It’s been over a decade since the Anti-social Behaviour, Crime and Policing Act 2014 introduced the ASB case review, originally known as the community trigger. Designed to give victims of persistent anti-social behaviour a voice, the review was intended to ensure agencies stepped back, re-evaluated and asked: Have we truly done all we can?

Yet here we are, 11 years on, and this vital mechanism remains underused and widely misunderstood.

Too often, the review is mistaken for a complaints procedure – a perception that leads to reluctance among some practitioners to initiate it. But the ASB case review is not about assigning blame; it’s about collaboration, reflection, and problem-solving. At its heart, it’s a second chance to get things right for victims who have been let down by the initial response. Of equal concern is the inconsistency in how reviews are conducted across the country: some areas invite the victim to participate in the process, while others don’t. Some meetings are run with care, structure, and professionalism; others feel disorganised or lack focus. This variation can undermine trust in the process and further isolate victims.

Victim involvement isn’t just a box-ticking exercise; it’s essential. It is the thread that connects agencies’ decisions with real-life impact. Giving victims a voice in the review meeting ensures the human cost of ongoing ASB isn’t lost in paperwork or policy.

Changes are underway, with the Crime and Policing Bill proposing reform, particularly concerning accountability, meaning there’s an opportunity to breathe new life into the ASB case review. But legislation alone won’t drive change: culture, training and awareness must evolve alongside policy.

Consequently, RHE Global is launching a new online course this autumn, designed to support ASB professionals in delivering better reviews that have greater consistency. Led by seasoned expert Anna Smith, this training will explore what good practice looks like and how to engage with victims meaningfully, as well as provide tips for running effective and purposeful meetings.

If we want the ASB case review to fulfil its potential, we need to stop treating it as an administrative burden and start seeing it as a lifeline – a critical tool to ensure victims aren’t left unheard or unsupported.

Training details and course dates will be available from September 2025 and can be found here. 

It’s time to raise the standard and put the ‘review’ back into the ASB case review.

The UK Government’s consultation on a reformed Decent Homes Standard (DHS), launched in July 2025, marks another major milestone in the evolution of housing quality regulation in England. The Decent Homes Standard (DHS) has long served as the primary benchmark for housing quality in England’s social rented sector (SRS). However, the government’s 2025 consultation aligns the DHS more closely with modern housing expectations in quality, safety and energy efficiency standards. The new standard also proposes extending its mandate to the private rented sector (PRS) for the first time, anticipated through the Renters’ Rights Act, currently progressing through parliament. 

The Decent Homes Standard was originally introduced in 2000. It was updated in 2006 to reflect the introduction of the Housing Health and Safety Rating System (HHSRS) under Part 1 of the Housing Act 2004. The process of review began with the publication of the Social Housing White Paper in November 2020, in which the previous government pledged to review whether the current DHS remained suitable for the social housing sector. This was followed by the Levelling Up White Paper published by the previous government in February 2022, which set a national target to halve the number of non-decent rented homes, both social and private, by 2030. A two-stage review process followed: Stage 1 (2021) focused on the suitability and modernisation of the standard for the social sector; Stage 2 (2022) consulted on its potential extension to the PRS. More recently, in its October 2024 consultation on future social housing rent policy, the Government reaffirmed its intention to consult on a reformed DHS. 

The standard
The current consultation proposes to retain and update the four core DHS criteria while introducing a fifth explicitly to address damp and mould. The Government proposes that the DHS will be supported by updated definitions, usability assessments (i.e. based on condition, safety and layout rather than age thresholds) and prescribed ‘building component’ standards. Each criterion is summarised below:

Criterion A: Free of serious hazards (HHSRS)
A home must be free of any Category 1 hazard as defined by the HHSRS and associated regulations. The criterion refers to the absence of Category 1 hazards, but does not in itself replace local housing authority HHSRS enforcement powers. This criterion reinforces the importance of the HHSRS but also highlights the need for joined-up inspection protocols between hazard-based and standard-based enforcement tools. We discuss the interplay between DHS and the HHSRS further in the article below.

Criterion B: Maintains a reasonable state of repair
Under the proposed standard, building components no longer need to be both old and in disrepair to fail the standard, removing age thresholds from the definition. Key building components (e.g. roofs, external walls, windows, boilers, chimneys, heating systems and electrics) must not be in poor condition and the standard defines disrepair for both 'key' and 'other' building elements. Key building components refer to those that, if in disrepair, could compromise the structure or present major health or safety risks. Other building components such as internal doors, flooring, plasterwork, skirting boards and rainwater goods must also be in a reasonable state of repair. Under the revised DHS, a property will be considered non-decent if it has either:

• One or more key building components that are not in a reasonable state of repair, or

• Two or more other building components that are not in a reasonable state of repair.

