The impending uplift in housing standards is welcome, but the sector’s real test will lie beyond it. The organisations that set out to exceed these regulations will define the next generation of British housing, according to Mike McGowan, chair of the policy working group at the National Home Decarbonisation Group (NHDG) and divisional director at WPS.
In 2027, the Future Homes Standard (FHS) will take effect. It will bring with it the most significant uplift in standards for new-build housing that England has seen in a generation, mandating that new homes use at least 75% lower operational carbon than those built to 2013 regulations.
I spend much of my working life thinking about the homes built by the last generation of policy. The retrofit sector depends upon building decisions that were made at the design stage, and that is the lens through which those of us in decarbonisation read the Future Homes Standard: it is the specification for the homes we, or our successors, will one day be asked to manage.
First announced in 2019, the FHS is, by any reasonable measure, a sizeable change that is long overdue. Heat pumps and low-carbon heat networks take precedence ahead of gas boilers. Solar PV will be standard, covering the equivalent of 40% of a house’s ground-floor area at minimum. Fabric will improve and energy demand should reduce.
But the sector must treat it as what it is – a pointer to the direction of travel, not the destination itself. In retrofit, we work on homes once considered modern, and we know that the homes built in 2027 will still be standing in 2050 and beyond, shaped by the decisions that are taken now. They must remain affordable to run, comfortable to live in, and worth keeping.
What the FHS gets right
The move away from gas is a significant structural shift. Every new home built with a gas boiler today is a future retrofit job; the FHS pre-empts that necessity. Mandatory onsite renewables, improved fabric and the elimination of gas standing charges together will make a real dent in running costs, which matters particularly for fuel poor households who have borne the brunt of four years of energy market volatility.
Homes compliant with the new FHS, the government estimates, could save up to £830 per year on energy costs when compared to a standard EPC C-rated property. The combination of lower energy demand, onsite generation and the elimination of gas standing charges adds up to a genuine push for affordability.
Where it falls short
Yet we should consider what the FHS does not currently provide.
Firstly, “zero-carbon ready” is, by definition, not zero-carbon. The standard relies on future grid decarbonisation, and while that is a reasonable assumption over a 25-year horizon, it does have the effect of transferring responsibility from today’s design decisions to tomorrow’s infrastructure. Homes built only to the minimum may well need further regulatory intervention, or retrofit, sooner than the industry currently anticipates.
The impact of embodied carbon is also largely absent. The FHS does not do much to address emissions locked into the building’s wider lifecycle, such as materials and construction. As operational carbon falls closer to zero, embodied carbon will become the majority of a building’s net-zero impact. ‘Embodied carbon’ is already part of the public conversation, and this runs the risk of becoming a visible policy gap.
And we should always be mindful that better standards on paper do not guarantee better outcomes in use. If installation or commissioning is poor, then the industry may continue to produce some homes that underperform their specifications. This affects residents’ trust in the energy transition itself, and that is a cost the sector cannot afford.
The real destination: a better living experience
The conversation about zero-carbon housing can feel abstract. Sitting alongside Part F’s tightened ventilation guidelines, the FHS’ more stringent airtightness offers benefits that are tangible to residents. But improved airtightness and mechanical ventilation only deliver on that promise if they are designed, installed and commissioned properly.
Get them right, and residents benefit from cleaner air, comfort and wellbeing. Get them wrong, and we create the conditions for damp, mould and the headlines that have dominated the sector in recent years – and that regulators and residents will not forget.
The Met Office predicts that there is a 50% chance of seeing 40°C temperatures in the UK before 2037. Designing for Britain’s future summer conditions rather than its historic averages is necessity for residents’ wellbeing. When building dwellings we should prioritise passive measures such as orientation, shading and cross-ventilation, as well as reducing reliance on mechanical cooling.
From compliance to affordability
Design assumptions built around how occupancy works in an ideal world scenario can often collide with residents’ real patterns of life. Heat pumps can cost less to run than gas boilers, but they will only do so if correctly sized, specified and matched to household behaviour. Residents who are unfamiliar with time-of-use tariffs will be less likely to benefit from the savings available to them.
The sector’s response has to be led by evidence. We should design systems around real patterns of use, and favour simple, robust design; to this end we should also embed fuel stress prevention into our performance metrics, rather than treating it as somebody else’s problem further down the supply chain.
And we must not forget how people actually experience their homes. Low-carbon houses can introduce technology that is unfamiliar. Confusing controls and inconsistent guidance could raise residents’ bills and lead to misuse or mistrust, so ease-of-use must be a guiding principle, and energy education will be essential.
What leadership looks like after 2027
The Future Homes Standard establishes a new minimum. But those who want to establish leadership in our sector will be defined by what they choose to do above and beyond it.
The leading housebuilders, or those commissioning those programmes, will go beyond minimum fabric standards where viable. They will advocate for the implementation of the recently-announced Healthy Homes Standard, which takes seriously the fact that the home is, for most people, the single most significant determinant of their physical and mental wellbeing. But in the meantime, they will begin addressing embodied carbon voluntarily and with transparency, rather than waiting for the regulation that will eventually compel them.
Those of us in retrofit are, in a real sense, the downstream consequence of every building decision that preceded us. The housebuilders, housing providers and delivery partners who treat FHS as a floor for standards rather than a ceiling are, whether they realise it or not, reducing the retrofit bill for the next generation. That is leadership worth naming.
