The New Decent Homes Standard: What It Means for Building Condition Evidence

Five criteria, five tests

A home meets the Decent Homes Standard only if it passes all five criteria simultaneously. Criterion A: free from category 1 hazards under the HHSRS. Criterion B: key building components in a reasonable state of repair. Criterion C: reasonably modern facilities and services. Criterion D: a reasonable degree of thermal comfort. Criterion E: free from damp and mould. Failing any one means the home is non-decent.

Criterion A: free from serious hazards

The HHSRS covers 29 hazard types. Several relate directly to the building envelope: damp and mould, excess cold, excess heat, structural collapse, falling elements and fire. A deteriorating roof, failed insulation, cracked render or defective cladding can each contribute to a category 1 hazard. Demonstrating compliance requires evidence that no category 1 hazard exists, and for hazards linked to the building fabric, that means holding current condition data for the external envelope.

Criterion B: in a reasonable state of repair

This criterion directly assesses building components. A home fails if one or more key components need repair or replacement, or if two or more other components need repair. The standard defines 14 key component types including wall structure, roof structure, roof covering, windows, external doors, chimneys, kitchens, bathrooms, electrical systems, heating systems, fire alarms, sprinklers, fire signage and mechanical ventilation, plus 3 other component types: rainwater goods, balustrades and door entry systems.

A single key component in poor condition is enough to fail. For any landlord managing multi-storey buildings, wall structure, roof structure, roof covering, windows, external doors, chimneys and rainwater goods are all elements of the building envelope that are difficult to assess from ground level or from inside the property.

Criterion D: reasonable thermal comfort

The standard sets energy performance targets: EPC Band C or above by 1 April 2030 for both social and private rented housing. The thermal performance of a dwelling is determined not just by the heating system but by the fabric through which heat is lost. Insulation failures, thermal bridging, draughty windows and uninsulated roof spaces all reduce effective performance regardless of how modern the boiler is.

Thermal imaging of the external envelope can detect insulation voids, cold bridging, air leakage paths and areas of anomalous heat loss that an EPC assessment alone will not reveal.

Criterion E: free from damp and mould

The entirely new criterion. Landlords must ensure properties remain free from damp and mould. This goes beyond the HHSRS hazard assessment: a property could pass Criterion A (no category 1 damp hazard) while still failing Criterion E if any damp or mould is present.

For the building envelope, this means understanding where moisture enters the building fabric. Rising damp, penetrating damp from failed roofing or pointing, condensation from cold bridging or insulation failures: each has a source in or around the external envelope. Internal inspections identify where moisture is presenting. Identifying where it is entering requires external evidence.

Which criteria need building condition evidence

Four of five criteria have a direct connection to the condition of the building envelope. Criterion A links to HHSRS hazards caused by external building condition. Criterion B requires assessment of seven external key components and all three other components. Criterion D depends on building fabric thermal performance. Criterion E requires understanding moisture entry points in the envelope.

If your condition records only cover the interior of the property, you are evidencing less than half the picture.

The connection to Awaab's Law and the golden thread

The Decent Homes Standard sits alongside Awaab's Law, which sets statutory timescales for investigating prescribed hazards, and the golden thread, which requires digital condition records for higher-risk buildings. These three obligations reinforce each other: the Decent Homes Standard tells you what condition the building must be in, Awaab's Law tells you how quickly you must act when it is not, and the golden thread tells you what records you must keep.

Holding structured, dated, graded condition evidence for your building envelopes serves all three simultaneously. Not holding it creates a gap in each.

How building condition intelligence supports compliance

High-resolution visual inspection of every elevation and roof zone covers every external component at close range. Radiometric thermal imaging identifies insulation failures, moisture paths and heat loss for Criteria D and E. Graded, located, costed findings map directly to the Criterion B assessment. AI-assisted detection with human validation delivers consistency across the portfolio. All evidence is held in Atlas as a persistent digital record.

On repeated inspection cycles, the same methodology allows year-on-year comparison, evidencing whether components have improved after remediation, remained stable, or deteriorated.

Timeline: what to do now

The full compliance deadline is 2035, but milestones arrive sooner. Awaab's Law Phase 1 is already in force (damp and mould timescales are live). Phase 2 extends to excess cold, heat, fire, structural and electrical hazards in 2026. MEES Phase 1 requires EPC Band C for new tenancies by 1 April 2030. Landlords managing large portfolios cannot assess every building in year nine and expect to achieve compliance.

Start with the buildings you know least about: those where external components have been recorded as 'not inspected.' Prioritise buildings with known complaints. Assess higher-risk buildings first, where golden thread obligations add to the evidence requirement. Build the evidence into your CAPEX plan so the investment programme is in place before the compliance deadline.

Which criteria need building envelope evidence: