Written evidence submitted Royal Institute of British Architects [HCE 058]

 

Royal Institute of British Architects

Housing, Communities and Local Government Committee inquiry:

Housing conditions in England

August 2025

 

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The Royal Institute of British Architects (RIBA) welcomes the opportunity to respond to the Housing, Communities and Local Government Committee’s inquiry on housing conditions in England. 

 

Recent data estimates that 15% of English housing stock is non-decent, and over six million people are living in poor-quality housing. Those living in poor-quality housing are twice as likely to have poor general health, and housing conditions alone have been estimated to cost the NHS £1.4 billion a year. Such housing also exacerbates existing inequality. The Marmot Review has recognised this, highlighting that housing conditions are “an increasingly significant driver of health inequality”, both in terms of physical and mental health outcomes. We are pleased that the Government has acknowledged this in its consultation on the Decent Homes Standard (DHS).

 

To improve our housing stock, there is a clear role for architects in helping to deliver high-quality homes. There is also a pressing need for further investment in the planning system and energy efficiency measures, which will ensure that housing stock is fit for purpose now and in the future.

 

RIBA recommends that the Government:

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

Housing stock in the UK is among the oldest and least energy efficient in Europe. Research by the Home Builders Federation has shown that England has 15% of its population living in a dwelling with a “leaking roof, damp walls and similar issues”, a greater proportion than the EU (14%). 

The most recent iteration of the English Housing Survey, from 2023-2024, estimates that 5% of dwellings in England had a problem with damp in 2023. The problem was most prevalent in the private rented sector (PRS), at a level of 9% of dwellings.

The survey also states that there has been a “notable increase in levels of dangerous damp and mould” in all tenures between 2019 and 2023, despite “improvements in the Decent Homes Standard, the reduction of Category 1 hazards [classified as hazards where councils have a duty to take enforcement action], and improvements to energy efficiency”.

There are a number of measures which must be taken to rectify these issues. We are pleased that the Government has recently committed to investing another £6.6 billion in the Warm Homes Plan. High-quality retrofit is vital, as poor installation can lead to wet insulation, mould, damage to roof timbers and potential reduction in air quality.

In 2021, the Government's Green Jobs Taskforce report found that the UK needs another 230,000 trained workers by 2030 to deliver retrofit for homes that need it. On a longer-term basis, in 2024 the Retrofit Academy has found that the UK will need 400,000 skilled retrofitters by 2050. To ensure high standards of installation and meet growing demand, the Government must invest in education and training for school leavers to pursue a career in retrofit and to upskill those already in the sector. 

It is also essential to implement steps to reduce overheating. Overheating is one of the 29 hazards identified in risk and hazard assessment tool, the Housing Health and Safety Rating System (HHSRS), as a significant public health problem. In 2022, a University of East London study found that 82% of homes in the UK reported being “uncomfortably warm”, with the UK Health Security Agency finding that there were an estimated 2,985 deaths associated with heat in the same year.

It must also be noted that exposure to housing hazards is not evenly represented across sociodemographic groups. Evidence from the 2022-2023 edition of the English Housing Survey has shown that in the social rented sector, 6.4% of households with a minority ethnic household reference person – used for census purposes to characterise a whole household – have a Category 1 HHSRS hazard fail compared to 3.5% of households with a white household reference person. More broadly, research by the Resolution Foundation has found that disabled people, and people from Pakistani or Bangladeshi, black, or mixed/multiple ethnic groups, were much more likely to be living in poor quality housing.

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

We welcome many of the changes proposed in the reforms of the DHS. As the Government’s consultation notes, not meeting Criterion B, the criteria for disrepair, is the most common reason for failing to meet the DHS in both the social and private rented sectors.

Updating the definition of disrepair to include components in poor condition, regardless of age, is a clear positive, as is the proposed reduction in the number of components in need of major repairs needed for housing to qualify as being in disrepair.

Another positive element of the proposed reforms is the introduction of window restrictors that can be overridden by adults. Windows are important for improving ventilation, so the ability to override a restriction is important if required. The previous 650mm restriction from the inside face of the walls can act as an impediment when building thicker walls, so the suggested increased 1100mm restriction is welcome.

