The Decent Homes Standard arrives in… 2035

That’s over a million homes – almost exactly the same number that failed it in 2006.

Fewer than 2 per cent of tenant complaints to councils result in formal enforcement of any kind. And on the government’s own working assumption, the majority of landlords will do nothing about any of it until 2035.

That’s the picture painted by the Housing, Communities and Local Government Committee’s new report on housing conditions in the private rented sector (PRS), published this morning – the fourth in its series on housing conditions in England, following earlier reports on social housing and temporary accommodation.

The committee’s overall verdict is broadly warm. It reckons the Renters’ Rights Act 2025 and the reforms trailing behind it “constitute a proportionate package of measures that are likely to improve housing conditions for tenants”, and it finds little evidence of the landlord exodus that the lobby has spent two years predicting.

But the warmth cools considerably once you get into how long tenants will be waiting, how little enforcement actually happens, and how much of the new framework depends on individual tenants being willing and able to take on their landlord.

And there’s a group of tenants for whom every one of those problems is worse – a group the report manages not to mention once.

The fix arrives in 2035

Let’s start with the timeline. The new tenancy regime – the abolition of Section 21, once-a-year rent increases, two months’ notice – came into force on 1 May 2026. The Private Rented Sector Database starts rolling out later this year. The new PRS ombudsman is due to be running by 2028. The new minimum energy efficiency standard bites from October 2030.

Awaab’s Law – legal timescales for landlords to fix serious hazards, the thing named after a two-year-old who died from mould exposure – has no date at all for the PRS, just a promise to consult. And the Decent Homes Standard, the actual minimum quality benchmark, doesn’t become enforceable against private landlords until 2035.

The committee wants Awaab’s Law rollout to start this year and be complete by the end of 2028/29, and wants incentives for landlords to upgrade early. It has good reason to worry about the alternative, because the ministry’s own final impact assessment for the Decent Homes Standard assumes landlords will wait until at least two years before the deadline to do the work – with 60 per cent waiting until 2035 itself. The government is not hoping landlords act early. It is planning on the basis that most of them won’t.

Around 48 per cent of PRS homes – some 2.4 million – are estimated to need work to meet the new standard, at a median cost of just under £5,000 per affected property. The committee notes, dryly, that on this trajectory the rate of progress “risks falling below the previous government’s target to halve the rate of non-decent rented homes by 2030”. That’s the previous government’s target – the one from the levelling up white paper.

Less than 2 per cent

On enforcement, the report collects the numbers that make the whole edifice wobble. Half of all Housing Health and Safety Rating System inspections between 2021 and 2023 were carried out by just 20 local authorities, and 16 per cent of councils couldn’t say how many inspections they’d done at all.

Between 2021 and 2023 nearly half of all local authorities had not served a single civil penalty notice. Guardian FOI data cited by the committee found that between 2022 and 2024 two thirds of councils prosecuted no landlords whatsoever, and that fewer than 2 per cent of tenant complaints resulted in formal enforcement of any kind.

The capacity numbers explain why. New Economics Foundation analysis puts the average caseload at 3,319 privately rented properties per enforcement officer. The Local Government and Social Care Ombudsman told the committee about a tenant who waited seven months for an inspection against the council’s own two-week target.

The committee calls it what its predecessors called it in 2018 and what the Public Accounts Committee called it in 2022 – a postcode lottery – and recommends a full assessment of council resources, mandatory annual enforcement reporting, and ring-fenced funding from database registration fees.

It’s all sensible, and it’s all also a tacit admission that the state’s answer to poor conditions – “complain to your council” – has been largely decorative for years.

The word that never appears

If you search the report for the word “student”, you’ll be searching a while.

The committee is alert to the PRS’s changing population. It devotes paragraphs to older renters (set to quadruple by 2040), to the quarter of children now growing up in the sector, to migrant workers in Great Yarmouth HMOs with moss growing inside the windowpanes, to families with no recourse to public funds. What it never gets to is the roughly 730,000 students – around 30 per cent of all students in England – living in off-street private rented housing, per Unipol and HEPI’s figures.

