Written evidence submitted by Royal Institution of Charted Accountants [HCE 043]

RICS Response to the Levelling Up, Housing and Communities Committee Inquiry into Housing Conditions in England

Overarching

What is the general condition of homes in England and how prevalent are housing hazards such as damp and mould?

The condition of homes in England remains a significant concern, particularly in relation to health-impacting hazards like damp and mould. According to the English Housing Survey 2023–2024:

• 14% of all homes are classified as non-decent, with damp and mould among the most prevalent issues.
• In the social rented sector, 17% of homes are non-decent, and 11% are affected by damp or mould.
• In the private rented sector, 21% are non-decent, with 10% experiencing damp or mould.
• Among owner-occupied homes, 13% are considered non-decent.

Damp and mould are not only structural problems—they are serious health hazards. RICS guidance highlights that these issues often stem from poor ventilation, inadequate insulation, or unresolved leaks. Surveyors can identify root causes and recommend proportionate, effective remediation strategies.

As the UK moves toward tightening Minimum Energy Efficiency Standards (MEES), the drive to retrofit homes is accelerating. While retrofitting is essential for improving energy performance and reducing emissions, it must be done carefully. Poorly executed retrofits can inadvertently exacerbate issues like damp and mould if ventilation and moisture management are not properly addressed.

To support high-quality, safe retrofit work, RICS has developed a suite of resources, including the Residential Retrofit Standard and the Retrofit Consumer Guide. These tools help ensure that retrofit projects are delivered to a high standard, with occupant health and building performance in mind.

RICS is also exploring the introduction of a dedicated retrofit pathway into its professional qualification framework—one of the only initiatives of its kind globally. This will help raise standards across the sector by ensuring that professionals undertaking retrofit work are properly trained, competent, and accountable.

RICS continues to champion a whole-home approach to housing quality—combining physical inspections, occupant feedback, and environmental monitoring. The forthcoming Social Housing Stock Condition Survey Standard, developed in partnership with the National Housing Federation, will further support consistent, reliable assessments across the sector.

Social Housing Sector

How effective will the proposed reforms to the Decent Homes Standards be at improving the conditions of social housing?

• The proposed reforms to the Decent Homes Standard (DHS) offer a timely and necessary update to reflect modern housing challenges, particularly around energy efficiency, damp and mould, and building safety. The introduction of a new damp and mould standard is especially welcome given the serious health implications and the need for landlords to address structural causes rather than relying solely on tenant behaviour.
• Removing the age-based criterion in favour of condition-based assessments could encourage more proactive maintenance, but risks undermining long-term planning and tenant expectations. Without clear benchmarks, landlords may struggle to schedule preventative maintenance, and residents may lose confidence in the consistency of service delivery.
• The inclusion of new facilities—such as child-resistant window restrictors and home security measures—reflects a more holistic approach to housing quality.
• RICS supports the principle of improving standards across social housing but urges the government to commit to regular review cycles of the DHS to provide regulatory certainty. This will help landlords plan investments and maintenance more effectively and ensure the standard remains responsive to evolving housing needs.

Have social landlords been abiding by the Decent Homes Standard; are the consequences for non-compliance tough enough or do these need to go further?

• While compliance with the Decent Homes Standard in social housing is reported at around 90%, this figure masks significant variation in quality and consistency. The current system relies heavily on self-declaration by landlords, which raises concerns about impartiality and the robustness of oversight. Without independent verification, there's a risk that non-compliance goes unchallenged or underreported – however that brings its own challenges around resource capacity for such verification.
• Consequences for non-compliance are currently limited and lack the necessary weight to drive consistent improvement. RICS and other stakeholders have called for stronger enforcement mechanisms, including independent assessments and clearer accountability frameworks. Without these, the standard risks being perceived as aspirational rather than enforceable.
• To ensure meaningful adherence, the government should consider introducing mandatory external audits, clearer sanctions for persistent non-compliance, and a formal review cycle to maintain pressure for continuous improvement. This would also help restore tenant confidence and ensure that the standard delivers tangible improvements in housing quality.

What should be included in the Regulator of Social Housing’s forthcoming Competence and Conduct Standard to help improve the service social tenants receive?

• RICS are having productive conversations with government as they look to consult on the introduction of mandatory qualifications for social housing managers and executives. We have been calling for government and the regulator to recognise the importance of professional body membership within the qualification criteria and are reviewing our pathways to ensure it meets the ambitions of such standards to ensure a high-quality tenant experience. 

• While focusing on managers and executives to have the qualifications is understandable and they will feed down their experience, most front-line social housing staff will not be required to hold such qualifications. RICS is concerned this could also deter people from outside of social housing from moving into the sector and restrict more junior staff from being promoted without having to undergo additional training – costing the social landlord time and resources.

How effective is the Housing Health and Rating System as a framework for identifying hazards and how could it be improved?

• The HHSRS provides a broad framework for assessing housing hazards, but its complexity and lack of clarity have made it difficult for consistent application across the sector. Many social landlords find the system overly technical, and the absence of clear thresholds or scoring guidance can lead to inconsistent assessments and enforcement.
• The system’s reliance on subjective judgment, rather than quantifiable standards, undermines its effectiveness as a regulatory tool. This has been particularly problematic in areas like damp and mould, where the health impacts are well-documented, but the HHSRS lacks the specificity needed to drive timely interventions.
• Improving the HHSRS should involve simplifying the framework, introducing clearer definitions and thresholds for key hazards, and aligning it more closely with the updated Decent Homes Standard. Greater training and competency requirements for assessors would also help ensure consistency and reliability in hazard identification.

What will the impact of Awaab’s Law be on social housing providers, and will this affect social and affordable housing supply?