The introduction of a new minimum damp and mould standard through Criterion E is also welcome. As set out in a previous question, damp and mould can have serious implications for both the physical and mental wellbeing of residents. Measures to make the DHS more “preventative, robust and explicit” on damp and mould are necessary to ensure that this is tackled.

However, a survey by the Local Government Association (LGA) found that the new, and necessary, increased requirements and demand for hazard mitigation, such as those required under Criterion E, will leave many councils with significant funding difficulties. This will also impact councils’ ability to build new affordable housing. To meet these new requirements, the Government must take action to avoid local authorities drawing on their existing reserves to meet the reformed DHS.

We are also pleased that the Government is proposing to set a Minimum Energy Efficiency Standard (MEES) for social housing, which will encourage improvements in thermal comfort in existing properties. We have set out more detail on this in the question on proposed MEES reforms below. 

The DHS could also consider other ways to improve the condition of social housing. To reduce overheating in homes, it should encourage a focus on passive solutions, such as shading and ventilation, to avoid overreliance on energy use for cooling. The Government should also consider the role of secure and, where necessary, acoustically attenuated nighttime ventilation to mitigate excess heat without exposure to excess noise. Additionally, we must stop over-glazing in both new buildings and extensions. As summer temperatures continue to rise, over-glazing will lead to more frequent problems with overheating.

Additionally, post-occupancy evaluation (POE) should be introduced as a mandatory requirement to support the continuous improvement of new homes. POE is the process of obtaining feedback on a building’s performance in use after it has been built and occupied. It collects information on building and energy use and user satisfaction, and informs building users if their building is energy efficient and is being used as intended. POE can be used, for example, to help ensure that homes are meeting required overheating standards and can also help to prevent damp and mould by identifying and addressing root causes and ensuring improvement in future.

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

As above, we are pleased that Government is consulting on the introduction of MEES for social housing. Introducing MEES, raising the EPC requirements for social housing, and introducing a requirement for landlords to meet the fabric metric will help to drive energy efficiency improvements, which are vital to addressing the energy and climate crises. These changes will help to reduce household energy bills, resulting in a sustained boost to the economy and consumption through increased disposable incomes in the long term.

However, the Government’s proposals do not go far enough, and we recommend that it implements targets for operational energy use for both new and existing buildings in the Building Regulations. These figures should be aligned with those that will be set out in the UK Net Zero Carbon Buildings Standard (UKNZCBS). We would therefore welcome operational energy as the key metric for MEES.

If the Government includes an energy use metric in EPCs, it will encourage architects, engineers, developers and building owners to be innovative and will reward good design based on form, orientation and fabric performance.

Understanding the fabric performance of a building could also incentivise fabric improvements, so we are pleased the Government’s proposals reflect this. Fabric efficiency should be a key consideration when retrofitting existing buildings. Any method of smart readiness or delivery heat should be secondary considerations as set out in the Government’s proposals.

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?

As outlined above, POE can be used to help monitor and improve the condition of homes.

Making POE mandatory can help reduce operational costs and provide data to increase understanding of how buildings are performing compared to their design intention. Using technology in POEs, such as environmental monitoring sensors and smart meters to record temperature, humidity, air quality and light, as a major part of the POE process would deliver huge value to architects, construction firms, buildings owners and occupants alike. 

The Smart Building Overlay to the RIBA Plan of Work advocates for the use of technology such as IOT sensors – often referred to as smart sensors, which take input from the physical environment – to monitor the way that space is used, allowing data to support monitoring and inform and optimise performance.

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

We welcome the introduction of the DHS for homes in the PRS. As the consultation notes, there is no currently comprehensive standard of decency in the PRS. This is an omission which has gone too long without rectification.

We are pleased to see that the Government proposes to grant councils greater powers to take action on criteria B, C (reasonably modern facilities and services), D (efficient heating and effective insulation) and E of the DHS, and impose a duty to take enforcement action where type 1 failures are identified.

However, effective enforcement of these duties and powers requires both resource and knowledge, which may impact the efficacy of the introduction of the DHS to the PRS. Government research from 2021 found that “few local authorities…had sufficient, comprehensive knowledge of the local private rented stock”.

Further to this, 2024 research from the LGA found that due to existing funding pressures, many councils may fail to meet statutory repair obligations for their own housing stock. Extending the DHS to the PRS will require further funding to ensure local authorities can comprehensively monitor and enforce it. As such, local authorities must be allocated additional resource to enable this, which should be separate to budget used to uphold standards in the social rented sector.

