06 Mar 2026
CIH Northern Ireland submit to consultation on revised Decent Homes Standard proposals
The Decent Homes Standard is a crucial piece of legislation that outlines the standards that all social housing providers are expected to deliver. However, it has not been updated since 2004, and the housing context has changed significantly in the past twenty-two years.
These proposals provide a clear modernisation of the Decent Homes Standard, placing an emphasis on safety, health, and dignity for tenants, as well as key considerations such as energy efficiency and cost effectiveness for housing providers. These proposed changes would also bring Northern Ireland housing standards up-to-date and align with amendments to housing, health and safety legislation across the UK.
Our response reflects our support for the proposed changes and refinement of standards. However, we believe clearer guidance, stronger support and engagement with housing providers, realistic cost assessments, and sustained funding are essential to ensure successful delivery of the new Decent Homes Standard.
Overall, our key points and recommendations are:
- Funding and delivery: The Executive should provide additional funding and establish a long-term decent homes programme to support delivery of improved standards. Work should continue in securing additional funding streams for the Housing Executive and housing associations so providers can deliver the updated requirements.
- Refinement of standards: We support adopting more descriptive thresholds, increasing the component list and treating ventilation, lifts and prevention of damp and mould as essential to safety and wellbeing, and ensuring providers put in place measures to deal with flooding and overheating. However, we would recommend that age is removed as a measure of disrepair, as it does not provide an accurate assessment of a component’s condition.
- Resident dignity: The new DHS should prevent trade-offs between essential elements, enhance measures addressing damp and mould, embed resident voices to reduce stigma and strengthen accountability, and provide sufficient time to develop practical solutions for incorporating floor coverings.
- Communication and support to housing providers: The Department for Communities should work closely with housing providers to clearly communicate the updated changes, the requirements, and the timeline. Funding support should be provided where needed to allow providers to bring their homes up to the new standards, while also retaining the funding capacity to continue building new social housing to meet the considerable demand that exists in Northern Ireland.
- Implementation: A phased approach is needed, with priority given to core health and safety issues such as damp and mould, kitchens and bathrooms, and heating. Housing providers should be given realistic timelines to ensure any works are completed to a high standard in an efficient manner.
Responses to individual questions
Early feedback from social housing providers told us that they would find it useful to have an objective definition of the terms 'reasonable' and 'reasonably' as used within the four pillars of the DHS. For this purpose, the department interprets ‘Reasonable state of repair’ to mean 'the condition of being structurally sound, free from significant damage, rot or other deterioration and safe for intended use'. Furthermore, looking at the standard in its entirety, further details and timescales are already provided; for example, reasonably modern facilities is defined as a kitchen that is 20 years old or less and a bathroom that is 30 years old or less.
Yes.
The Department considered removing the 'age' requirement from the definition of 'reasonable state of repair'. The impact of removing the age requirement from Pillar B would mean that it would be the condition of the component regardless of the age that would determine, if a property met the required DHS standard.
However, feedback suggested that 'age' is easy to define and measurable as well as providing tenants with a clear indication of when a component is to be replaced. If the 'age' requirement was removed, there were concerns that the onus would be transferred to tenants to report faults with components in order for maintenance works to be completed. Feedback from the majority of housing providers also stated that 'age' is a core criterion for planned maintenance programmes and is therefore essential for budget forecasting.
No.
If no please explain why you believe the 'age' requirement should be removed from the DHS?
CIH believes that the new Decent Homes Standard should move away from using age as a determining factor when assessing housing components. The key consideration should be whether a component is operating safely and effectively, which depends on more than its age alone. An overreliance on age can result in inefficient or premature replacements, rather than sound asset management decisions based on actual condition.
CIH therefore supports removing age as a strict test for disrepair, reflecting growing recognition that a condition-based and preventative approach is more effective. The new Decent Homes Standard in England, for example, shifts away from age-based measures towards assessments based on condition.
We do recognise that age can still play a useful role for landlords by indicating when components may require inspection and helping to plan future replacements. Age can therefore act as a prompt for investigation, rather than a trigger for automatic replacement.
CIH believes that age should be replaced with a clear and robust framework for assessing condition. Without clear guidelines, there is a risk that investment will be delayed until components fail, undermining the preventative intent of the Decent Homes Standard.
