‘Bring forward DHS and mandatory inspections for temporary accommodation’: sector responds to housing conditions inquiry

Regulator of Social Housing

The Regulator of Social Housing’s (RSH) evidence recognised that many landlords are “making significant efforts and considerable financial investment” to deliver safe homes.

Nevertheless, there remain examples where homes are not maintained in “good enough condition”, with the “vast majority” of non-compliant C3 and C4 graded regulatory judgements where landlords are failing to meet safety and quality standards.

On finance, the RSH told the committee that registered providers “continue to face pressure to improve stock quality and meet energy-efficiency requirements”, which is “increasingly resulting in boards having to make difficult decisions as to how to use cash resources most effectively”.

Housing Ombudsman 

The Housing Ombudsman told the committee that “property condition is the most complained-about category”, based on its casework data. According to the watchdog, there has been a “constant rise” in the number of these types of complaints, which cover defects, repairs, and damp and mould, among other issues.

On proposed reforms, the ombudsman said the DHS was “positive and to be welcomed”, but expressed concern about the proposed implementation dates of 2035 or 2037. “Implementation should be brought forward both in terms of improving property conditions and the impact on residents’ lives,” it told the committee.

Like the regulator, the watchdog also highlighted the pressure on social landlords, and warned that “strategic disposals of properties” could increase as landlords incur higher costs in order to meet new standards.

The ombudsman said: “We recognise there will be a balance to be struck. Social landlords will not be able to make a sustainable contribution to vital new homes without also having a strong strategic grip on how they will maintain these, alongside their existing stock and meeting a reformed standard.”

It suggested a series of measures the government could take to better support landlords, including the creation of a “single integrated system of redress” for the social and private rented sector as well as temporary accommodation. Its evidence highlighted the “obvious benefits” of an integrated system, since both the DHS and Awaab’s Law will apply to other tenures beyond the social housing sector.

“An integrated ombudsman service across all housing tenures would bring greater accessibility and simplicity to the redress landscape, benefiting both residents and landlords in terms of accessibility, consistency of outcomes and sharing learning,” the ombudsman told the inquiry.

It also repeated its call for the establishment of a national tenant body, which it first announced in May this year after revealing a 474% rise in repair complaints since 2019-20.

National Housing Federation

The National Housing Federation highlighted to the committee that the “majority of social homes are good quality and safe”, with 91% meeting the current DHS, which is a higher proportion than any other tenure. It also stressed that housing associations plan to spend around £50bn on repairs in existing homes over the next five years.

But the NHF recognised that there is still work to do, saying it has “fundamentally reassessed how it can and should maintain and improve residents’ homes” through the Better Social Housing Review in 2022.

On reforms to tackle poor conditions, the trade body said its members welcome the updated DHS bringing “additional clarity” in driving up standards, but highlighted the need for “additional grant funding from central government” to support this.

The NHF also said associations “strongly support the principle of Awaab’s Law” and are “investing significant resource and capacity” to prepare for its implementation. This includes the development of “specialist, dedicated teams to respond to damp and mould issues”, with the recruitment of “significant numbers of additional staff”.

“While the introduction of Awaab’s Law is a vitally important step, the additional costs it will place on social landlords are substantial,” the evidence added.

The NHF said the government’s £39 billion Social and Affordable Homes Programme is a “positive step” but stressed the need for “greater flexibility” to use funding for the regeneration of homes that are no longer fit for purpose. “There is a risk that, without additional flexibility in using SAHP grant funding for regeneration, housing associations will increasingly make the difficult decision to sell homes which would be too difficult or expensive to bring up to meet new standards,” it told the committee.

Chartered Institute of Housing

The Chartered Institute of Housing (CIH) said members have expressed “significant concerns” about the costs of the reformed DHS, minimum energy-efficiency standards and Awaab’s Law. CIH said the government’s various impact assessments of these measures “underestimate” the costs for landlords.

The membership body therefore recommended the establishment of a “long-term, multi-year investment programme for improving existing homes”, which would essentially function as a “new, modernised Decent Homes Programme”.

On temporary accommodation, CIH told the committee it “supports the extension of decency requirements” to this sub-sector, and said there should be a “requirement for national minimum standards including removal of any category-one hazards”.

It also warned that some providers of “quality” supported housing are “exiting this vital sub-sector” due to the ongoing lack of revenue and capital investment. “Whilst regulatory measures are needed and welcome, the lack of funding to support this continues to be a concern for CIH members seeking to maintain existing supported homes.”

Several other organisations raised serious concerns about the state of temporary accommodation.

Crisis

Crisis described the state of this housing as a “national scandal”.

The charity told the committee that, for many people, temporary accommodation “does not provide a safe environment”, and they are often “contending with things like mould and sometimes infestations”.

Its evidence continued: “Often, people feel that they have no choice but to accept unsatisfactory living conditions in temporary accommodation. The process of applying for help under the homelessness legislation and waiting for an offer of suitable temporary accommodation is often extremely challenging and distressing for the people we support.”

Like CIH, Crisis called on the government to apply the current and new DHS to temporary accommodation, among other measures such as an increase to the number of one-bedroom social homes to ensure more people experiencing homelessness are able to access housing.

Justlife

Justlife stressed to the committee that the “appalling conditions” in temporary accommodation are “out of control”. The charity said this sub-sector is “always treated differently” due to residents being seen as “deserving of their situation” or concerns about landlords leaving the market. This results in “rules not being applied” when it comes to temporary accommodation.

To tackle this, the charity recommended new legislation creating standards specifically for temporary accommodation, alongside an “independent regulator overseeing their enforcement”. “We have regulators for all other statutory services, and there is an equal or even greater need in the temporary accommodation sector,” it told the committee.

Shared Health Foundation

The Shared Health Foundation (SHF) charity, which aims to combat the negative impact of poverty on health, also pointed to the “lack of regulation around the standards of temporary accommodation”. This means there are “few barriers to stop rogue landlords from leaving their properties in disrepair or hazardous conditions”. The charity’s key areas of concerns are the prevalence of mould and the consequences for children, lack of facilities, disrepair and overcrowding.

Similar to the ombudsman, the SHF warned that the 2035 implementation date for the DHS is “too far away”.

“It is vital these measures are introduced immediately to prevent harm to children, particularly in the case of child mortality,” the charity told the committee.

It also recommended mandatory inspections of temporary accommodation properties, since councils are “unaware of the state of disrepair”.

“If local authorities were required to carry out mandatory inspections of the properties they procure as temporary accommodation and report to the Ministry for Housing, Communities and Local Government, there will be a greater chance of standards being upheld and more accountability for temporary accommodation landlords to maintain their properties.”

Local Government Association

The Local Government Association (LGA) also provided evidence to the inquiry, telling the committee that councils are “at the sharp end of the housing and homelessness crisis”.

Given that 131,000 households – including 169,050 children – are now living in temporary accommodation, the LGA said costs are “unsustainable” and they “divert resources away from delivering the genuinely affordable homes that prevent homelessness in the first place”.

“Against this backdrop, any new prescribed standards for temporary accommodation should be implemented carefully to avoid inadvertently reducing supply in the short to medium term, given the extreme pressures councils face in sourcing suitable accommodation,’ its evidence said.