The consultation on a Reformed Decent Homes Standard (DHS) for social and privately rented homes closed on 10 September 20251. The Chartered Institution of Building Services Engineers (CIBSE) submitted a response, published on its site, setting out where it supports the proposals and where it wants more detail1.
CIBSE said it supports the general direction of upgrading standards and aligning expectations across the social and private rented sectors1. Under the proposals as CIBSE describes them, the private rented sector would be brought within the DHS, while the social rented sector would become subject to Minimum Energy Efficiency Standards (MEES)1. CIBSE states that the current MEES requirement, EPC F, is "wholly inadequate to reduce fuel poverty and provide healthy and comfortable homes"1.
On energy performance, CIBSE agrees the fabric criterion should be used from the proposed new EPC metrics to reduce fuel poverty risk, but its support for applying MEES in the social rented sector is conditional on points it made in the EPC consultation1. It describes the proposed fabric metric, FEES, as "highly theoretical and not measurable" and recommends alternative metrics1. CIBSE also supports new damp and mould requirements in principle, but notes these rely on the Housing Health and Safety Rating System (HHSRS), which it says has not been updated for two decades, and recommends a further review so the HHSRS bands rest on the latest evidence1.
"CIBSE are in support of the general direction i.e. 1) upgrading standards, and 2) aligning expectations in the social and private rented sectors"
Other points in the response cover ventilation, electrical systems, window safety and overheating. CIBSE welcomes the addition of mechanical ventilation systems to the list of items that must be kept in a good state of repair, but recommends this be expanded to all ventilation systems, including local extract fans, and that definitions cover good operation rather than basic repair1. It recommends more attention to the standards required of electrical systems, which it says have evolved significantly since the DHS was last updated1. It supports requirements for window safety, while flagging the risk of restrictors increasing overheating if they excessively limit airflow1. On overheating, CIBSE strongly recommends reviewing the reliance on the HHSRS and the option to strengthen DHS requirements1.
| Area | CIBSE position |
|---|---|
| Overall direction | Support for upgrading standards and aligning sectors1 |
| Social rented sector and MEES | Support in principle, conditional on EPC consultation points1 |
| Fabric metric (FEES) | Described as highly theoretical and not measurable1 |
| Damp and mould requirements | Support in principle; HHSRS evidence questioned1 |
| Ventilation | Expand repair duties to all systems and cover operation1 |
| Electrical systems | More attention recommended1 |
| Window safety | Support, with overheating caveats1 |
Why it matters for households
The DHS sets the baseline conditions that social and privately rented homes must meet, so changes to it shape what tenants can expect on heating, insulation, damp, ventilation and safety. Bringing private rented homes within the DHS and social rented homes within MEES would extend energy efficiency duties across both sectors, which bears directly on a home's running costs and its ability to stay warm affordably. CIBSE's reservations matter because the metrics chosen determine whether improvements are actually delivered: a fabric metric it calls unmeasurable, or a damp and mould regime resting on two-decade-old evidence, could leave households in the same conditions the reforms aim to address. The ventilation and overheating points connect to health outcomes, particularly for households on low incomes or with older members, which CIBSE notes are more likely to experience overheating1.
What happens next
The consultation closed on 10 September 20251. No government response or timetable for the reformed standard has been reported. CIBSE's full response is published on its site1.