The Board broadly welcomes the Government’s Future Homes Standard (FHS) as a necessary and positive step. However, its success will depend less on policy intent and more on how homes are designed, constructed, commissioned, and lived in.
A consistent theme across our reflections is that the Standard places significant emphasis on system-led solutions—particularly heat pumps and electrification—without sufficient focus on the fundamentals that enable their success. Chief among these is building fabric quality. Without rigorous attention to insulation, airtightness, junction detailing, and the elimination of thermal bridging, there is a clear risk that increasingly complex technologies will be installed in homes unable to support their effective performance. A genuinely “fabric first” approach must therefore be more strongly embedded and explicitly prioritised if the intended outcomes are to be realised.
Closely linked to this is the persistent performance gap between design-stage compliance and in-use reality. There is concern that the FHS, like previous frameworks, may appear robust on paper while underperforming in practice. Addressing this requires a decisive shift toward mandatory, comprehensive testing, clearer allocation of responsibility across project teams, and much stronger accountability for delivered outcomes. The Board considers it essential that the Standard moves beyond compliance-based metrics and instead holds the industry accountable for how homes actually perform once occupied.
A critical and currently under-recognised dimension of this performance gap is the discrepancy between manufacturers’ claimed performance and what can be achieved in real-world conditions. There is a clear risk that technologies are assessed and specified based on idealised laboratory conditions or optimised usage scenarios that do not reflect how homes are actually lived in. In practice, achieving stated performance levels may depend on patterns of operation that are unrealistic for most occupants. This creates the potential for systemic underperformance and risks undermining confidence in low-carbon technologies.
The Board is concerned that, without intervention, this could distort the market—penalising manufacturers whose products perform reliably under typical conditions, while rewarding those whose claims are based on less representative assumptions. To address this, the FHS should move toward standardised performance metrics that reflect real-world usage, alongside more transparent testing methodologies. This would support fair comparison between technologies, provide greater clarity for designers and installers, and ensure that performance expectations are both credible and achievable in practice.
The role of the end user is equally critical. The Board emphasises that operability and lived experience must be central to the FHS. Current approaches often assume levels of engagement and behavioural adaptation that cannot be relied upon in practice, particularly in social housing. Most occupants want homes that are warm, comfortable, and easy to control, without needing to understand complex systems or significantly change established behaviours. Where technologies are not intuitive or fail to meet these expectations, occupants may disengage, override systems, or adopt less efficient alternatives—undermining performance and eroding trust. Designing around real human behaviour, rather than expecting users to adapt, is therefore essential.
This is particularly acute in the affordable and social rented sectors, where occupants have less choice over their home, less disposable income to absorb the consequences of underperformance, and (in many cases) pre-existing vulnerabilities that make cold, damp or poorly ventilated homes a direct risk to health and well-being. The lessons of Awaab’s Law and the wider damp and mould crisis must be carried directly into FHS implementation: a standard that performs only under ideal conditions will fail the very households it should most protect.
This user-centred perspective is supported by research highlighting the importance of effective commissioning, clear handover, and ongoing support. Ensuring that systems are simple, reliable, and well understood in real-world conditions is critical to achieving intended outcomes and avoiding unintended consequences.
The Board also recognises the practical challenges of implementation, particularly for SME developers who play a vital role in housing delivery. The increased complexity associated with the FHS—in design coordination, technical detailing, and system integration—risks marginalising smaller developers unless clear and accessible pathways to compliance are established. There is a significant opportunity for Government and industry to support SMEs through standardised solutions, better-aligned guidance, and stronger integration between policy and construction practice.
The Board further notes that the FHS will land differently across tenures, and that registered providers and affordable housing developers face a distinct set of pressures that warrant specific recognition. Unlike market housing, affordable schemes are delivered within fixed grant envelopes, section 106 viability constraints and long-term stock ownership models—meaning Registered Providers (RPs) bear both the upfront capital cost of compliance and the long-tail responsibility for in-use performance, maintenance, and resident outcomes. Without targeted support, there is a real risk that the additional cost and complexity of FHS compliance will reduce affordable housing delivery at precisely the moment national need is most acute. The Board would encourage Government to ensure that grant rates, benchmark land values, and viability frameworks are recalibrated in parallel with FHS implementation, so that higher standards do not come at the expense of housing numbers.
Ultimately, FHS cannot be considered in isolation from the wider housing delivery system. A significant proportion of new homes (particularly affordable homes) are delivered through section 106 agreements, package deals, and golden brick acquisitions where specification is effectively set by the host developer rather than the ultimate owner. Clearer contractual and regulatory mechanisms will be needed to ensure FHS standards are genuinely passed through these delivery routes, and that registered providers acquiring homes can rely on—and evidence—the performance they are paying for.
Finally, the proposed delay to full implementation until 2028 is considered pragmatic. However, this lead-in period must be used proactively and deliberately. It presents a critical opportunity to invest in workforce skills, training, and employer support to ensure the industry has the capacity to manufacture in the UK, as well as to install, commission, and maintain low-carbon technologies at scale. Without this investment, there is a significant risk that supply chain constraints and skills shortages will undermine delivery, increase costs, and limit the effectiveness of the Standard.
In summary, the Board’s position is that the Future Homes Standard has the potential to be transformative, but only if there is a decisive shift in focus—from what technologies are specified to how homes are actually delivered, operated, and experienced. This means explicitly prioritising fabric performance, embedding real-world testing and verification, aligning stated and actual technology performance, designing for real users, investing in skills and supply chain capacity, and enforcing clear accountability for in-use outcomes. Without this shift, the Standard risks falling short of its ambitions; with it, there is a genuine opportunity to reset how high-quality, low-carbon homes are created.
This response has been produced by collating the written views of members of the Centre’s Housing and Communities Leadership Board. Further information on the composition of our Board and the work of the team can be found by clicking here
We would recommend visiting the Chartered Institute of Housing’s website to access all of the relevant regulations and documents – please click here for more information