Initial feedback from stakeholders was that they believed the existing list of key components1 were missing the components listed below.
- Ventilation2
- Damp and mould
- Heating system inspection
- Fire safety
- Fire risk assessments
- Carbon Monoxide
- Lifts
1Minimum fitness standards | Department for Communities (under heading Key Building Components)
2Ventilation is already included within the fitness standard, but given its
| Yes | No | |
| Ventilation |
X |
|
| Damp and mould |
X |
|
| Heating system inspection |
X |
|
| Fire safety |
X |
|
| Fire risk assessments |
X |
|
| Carbon monoxide |
X |
|
| Lifts |
X |
No.
The Department considered removing the multiple-choice option from Pillar C of the DHS.
Pillar C
A home must have reasonably modern facilities and services, properties that fail to meet his criterion are those that lack three or more of the following:
- a reasonably modern kitchen (20 years old or less)
- a kitchen with adequate space and layout
- a reasonably modern bathroom (30 years old or less)
- an appropriately located bathroom and WC
- adequate insulation against external noise (where external noise is a problem)
- adequate size and layout of common areas for blocks of flats
Properties that fail to meet this criterion are those that lack three or more of the components as listed above. If the multiple-choice option was removed, a property would fail to meet the DHS if only one component failed (as listed above). This would therefore affect the requirement to identify and prioritise “key” and “other” components. Pillar B on the revised DHS table defines “key” and “other” components.
If a component in disrepair is identified as “key”, depending on the level of disrepair it would be triaged as an emergency (repaired within 24 hours) or urgent (repaired within) 4 working days. If the component is defined as “other” the repair should be triaged as routine (repaired within 4 calendar weeks).
Taking this into account as the review developed, the proposal is to maintain the split between ‘key’ and ‘other’ components, and not to remove the need for ‘one or more’ components to be affected.
No.
If no, please provide details
We believe these thresholds are set too high and risk masking serious issues until they reach a crisis point. What can be perceived as inconsequential concerns, particularly relating to damp and mould, can quickly escalate into serious threats to health.
For example, the new Decent Homes Standard in England has lowered the threshold for triggering repair to two components, or one key component, reflecting a more robust approach to maintaining adequate standards.
We therefore support lowering the threshold so that action can be triggered by the failure of fewer components. This would better reflect how risks develop in practice and how residents experience these in their homes and would help move the sector towards a more preventative, resident-focused approach to disrepair and decency.
Currently, target timelines for the completion of maintenance and repairs are laid out in the Housing Association Guide. However, as these are crucial to the comfort and safety of properties, we propose to include timeframes for repairs within the DHS. These will be categorised as emergency, urgent and routine. This will bring these targets into alignment with the status of the DHS and reporting arrangements, so that their significance is clear. We believe that this is a proportionate response to addressing hazards within social homes. The timeframe for repairs included in the Housing Association Guide (HAG) are listed below:-
Emergency repairs should be completed within 24 hours (defects affecting the safety, security or health of a tenant).
Urgent repairs should be completed within 4 working days (defects causing loss of facility to a tenant or likely to cause further deterioration to the structure, fabric, fittings, fixtures or services to the building).
Routine repairs should be completed within 4 calendar weeks (defects which can be deferred without serious inconvenience to the tenant).
Yes.
From October 2025, Awaab's Law came into force in England. This law requires all social housing landlords to investigate and resolve dangerous damp and mould hazards within a set timeframe, as well as addressing all emergency repairs within 24 hours. The option to incorporate these timeframes into the DHS has been considered in this review.
The department has worked closely with the sector to identify risks and support them to address these. We consider that a proportionate and appropriate response here may be to incorporate similar, robust standards around investigation and resolving hazards within existing social housing frameworks.
This will include introducing timeframes to assess risks and triage repairs and damage appropriately for investigation, with emergency and urgent repairs prioritised accordingly.
Yes.
| Yes | No | |
| Roof, loft and wall insulation | X | |
| Hot water cylinder insulation | X | |
| Draught proofing | X | |
| Heating controls | X | |
| Replacing glazing (Window and doors if inefficient) | X | |
| Install or upgrade inefficient heating systems | X | |
| Functional and adequate ventilation | X |
No.
