Somewhere between the last EPC upload, the latest damp & mould case review, and the consultation on DHS+ compliance… something shifted.

We’re heading toward a new Decent Homes Standard but the path is unclear. And that ambiguity is already shaping how landlords behave, how boards make decisions, and how residents experience their homes.

This edition explores how the looming DHS+ reform is influencing compliance strategies, risk registers, and capital budgets right now long before the policy is finalised. Because whether or not the standard has arrived, its shadow already has.

👻 The Ghost in the Machine

Ask most asset teams about DHS+, and you'll get the same answer:

And yet look deeper, and you’ll notice it's already changing things.

• Damp & mould risk is now shaping Board assurance conversations, with many organisations proactively reviewing case management and reporting to avoid the reputational and regulatory fallout seen in recent high-profile cases (like the tragic Awaab Ishak case).

• Localised EPC shortfalls are driving reactive retrofit plans, as landlords try to pre-emptively address properties at risk of failing future energy efficiency requirements.

• Capital budgets are being reprofiled with DHS+ “in mind” even if nothing’s confirmed leading to a reallocation of funds toward compliance-related works and away from discretionary improvements.

This isn’t just anticipation. It’s action based on ambiguity and that’s a powerful, sometimes risky, force.

Working Without a Map

One of the sector’s sharpest pain points is the lack of a clear route to compliance. We know the direction health, safety, decency, sustainability but the criteria are still evolving. The government’s consultation on Decent Homes Standard 2 (DHS+) has signalled tougher standards, but the specifics remain in flux.

This is driving:

• Over-cautious investment — focusing spend on visible wins (like tackling damp, mould, and insulation gaps) rather than longer-term value (like whole-house retrofit or digital infrastructure).

• Compliance inflation — where landlords start treating every minor gap as a potential regulatory breach, increasing costs and administrative burden.

• Operational drift — especially when service teams and strategy leads don’t share the same interpretation of “decent”, leading to inconsistent delivery and resident confusion.

In short: Everyone’s moving. But not always in the same direction.

Decency Meets Data Fatigue

There’s another layer.

Landlords know their DHS+ readiness will be judged on data. But the data systems, surveys, and dashboards in many organisations aren’t calibrated to this new lens.

• Stock condition data is often incomplete, out of date, or siloed by department.

• EPC ratings may not reflect recent works or the lived experience of residents.

• Complaints and repairs data are rarely integrated into strategic asset planning.

That’s creating a new tension:

• Do we pause investment while improving data, risking delays and resident dissatisfaction?

• Or invest based on partial data and risk misfiring, spending money on the wrong priorities or missing hidden risks?

Either choice carries risk — reputational, financial, or compliance-based. The only certainty is that inaction is now its own kind of liability.

What We’re Seeing on the Ground

Across the sector, these patterns are emerging:

• Stock condition strategies are pivoting — from "refresh the 5-year cycle" to "triage by risk and regulatory exposure," with more frequent, targeted surveys on high-risk archetypes (e.g., pre-1919 terraces, system-built blocks).

• Void standards are tightening — as landlords use relet opportunities to quietly lift DHS+ compliance, upgrading insulation, ventilation, and fire safety features before new tenants move in.

• Legal and comms teams are getting involved earlier — helping shape the narrative around what’s considered “reasonable” improvement, and preparing for increased scrutiny from regulators, the Housing Ombudsman, and the media.

• Resident engagement is rising — with more landlords piloting resident panels and co-design sessions to define what “decent” means in practice, beyond the technical minimum.

This isn’t just technical. It’s cultural. The sector is moving from compliance as a tick-box exercise to a more holistic, risk-based, and resident-centred approach.

So What Should We Do?

Until the full DHS+ framework lands, here's how landlords can lead with intent not fear:

1. Frame the Standard Internally Now

Don’t wait for government to define “decent”. Start your own internal definitions, linked to resident health, condition insight, and risk appetite. Use resident feedback, complaints data, and lessons from serious cases to shape your priorities.

2. Triangulate, Don’t Isolate

Align compliance, complaints, repairs, and asset data into a shared DHS+ view especially for high-risk archetypes. Invest in data integration and analytics to spot emerging risks and target interventions.

3. Model Scenarios

Run 3–5 investment and compliance scenarios based on likely versions of the standard and use these to test your delivery and resourcing assumptions. Build in flexibility to pivot as the policy picture clarifies.

4. Upskill Strategically

Prepare teams for wider ‘decency’ conversations — health risk, net zero, resident experience not just SOR codes and lifecycles. Invest in training on damp and mould, retrofit best practice, and effective resident communication.

5. Engage Residents Proactively

Don’t just inform involve. Set up resident panels, surveys, or focus groups to co-design your approach to “decent homes.” This builds trust and helps ensure your strategy reflects real needs.

6. Strengthen Governance and Assurance

Review Board and executive oversight of decency and compliance risks. Ensure there’s a clear line of sight from frontline issues (like damp and mould) to strategic decision-making.

Final Thought

Decent Homes 2 might still be in draft but the sector’s behaviour is already shifting. The risk now isn’t just non-compliance. It’s waiting passively for clarity while the expectations (and pressures) grow around us.

The smartest landlords are moving before the standard lands, using the current ambiguity as a catalyst for innovation, collaboration, and culture change.

Because sometimes, the most dangerous ghost in the machine is the one no one’s willing to name.

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