Response to the Department for Communities’ Revised Decent Homes Standard Consultation

No.

We welcome the use of the ‘Easy Read’ versions of the consultation, which provide high-level oversight, identify the key aspects and use clearer language than would traditionally be found in a consultation or guidance document.

However, we believe there is scope to improve how these materials are presented. The consultation page states:

‘This document sets out the proposals for consideration, ensuring tenants live in a safe, warm and affordable home’ and then lists links to six documents (consultation, easy read version, summary tables).

Some additional suggestions for improving navigation and overall understanding include:

• Adding an explanatory paragraph on the consultation page, that outlines the purpose of each of these six documents.
• Reformatting the tables, to enable direct comparison of existing standards and proposed changes within a single table or using colour coding to highlight new or amended
  requirements.
• Including hyperlinks or page numbers within the contents.

Yes.

We welcome the inclusion of these tables and commend the efforts made to improve reader understanding. However, we believe that some minor formatting adjustments could further enhance clarity for some readers.

These are listed in our previous response.

Yes.

We agree that the addition of Pillar E is appropriate. A safe, secure and sustainable home is a key foundation for tenants’ wellbeing and adding this pillar will help strengthen areas not fully addressed within the existing standard.

We note that several elements are currently described as ‘desirable’ under Pillar E. The 2023 consultation on proposed uplifts to Northern Ireland’s Building Regulations proposes making measures such as charging points or ducting infrastructure mandatory requirements for new buildings and major renovations in the future.

However, under Pillar E, electric vehicle charging is categorised as desirable with a requirement to merely consider installation of electric vehicle charging infrastructure. If these proposals are progressed, these elements would no longer be optional.

It may therefore be appropriate for the revised Decent Homes Standard to reflect the likelihood that such measures will become mandatory, rather than presenting them only as desirable.

We welcome the inclusion of adaptation measures to mitigate risks to health and wellbeing resulting from over-heating and flooding in homes and buildings.

As Northern Ireland’s climate continues to change and rising temperatures increase the risk of overheating and flooding in homes, it will be increasingly important for social housing standards to consider appropriate adaptation measures where necessary so that homes are properly future-proofed.

In the social housing context, these measures will have an important role to play in safeguarding tenants’ health, comfort and wellbeing – particularly for households more likely to be vulnerable to extreme heat.

Cooling measures should form a part of the clean heat transition in social housing. Ensuring that homes can remain comfortable during periods of higher temperatures will also help tenants to avoid unnecessary increases in energy use, emissions and household costs

Overheating can pose health risks including dehydration, heat exhaustion and heat stroke. This has been recognised under the Northern Ireland Programme for Government (2024-2027) launched in March 2025, which highlighted that “we have begun to see the very real impact of climate change locally, through extreme heat”.

The Review of energy efficiency requirements and related areas of Building Regulations proposes to follow ‘The Chartered Institution of Building Services Engineers (CIBSE) TM59’ modelled approach or Scotland’s simplified approach to mitigating against the effects of overheating, given similar climatic conditions. Consideration should be given to this when setting requirements to prevent or mitigate against overheating within the Decent Homes Standard.

aWe also note that policy should prioritise passive cooling measures such as effective shading and natural ventilation. These can often reduce or eliminate the need for mechanical cooling (such as air conditioning), helping households stay comfortable without driving up energy demand or costs.

However, without clear and accessible advice, there is a risk that households will default to energy-intensive solutions like standalone air conditioning units and fragmented inefficient solutions.

For some households, the ability to cool as well as heat their home may accelerate and encourage adoption of heat pump technology, especially in homes where overheating risk is already a concern.

We also note that community-based cooling measures – such as establishing community cool rooms during extreme heat events can offer safe, accessible spaces for residents who are unable to keep their homes adequately cool. These facilities can provide safe, accessible environments for vulnerable groups, reduce health risks during heat waves, and help avoid widespread reliance on individual energy-intensive cooling solutions.

At the same time wider estate/area-level interventions, including planting trees and creating green spaces can provide shade and reduce urban temperatures. Anti-heating measures could also include mandating solar canopies over car parks – a proposal currently under consideration by the UK Government – which will not only generate renewable electricity but also provide shade for vehicles, helping to keep them cooler. Such a requirement has already been introduced in France.

The Decent Homes Standard could usefully provide guidance to social housing providers on the range of cooling strategies available.

Yes.

While we are supportive of the elements included, many are classified as ‘desirable’, which will significantly limit their application and benefits. We acknowledge that financial and technical limitations exist but would recommend that where elements are not covered by other guidance, these desirable elements are re-examined to identify potential aspects within these that could be split-out and considered above the baseline for the standard.

This includes community cool rooms where feasible, and internal wall and ceiling finishes as a key component.

This includes:

• Community cool rooms where feasible, (see our earlier response on whether we agree with Pillar E).
• Internal wall and ceiling finishes as a key component (see our later response on the updated key components list).

Yes

Tenants should not be expected to determine or gauge what is considered reasonable. An objective definition will equally support social landlords to budget and consistently apply the standards.

