05/08/2026
Introduction
The Housing Health and Safety Rating System (HHSRS) has undergone its most significant overhaul since its introduction in 2006. Following a comprehensive review, the Housing Health and Safety Rating System (England) (Amendment) Regulations 2026 came into force on 23 June 2026, and revised operating and enforcement guidance has been published. These changes are designed to make the system more accessible, more intuitive, and better aligned with modern enforcement practices. This article outlines the key updates that landlords, housing managers, and local authorities should be aware of.
Recap
The HHSRS is the risk-based evaluation tool used by local authorities to assess housing hazards.
The underlying reason for these changes is to ensure that HHSRS assessments are easier to understand by everyone, while strengthening the tools available for consistent and proportionate enforcement.
A notable change in the operating guidance is that the total number of hazards to assess have been reduced from 29 to 21, meaning the results of assessments can be banded and indicative baselines can be published to ensure clarity on improvements for properties. This has however involved previous hazards being combined rather than removed.
We will first review changes to the operating guidance, followed by changes to the enforcement guidance.
Changes to the statutory guidance
The operating guidance is now split into three parts:
Part 1: An introductory guide
The first part provides general guidance on the assessment process for those wanting an introduction to the HHSRS. This deals with the underlying principles of the HHSRS and provides an overview of the assessment process including a flowchart detailing how to conduct an HHSRS assessment. This part also confirms the updated list of 21 hazards and the four groups they are arranged into.
Part 2: A technical guide for assessors
The second part provides more in-depth technical information for assessors, to support the inspection process itself. It contains a series of hazard profiles providing essential information on each of the 21 hazards. This part also confirms the introduction of baseline indicators, discussed further below.
Part 3: A supplementary guide to the hazard of fire and explosions
Further guidance on fire safety assessment has been included in the third part. This provides information beyond the hazard profile, to assist in property inspection and risk assessment.
The decision to provide dedicated supplementary guidance on fire and explosion reflects the heightened focus on fire safety in residential buildings following the Grenfell Tower tragedy and the subsequent regulatory reforms introduced under the Building Safety Act 2022 and the Fire Safety Act 2021 (which amended the Regulatory Reform (Fire Safety) Order 2005).
The below considers the changes made in the operating guidance in response to the findings of a comprehensive stakeholder engagement exercise.
Amalgamated hazard categories
As mentioned above, the number of hazard categories covered by the HHSRS has reduced from 29 to 21.
In particular, certain hazards have been combined for simplicity, reflecting the basic health requirements set out in the previous version of the HHSRS:
- Collision and Entrapment and Position and Operability of Amenities were combined
- Uncombusted Fuel Gas, Biocides, Carbon Monoxide and Fuel Combustion Products and Volatile Organic Compounds were combined
- Fire and Explosions were combined
- Falls on Level Surfaces Etc. and Falls Associated with Baths Etc. were combined
- Food Safety, Domestic Hygiene, Pests and Refuse and Personal Hygiene, Sanitation and Drainage were combined
By reducing the total number of assessable hazards from 29 to 21, the revised guidance will allow local authority assessors to conduct inspections more efficiently whilst retaining the breadth of coverage that the system requires. However, it is worth noting that the combination of the previously distinct hazard categories means that some nuances in assessment may be lost. Landlords and housing managers should familiarise themselves with the revised hazard profiles to understand how the newly combined categories may affect the way deficiencies in their properties are identified and scored, especially ahead of phase 3 of Awaab’s Law which is due to be implemented into the social housing sector in 2027, and which will relate to all hazards, save for overcrowding.
Hazard profiles
Another change in Part 2 of the operating guidance provides hazard profiles for each of the hazard categories. At a high-level, this covers aspects such as the hazard title, a description of the hazard which states what is or is not included and a summary box providing a summary of the information about the hazard. The hazard profiles include behavioural factors which can contribute to hazards, for example a desire to reduce heating costs could contribute to excess cold in homes. The hazard profiles also now include reference to other hazards which can have an impact on the likelihood and/or harm outcomes of a hazard.
Put simply, the revised hazard profiles are designed to give assessors a single, comprehensive reference point for each hazard. The profile will also cover more in-depth information such as a table of vulnerable age groups which includes information such as national average likelihood, harm outcome and HHSRS scores for the hazard, broken down by property type, data permitting. It will also cover health effects, causes of the hazards, preventative measures, notes on other considerations for a landlord’s assessment of the hazard and further reading on the hazard which will sign post information sources.
Relevant matters and baseline indicators affecting the likelihood and harm outcomes
Another significant change introduced under hazard profiles are baseline indicators.
The operating guidance states these will provide a prescriptive non-exhaustive, list of proportionate building measures designed to protect the health, safety, and wellbeing of occupiers. However, these are not a mandatory set of requirements for dwellings.
In summary, the baseline indicators outline any other hazards impacting on the likelihood and harm outcomes, and the guidance provides a checklist of baseline indicators and relevant matters to consider when scoring likelihood and harm outcomes. This essentially gives examples of best practice.
A failure to meet a relevant baseline indicator should be regarded as a deficiency, the same is addressed under Part 1 of the guidance.
The aim of this is to address common health related housing deficiencies found across the housing stock, albeit this will not eliminate risk. These indicators have been designed so that they can be applied to most property types and ages. Exceptions may apply to this, such as where a baseline indicator can’t be met due to a lack of listed building consent, or when a non-traditional building is being assessed.
The classes of harm outcomes have been retained from the previous version of the HHSRS although they have now been renamed from Class I – IV to the descriptive titles, Extreme, Severe, Serious and Moderate harms. The aim is that these titles will help to make assessments clearer to those who have not had formal training in the HHSRS.
