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441,000 Rental Homes Fail Thermal Comfort Standards As Housing Safety Rules Evolve

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Wesley Ranger • 4 July 2026
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New analysis suggests hundreds of thousands of privately rented homes are failing thermal comfort standards, highlighting the growing importance of property improvements as housing safety guidance places greater emphasis on both cold homes and overheating risks.

Landlords across England are facing increasing pressure to ensure their properties meet modern housing standards after new analysis revealed that an estimated 441,000 privately rented homes failed thermal comfort standards during 2024.


The figures, reported by Property Reporter, come as the Government's updated Housing Health and Safety Rating System (HHSRS) places greater emphasis on thermal comfort, recognising that both excessively cold homes and overheating can present genuine risks to occupants' health and wellbeing.


While many landlords already invest regularly in maintaining their portfolios, the findings serve as another reminder that the regulatory landscape continues to evolve. As standards increase, property improvements are becoming not only a matter of tenant satisfaction but also an important consideration for compliance, long-term asset value and future financing.


What Has Been Announced?


The latest research estimates that around 441,000 homes within England's private rented sector failed thermal comfort standards during 2024, making thermal comfort one of the most significant housing quality issues affecting rental accommodation.


The publication coincides with revisions to the Housing Health and Safety Rating System (HHSRS), the framework used by local authorities when assessing potential health hazards within residential properties.


Historically, much of the focus surrounding thermal comfort has centred on homes that are difficult or expensive to heat. Poor insulation, inadequate heating systems and excessive heat loss have long been recognised as potential health hazards.


However, the revised guidance reflects a changing climate as well as changing housing policy. Overheating has now become a much greater consideration, with homes that retain excessive heat during warmer weather also capable of creating health risks for occupants.


As summers continue to become warmer across parts of the UK, regulators are increasingly recognising that maintaining comfortable internal temperatures throughout the year is becoming an important part of providing safe, high-quality accommodation.


Why Does This Matter For Landlords?


Although the announcement does not automatically require landlords to undertake immediate improvement works, it does reinforce the direction of travel for the private rented sector.


Over recent years landlords have already adapted to significant changes involving electrical safety inspections, smoke and carbon monoxide alarms, energy performance requirements, licensing schemes and wider tenant protections.


Thermal comfort now appears set to become another area receiving greater regulatory attention.


For many landlords, particularly those with older housing stock, improvements such as upgrading insulation, replacing inefficient windows, modernising heating systems or improving ventilation may become increasingly important over the coming years.


These improvements are not simply about satisfying regulatory expectations.


Properties that maintain comfortable temperatures throughout the year are often more attractive to prospective tenants, may experience fewer maintenance issues associated with damp or condensation and can contribute towards lower household energy costs.


In an increasingly competitive rental market, well-maintained, energy-efficient properties are often better positioned to attract and retain quality tenants.


How Could This Affect Property Finance?


The evolving regulatory environment is also influencing how many landlords approach borrowing.


Rather than waiting until significant works become unavoidable, many investors are choosing to review their portfolios proactively and incorporate refurbishment projects into wider refinancing plans.


Where sufficient equity exists, a buy-to-let remortgage may allow landlords to release capital for improvement works while potentially restructuring existing borrowing at the same time.


For landlords who wish to retain an existing mortgage product, a second charge mortgage may provide an alternative means of funding refurbishment costs without replacing their current loan.


Larger portfolio landlords may also consider refinancing across multiple properties simultaneously, allowing improvement programmes to be completed in a planned and cost-effective manner rather than reacting to individual issues as they arise.


Where more extensive renovation is required before a property can return to the rental market, specialist refurbishment finance or bridging finance may also provide a suitable short-term funding solution before longer-term buy-to-let finance is arranged.


The most appropriate option will always depend on the individual property, existing borrowing, rental income and the landlord's wider investment objectives, but increasingly landlords are viewing finance as part of a longer-term asset management strategy rather than simply a means of purchasing property.


Looking Ahead


The private rented sector continues to undergo significant change, with landlords expected to meet increasingly demanding standards covering safety, energy efficiency and overall property quality.


Although the exact pace of future regulatory reform remains uncertain, the overall direction is becoming increasingly clear. Government policy continues to encourage better quality housing that supports healthier living conditions for tenants while improving the resilience of the UK's housing stock.


