes Standard in England’s Private Rented Sector.

The proposed standard will be broadly consistent with the one used in the social rented sector  but includes adjustments to reflect the specific circumstances of the private rented sector- this includes reflecting the existing requirement to meet minimum energy efficiency standards in the private rented sector.

What is considered a ‘decent’ home in the private rented sector?

A decent home in the PRS must meet all of the following four criteria in order to meet the Decent Homes Standard:

  1. It must meet the current statutory minimum standard for housing
  2. It must be in a reasonable state of repair
  3. It must have reasonable facilities and services; and
  4. It must provide a reasonable degree of thermal comfort

Elmhurst’s Response

Elmhurst has issued a response to this consultation, and overall, agrees with the proposal to introduce the Decent Homes Standard within the private rented sector. However, further clarity with regards to targets should be considered. Our response can be summarised by the following points:

Publish the results of MEES

We would encourage government to publish the results of the Minimum Energy Efficiency Standards (MEES) as soon as possible to allow landlords to begin implementing improvements measures to the their properties. It has been almost 2 years since the Improving the energy performance of privately rented homes consultation, was released. This consultation proposed the introduction of a new target of Energy Performance Certificate (EPC) Band C by 2030 for private rented homes. We still await the result of this consultation, today.

Use existing energy professionals

Energy Assessors are in a great position to provide landlords with advice in relation the energy certificates and what measures can be installed to improve a property.

The EPC should be used

The EPC must be the tool to measure the thermal comfort of a property. The majority of heating systems described in criterion D:

  • any gas or oil programmable central heating; or
  • electric storage heaters; or
  • warm air systems; or
  • underfloor systems; or
  • programmable LPG/solid fuel central heating; or
  • similarly efficient heating systems.


would be costly to run, which would be reflected on the EPC, plunging tenants in to fuel poverty. We would encourage government to align this standard with their other policies and consider whether the target is moving people away from fuel poverty, having more efficient homes, or reducing carbon emissions.

Adopt PAS 2035

We would encourage that this standard adopts PAS 2035. This will enable clear energy efficiency measures to be installed based on the condition of properties. Ultimately working with fabric first, then moving on to improving the heating system(s).

The ‘A Decent Homes Standard in the private rented sector: consultation‘ is still open to responses from landlords, tenants and other professionals operating in the sector until Friday 14th October.