In previous blogs, we set out the case for updating the Housing Health and Safety Rating System (HHSRS) and mapped the path from early consultations through to the formal review of the HHSRS and the ongoing implementation process. This third instalment turns to the stakeholder engagement programme that underpinned the HHSRS Review and to how their input helped shape those proposals.
Methodology and stakeholder participation
The HHSRS review used a mixed-methods approach to engagement, gathering evidence across sector-wide stakeholder groups. Over the course of the review, the team gathered survey responses, held focus groups and conducted one-to-one interviews. Engagement also involved national experts, including HHSRS trainers and academics, legal specialists and fire sector representatives.
The ten HHSRS2 proposals
Reviewed and updated HHSRS Operating Guidance
During engagement, stakeholders were clear that the Operating Guidance required substantial update and modernisation. There was a strong consensus that the existing guidance, now more than two decades old, was difficult to navigate, and, in several areas, insufficiently aligned with modern building practices and housing- and health-related statistical evidence. Clarity of guidance was found to be particularly important to landlords, reflecting a sector-wide need for accessible and clear guidelines. Assessors demonstrated a preference for a five-year refresh cycle, emphasising the importance of ensuring that technical guidance, statistical baselines and building-safety references remain up to date and representative of current housing stock.
In direct response to these findings, the HHSRS Review put forward a new three-part, more navigable guidance suite, comprising:
Part 1: An Introductory Guide, setting out principles, scope and structure
Part 2: Technical Guidance for Assessors, covering methodology, updated hazard profile information and detailed hazard assessment criteria
Part 3: Fire Safety Supplement, addressing the specialist fire-related risks and interface with other statutory regimes, including detailed guidance on multi-occupied buildings.
Hazard profiles were rewritten and restructured, with clearer scope definitions, updated causal pathways, health-outcome evidence, relevant matters affecting the likelihood and harm outcomes, and hazard specific baseline indicators.
Updated comprehensive set of worked examples
Stakeholders were united in their expectations for a modernised suite of worked examples and were equally clear about what they wanted from them: up-to-date case material, photographs illustrating what ‘good’ and ‘not good’ look like, and a greater range of different property types and ages. These preferences reflect a sector-wide need for tools that not only support scrutiny but also help inspectors navigate borderline ‘grey area’ situations, the scenarios that tend to generate challenge, inconsistency or dispute. Approximately one-third requested more Fire hazard worked examples. EHPs frequently operate between the HHSRS and other fire-safety regimes, and often rely on worked examples to inform this increasingly complex regulatory landscape.
In light of this evidence, the HHSRS Review delivered a fully updated suite of case studies/worked examples, rewritten to support the revised hazard profiles, the proposed traffic-light banding model and the introduction of baseline indicators, discussed further below. It also rebalanced the spread across varying property types and ages and increased the range of hazard rating scores. The updated suite also incorporates a greater number of fire-specific examples, including ‘marginal cases’, to support assessments and ensure stronger alignment between HHSRS practice and wider fire-safety requirements.
Review of training requirements and competency frameworks
Stakeholders across all groups affirmed that competence is an essential condition for a robust and defensible HHSRS system. EHPs stressed the need for updated, standardised training materials, aligned with the revised Operating Guidance and worked examples, as well as specialist training relating to certain areas such as fire safety and building safety, reflecting the need for specialist input. Also, scenario-based training was deemed valuable, particularly using the revised worked examples, to build consistency and strengthen practitioner confidence in marginal or ambiguous cases.
Consequently, the review delivered a refreshed competency framework, designed to provide a national structure for skills development and professional expectations. Training recommendations were aligned with the updated Operating Guidance, the modernised worked examples and new baseline indicators.
Simpler means of banding assessment results
There was unambiguous support for retaining the ‘justifications’ as the evidence to demonstrate how observations lead to scoring decisions and how professional judgement has been applied in context, providing decision‑making transparency and reasoning. However, concerns were expressed about how results are communicated to landlords, tenants and other professionals. Very few favoured removing banding altogether, rather that outputs should be easier to understand, without losing the professional robustness that underpins them. Stakeholders stressed the need for plain‑English summaries that allow non‑specialists to follow the conclusions.
