This is the fourth blog in our five-part series on the Decent Homes Standard reforms, where our experts highlight the operational challenges and opportunities facing repairs and maintenance teams.
The reformed Decent Homes Standard (DHS) consultation is a long-overdue move for the housing sector. Considering the scale of change happening across the board, from updated legislation to new regulatory requirements, it is time this core standard caught up. Whilst the review is welcome, it brings some critical implications for repairs and maintenance teams that cannot be ignored.
One of the most significant shifts is the removal of age requirements for key components like kitchens and bathrooms. Under the original DHS, having both an age-based requirement and a condition requirement for components enabled organisations to plan replacements as part of wider programmes, with the benefit of economies of scale, better financial control, and more efficient resource allocation.
Without the age requirement, repairs and maintenance becomes more complex. Organisations are likely to face two scenarios:
This change will place significant pressure on repairs and maintenance budgets and risk shifting from planned to reactive maintenance.
Under the current standard, no organisation today would leave a kitchen or bathroom that was in disrepair. Replacement or remedial works would be undertaken to ensure this was safe, and the customer would be potentially recharged if it was down to misuse or damage. However, removing the age requirement, outside of purposeful damage, does seem to be a step that penalises residents who look after these components and rewards individuals who decide not to.
Removing age-based criteria for key components does not just affect how we plan maintenance; it also disrupts financial planning. Asset depreciation relies on component life cycles to forecast future investment needs. If you remove the age requirement, organisations will still need this number to understand how to depreciate the asset, therefore creating a disconnect between operational and financial strategies.
Find out more about the broader implications of the reformed DHS from a strategic asset management perspective in our dedicated blog, ‘How the Decent Homes Standard Reforms Will Transform Strategic Asset Management in Housing’, which you can access here.
Another proposed change is the requirement of floor coverings, which typically comes under reactive repairs. Socially, this is a positive, as no one should move into a home without basic floor finishes. However, from a practical and financial perspective, this is a major challenge. Reactive budgets are already stretched, and rolling out floor coverings across all properties could mean cutting back on other services or investment areas to cover the cost.
There is also a liability aspect to consider. If landlords start supplying carpets and other floor coverings, do they also take on responsibility for maintaining them? This will start to blur the lines with Personal Injury claims and the Housing Health and Safety Rating System (HHSRS) if someone trips and falls over the floor covering, introducing the question of who is liable if someone gets injured due to a damaged or poorly installed carpet.
Under the original DHS, kitchens and bathrooms were classed as “other components”, and a property would not fail unless two of them were in disrepair. In the revised standard, kitchens and bathrooms are being reclassified as key components, meaning a failure in just one now renders the whole property non-decent.
This is a significant change as it will increase the number of properties flagged as non-decent and add further pressure to repair and maintenance teams to respond quickly.
The addition of a standalone requirement for homes to be free from damp and mould (Criterion E) is another welcome reform, and something most landlords should already be focused on.
However, the challenge lies in its alignment with other requirements. The DHS is linked with the HHSRS, under which you are legally required to undertake any works that fall within a category 1 hazard. Awaab’s Law will make that line more blurred, as action may be required even if the hazard is not a category 1 hazard. Under the reformed DHS, action is required for any damp and mould issues rated Band H or above, introducing uncertainty about how this should interact with HHSRS assessments in practice. Greater clarity on how the various pieces of legislation align will be essential to ensure consistent and fair implementation.
A standalone criterion on damp and mould is undoubtedly the right thing to do. I also personally believe that, from an asset management perspective, organisations should investigate and subsequently deal with damp and mould as soon as evidence arises that there is an issue; this is simply good management. However, this again puts more onus on repairs teams to act faster and more frequently, adding to the ever growing cost and workload.
As the revised DHS is still in the consultation phase, the changes may not arrive exactly as drafted, but most of these changes will be introduced in some form. Therefore, I strongly encourage all organisations to start looking at the potential impacts now, even by beginning with a desktop review.
More importantly, I urge everyone to respond to the consultation. This is likely to be the standard we work with for the next 20-25 years, just as we have with the original DHS. If we do not help mould and shape these new standards, we risk ending up with a standard that is not practical, sustainable, or potentially fit for purpose.
Although I have highlighted some pitfalls in this blog, let me be clear, as someone who has worked in repairs and maintenance for many years, I can absolutely see the value in many of these changes, and they are welcomed. However, to ensure we get this right and we have a standard that organisations can implement, we must be realistic and upfront around what this means for delivery teams. Repairs teams are already under pressure, and these changes will add new layers of responsibility. Context, clarity, and phased implementation will be key to getting this right.
For further support in understanding what the changes to the Decent Homes Standard mean for your repairs and maintenance approach, get in touch with our experts.