Professional landlords who regularly review their portfolios, invest in planned improvements and consider future compliance requirements early are often better placed than those forced into reactive decisions when regulations tighten or maintenance issues emerge.


For many investors, funding improvements through carefully structured property finance can help spread costs, protect cash flow and ensure properties remain competitive within an evolving rental market.


As the expectations placed upon landlords continue to rise, ensuring properties remain both compliant and commercially attractive is likely to become an increasingly important part of successful long-term portfolio management.

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Frequently Asked Questions


What are thermal comfort standards for rental properties?

Thermal comfort standards relate to whether a rental property can maintain safe and reasonable internal temperatures for tenants. This includes protection from excessive cold during winter, as well as overheating during warmer months.


Why are landlords being warned about thermal comfort?

New analysis reported that an estimated 441,000 privately rented homes in England failed thermal comfort standards during 2024. Updated HHSRS guidance also places greater focus on both cold homes and overheating risks.


What is the HHSRS?

The Housing Health and Safety Rating System, or HHSRS, is the framework used by local authorities to assess potential health and safety hazards in residential properties, including risks linked to temperature, damp, ventilation and poor housing conditions.


Does this mean landlords must upgrade their properties immediately?

Not necessarily. The announcement does not create an automatic requirement for every landlord to carry out immediate works. However, it does show that housing standards are moving towards greater scrutiny of property condition, energy efficiency and tenant comfort.


What improvements may help landlords meet thermal comfort expectations?

Common improvements may include better insulation, upgraded heating systems, replacement windows, improved ventilation, draught proofing and measures to reduce overheating during warmer weather.


Can landlords finance property upgrades through a buy-to-let remortgage?

Yes. Where there is sufficient equity, landlords may be able to release funds through a buy-to-let remortgage to pay for refurbishment, insulation, heating or wider property improvement works.


What if a landlord does not want to replace their existing mortgage?

A second charge mortgage may be an option where a landlord wants to raise capital while keeping their current mortgage in place. This can be useful if the existing mortgage has a competitive rate or early repayment charges.


Can portfolio landlords fund upgrades across several properties?

Yes. Larger landlords may be able to refinance across multiple properties to fund improvement works across a portfolio. This can help spread costs and support a more planned approach to compliance and asset management.


Is bridging finance suitable for rental property refurbishment?

Bridging finance may be suitable where a property requires more substantial works before it can be let or refinanced onto a longer-term buy-to-let mortgage. It is typically used as a short-term funding solution.


Why should landlords act before regulations tighten further?

Planning ahead can help landlords protect rental income, avoid reactive costs, improve tenant appeal and preserve long-term property value. It can also make future refinancing easier if lenders continue to focus more closely on property quality and energy performance.

If you are a landlord considering property upgrades, refinancing or refurbishment funding, Willow Private Finance can help you explore the most suitable finance options for your portfolio.


Ready to Fund Your Next Property Upgrade?


Whether you're improving a single buy-to-let or planning refurbishment works across an entire portfolio, securing the right finance can help you spread costs, protect cash flow and keep your properties aligned with evolving housing standards.


At Willow Private Finance, we advise landlords on a wide range of funding solutions, including buy-to-let remortgages, second charge mortgages, refurbishment finance, bridging loans and portfolio refinancing. With access to specialist lenders across the market, we can help structure finance that supports both your immediate improvement plans and your long-term investment strategy.



Contact Willow Private Finance today to discuss your refurbishment funding requirements and discover the most suitable finance options for your property portfolio.

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Important Notice

This article is provided for general information only and does not constitute financial, legal, tax or property advice. Mortgage availability, lending criteria and refurbishment finance options vary between lenders and are subject to individual circumstances. Landlords should seek professional advice before undertaking significant property improvements or arranging finance. Willow Private Finance is authorised and regulated by the Financial Conduct Authority.


Sources

Property Reporter – 441,000 Rental Homes Fail Thermal Comfort Standards (3 July 2026)
https://www.propertyreporter.co.uk/

GOV.UK – Housing Health and Safety Rating System (HHSRS) Guidance
https://www.gov.uk/guidance/housing-health-and-safety-rating-system-hhsrs-guidance-for-landlords-and-property-related-professionals