Feedback was more divided on the question of whether very low scores (Bands F or below) should be treated as ‘tolerable’ or ‘acceptable’. While a slight majority agreed these scores could be interpreted as satisfactory, it was often with important caveats regarding discretion, cumulative hazards, property context and vulnerable occupants.
In response, a traffic‑light banding model was developed, designed to make scoring outputs more intuitive and visually accessible while retaining the underlying likelihood and harm calculations. This approach provides clarity for landlords and tenants without compromising the technical integrity of the assessment process.
New baseline indicators for incorporation into HHSRS
Minimum standards, or baseline indicators, emerged as one of the most recurrent themes across the entire stakeholder engagement programme. The case for these was not as a substitute for professional judgement but as a means of supporting it, particularly in situations where conditions are frequently encountered and remedies are predictable and well understood.
Several hazards were repeatedly identified as priority candidates. The most frequently cited hazards were Excess Cold, Fire and Crowding & Space. Stakeholders emphasised that areas in which objective, measurable criteria could meaningfully reduce ambiguity would support earlier and more productive dialogue with landlords and enable greater levels of self‑regulation within the sector. Landlords, for their part, expressed a strong preference for standards that were clear, measurable and component‑based, with many favouring criteria grouped around building elements rather than hazard categories.
Two cross‑cutting cautions were voiced across groups and methods. The first was the risk of a ‘race to the bottom’, where standards might be interpreted as the maximum required, not the minimum expected. The second was the need for regular review, ensuring that standards evolve with building practices, technological advances and changes in the housing stock before becoming static or outdated. There was a strong appetite for hybrid models, viewing minimum standards as a foundation or a baseline to support consistency, not to constrain professional judgement.
As a result, the HHSRS Review produced a system of baseline indicators, a term deliberately chosen to avoid the unhelpful implications of ‘minimum standards’ as a term. These indicators were designed to be component‑based, to support uniform assessments while preserving the flexibility and nuance of the risk‑based scoring methodology on a case-by-case basis.
Assessment of amalgamation or removal of hazard profiles
Stakeholder feedback showed a clear appetite for simplifying the hazard set through amalgamation, rather than reducing it through deletion. Stakeholders emphasised that the aim was not to ‘water down’ hazard types, but to reduce avoidable complexity. The most frequently suggested pairings reflected areas where practitioners routinely encountered duplication in inspection and assessment, the explanation being that such combinations better reflected the real-world way in which hazards present, thus streamlining assessments.
In light of this, the review delivered a structured and evidence-based consolidation of the hazard list. The total number of hazards was reduced from 29 to 21, tested by four agreed amalgamation criteria and underpinned by updated hazard definitions and rewritten profiles.
Identification of what a digital assessment tool would achieve
Expectations were unanimous on how digital tools should support, not redefine, HHSRS practice. The engagement produced a clear and detailed picture of what practitioners would find useful, consistently identifying a need for:
Integration with case management and property databases
Capture of timestamped photos and sketch plans
Pre-populated known data, e.g. EPC information
Integrated HHSRS calculator, providing structured assistance with the numerical elements of scoring without restricting professional judgement.
Stakeholders opposed forcing assessors to score hazards on site, stressing that reflective scoring undertaken back in the office, with access to worked examples, team discussion and supporting guidance, helps ensure consistency and reasoned judgements.
Stakeholders expressed a strong preference for fully integrated digital workflows to support consistency, record-keeping and operational efficiency. In response, the review delivered a clear specification for a future digital assessment platform, setting out functional requirements.
Reviewed and updated guidance for landlords and tenants
Stakeholders were clear that the existing guidance for landlords and tenants required substantial improvement, both in clarity and accessibility. Findings showed that landlords expressed a need for practical checklists and examples, reflecting a preference for guidance that is component-based, measurable and easy to apply in day-to-day property management. Tenants, by contrast, prioritised the need for plain-English explanations of hazards, their potential impacts and direction as to what constitutes a reasonable standard of safety in a rented home. Providing hazard information in accessible, non-technical language was seen as critical for supporting informed engagement and reducing conflict between parties.