Criterion C: Provides reasonably modern facilities and services
This criterion focuses on the functionality, safety and usability of facilities. The consultation proposes a shift away from rigid age thresholds (e.g. kitchens being less than 20 years old, bathrooms being less than 30 years old) towards a condition and layout-based assessment. A home should have a kitchen and bathroom in functional condition, with a safe layout, appropriate storage, lighting and usability. In addition to kitchen and bathroom usability, a decent home must have appropriate window restrictors for safety, a safe and compliant electrical system, effective ventilation to manage moisture and condensation and safe, suitable flooring, particularly in wet or high-use areas. The consultation also considers introducing minimum security standards and requiring floor coverings to be provided in all rooms at tenancy start. 

Criterion D: Offers a reasonable degree of thermal comfort
The revised standard strengthens expectations around energy efficiency and whole-home warmth. It replaces the previous requirement for heating in the living room and at least one other room with a broader requirement for fixed, efficient heating systems capable of providing adequate warmth throughout the entire dwelling.

The revised DHS also proposes alignment with other energy-related policies, such as the Minimum Energy Efficiency Standards (MEES) in the PRS and the target for all homes to reach EPC Band C by 2030. In addition to heating, the criterion includes adequate insulation and fabric improvements to ensure homes are thermally efficient and are affordable to run.

Criterion E (proposed): Free of damp and mould likely to cause harm to health
This new criterion reflects the lessons of the Awaab Ishak inquest and underpins Awaab’s Law, which establishes statutory timeframes for landlords to investigate and remedy hazards like damp and mould. The inquest into Awaab’s tragic death in 2020 highlighted systemic failures in landlord response, communication and accountability. As a result, Awaab’s Law introduces a clear legal duty to act within 24 hours for emergency hazards and within 7 days for repairs. The proposed Criterion E directly aligns with these requirements. It puts forward a legal requirement for homes to be free of:

• Black mould growth (regardless of cause)

• Structural damp penetration or rising damp

• Persistent condensation, typically from poor ventilation or insulation

• Inadequate heating or ventilation systems, or damaged building fabric.

The consultation also calls for views on:

• Introducing best practice guidance to sit alongside the DHS, including information to landlords on how they might voluntarily exceed the minimum requirements

• Making compliance with the DHS an enforceable requirement in the private rented sector by 2035 or 2037, and a regulatory requirement in social housing over the same timescales

• How regulators and enforcement authorities should respond where landlords are unable to meet the standard due to limitations associated with the building, the tenant or the landlord’s own capacity.

Modelling its impact
In preparation for the public consultation, the Ministry of Housing, Communities and Local Government (MHCLG) published a technical EHS modelling briefing (English Housing Survey Briefing: Modelling a Revised Decent Homes Standard (2024), outlining how changes to the DHS would impact the classification of non-decent homes. The modelling uses the 2022 English Housing Survey to estimate how the new and updated criteria would shift compliance levels across both sectors. Based on the most recent data, the proportion of non-decent dwellings in England was 15%, based on the current standard. However, when applying the new standards:

• In the social rented sector, non-decency would rise from 12% to 40%, affecting 1.6 million homes

• In the private rented sector, it would jump from 23% to 47%, impacting 2.2 million homes.

This increase is driven largely by updated disrepair and thermal comfort requirements, as well as the introduction of Criterion E, which focuses on damp and mould. The modelling also found that 81% of non-decent social homes and 71% of non-decent PRS homes would fail only one DHS criterion. This suggests that while the overall number of homes classified as non-decent under the revised standard will increase substantially, the majority of interventions may be targeted to address just one major failing, such as inadequate insulation, outdated heating systems or visible damp and mould. In practice, this might enable local authorities and landlords to prioritise resources, addressing the most common and critical deficiencies without requiring wholesale refurbishment in many cases. 

Importantly, the scale of impact is significant, with over 9 million individuals estimated to reside in homes across both the PRS and SRS that would need to be brought up to standard through this reform. These individuals include vulnerable residents, such as older adults, families with children and those with pre-existing health conditions, who stand to benefit most from improved housing safety, thermal comfort and moisture control. The additional compliance costs associated with moving to a new, higher standard are estimated in 2019 prices, at £836 million for the SRS, and £2.4 billion in the PRS, assuming all currently non-decent homes are brought up to the proposed standard without grants or phased implementation.