If no, please provide details
CIH does not agree with the removal of a mandatory target. It would risk the loss of investment in making homes warmer, which would be disastrous in the context of Northern Ireland’s fuel poverty crisis.
There are concerns from the sector that the current EPC system does not place adequate primacy on fabric conditions in homes and does not accurately represent the true energy performance of a home, and we welcome the initiative to reform the EPC system as outlined in the Warm Healthy Homes Strategy 2026 – 2036. However, until there is a robust replacement, we would propose the new Decent Homes Standard retains a target of achieving EPC band C by 2030, but should include safeguards to ensure that i) improvements actually lead to warmer homes, and should therefore include monitoring and evaluation, and ii) there is a transition period that gives providers sufficient time to shift to the new EPC system when it is reformed and introduced. For example, if providers were to meet current EPC band C by 2030, and then the EPC system changes in 2031, they are given time until 2039 to meet targets as part of the new system.
Overall, seventy-five per cent of housing association homes operate at EPC band C or higher, and the proposed transition will be less difficult for these organisations. The most obvious challenge is the retrofitting and upgrading of Northern Ireland Housing Executive homes, the majority of which are EPC band D or lower. This requires solving structural issues around access to funding to provide necessary supports to the Housing Executive, as well as a review of sustainable rents.
There is no standard cost for improving energy efficiency, as each property will require different measures depending on the individual condition of each property. The Department recognises the challenges to improve an EPC rating. If costs are excessive to achieve the recommended EPC band C rating, it is recommended housing providers take a basket of measures approach, prioritising improvement measures tailored to the specific property. This should improve the energy efficiency and comfort of the property and ideally the EPC rating.
These measures could involve the installation, replacement or upgrading of:
- Roof/loft, wall or floor insulation
- Hot water cylinder insulation
- Draught proofing
- Low energy lighting
- High heat retention storage heaters/dual immersion cylinder and thermostat
- Heating Controls
- Heating systems (if inefficient)
- Solar water heating
- Windows and doors (if inefficient)
- Solar photovoltaic
No.
Access to property
Age of property
Listed buildings
Size of property
Cost of works
Other – The potential disruptive nature of intervention required to bring a house up to EPC band C rating could have detrimental effects on tenants, for example being rehoused for a significant period of time, when there are a lack of accommodation options.
| Yes | No | |
| Flooding | X | |
| Overheating | X |
No.
We agree that floor coverings are an important component of a decent home and should be required in circumstances where there is need and agreement with the tenant.
However, CIH recognises the complexities of such an approach, both in terms of cost and delivery. We believe that the government should work with landlords to develop practical approaches so that this can be delivered fairly and sustainably.
The new Decent Homes Standard in England does not require mandatory floor coverings, balancing the needs of tenants with the impacts for landlords. However, it will explore options to encourage landlords to look at how to support tenants through either best practice guidance or pilot projects with landlords to assess the costs more effectively. We would support a similar approach for the Northern Ireland Decent Homes Standard with similar proactive engagement with landlords to agree on best practice.
Yes.
If yes, please provide details
CIH welcomes the Department for Communities’ long-awaited proposals for a reformed Decent Homes Standard, twenty-two years after the original policy was published in 2004.
Overall, we agree with the broad direction of reform, particularly the focus on safety, health, wellbeing and dignity. It brings Northern Ireland housing standards up-to-date and reflects changes in housing, health and safety legislation across the UK. However, we believe there is a need for clearer guidance, support and engagement with housing providers, realistic cost assessments, and sustained funding to ensure successful delivery.
We particularly welcome the addition of Pillar E, where the home “is safe, secure, sustainable and promotes wellbeing”. Living in a safe, secure and sustainable home, that prioritises comfort and enjoyment, is essential to the dignity and wellbeing of residents.
In summary, CIH strongly supports the principle of an updated DHS but emphasises that its success depends on adequate funding, clear guidance, and a cultural shift towards prevention, resident engagement, and long-term investment in existing homes. Along with the Warm Healthy Homes Strategy, this updated DHS is a positive step in the right direction towards safe, secure and sustainable homes for all, but faces similar obstacles due to insecurity of funding.
For more information on our response please contact Georgia Knapp CIHM, policy and public affairs manager Northern Ireland: georgia.knapp@cih.org.
For more information on the consultation visit the DfC website.