New-build homes

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

Primarily, the Government should ensure that properly trained people design new build homes in the UK. Architecture is a regulated and highly skilled occupation, and architects go through at least seven-years of training before becoming fully qualified. At present, not enough new homes are designed by architects which can result in poorly designed buildings. Given the impact that poor housing can have on those who live there, ensuring architects are involved from the outset of projects is vital.

The Government’s ambitious target of delivering 1.5 million homes over the course of this Parliament, alongside its longer-term ambition to create a new generation of new towns and urban extensions, provides an opportunity to utilise and showcase best practice in housing development.

High-quality design must be prioritised throughout the creation and delivery of housing. This will ensure that homes and places meet the needs of residents and communities in practice, and adhere to principles of safety, sustainability and accessibility. Not only does this have has wide-ranging positive impacts for both people’s health and wellbeing, but also the longevity of the built environment itself. Architects should be involved in the creation and delivery of all new homes to facilitate the use of innovative design solutions.

One way of achieving this is through an additional requirement we are recommending is added to the Planning and Infrastructure Bill. We welcome the Bill’s aim to implement strategic planning across England, with the purpose of delivering sustainable growth while meeting housing and infrastructure needs. RIBA has long called for a strategic, contextual approach to planning to be enacted through planning policy.

The Bill specifies that strategic planning will be carried out via the implementation of Spatial Development Strategies (SDSs), and we are pleased that SDSs will be required to provide a spatial strategy to guide local plans, and identify key infrastructure requirements and strategic locations or development. The inclusion of a requirement to distribute and apportion housing to ensure that it is in the most appropriate location is also welcome.  

However, we are concerned that there is currently no requirement for SDSs to set out a design vision for the area they cover. A design vision is a clear articulation of what an area or project should be like in the future, developed with the local community and stakeholders. This includes identity and character, sustainability and resilience, connectivity and accessibility, and user experience.  

To ensure that we not only deliver new homes, but that they are built to exemplary standards, high-quality design – in line with the above principles – must be a key consideration from the earliest possible stage. As such, we are calling for a requirement for SDSs to contain a design vision to be added to the Bill.

In addition, new housing development of any reasonable size should be comprised of different typologies and tenures to cater to the needs of different demographics. Not only does this create a sense of place, but allows for adaptability so people can stay in the same place across their life course and through changes of circumstance. This is also crucial to minimise the prevalence of overcrowding, which research has shown can have severe mental and physical health impacts, alongside correlating to a higher incidence of damp and mould.

We should take into account shifting patterns of demography when building new homes, providing flexibility and choice in terms of tenure and type. The homes we build should be suitable for the changing needs of our population, including different family structures and living arrangements. This includes implementing Part M4(2) of the Building Regulations as the minimum accessibility standard for all new homes. As such, the Government should bring forward the consultation on its implementation.

Resource in the planning system can be a barrier to the delivery of well-designed homes. Planning departments have experienced one of the most severe cuts in terms of real terms budget allocation from 2010 to 2020, with research showing that spending on planning is still down 40% from 2010/11.

Local authorities must be empowered and comprehensively resourced to promote high-quality placemaking, including the delivery of high-quality new homes. To do this, we must invest in planning teams with the skills and capacity to promote best practice in the design and building of our homes and places. This also requires investment in regional spatial planning if we are to deliver long-term infrastructure projects to drive growth.

To build good homes, we must also build good places: bringing homes, public transport options, schools and workplaces, retail, green space and community space within close proximity. This has positive implications for quality of life, health and wellbeing, and access to services and recreation. Neglecting to plan for homes and infrastructure in a strategic way can lead to adverse outcomes. Research has shown that a lack of integration in the planning process has led to an increase in the car dependency of new homes.

A considered approach to site selection for new housing is therefore crucial. It should prioritise areas where people want to live and where the need for development is most urgent, with data-driven site analysis being used to help understand this. 

The Government needs to ensure that new builds are energy efficient and comfortable to live in throughout the year. As mentioned in a previous question, we would like to see targets for operational energy use for new buildings in the Building Regulations. Noise disturbance and overheating should be mitigated and the Government should introduce POE as a mandatory requirement for new homes.

 

August 2025