DHS and the Housing Health and Safety Rating System (HHSRS)
The HHSRS remains the statutory framework for hazard assessment under the Housing Act 2004, enforced by local authorities. The DHS complements rather than replaces the HHSRS. Criterion A (hazards) and Criterion E (damp and mould) are particularly linked. However, a home may still fail DHS while being HHSRS-compliant, or vice versa. In parallel with the DHS reform, the Government has also concluded its review of the HHSRS, delivered by us at RHE Global. The review’s headline outcomes, published by the Government in September 2023, include:

• Reviewed and updated HHSRS operating and enforcement guidance

• Reviewed and updated guidance for landlords and property-related professionals and the introduction of new guidance for tenants

• A simpler means of banding the results of HHSRS assessments

• Amalgamation of existing hazard profiles, reducing the number of hazards from 29 to 21

• Creating a new set of baseline indicators (or minimum standards) for key hazard areas (e.g. excess cold, damp, fire safety)

• Review of the ‘Fire Safety Hazard’ to ensure the risk of fire in tall buildings can be assessed effectively

• A new and updated suite of case studies (‘worked examples’) across all prescribed hazards and based on the recommended changes

• Recommendations for introducing a digital assessment tool for consistent enforcement and training competency requirements.

The revised DHS will operate as a condition-based benchmark that defines a decent home, while the HHSRS will remain the legal tool for risk-based enforcement under the Housing Act 2004. The Government is seeking feedback on how these frameworks can best align in practice, and acknowledges the need for clear guidance to avoid duplication, overlap or inconsistency in enforcement.

For local authorities, this reinforces the need to integrate DHS assessments within existing housing inspection processes and to develop robust protocols for when a dwelling may fail the DHS but not meet the threshold for HHSRS enforcement. The consultation seeks views on how to clarify this dual operation in practice, including how local authorities can apply both frameworks effectively without duplication or legal conflict.

Regulatory and legal implications
The consultation proposes two potential implementation dates by which compliance with the Decent Homes Standard would become a statutory requirement across both sectors: April 2035 or April 2037. These timelines would make the DHS an enforceable duty for landlords in the PRS and a regulatory obligation for providers in the social housing sector. The Government is seeking views on which option allows sufficient time for landlords, local authorities and the Regulator of Social Housing to prepare for the necessary infrastructure, guidance and enforcement frameworks. Until then, voluntary adoption and best practice will be encouraged, supported by enhanced inspection protocols, digital compliance tools and performance monitoring. 

The proposed Decent Homes Standard (DHS) will have important implications for both the social and private rented sectors. In the SRS, the DHS is expected to become a tenant-facing compliance obligation. Landlords would be required to publish data on their compliance with DHS criteria, inform tenants about how their home meets each of the five DHS criteria and involve tenants in inspection and remedial planning processes. These proposals reflect the wider tenant empowerment and an accountability agenda set out in the Social Housing (Regulation) Act 2023.

In the PRS, the DHS would be enforceable by local housing authorities using their powers under the Housing Act 2004. The consultation indicates that:

• DHS compliance could be monitored through the PRS Property Portal

• Landlords may be required to complete self-assessments and submit evidence

• Local authorities would be expected to implement risk-based inspection strategies using both DHS and HHSRS frameworks.

The consultation acknowledges that the proposed dual-framework, combining the HHSRS (risk-based hazard assessments) with the reformed DHS (standard-based compliance system), presents several operational challenges. The DHS will set enforceable minimum standards for housing decency, while the HHSRS will remain the legal tool for assessing serious health risks. A home might fail the DHS without triggering enforcement under the HHSRS (e.g. a kitchen that is outdated but not hazardous). DHS breaches, such as ‘functional’ facilities or insufficient insulation, may not always meet the thresholds for hazard-based action. Clear statutory guidance will be needed to support consistent enforcement.

In social housing, non-compliance may be actionable through the Housing Ombudsman or the Regulator of Social Housing. In the PRS, the consultation proposes that DHS compliance could be linked to future redress schemes, offering tenants an alternative enforcement route beyond local authorities. Local authorities will play a key role in monitoring compliance and taking enforcement action. The consultation recognises the resource implications and proposes operational support which may include standardised guidance, training and a centralised compliance database, potentially integrated with other PRS systems.

Final thoughts
The reformed Decent Homes Standard has the potential to raise the bar for housing quality across both the social and private rented sectors when combined with Awaab’s Law, MEES and the proposed updates to the Housing Health and Safety Rating System (HHSRS), as examples. However, the success of this new framework will depend on legal clarity (including how the DHS and other regulations, including the HHSRS, operate in tandem), the operational capacity of housing providers and enforcing authorities to implement those changes and achieving consistency in the delivery of improvements across tenures. 