An updated draft landlord guidance was delivered by the review, aligned with the new baseline indicators, ensuring that expectations for safety and property conditions are presented in a standard checklist-and-actionable format. Alongside this, a separate tenant-facing guidance was produced, written in plain language and designed to increase awareness of hazard types, typical indicators of poor conditions and the routes available for seeking assistance or redress, informing tenants of their rights and responsibilities.
Reviewed and updated enforcement guidance
Stakeholders were clear that the existing enforcement guidance required significant improvement to ensure greater proportionality and national consistency. The need to reflect the full suite of enforcement tools now available under Part 1 of the Housing Act 2004, particularly the growth of civil penalties but also other relevant powers across the housing and environmental protection landscape, was highlighted. Prominence was also placed on enforcement operating within a standard, proportionate framework, reducing unnecessary variation while preserving space for professional discretion. The growth of civil penalty regimes, increasing resource constraints and the expanding complexity of the wider regulatory environment were also identified as factors intensifying the need for updated clearer, more structured guidance.
A fully updated Enforcement Guidance was delivered, designed to promote early clarity, proportionality and transparent decision-making pathways. The revised guidance also integrates relevant legislative developments, including civil penalty provisions, protections for tenants against retaliatory eviction and the full range of powers available across related regulations, such as HMO licensing and environmental protection.
. Review of Fire safety hazard and supplementary guidance
Practitioners reported that they routinely work between the HHSRS and other statutory and non-statutory fire-safety frameworks. A very high proportion of assessors said they use additional fire safety guidance alongside the HHSRS, and a significant number described turning to other mechanisms where HHSRS scoring did not align with expectations.
When asked where baseline indicators would be most beneficial, EHPs repeatedly pointed to settings where fire risk is compounded by building configuration, occupancy patterns or shared systems (like HMOs, blocks of flats or mixed-use buildings). Standardisation was also regularly identified for the following: automatic fire detection and alarm systems, fire doors, means of escape and compartmentation. There was strong support for better alignment with BS 5839-6 and other statutory regimes.
Fire expert groups typically called for updated training and clear limits, detailing what EHPs should reasonably check and when specialist fire engineering or building-safety expertise must be engaged.
As a result, a comprehensive Fire Safety Supplement was developed as part of the revised guidance suite. This supplement contains:
Clear signposting to specialist fire-safety guidance
Proposed baseline indicators for domestic alarms and related components
A strengthened set of worked examples, including ‘marginal calls’ where professional judgement is most often challenged.
Conclusion
The stakeholder engagement programme reaffirmed the themes from the 2018–19 Scoping Review but with a far stronger appetite for practical usability, operational clarity and consistency of application of the HHSRS inspection and assessment process.
The new Operating Guidance and fire supplements have been updated, restructured, user-tested and are now aligned with modern standards and evidence, incorporating baseline indicators in a hybrid-based approach. The worked examples have been modernised and rebalanced across a spectrum of risks. The introduction of baseline indicators responds to years of concern about ambiguity, while deliberately ensuring that minimum expectations do not displace professional judgement or the ability to act where cumulative hazards or contextual risks demand it.
The consolidation of hazards from 29 to 21 reflects an evidence-based approach to simplification, reducing duplication without reducing scope. The digital tool specification acknowledges that professional judgement cannot be automated, but that digital integration can support efficiency and reliability in the application of housing standards and enforcement requirements. Updated landlord and tenant guidance recognises that clarity must exist on both sides of the rented sector, and revised enforcement guidance addresses the long-standing concern around ‘postcode lotteries’ in enforcement and the need for consistent, policy-led enforcement action.
Stakeholder engagement was, quite rightly, an extensive phase of the review, shaping the direction of the research and system update. HHSRS2 recommendations aim to address those findings, alongside in-depth housing and health research, to provide a more transparent, accessible and better-equipped system to meet the demands of modern housing standards.
