PPR’s response to DFC consultation on the Decent Homes Standard: a missed opportunity
The DFC seem to have consulted on updates to the Decent Homes Standard, not in the interest of actual improvements for social tenants, but mainly so as to be seen to have done so.
The DFC’s Decent Homes Standard, which sets the bar for the condition of the Housing Executive’s roughly 83,000 (and housing associations’ nearly 60,000) social homes, dates from 2004. Its legally binding bit– applicable to all residential properties in the north – is the ‘minimum fitness standard’ defined in section 46 of the Housing (NI) Order 1981 (and explicitly extended to private tenancies by the Private Tenancies (NI) Order 2006).
In addition to this legal minimum, the 2004 Decent Homes Standard also requires social homes to be in ‘a reasonable state of repair’, with ‘reasonably modern facilities and services’ and ‘a reasonable degree of thermal comfort’. What it lacks -- even after the DFC’s consultation -- is accessible and transparent mechanisms that tenants can use to ensure their landlord’s property meets the standard in practice. (Responsibility for inspections of private rented properties fall to councils, and those of social homes, to the Housing Executive itself).
The Decent Homes Standard has not been updated since 2004, though a 2016 consultation presented “options for change”. (The 2016 consultation document is no longer publicly available; PPR requested a copy by Freedom of Information in autumn 2025 but the DFC refused, claiming a ‘policy development’ exemption on the basis of this current consultation.)
In the current consultation papers, at any rate, the DFC seems to present little in the way of “options for change”. Real opportunities for substantive improvements – for example by emulating the examples of the Housing Health and Safety Rating System brought in to monitor compliance with the Decent Homes Standard in England and Wales, and their 2025 Awaab’s Law giving tenants scope to take landlords to court over mould, damp and other health threats, have been passed over in favour of the status quo.
The purpose of the exercise appears to have been, at least in part, simply to update the Decent Homes Standard’s 20-year-old wording to match subsequent building regulations and Housing Association Guide content.
New text (on lifts, communal areas and fire risk assessment, for instance) is specific to flats -- highly relevant given the recently announced decision -- grounded in regulations in England and Wales that also have not yet been brought in here -- to evacuate the Housing Executive’s Carnet House tower block due to fire safety concerns. But regulation-based additions hardly need consultation.
In addition, the DFC have chosen to add a host of aspirational elements (from smart meters and electric vehicle charging points to more basic components like recycling, storage and drying space), framed as ‘desirables’ only. Its consultation asks whether these have public approval – but given that it doesn’t propose to make them binding anyway, it’s hard to see the point.
Equally telling are the elements that remain unchanged. ‘Reasonably modern facilities and services’ still means, at a minimum, a 20-year-old kitchen and a 30-year-old bathroom. A home in which both are older than that would, as before, still meet Decent Homes Standard unless it failed in a third area.
The DFC seem to have consulted on updates to the Decent Homes Standard, not in the interest of concrete changes to make it more impactful and useful for social tenants, but mainly to be seen to have done so.
PPR’s full consultation response can be found here.