Nationally students are a decent slice of a 4.7 million household sector – perhaps 6 or 7 per cent of households, more like one in seven or eight adults. But nobody experiences the PRS nationally. Student renting is intensely concentrated in exactly the neighbourhoods – Headingley, Lenton, Fallowfield, Selly Oak – where selective and additional licensing were invented, in exactly the stock the report identifies as most likely to fail the new standard.

Just under a third of PRS properties were built before 1919, the report notes, and such properties are more prone to damp and mould, less energy efficient, and costly to fix. It’s a description of the classic student terrace so precise it could have a “to let” board outside.

Self-reported evidence suggests student conditions run well ahead of the sector average – the SOS-UK and Universities UK Homes Fit for Study survey found 54 per cent of students in the PRS living with damp or mould and 59 per cent reporting feeling uncomfortably cold.

Self-reported figures always exceed surveyed ones, as the committee itself notes when comparing Citizens Advice’s numbers with the English Housing Survey. But nobody has modelled what share of the 2.4 million homes needing DHS work are student lets, and on this evidence nobody in Parliament is asking.

The Act’s theory of change

The omission matters because the report’s central anxiety – that the whole framework leans too heavily on individual tenants enforcing their own rights – applies to students with the dial turned up.

The committee’s optimism rests on one mechanism. Abolishing Section 21 removes the fear of retaliatory eviction, tenants gain the confidence to complain, landlords fix things. It then spends a chapter worrying that the mechanism is fragile – that retaliatory rent increases could act as “a form of economic eviction”, that nearly seven in ten renters have never heard of the tribunal that’s supposed to police them, that awareness of the Act itself remains low, and that in Scotland, years after equivalent reforms, repairs made up just 4 per cent of applications to the equivalent tribunal because tenants simply didn’t use their new rights.

Now run each of those worries through a student house.

Ground 4A – the possession ground Parliament built specifically so that landlords of student HMOs can recover the property each summer to re-let to the next cohort – quietly rebuilds, for this market alone, the certainty that Section 21’s abolition was supposed to remove. A landlord doesn’t need to threaten retaliation against a complaining student in October. Both parties already know the tenancy ends in June. The churn does the intimidating on the landlord’s behalf, entirely lawfully, and the “empowered tenant” theory of change never gets started.

The redress routes fare no better against the calendar. An ombudsman that opens in 2028 and then takes months per case is structurally useless to a tenant whose entire tenancy lasts ten. A council inspection regime running seven months behind its own two-week target consumes most of an academic year before anyone knocks on the door.

The tribunal’s protection against in-tenancy rent increases barely applies to a market where the rent can be jacked up between tenancies, and usually is.

And the committee’s own preferred answer to all of this – proactive, strategic regulation through selective licensing rather than reliance on individual complaints, with schemes extended to ten years and licence conditions allowed to require physical improvements – is a remedy practically designed for student neighbourhoods, the historic heartland of licensing.

A transient, complaint-averse population on twelve-month horizons in the oldest stock in the sector is close to the perfect case study for licensing-led rather than rights-led enforcement. It’s just a case study the report declines to run.

A student starting this September will graduate with no ombudsman for most of their course, no legal repair timescales, no energy standard, and no decency standard. A student starting in 2032 could still complete a degree before the Decent Homes Standard bites.

On the government’s own timeline, no one currently in secondary school will ever rent a student house covered by the full framework – and on the government’s own impact assessment, their landlords are expected to spend the intervening decade doing nothing.

Students fall between DfE, which doesn’t do housing, and MHCLG, which – on the evidence of this report and the select committee scrutinising it – doesn’t do students. The government has two months to respond to the committee. It would be nice if, somewhere in that response, the tenure’s most concentrated, most churned and least protected renters got a sentence.