Awaab’s Law is a vital step toward protecting tenant health. However, without:

• Additional funding,
• Workforce expansion,
• Access to professional expertise,

the law could inadvertently reduce housing supply. RICS recommends a phased rollout and support for capacity-building.

What impact will the Government’s proposed Minimum Energy Efficiency Standards have on the social housing sector?

• Awaab’s Law introduces legally binding timeframes for social landlords to investigate and remedy hazards like damp and mould—requiring action within 24 hours for emergency risks and 10 working days for significant hazards. This marks a significant shift in accountability and responsiveness and rightly prioritises tenant health and safety.
• However, the operational impact on providers will be substantial. Many will need to overhaul internal processes, invest in inspection and repair capacity, and ensure staff are trained to meet the new legal obligations. For larger housing associations, this may be achievable with strategic planning, but smaller providers could face resource constraints.
• There is a real risk that these pressures could affect the pace of new social and affordable housing delivery. Providers may need to divert capital and staff time away from development programmes to meet compliance demands, particularly as the law expands to cover additional hazards by 2027.
• To mitigate this, government support—whether through funding, guidance, or capacity-building—will be essential. Without it, the unintended consequence could be a slowdown in housing supply at a time when demand is already outstripping availability.

How can technology help to monitor and improve the condition of homes, and what more can the Government do to facilitate the effective use of technology in this area?

• Technology offers significant potential to improve housing condition monitoring—particularly through digital stock condition surveys, smart sensors for damp and mould, and building passports that track maintenance and energy performance over time. These tools can enable earlier intervention, reduce reactive repairs, and support data-driven asset management.
• However, uptake across the social housing sector is uneven. Smaller providers often lack the resources or digital infrastructure to implement these technologies at scale. The Government could play a more active role by funding pilot programmes, supporting sector-wide digital standards, and investing in training to build digital capacity among housing professionals.
• A case can be made for the digitisation of Decent Homes Standards results, to support the regulator checking for social housing compliance, as well as aiding the eventual expansion to the PRS.

What other measures can the Government take to support social landlords and residents to take effective action against hazards and improve the condition of non-decent homes?

• Introduce targeted funding and fiscal support to help social landlords meet new regulatory requirements—particularly for damp and mould remediation, energy efficiency upgrades, and digital infrastructure. Without this, providers may struggle to balance compliance with investment in new housing supply.
• Invest in workforce development, including training and professional qualifications – which can then support delivery of consistent stock condition survey assessments. A shortage of qualified professionals is already a barrier to effective hazard management.
• Provide clear, accessible guidance for tenants on how to identify and report hazards, and ensure that complaints processes are transparent, timely, and responsive. Empowering residents is key to early intervention and sustained improvements. RICS recently published its new Damp and Mould Consumer Guide to provide impartial advice on identifying and remediating such issues.

Private Rented Sector

Does the Renters’ Rights Bill go far enough to address poor housing conditions in the private rented sector?

The Bill is a positive step but lacks robust enforcement mechanisms and clear definitions of housing quality. RICS supports the extension of the Decent Homes Standard to the PRS, but implementation must be supported by professional oversight.

The Bill is coming at a significant period of change in the PRS, and while the proposed expansion of the Decent Homes Standard to the sector will drive up quality, other factors also need to be considered. Plans to introduce updated Minimum Energy Efficiency Standards (MEES) as early as 2028 for new lets to meet EPC C, will see improvements made ahead of the proposed implementation date of the DHS.

How effective will the introduction of the Decent Homes Standard be at improving the condition of homes in the private rented sector?

The standard will have significant implications. With 21% of PRS homes non-decent and 12% containing Category 1 hazards, RICS recommends:

• Phased implementation, which also combines with wider MEES reforms.
• Government to explore funding opportunities for PRS landlords to meet compliance, and if existing schemes are effective. This is particularly important to meeting the DHS, as most funding schemes today have focused on energy-efficiency and low-carbon technologies.

What impact will the introduction of the Decent Homes Standard have on landlords in the private rented sector?

RICS is concerned that without sufficient implementation time, funding support and guidance – many landlords may leave the sector, putting a greater strain on an already under-supplied sector. Between relatively short implementation dates for MEES, the scale of PRS homes not meeting DHS, the costs involved in complying, combined with wider Renters’ Rights Bill reforms and high property values, may make for an appealing case for landlords to sell.

What impact would applying Awaab’s Law to the private rented sector have on landlords and will this affect housing supply in the private rented sector?

RICS have similar concerns to the previous answer but we recognised almost all landlords do work to create safe, high-quality homes so Awaab’s law should be supportive of their work – however in the PRS, many landlords also use letting agents for their property management. In the absence of the full implementation of Lord Best’s Regulation of Property Agents (RoPA) report, there is a risk many of those agents who are the tenant-facing side of landlords will need additional training and resource to action a tenants concerns.

New-Build Homes

How can the Government ensure that new-build homes are as high-quality as possible?

• Embed quality from the outset by aligning new-build requirements with the updated Decent Homes Standard, due to be finalised by the end of 2025. The revised standard places greater emphasis on energy efficiency, damp and mould prevention, and modern safety features—all of which should be designed into new homes, not retrofitted later.
• Ensure full implementation of the Future Homes Standard (FHS), which is set to come into force in 2025. The FHS will require new homes to produce 75–80% fewer carbon emissions compared to current standards. To be effective, this must be accompanied by robust enforcement, clear guidance for developers, and support for local authorities to monitor compliance.
• Introduce a national digital ‘building passport’ system for all new homes, capturing construction details, materials, energy performance, and maintenance history. This would support transparency, long-term asset management, and consumer confidence.

August 2025