Scoring system
Under the previous system, hazard scores were categorized into ten bands (A to J), where bands A through C represented Category 1 hazards and bands D through J represented Category 2 hazards. This ten-band structure was unnecessarily complex and proved difficult for non-specialists to interpret. The revised guidance replaces the old system with a simplified three-band structure - High, Medium, and Low (detailed below), supported by a traffic light colour-coding system. This shift is intended to produce assessment reports that are immediately comprehensible to landlords, tenants, and housing managers, removing the need for technical expertise in the underlying scoring methodology.
- High: Category 1 hazards, scoring over 1,000 (these were previously bands A – C)
- Medium: Category 2 hazards with a score between 100 and 999 (these were previously bands D – F)
- Low: Category 2 hazards scoring up to 99 (these were previously bands G – J).
Changes to the enforcement guidance
What remains unchanged is the fact that under the Housing Act 2004 (the “2004 Act”) local housing authorities have a duty to take action if they find a hazard at the most dangerous ‘Category 1’ level and the option to take action if they find a hazard at the lower ‘Category 2’ level when inspecting a dwelling under the HHSRS.
The enforcement guidance is designed to help local housing authorities approach their enforcement roles using the HHSRS under section 9 of the 2004 Act. Local authorities are required to have regard to this guidance, which replaces the previous enforcement guidance issued in 2006.
The enforcement guidance has been produced following extensive engagement as part of a research programme considering the HHSRS suite of guidance. In response to the research, key principles are introduced to underpin the enforcement guidance.
Key principles of the revised enforcement guidance
The revised enforcement guidance, published in June 2026, is built around four core principles:
- Enforcement is a process not an outcome. It involves a series of decisions, from initial awareness through to the choice of enforcement action. This balances statutory duties with cooperative engagement
- Category 1 hazards trigger a strict duty to act under section 5 of the 2004 Act. For Category 2 hazards, enforcement remains discretionary
- Local authorities must be transparent in their approach and provide clear guidance to help those they regulate to comply
- The goal is safe, healthy homes free from dangerous hazards, benefiting current and future occupants
Enforcement options
The available enforcement options under the Housing Act 2004 remain as follows: improvement notices, hazard awareness notices, prohibition orders, emergency remedial action or emergency prohibition orders and demolition orders or slum clearance declarations.
Which option is pursued depends on the local authority's enforcement policy and the circumstances of the case such as the property type, occupier vulnerabilities and whether remedial works are reasonable. An authority may only take one enforcement action per hazard but may pursue different actions for different hazards in the same property.
Civil penalties
The Renters’ Rights Act 2025 inserted a new section 6A into the 2004 Act which allows local authorities to impose a civil penalty of up to £7,000 for Category 1 hazards in qualifying residential premises (as defined in section 2B of the 2004 Act). The penalty is imposed on the ‘responsible person’ if the local authority concludes that it would have been reasonably practicable for them to secure the removal of the hazard.
Local authorities must have regard to chapter 7 of the enforcement guidance when setting their civil penalty policies and imposing civil penalties. The guidance is clear that a local authority must have a policy basis to guide any decision on when to issue a civil penalty.
The civil standard of proof applies when imposing a civil penalty, i.e. the local authority will need to be satisfied ‘on the balance of probabilities’ that a breach has occurred.
When determining the level of a civil penalty, local authorities should go through the following four-step process:
- assess the seriousness of the breach
- apply aggravating and mitigating factors
- consider financial circumstances
- apply a totality check to ensure proportionality
Before imposing a civil penalty, the local authority must give a notice of intent to the responsible person within six months from the day when the authority has sufficient evidence for it to take appropriate enforcement action. The responsible person has 28 days from the day after being given the notice to make representations, after which the local authority will make a decision on whether to impose a penalty and, if so, the level of the same.
Where a local authority decides to impose a civil penalty, it must give the responsible person a final notice requiring payment of the penalty within 28 days from the day after the final notice is given. The responsible person has the right to appeal to the First-tier Tribunal (Property Chamber) against the penalty itself or the level of the penalty.
Wider legislative context:
These changes do not sit in isolation. A key provision of the Renters’ Rights Act 2025, which took effect on 1 May 2026 for the Private Rented Sector (PRS), amended the powers of entry under Section 239 of the 2004 Act. This amendment removes the requirement to provide 24 hours' notice to the owner before entry and allows occupiers to waive their right to prior notice. This measure is specifically intended to prevent landlords from concealing hazards ahead of local authority inspections.
Separately, the revised Decent Homes Standard will apply to social landlords and the PRS from 2035, requiring all rented homes to be free of serious Category 1 hazards.
The direction of travel is clear: regulatory expectations on landlords regarding property conditions are increasing across the board.
Looking ahead
The revised HHSRS guidance represents the most significant update to the framework in two decades. By streamlining hazard categories, introducing baseline indicators, and simplifying the scoring system, the new operating guidance aims to create a more transparent and user-friendly framework for practitioners.
The revised guidance provides a robust framework for local authorities to exercise their enforcement powers, underpinned by the principles of the Regulators' Code and supported by new statutory guidance on civil penalties. When combined with the reforms introduced by the Renters’ Rights Act 2025 and the forthcoming Decent Homes Standard, these revisions signal a clear shift toward stronger and more consistent enforcement of housing standards across all tenures.
Landlords and housing providers should therefore review their property portfolios against the revised hazard categories and baseline indicators now these are in force. It is also essential to ensure that internal compliance processes align with the new assessment and scoring framework to remain compliant.
Should you require any further information, or wish to discuss this matter further, please contact Sarah Orchard or Louise Mansfield.
Build your knowledge of housing law — follow our Housing page.
