Andrew Burke, Deputy Secretary, Adviser to National Housing Maintenance Forum (NHMF) and Lead for the NHMF’s Net Zero Working Group discusses how Housing Providers can benefit by integrating safety compliance and retrofit workstreams.

The UK housing sector faces a genuine challenge: delivering large-scale retrofit programmes that decarbonise homes whilst ensuring quality outcomes and maintaining resident trust. Recent legislation through the Building Safety Act, Awaab's Law, and Fire Safety (PEEPs) regulations creates additional compliance obligations. But rather than viewing these as separate burdens, integrating them offers practical advantages for retrofit delivery.

The Building Safety Act, Awaab's Law, and Fire Safety (PEEPs) create the mechanisms for systematic engagement. The Building Safety Act requires resident engagement on building safety decisions. Awaab's Law's investigation of damp and mould reveals actual ventilation failures and heating performance reflecting occupancy patterns. Fire Safety (PEEPs) requires identifying vulnerable residents and understanding their individual evacuation needs - a template for person-centred assessment. Scale and responsiveness are compatible when underpinned by systematic understanding of resident needs.

From Compliance to Co-Design

Residents’ engagement driven by compliance requirements can overlap with and reinforce co-design initiatives. While co-design often means consulting residents on minor choices whilst technical decisions remain expert-driven, the Transforming Homes Consortium and Healthy Homes Hub demonstrate a different approach. Rather than residents choosing retrofit specifications, they define what the retrofitted home must achieve and what the success criteria looks like.

Residents are experts in their own lifestyles, comfort levels, financial situations and health, all of which affect retrofit outcomes. Through engagement, residents segment themselves by usage patterns and priorities. Armed with this understanding, technical teams design retrofit packages addressing different combinations of needs.

One household needs to be cheap to heat at low level, all day long with secondary heating (consistent daytime occupancy), whilst another needs the whole house to respond quickly and reach heat at speed (shift workers, variable schedules). Both require completely different retrofit approaches.

The Transforming Homes Consortium demonstrates the feasibility of this approach at scale, working across 1.4 million 1920-1940 council houses by identifying property typologies and occupancy archetypes, then designing adaptive retrofit packages. This is intelligent standardisation: not bespoke customisation of every home, but adaptive packages where data obtained through compliance with the aforementioned legislation and active engagement with residents identifies what matters to make successful large-scale retrofits.

https://www.transforminghomes.org.uk/

From EPC Estimates to Actual Performance Data

A persistent problem in retrofit planning is reliance on Energy Performance Certificates. Whilst EPCs provide the standardised outputs funders require, they reflect assumed construction and insulation levels, rather than measured heat loss parameters. Data from the Social Housing Decarbonisation Fund shows that almost 100% of upgraded homes improved to EPC band C or above, yet only 69% have measured pre- and post-installation EPC data.

Recent technology changes this equation. Smart metering platforms integrated with energy monitoring can measure actual heat loss, thermal demand, and running costs. Rather than assuming all homes in a property type perform identically, landlords can now identify which homes deviate significantly from predictions and why. Combined with data from compliance activities, this creates comprehensive pictures supporting targeted retrofit.

The key distinction is between building data (material composition, ventilation systems, heating specifications) and occupancy data (work patterns, thermal preferences, household vulnerability). Building data and thermal performance, if verified by measurement, can be standardised for large-scale programmes. Occupancy data is fluid but crucial for appropriate retrofit sizing. Using compliance data to identify which properties require specific adaptations prevents both under-tailored standardisation and endless customisation.

Quality Failures and Accountability

The National Audit Office report published in October 2025 revealed that 98% of external wall insulation installations require remediation,  installations in between 5,600 and 16,500 homes with remediation costs range from £5,000 to £18,000 per property. Furthermore, 29% of homes with internal wall insulation have major issues requiring remediation - costing from £250 to £6,000 per property. The NAO identified potential fraud worth between £56 million and £165 million caused by retrofit businesses falsifying or exaggerating claims for ECO (Energy Company Obligation) installations. Root causes included fragmented governance, weak oversight, and unclear accountability for quality.
https://www.nao.org.uk/wp-content/uploads/2025/10/energy-efficiency-installations.pdf

PAS 2035 and PAS 2030 standards exist to define retrofit quality, yet implementation remains inconsistent. Without regulatory enforcement, standards depend on intrinsic motivation and cost pressures frequently win.

Organisations demonstrating quality outcomes typically employ blended delivery models: internal expertise overseeing external consultants and main contractors. This approach creates multiple quality assurance checkpoints. However, effectiveness depends on formalising accountability. Those signing off retrofit completion should be named to funders, independently verify PAS compliance, review resident feedback, and remain accountable for defects discovered post-completion.

Moving Forward

The tension between scale and bespoke solutions is real but not insurmountable. Large-scale delivery requires standardised retrofit packages for known issues (loft insulation, windows, heating systems). Flexibility targets homes where data identifies specific needs. This intelligent standardisation, informed by data from compliance activities, enables both efficiency and appropriateness.

For housing providers, practical next steps include mapping existing compliance activities and their timing, integrating data sources into comprehensive asset profiles, designing retrofit packages around identified patterns, and formalising quality procedures with named accountability. Beginning with pilots using current delivery approaches allows processes to be refined before scaling.

Rather than treating safety compliance and retrofit as separate workstreams, they should be integrated. Compliance activities generate the resident relationships, data insights, and engagement momentum that make large-scale retrofit delivery both feasible and genuinely responsive to resident needs. This integration is not just operationally efficient; it is legally sound and ethically appropriate.

We’re called Working Groups because that’s precisely what we’re doing – working, not just talking and meeting. If you’d like to join us working on behalf of creating a better social housing landscape by becoming a member of this NHMF Net Zero Working Group or the 6 other areas our Working Groups cover; Procurement, Building and Fire Safety, Net Zero, Technology, Training, Skills & Culture or Hammar regional please contact: Andrew Burke at ajburke7@gmail.com or Julian Ransom at julian@ion-consultants.co.uk