The Renters’ Rights Act 2025 – Awaab’s Law, EPC level C and the Decent Homes Standard

Our guide to the Renters' Rights Act 2025 can be downloaded for free:  The Renters' Rights Act 2025

This is a deeper dive into three high-profile changes that are connected to the Renters' Rights Act 2025 and relate to the physical condition of let homes: 

• Awaab’s Law 

• Minimum EPC level C 

• The Decent Homes Standard 

Awaab’s Law

Awaab’s Law is the obligation on landlords to deal with mould and other health hazards promptly, named for and enacted following the death of toddler Awaab Ishak.  It was introduced in July 2023 as part of the Social Housing (Regulation) Act 2023. 

The Government’s stated aim is: 

“to force landlords to fix dangerous homes or face the full force of the law”.  

There is no set implementation date for Awaab’s Law in the private rented sector yet as the Government has said that the implementation date will be subject to further consultation.   But it is expected to be extended to the private rented sector from 2027, with landlords being required to address hazards such as damp and mould within a specified time period or face enforcement action being brought against them by tenants. 

Implementation in the social housing sector is already underway, and this gives a picture of likely wider implementation: 

• From 27 October 2025, social landlords have been required:

  • to address damp and mould hazards that present a significant risk of harm to tenants within fixed timescales.   The “fixed timescales” appear likely to mean duties to investigate complaints within 14 days and start repairs within a further 7 days.

  • to address all emergency repairs including for damp and mould or other hazards as soon as possible, and within 24 hours.

• In 2026, requirements will expand to apply to a wider range of hazards.  In addition to damp and mould, this is expected to include: 

  • excess cold and excess heat

  • fall hazards

  • risks of structural collapse

  • fire risks 

  • electrical and explosion risks, and 

  • hygiene hazards.

• In 2027, the requirements of Awaab’s Law will expand to all the remaining hazards that are considered in the Decent Homes Standard, with the exception of overcrowding. 

  The full list of hazards can be found in schedule 1 to the Housing Health and Safety Rating System (England) Regulations 2005.

What if a private landlord fails to comply with Awaab’s Law when it comes into force?

Government guidance indicates that options for tenants to bring action against their landlord will include:

• Civil legal action for breach of contract 

• Private rental tenants will also be able to complain to the new Private Rented Sector Ombudsman, which will be mandatory for landlords to join, and is expected to be operational from 2028. 

Minimum EPC level C

As part of the Decent Homes Standard, rented homes must provide thermal comfort. 

The Government sees improving the energy efficiency of homes as a critical step to achieving this. 

By 1 October 2030 the Government will require private landlords to: 

“Ensure all new and existing domestic private rented properties must be at an EPC C or equivalent … or for a valid exemption to have been registered.”.

This is an increase from the current EPC standard, which is E.

Landlords will be required to invest up to a capped amount of £10,000 per property to meet EPC C.  

If the property falls short of EPC C, the landlord may register the property for an exemption.  This exemption will be valid for 10 years and the landlord can continue to let the property while the exemption remains valid.  Once the exemption expires, the landlord must again make improvements to try to bring the property up to standard. 

EPCs obtained prior to 1 October 2029 that are rated C or higher, will remain valid until their 10-year expiry date.

The Government has said that it will amend the MEES Regulations to raise the standard for domestic private rented properties, aiming to have the legislation come into force in 2027 with a deadline for compliance of 1 October 2030.  

The Government is encouraging landlords to make upgrades to their properties during any vacant periods between now and 1 October 2030 to bring the property up to standard.  

Importantly, spending on improvements from 1 October 2025 will be recognised under the cost cap, meaning that landlords should ensure that they keep proper records of their spending. 

The Decent Homes Standard

On 28 January 2026, the government clarified that the Decent Homes Standard (also known as DHS) “will apply from 2035 in both the social and private rented sectors”.  The delay until implementation has caused a lot of controversy.

Even though it seems a long way away, it is worth private landlords being aware of its obligations, so that when and if it is implemented in the private rented sector, they are ready for it.   

When enacted, it will require properties to:

• Be free from serious hazards that could cause major harm 

• Be in a reasonable state of repair and have modern facilities like kitchens and bathrooms, and 

• Provide appropriate thermal comfort – which should be addressed by meeting the applicable EPC standard.

Serious Hazards are those that pose a significant risk of injury or death, such as:

• Physiological hazards e.g. damp, mould, excess heat or cold, asbestos, carbon monoxide,

• Psychological hazards e.g. overcrowding, poor lighting, noise,

• Infection risks e.g. sanitation, drainage, pests, water supply, and 

• Accident risks e.g. fall hazards, electrical hazards, fire risk, structural collapse.

To have Modern Facilities, homes should not lack three or more of the following:

• A reasonably modern kitchen (20 years old or less) or bathroom (30 years old or less),

• Adequate space and layout in the kitchen or appropriately located bathroom and WC, 

• Adequate insulation against external noise (where external noise is a problem), or 

• Adequate size and layout of common areas for blocks of flats.

Thermal comfort means that the property should not be likely to get excessively hot or cold. To achieve this, dwellings will need to have both efficient heating and effective insulation.  

This should already be the case for the majority of private rented homes as these are presently required to achieve an EPC rating of at least E, which is highly unlikely in the absence of efficient heating and effective insulation (and note the section about EPC level C, above).

The Act will introduce the DHS to private rented homes and landlords will have to meet those minimum standards, otherwise they could face legal action and fines.

Useful links:

• The full Government definition and guidance for the DHS is here

• The full list of hazards can be found in schedule 1 to the Housing Health and Safety Rating System (England) Regulations 2005 

• Government guidance on how hazards are rated is available here.

What if a private landlord fails to comply with the DHS when it comes into force?

There are a number of potential consequences for a non-compliant landlord, including: 

• A notice to remedy being issued by the local authority.  If the landlord fails to comply with that notice, it could lead to a civil penalty or criminal prosecution. 

• A civil penalty issued by the local authority could be up to £7,000 for a first minor breach or up to £40,000 for serious, persistent or repeat offenders or the risk of criminal prosecution.

  If an offence is committed, the tenant or local authority can also apply to the tribunal for a rent repayment order 

Most private rented homes should already be up to standard (the Government estimates around 80% are already “decent”).   For those that are not, renovation and improvements will be required, but at present they have almost 10 years to undertake those works. 

Written with Ryan Small and Lucy Mostyn