Decent Homes Standard

In September 2025, the government consulted on reforming the Decent Homes Standard, including the introduction of a Minimum Energy Efficiency Standard for the social rented sector.  

The NHF submitted responses to both consultations based on feedback from our members and engagement with wider sector stakeholders.  

Decent Homes Standard 

We welcomed the review of the Decent Homes Standard and its increased focus on the condition of homes. 

We support most of the proposed changes to the Decent Homes Standard in principle, but emphasise that they must be implemented in a way which sets reasonable expectations for housing associations and allows them adequate time to prepare.

The proposed new requirements will come with significant additional costs for housing associations. For the new Decent Homes Standard to be achievable, particularly alongside the development of new social homes, we urge the government to provide additional funding for social landlords to invest in the quality of existing homes. 

Minimum Energy Efficiency Standard 

We welcome the government’s commitment to improving the energy efficiency of social rented homes. As housing associations continue to lead on sustainability, our recent consultation response outlines both support for the government’s ambitions and key recommendations to ensure a fair, practical transition for housing associations and residents.

The NHF fully supports the government’s intention to set a 2030 target for all social homes to reach Energy Performance Certificate (EPC) band C. With a proposed £10,000 per home cost cap and appropriate exemptions, this target builds on years of progress. Housing associations already have a strong track record, with many homes meeting or exceeding EPC C standards – in fact, our sector leads the way over other tenures in the percentage of homes already at the right standard.

Our concerns

However, the NHF has raised concerns about the government’s proposal to change the metrics used to assess energy efficiency at the same time as introducing the new target. Such a shift – which would see a pathway of energy efficiency measures up to 2030 replaced with a combination of metrics, including heat pumps and smart readiness from 2028 onwards – would represent a significant change in sector practice, creating uncertainty and additional costs. This would undermine the stability provided by other recent policy and funding decisions, notably the valuable work undertaken through the Warm Homes: Social Housing Fund and funding provided for the delivery of new homes.

The importance of maintaining the current metric to 2030

The government’s consultation suggests that homes meeting EPC C under the current metrics by 2028 would be exempt from the new requirements for a further 10 years. The NHF recommends extending this exemption to 2030.This relatively minor, but crucial, extension of two years would allow housing associations to continue with their current plans, and provide vital continuity and certainty for the sector at a time when we need to balance investment in existing homes with building desperately needed new homes.

The NHF urges the government to confirm the extended exemption period as soon as possible. If this could be before the next round of Social and Affordable Housing bids, it would give housing associations the confidence to make ambitious bids and long-term investments in energy efficiency.

Other benefits

Extending the exemption would also give the government more time to finalise the new Home Energy Model (HEM) and revised EPC system. This is crucial for setting out how these changes relate to MEES and the post-2030 regulatory framework needed to meet the 2050 net zero target. Once finalised, housing associations can incorporate the new metrics into their long-term planning, and even into pre-2030 works where possible. 

NHF members can log in to download our full responses.

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Who to speak to

Annie Owens, Policy Leader