New HHSRS Guidance: Do Landlords Need Window Restrictors, Grab Rails and Child-Proof Consumer Unit Cupboards?

The government's long-awaited update to the Housing Health and Safety Rating System (HHSRS) came into force in June 2026 and represents the biggest overhaul of housing safety standards in nearly 20 years. The new guidance signals a clear shift towards prevention, with greater emphasis on reducing risks before accidents occur rather than waiting until someone gets hurt.

While the updated HHSRS does not specifically create new legislation requiring every landlord to install window restrictors, bathroom grab rails, or child locks on consumer unit cupboards, the guidance is likely to influence how local authorities assess properties and determine whether hazards exist.

For landlords, the direction of travel is becoming increasingly clear.

Falling From Height: Upstairs Windows Under Increased Scrutiny

One of the areas receiving significant attention under the revised HHSRS is the risk of falls from windows.

Many local authorities have already been encouraging the use of window restrictors on accessible upper-floor windows, particularly where children may be present. The updated guidance's focus on preventing serious injuries means it is likely that inspectors will increasingly expect landlords to have considered this risk and taken reasonable steps to reduce it.

In practical terms, landlords should consider whether upstairs windows could:

• Open wide enough for a child to fall through.

• Be easily accessed from furniture or beds.

• Present a foreseeable risk to occupants.

  
  

Where appropriate, fitting a suitable restrictor may be a simple and inexpensive way of reducing that risk.

ELA Warning: Don't Create a Fire Hazard

Before rushing out and fitting restrictors to every upstairs window, landlords need to stop and think about fire safety.

Many bedroom windows form part of a property's emergency escape route. If a window already requires a key to open, adding a restrictor could make that escape route unusable during a fire if the key cannot be located quickly.

A safety improvement should never create a new hazard.

Landlords should carefully assess:

• Whether the window serves as an emergency means of escape.

• Whether the window lock requires a key.

• Whether any restrictor can be overridden quickly and easily without the use of a key.

• Whether the installation could delay escape in an emergency.

  
  

The last thing anyone wants is a child prevented from falling out of a window one day but a family unable to escape through it in a fire the next.

The key message is simple: reduce fall risks while maintaining safe escape routes.

Bathroom Safety: Grab Rails May Become the New Expectation

The revised HHSRS also places a greater focus on hazards arising from slips, trips and falls within the home. Bathrooms are one of the most common locations for serious domestic injuries, particularly amongst older people and those with mobility difficulties.

Although there is currently no blanket legal requirement for every bathroom to contain grab rails, many landlords may find that installing them becomes increasingly difficult to argue against as a reasonable preventative measure.

Relatively inexpensive grab rails positioned:

• Adjacent to baths,

• Inside shower enclosures,

• Beside toilets where appropriate,

  
  

can significantly reduce the likelihood of injury.

As local authorities place more emphasis on preventing foreseeable accidents, bathroom safety is likely to become an area of increasing scrutiny.

Consumer Unit Cupboards: A New Area of Concern

Another issue attracting attention under the updated HHSRS is the accessibility of electrical equipment.

Consumer units are often located inside cupboards at low level where curious children can easily reach them. Whilst modern consumer units are designed to be safe, accidental interference or tampering can still present risks.

As a result, landlords should consider fitting child-resistant locks to cupboards housing consumer units, particularly in family accommodation.

Simple measures may include:

• Child-proof catches on consumer unit cupboards.

• Ensuring cupboard doors close securely.

• Keeping electrical warning labels visible.

• Regular inspection of cupboard fixings and locks.

  
  

For a few pounds, landlords can substantially reduce the risk of children accessing electrical equipment and demonstrate a proactive approach to safety.

The End of "Minimum Standards"

Perhaps the most significant message from the new HHSRS is that enforcement is moving away from simply identifying obvious defects and towards assessing whether reasonably foreseeable risks have been managed appropriately.

In the past, landlords often asked:

"Is this legally required?"

Increasingly, local authorities may ask:

"Could this reasonably have prevented an injury?"

That subtle difference has major implications.

Landlords who wait until guidance becomes legislation may find themselves on the back foot if a local authority inspector takes a different view.

What Should Landlords Do Now?

ELA recommends landlords review their portfolios and consider whether the following improvements would be appropriate:

✅ Window restrictors on upper-floor windows where safe to do so.

✅ Careful assessment of escape windows to ensure fire safety is not compromised.

✅ Bathroom grab rails to reduce slip and fall risks.

✅ Child-proof locks on consumer unit cupboards.

✅ Secure stair handrails and guarding.

✅ General review of all fall-related hazards.

Many of these improvements cost very little compared with the potential consequences of enforcement action, civil penalties, or serious tenant injuries.

Final Thoughts

The updated HHSRS is sending a strong message to landlords: prevention matters.

Whilst not every safety measure is currently a legal requirement in every property, the expectations of inspectors are clearly moving towards a more proactive approach to risk management.

The landlords who adapt early are likely to be the ones who avoid enforcement action, protect their tenants, and future-proof their portfolios.

Just remember: when it comes to window restrictors, don't solve a fall hazard by creating a fire hazard. The safest property is one that protects tenants from both.