Compliance
The Decent Homes Standard 2026 Update and Damp
The revised Decent Homes Standard treats damp and mould as explicit failure criteria. What that means for housing-association stock teams and the surveyors who serve them.
The Decent Homes Standard has been around since 2006. For most of its life it was an oblique instrument — a requirement that homes meet a basic threshold, with damp and mould tucked inside a generic "reasonable state of repair" criterion. The 2026 revision breaks damp and mould out as an explicit, named failure criterion, and paves the way for the standard to reach the private rented sector for the first time.
For housing-association stock teams and the surveyors who serve them, this is the most significant procedural change in fifteen years.
What the Decent Homes Standard is, briefly
The Decent Homes Standard sets a minimum quality threshold for social housing in England. A home is "non-decent" if it fails any of four criteria. Pre-2026 those were:
- It must meet the statutory minimum standard for housing (HHSRS)
- It must be in a reasonable state of repair
- It must have reasonably modern facilities and services
- It must provide a reasonable degree of thermal comfort
Damp and mould previously lived inside criteria 1 (via HHSRS) and 2 (via "reasonable repair"). The interpretation was elastic; some landlords treated visible mould as a category-2 repair issue, others as a category-1 hazard. Narrowing that variability is what the 2026 revision sets out to do — though, as below, it does so by naming the criterion rather than by publishing a measurement.
What changed in the 2026 revision
The Government published its response to the reformed Decent Homes Standard consultation, together with The New Decent Homes Standard: policy statement, on 28 January 2026. The revision takes the standard from four criteria to five, and the fifth — Criterion E — is damp and mould as a named, standalone failure criterion. The five are:
- Criterion A — free of the most dangerous (category 1) hazards
- Criterion B — in a reasonable state of repair
- Criterion C — provides core facilities and services
- Criterion D — provides thermal comfort
- Criterion E — free of damp and mould
The policy statement puts Criterion E in these terms: landlords "should ensure their properties are free from damp and mould", which means addressing damp and mould when tenants report it and taking a proactive approach to prevention. The published failure test is expressed through HHSRS: a home fails Criterion E where a damp and mould hazard is assessed within bands A to H — that is, everything except the mildest hazards at the bottom of the old A–J scale.
What is not published — and why that matters
You will find commentary — including, until this update, an earlier version of this article — quoting hard numeric trigger points for Criterion E: a contiguous mould area in square metres, a count of affected rooms, a number of days of sustained moisture, or an automatic fail for any mould in a room slept in by a young child or someone with a respiratory condition. We have checked the consultation document, the government response, the policy statement and the Awaab's Law guidance, and none of those figures appears in any of them. They were not proposed in the consultation and they have not been confirmed in the final standard. We have removed them rather than hedge them.
The Government has been explicit that this level of detail is still to come: the policy statement commits to further DHS guidance defining key terms, setting out practical examples, and covering the circumstances in which landlords cannot or should not meet parts of the standard. The Awaab's Law Phase 2 triaging guidance is blunter still, stating that it "does not include specific thresholds — for example, on specific temperatures, the amount of damp and mould present". Vulnerability is treated there as a factor that raises the assessed risk — the listed groups include children aged 14 or under and people with pre-existing conditions such as asthma or COPD — not as a numeric pass/fail switch.
So Criterion E does not remove surveyor judgement; it relocates it. The judgement now sits in the HHSRS assessment of the damp and mould hazard, and a professional, well-evidenced assessment is what decides whether a home passes. Two live uncertainties are worth tracking: the band-based test was published in the old A–J vocabulary, and the HHSRS overhaul that took effect on 23 June 2026 replaced those bands with High / Medium / Low — so how "bands A to H" is restated under the new scale is a question for the forthcoming guidance. And private landlords are not expected to carry out HHSRS assessments themselves, so the assessment route for the private rented sector is also still to be set out.
The PRS extension
Until 2026, the Decent Homes Standard applied only to social housing. The Renters' Rights Act 2025 provides for it to be extended to the private rented sector, and the Government's policy statement of 28 January 2026 confirmed that a single revised standard will cover both tenures. The date to hold on to is 2035: that is when the reformed standard applies in both the social and private rented sectors, enforced by the Regulator of Social Housing and by local housing authorities respectively. Detailed guidance — including on assessment method and exemptions — is due between now and then.