The Government rightly notes that an effective standard must be clear, practical and enforceable. Whether you are a tenant, landlord, agent, housing provider or local authority officer, now is the time to give your views and help shape these proposals to deliver a system capable of delivering a reformed system which is best placed to achieve its aims.

The past few weeks have put a major spotlight on The Noise App, with national media features that have helped raise awareness, resulting in a surge of new users to the platform.

Our Sales Director Jonathan Williams appeared on BBC Radio Wales with presenter Jason Mohammad to discuss how The Noise App is helping to tackle neighbour noise complaints across the UK. Jon provided a practical overview of how the app works, from logging initial complaints to a walkthrough of how recordings are utilised by local authorities to support investigations. It was a great opportunity to share how technology is making it easier for both the public and professionals to address noise issues effectively.

In the same week, The Noise App was also featured on the BBC’s Morning Live, giving viewers a look at how simple it can be to report ongoing noise problems through the app. The coverage generated a significant increase in downloads and activity, as more people were introduced to a fast, accessible way to document and resolve noise disputes.

You can check out our Morning Live feature on BBC iPlayer, at 30:30, here. 

This media attention marks an exciting moment for us, as The Noise App continues to gain recognition as the go-to solution for noise-related complaints. Being featured on both radio and television in the same week highlights the growing relevance of its efficacy and the real impact it’s having for communities across the UK.

We’re proud to be making noise for all the right reasons, and we’re just getting started!

If you’d like to find out more about what The Noise App can do for you, don’t hesitate to get in touch.

The latest updates and insights from RIAMS Chief Editor Jeremy Manners

Welcome to the July edition of RIAMS Unpacked, where I’ll give you a quick update on what’s new, what’s been reviewed and anything significant that has come across my very warm desk in the world of environmental health.

Five new subscribing organisations have joined RIAMS Libraries, and Communities continues to buzz with conversation.

Following customer feedback, we’ve updated some of our letter templates covering HMO management regulations and produced a new procedure document on diverting rent to the local authority following works in default. We have also advised on the use of cautions, updating our simple cautions procedure, which is covered further in our July question of the month.

Several consultations have been launched, and a big question mark continues to hang over the HHSRS, how it will be applied moving forward in social housing and whether it will ever be updated.

Director of Community Safety Jim Nixon hosted the Community Safety Roundtable on 18 June. Jim was joined by Charles Pasfield from MRI Software to discuss tackling community noise and ASB through smarter integration. 

I’ve recorded my first ever podcast with Jim and it has just been released on YouTube. Jim shares his insights on the Crime and Policing Bill and how it will impact the work of practitioners. You can view the podcast here.

Legal and regulatory insights

• Crime and Policing Bill is waiting for its second reading in the House of Lords. A number of Government amendments have been tabled – these can be viewed here.

• Product Regulation and Metrology Act 2025 received Royal Assent on 21 July. It provides a legal framework for regulating product marketing and use in the UK and grants ministers delegated powers to set and update product safety and metrology rules, and to decide whether to recognise EU product standards.

• Renters’ Rights Bill is now paused for the summer recess and expected to be heard in the House of Commons in September. Lots of amendments have been tabled, which may or may not make their way into the final act. The Government has made some amendments, including removing the ability for landlords to require pet insurance. And it looks like LAs won’t be required to give 24 hours’ notice to landlords when inspecting for some offences under the RRB – watch this space. If only it could be rolled out to section 239 of the Housing Act 2004, it would be a wonderful improvement. Time is running out for royal assent before the parliamentary summer recess beginning on 22 July.

•  The Government has indicated its intention to introduce mandatory electrical safety checks into social housing in England from November for new tenancies and from May 2026 for existing tenancies. Social landlords will be required to inspect and test electrical installations every five years; provide a copy of the EICR to tenants within certain timeframes; carry out PAT testing on any electrical items supplied with the tenancy; and complete remedial works within 28 days.

• Awaab’s Law: Draft guidance and regulations have been laid out introducing Awaab’s Law into social housing in England. The Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025 and draft guidance for social landlords have brought some clarity on the requirements which will be phased in from October. The key points to note are:

  • The first phase will come in on 27 October 2025 for all damp and mould hazards and any ‘emergency hazards’ in social housing

  • Social landlords must investigate within 10 working days when they become aware of a potential hazard within scope, and provide a written summary of the findings to residents within 3 working days of concluding their investigation

  • Where a significant hazard is found, the social landlord must make the property safe within 5 working days after concluding their investigation, and any further work required must be started and completed within a reasonable time

  • In an emergency situation, the matter must be investigated and actioned as soon as reasonably practicable, and within 24 hours

  • Where a property cannot be made safe within the required timescales, suitable alternative accommodation must be offered to the occupants.