Yes to all

We welcome the inclusion of the components that influence energy demand and support tenants’ thermal comfort – specifically, ventilation, damp and mould and heating system inspection. Our
areas of expertise do not extend to the other components listed.

Yes

We would recommend that the requirement for certain key components to be structurally stable is extended to also include a requirement for these to be weather tight. This is in line with the revised Decent Homes Standard in England, where components such as external walls, roof structures, chimneys and windows must be weather tight in addition to being structurally stable.

Buildings that are not adequately protected from the elements can experience increased heat loss, reduced thermal comfort and higher energy use. Moreover, making sure that components are weather tight is also a pre-requisite for energy efficiency improvements.

We also note that England’s reformed Decent Homes Standard, expressly includes internal wall and ceiling finishes as a key component, as they are considered critical building elements that, if in poor condition, have an immediate impact on heat loss, the integrity of the home and well-being of its occupants due to condensation and mould growth.

Poorly maintained ceilings can contribute to draughts, heat loss and they can directly affect the “thermal comfort” criterion included in the standard. If a ceiling is in poor condition, it often suggests that the insulation above it may be old, damaged, or compressed, reducing its ability to trap heat.

The consultation proposes the inclusion of internal fabric finishes as an ‘other’ component which are not necessarily required to be repaired when they develop into a state of disrepair. As stated above, poorly maintained plaster, crumbling walls, or damaged ceilings can indicate the presence of moisture penetration or deeper structural issues, which can present serious health risks and immediate hazards to tenants.

To protect against this, we would advise that the approach in the reformed Decent Homes Standard in England is considered, whereby internal wall and ceiling finishes are included as a key component.

Yes to all

All of the measures listed will enhance the thermal comfort within a property. Roof, loft and wall insulation, hot water cylinder insulation, draught proofing and efficient glazing all help to reduce unnecessary heat loss, which is essential for lowering energy demand and improving comfort for residents.

Upgrading inefficient heating systems and introducing modern heating controls improves heating efficiency, enabling homes to achieve comfortable temperatures using less energy. This in turn supports lower running costs and helps address fuel poverty, delivering emissions reductions.

Functional and adequate ventilation is also important as it helps maintain good indoor air quality without compromising warmth.

Yes

We support the inclusion of Minimum Energy Efficiency Standards (‘MEES’) to the recommendations.

It is recognised within the Revised Decent Homes Standard in England, that MEES can “ensure a higher standard of energy efficiency and thermal comfort for the social rented sector.”

Additionally, the Department may wish to consider the experience of the Scottish Government, which has had energy efficiency standards in place for social housing since 2014 under the ‘Energy Efficiency Standard for Social Housing’ (EESSH), which introduced an obligation for social landlords to ensure their homes met a minimum energy rating (equivalent to EPC band C or D, depending on dwelling type) by 31 December 2020.

Its successor EESSH2, has helped drive improvements in energy efficiency across the sector. Scotland is now consulting on a new Social Housing Net Zero Standard, which proposes a target to maximise the number of homes in the social rented sector achieving EPC B by 2032. Scotland’s experience can offer useful insights as MEES are developed for the social rented sector in Northern Ireland.

The recently published ‘Warm Healthy Homes Strategy’ also states that “The Standard will take into account improved thermal comfort and, if approved, recommend a best-practice Minimum Energy Efficiency target for all social homes to achieve by 2030”, which does not appear to align with the proposed changes to the Decent Homes Standard.

No.

Energy Saving Trust supports the introduction of a mandatory minimum energy efficiency standard (MEES) for the social rented sector .

This should be set in a way that is consistent with Northern Ireland’s statutory climate change commitments and the emissions reduction trajectory required to meet them.

We note that the UK Government’s Decent Homes Standard sets a target of EPC band C by 2030 and the Energy Efficiency Standard for Social Housing in Scotland (EESSH) set a target of EPC C or D by 2020. A review of this standard (EESSH2) was undertaken because the 2032 milestone was not aligned with net zero targets for heating and in order to meet these, by 2045 all homes in Scotland must almost all be using a zero direct emissions heating system.

Under this review it is proposed that all social housing achieve an EPC band B, or are as energy efficient as practically possible, by the end of December 2032 (within certain limitations).

This demonstrates the pace and scale of energy saving measures needed to meet emission reduction targets and supports the need for mandatory MEES within the Decent Homes Standard.

We acknowledge the evolving complexity presented by EPC reforms. However, it is important to set clearly defined and measurable targets, which are calculated using a consistent methodology and regularly reviewed to help accelerate decarbonisation within the social rented sector.

Yes

Energy Saving Trust supports the recommendation of setting a minimum energy efficiency standard (MEES) for the social rented sector (SRS) at an EPC band C by 2030. This will help reduce
fuel poverty rates in the SRS, ensuring tenants benefit from warmer, more affordable to heat homes.

As stated in the Warm Healthy Homes Strategy (‘WHHS’), “draughty, inefficient homes require more energy to heat, and low-income households represent the highest percentage of those living in fuel poverty.”

Therefore, those that live in homes with lower energy efficiency are more likely to live in fuel poverty and setting this EPC target can drive energy efficiency improvements and support the
most fuel poor.

Furthermore, there is a commitment within the WHHS for the “government to demonstrate leadership by improving the energy efficiency of the social housing sector.” There is also a commitment to introduce MEES for the Private Rented Sector (PRS), driven by the fact that these are more likely to be older and less energy efficient than the homes in the SRS.

This represents an opportunity for the SRS to lead by example, demonstrating what effective decarbonisation looks like and driving behavioural change to building confidence for the wider housing market throughout Northern Ireland, ahead of MEES being introduced in the PRS.

EPC reform

We acknowledge the department’s concern in relation to the continually changing EPC landscape and would recommend that EPC reform should also be prioritised in NI. Some limitations identified with the existing EPC rating include the fact they must be updated regularly to ensure accuracy and are based on assumptions about fuel costs, which can quickly become outdated due to energy price fluctuations, particularly given that two-thirds of Northern Ireland households continue to rely on highly volatile fossil fuel heating.

However, as the adoption of low-carbon technologies accelerates, aspects of the current EPC rating related to fuel costs will become increasingly obsolete.

Given the extent of EPC reform throughout GB, we would encourage UK wide collaboration on these issues.

Cost-Cap and Time Limited Spend Exemption

While we recognise that many social landlords are managing a range of competing housing priorities, action on climate change and fuel poverty must be treated as core priorities and therefore the government must ensure that social landlords are adequately resourced to meet the standards. This may include introducing cost-caps on expenditure and certain exemptions as in GB.

The consultation on ‘Improving the energy efficiency of socially rented homes in England’ (EE for SRS) proposed introducing a ‘spend exemption,’ which would cap the required spend on energy efficiency measures, with a preference for this to be set at £10,000. It is proposed that this would be time limited and last for a period of 10 years.

If introducing a cost-cap, it is important to strike a balance between MEES’ being affordable, fair and proportionate with the need to meet necessary energy efficiency standards.

A lower cost-cap can support affordability concerns for social landlords and may reduce property disposals. A higher cost-cap can help ensure certain tenants in the SRS do not get left behind, particularly those living in the least energy efficient homes but may result in increased property disposals due to the standards being considered disproportionately onerous or financially unattainable.

Given that low-carbon heating technologies and whole-house retrofit often exceed £10,000 (proposed under EE for SRS in England), it can be challenging to balance the need to maximise the improvements being installed without over stretching social landlords to the extent that it has negative implications for tenants. Low-interest loans have been provided as a solution to this in neighbouring jurisdictions.

Yes to all.

Other – limited supply chain and skilled workforce

There are significant challenges posed by the shortage of skilled installers and the limited supply chain. A concerted effort will be required across government to grow the supply chain and upskill the workforce at the pace and scale necessary to meet decarbonisation targets. Rural, atypical and hard-to-treat properties may require additional expenditure and energy efficiency measures installed.

Other – advice and awareness

It will be imperative that enabling policies are in place well ahead of 2030 to ensure that social
landlords are fully supported to deliver on the new standards and to help them understand what is required of them (whether certain EPC ratings are mandated or not). Tenants may also lack awareness of available options and an understanding of when certain elements reach a threshold of serious disrepair.

While it will not affect an EPC being achieved, support for tenants after their property is upgraded and access to trusted and impartial advice will also be crucial to ensure that social tenants are able to realise the benefits of the improved energy efficiency of their house and help drive positive behaviour change.

This includes access to support for operating and maintaining any newly installed low carbon technologies to avoid increasing bills due to lacking the appropriate understanding of how to operate their system properly.

Yes.

Yes.

Raising smart meter and smart tariff awareness

We welcome the inclusion of smart meters within the proposed Decent Homes Standard. We are also encouraged that these have been prioritised by the Utility Regulator in their draft forward work programme 2026/27 on establishing regulatory frameworks to support implementation of the Department for Economy’s Smart Meter Design Plan by Q1 2026/27.

Smart meters will be essential for tenants to access smart tariffs, which can often lead to lower energy bills. Additionally, in-home displays on smart meters can also support tenants to better manage their energy usage following improvements so that any predicted energy bill savings can be monitored and realised.

However, many challenges remain in Northern Ireland around consumer awareness of and confidence in smart meters. Given that the Decent Homes Standard proposes that providers should offer occupants the option of having a smart meter installed in each home and the fact that they are relatively novel in Northern Ireland, it is essential that occupants are suitably informed of the benefits of smart meters and smart tariffs.

As the regulatory frameworks to support the implementation of the smart meter design plan are developed and implemented, we would emphasise the importance of and recommend:

• Close collaboration between the Utility Regulator, the Department for Economy, the Department for Communities and other relevant expert groups to ensure smart meters are rolled out as effectively as possible and to enable all households to benefit from the transition (including social tenants).
• Launching a consumer awareness raising campaign on the net zero transition, highlighting the benefits of energy efficiency and low carbon technologies. This campaign should be well-coordinated with any related messaging on smart meters so that households understand the importance of getting a smart meter without feeling that they are being imposed upon them. It should also provide clear signposting to trusted sources of advice and support, enabling people to act on the information they receive.
• Raise awareness and offer advice on how to engage with new, flexible tariffs if they have a smart meter.