That brings roughly four and a half million private rented homes in England into scope, and the Government's own impact assessment expects a substantial share of them to fail the updated definition, mostly on disrepair rather than on damp and mould. The implication for damp surveyors is significant even with a 2035 date: PRS landlords will need periodic stock surveys of the kind housing associations have been commissioning for decades, and the ones who move early will be commissioning them well before the deadline.
What stock condition surveys should be capturing
Pre-2026 stock condition surveys typically captured damp and mould as a free-text observation. Because Criterion E turns on an HHSRS judgement rather than a checklist, the practical answer is not to guess at future thresholds but to capture the evidence that will support whatever the guidance ends up requiring. Nothing below is a published DHS requirement — it is the record that makes an HHSRS damp and mould assessment defensible, and it is what stock teams are already asking for:
- Mould area in square metres per affected room
- Number of rooms with any visible mould
- Moisture readings in walls and at known condensation points, with date stamps
- Occupancy and vulnerability data: who uses each room, and whether any occupant falls into a group the HHSRS and the Awaab's Law guidance treat as more vulnerable to damp and mould — children, older people, and people with respiratory or cardiovascular conditions
- Photographic evidence for each finding, time-stamped and geo-tagged
- A recorded Criterion E view — the damp and mould hazard assessment and the pass/fail conclusion you draw from it, held separately from the other four criteria so it can be re-stated if the guidance changes the band vocabulary
This data feeds the housing association's reporting to the Regulator of Social Housing. Stock teams that ran surveys on paper-and-Excel are moving to digital capture — partly for speed, partly because structured fields survive a change of definition in a way that narrative observations do not. If the DHS guidance lands in 2027 with a measurement rule attached, a structured back catalogue can be re-queried; a folder of prose cannot.
Implications for damp surveyors
Three things flow from this:
- Bigger volumes. Housing associations are retrofitting damp-and-mould-specific survey rounds across their stock. With a 2035 deadline and a criterion that rewards proactive prevention, the sensible landlord strategy is to survey early and repeatedly rather than wait for the guidance.
- Structured outputs. Free-text findings are no longer enough. Reports need to feed structured data into the association's asset management system. Surveyors who can provide CSV / API output have a meaningful competitive advantage.
- Higher consequences. A surveyor who under-states a damp and mould hazard or misses a vulnerability factor is now feeding a regulatory pass/fail, not just a repair recommendation. Because the test is a judgement rather than a measurement, the reasoning has to be on the page — the band, and why.
The intersection with Awaab's Law
The Decent Homes Standard and Awaab's Law operate in parallel, not substitution. Awaab's Law sets the response framework when a hazard is reported by a tenant. The Decent Homes Standard sets the proactive quality threshold for the housing stock.
In practice this means a housing association now has two damp and mould workflows: a reactive one (Awaab's Law timelines triggered by tenant reports) and a proactive one (Decent Homes-driven stock surveys to identify problems before tenants do). The same surveyor can serve both, but the data capture requirements differ slightly.
For background on the reactive side, see our piece on Awaab's Law for damp surveyors. For the PRS angle, see the Renters' Rights Act 2025.
What to do this quarter
If you're a surveyor or a stock team reading this in 2026, the practical to-do list is short and specific — and none of it depends on guidance that hasn't landed yet:
- Update your survey forms to capture mould extent numerically, per room, rather than as free text. No threshold has been published, but a number can be tested against a future one and "patchy mould to the reveal" cannot.
- Add structured occupancy questions covering vulnerability by room, using the HHSRS and Awaab's Law vulnerability factors rather than a self-invented list.
- Record the damp and mould hazard assessment and its Criterion E conclusion as its own field, with the reasoning attached.
- Diarise the DHS guidance. It is the document that will turn Criterion E from a principle into a procedure, and it is the one worth reading the week it appears.
- Confirm your photographic capture is time-stamped and geo-tagged. Loose photos won't survive a regulator inspection.
- Confirm you can export structured data, not just PDF reports, for stock-team clients.
SurveyMate's Awaab's Law and compliance module captures all of the above by default — that's the product's reason to exist. But the underlying message is independent of any particular tool: damp and mould have moved from a soft observation to a structured regulatory data field, and survey practice needs to catch up. For stock teams weighing up tooling, our compliance overview maps the full regulatory stack.
Run damp surveys for a living?
SurveyMate is the on-site damp and mould inspection platform built for UK surveyors and housing teams. Capture findings on your phone, generate branded PDFs in seconds, stay compliant with Awaab's Law by default.