It’s also worth noting that the hazard assessment under Awaab’s Law takes a twist from that prescribed within the HHSRS and will require an assessment of the occupants and their potential vulnerabilities – not the vulnerable group. This is likely to lead to hazards being assessed as significant under Awaab’s Law, which will therefore require action by the housing association. Such an assessment is potentially contrary to that of an LA, which may, using the statutory provision defined by the Housing Act 2004, assess the same issue as a low-scoring hazard. It is going to be interesting to see how this plays out.

Consultations

• The Department for Energy Security & Net Zero are consulting on updated guidance for the assessment and rating of wind turbine noise. The draft guidance is available here and the government will issue a formal response on conclusion of the consultation.

• Consultation on Minimum Energy Efficiency Standards in the Social Rented Sector in England is currently underway. This follows the consultation for the PRS, which took place in February, with the expectation of maintaining a level of consistency with MEES across the two sectors.

• The Decent Homes Standard consultation proposes a single revised DHS for both the private and social rented sectors, focused on the standard of the property. The planned implementation dates for both tenures are either 2035 or 2037, and the standard will also apply to supported housing and temporary accommodation. New criterion for the DHS are proposed: free of Category 1 hazards; good repair (excluding the age of the building component); adequate facilities and services, including noise insulation; updated thermal comfort requirements; and a new criterion that properties should be free of damp and mould.

What’s new on RIAMS Libraries?
During June, we reviewed 168 documents for England, Northern Ireland and Wales, including 115 procedures as well as notices, letters and forms. We’ve added a few new documents to the libraries as well, including:

• Evidencing a Building as a Section 257 House in Multiple Occupation (HMO) (HP250) (England and Wales)

• Licensing of Primates (LP71) (England)

• Inspection Form (Housing) (HS160) (England and Wales)

• Recovery of Expenses and Interest from Occupiers for Works in Default under the Housing Act 2004 (HP252) (England and Wales)

• Renters’ Rights Bill guidance and procedures for England:

  • Renters’ Right Act 2025: Rent Increases and Rent in Advance (HP251)

  • Renters’ Rights Act 2025: Assured Tenancies, Grounds for Possession, Statement of Terms (HP253)

  • Private Rented Sector Ombudsman (Landlord Redress Schemes)– (HP254)

  All available in the Renters’ Rights Act procedures folder.

• Closure notices under section 19, Criminal Justice and Police Act 2001, are now available in the Licensing module.

RIAMS Northern Ireland – an update from our Northern Ireland Editor
Aaron Lawson joined us in December 2024 and has been leading a growing team of RIAMS specialists in the delivery of new and updated content to the RIAMS Northern Ireland Libraries.

• Overcoming various legislative challenges, Aaron and his specialist team have reviewed nearly 500 documents in the Libraries, including:
  226 procedures

• 60 documents

• 205 templates and forms 

A big thank you to all our RIAMS specialists and authors.

What’s new on RIAMS Communities?
The number of colleagues registering with our discussion groups continues to increase as debate and networking flourish across all areas of environmental health.

Our Question of the Month with Tim Everett for June, Out of Time? The Legal Limits and Leeway on Late Appeals Against Local Authority Notices, is available on Communities. And conversation about May’s question carried on throughout June - Two Worlds, Two Rules: Planning Permission and HMO Licensing. Easily our most popular question to date!

If you have a complex or niche question for Tim, please send it to me: [email protected].

New tribunal decisions will be released shortly.

Stay engaged, stay informed – upcoming events and training

-  2, 3, 30 September (08:45–13:00): HHSRS Practitioner Training [Online] (11 hrs, 45 mins CPD)

-  16 September (09:30–12:45): Practical Use of Community Protection Notices [Online] (2 hrs 50 mins)

-  16, 18, 23, 25, 30 September and 2, 7, 9 October 2025 (10:00–12:15): Introduction to Environmental Noise [Online] (20 hrs 15 mins CPD)

-  24 September, 1, 8, 15 October 2025 (09:15–12:40): Investigation Skills and PACE [Online] (12 hrs 35 mins CPD)

RHE Global supports environmental health practitioners across all specialisms to work smarter, network and share best practices. Visit RIAMS to stay up to date with the latest environmental health developments and discussions.

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