(NSW) Introduce Mandatory Insulation Standards for Rental Homes
Author: Olivia Limson, Alizée Bourgault, Ketut Divya S Bhavani, Meghna Mallik, Roma Heanly, Siva Nandhana P, Aryanshi Singh, Prachi Sharma, Vittoria Galgano, Siahn Fraser, Virginia Wills, Blake Allan, Abbey Bailey, Tahlia Lindsay, Natalie Chung, Bridie Long & Muhamad Fajar | Publish date: 2/10/2026
P: In NSW, rental housing laws do not mandate minimum insulation standards.
S: The NSW Minister for Housing should amend Section 52(1A) of the Residential Tenancies Act 2010 (NSW) to include insulation in rental minimum standards.
E: Sweltering Cities (2024): ‘Include … insulation in rental minimum standards.’
Problem Identification:
Section 52(1A) of the Residential Tenancies Act 2010 (NSW) (the Act) sets out 7 minimum standards a rental property must meet to be ‘fit for habitation’. However, this does not include insulation.
According to Better Renting (BR), renters ‘have limited control over the factors that shape indoor temperatures, including insulation ... and access to effective cooling’. They argued that many renters are ‘pushed to a literal and systemic boiling point’ as indoor temperatures rise.
Context:
Insulation refers to a ‘building material that slows … heat transfer from one area to another’, controlling temperature within the home.
A minimum insulation standard refers to an imposed standard on R Value, which measures ‘how well [insulation] resists heat flow’, including the various components of a roof, ceiling, wall or floor.BR reported that in summer, NSW apartments frequently exceed 25-30°C indoors, with ‘more than half of sleeping hours spent above 25°C’.
Blue Green Engineering (BGE) reported that ‘poor insulation is certainly the primary cause of low energy-efficiency.’ Energy Consumers Australia (ECA) reported that ‘only around a third (37%) of rental properties have at least one form of insulation, compared with 80% of owner-occupied homes.’
ECA referred to energy hardship indicators as spending more than 6% of household income on energy bills. This included finding energy bills ‘very difficult’ to pay, and financial stress combined with avoiding heating or cooling to save money. ECA identified that ‘renters make up 69% of those meeting two or more [energy] hardship indicators and 54% of those meeting at least one.’
Arguments:
The 2025 Heat in Homes Survey Report found that excessive indoor heat, including that attributable to inadequate insulation, has ‘serious negative impacts on health’. NSW Health noted that extreme heat can ‘[lead] to severe heat-related illness including heat stroke and heat exhaustion.’ BR recorded that ‘many rental homes are dangerously hot in summer, both chronically and during heatwave events, with indoor temperatures regularly exceeding levels considered safe, comfortable, or healthy’. The 2025 Heat in Homes Survey Report found that 87% of survey respondents agreed that ‘their homes get too hot’, and 54% stated they ‘struggle to cool their home.’ The 2026 Summer Survey by Sweltering Cities reported that 68% of respondents felt ‘unwell during heatwaves.’ BR further highlighted that ‘climate change is predicted to increase the frequency, duration, and severity of heatwaves, and this would lead to more deaths from heat.’ The World Health Organisation noted that ‘unstable temperatures harm the cardiovascular and immune system, and are associated with an increase in mortality.’
ECA found that ‘renters are disproportionately more likely to be vulnerable to, or experiencing, energy hardship’. BGE stated that ‘poor insulation forces heating and cooling systems to work overtime to maintain an indoor temperature’, causing energy consumption to rise and leading to higher electricity bills. Australian Housing and Urban Research Institute (AHURI) reported that energy hardship is prevalent among the majority of renters due to financial constraints. They elaborated that renters ‘do not have the legal right or authority to modify their dwellings’, which can ‘result in elevated energy usage and higher costs’.
Advice/Solution Identification:
Sweltering Cities and Better Renting have called for the adoption of minimum insulation standards in rental homes in NSW. The Tenants’ Union stated that this could enable rental properties to ‘protect [tenants] from the weather and [support families] to stay healthy.’ BR estimated that ‘improving the efficiency of [rental homes with poor energy efficiency] would achieve benefits worth $1.199 billion, or $1,683 per affected household.’
Precedent:
There is domestic and international precedent for including insulation in minimum rental standards. Both the ACT and VIC have introduced requirements for all rental properties to meet a minimum ceiling insulation standard. Internationally, New Zealand has also legislated the Healthy Homes insulation standard.
Public Support of the Solution
(This list reflects publicly stated positions and should not necessarily be taken as endorsement of this specific brief.)
Broad Support:
Tenants' Union of NSW - They have called for the implementation of ‘performance based minimum energy efficiency rental standards (MEERS) with the primary objectives of improving the thermal safety of rental homes to protect renters [sic] health and improve energy affordability and reduce energy hardship for renters.’ However, they have not explicitly called for mandating minimum insulation standards for rental premises.
The following organisations and experts support the Healthy Homes for Renters recommendations within this campaign: the Healthy Homes for Renters, a campaign with 125 organisations, campaigns for the ‘Australian governments to commit to introducing minimum energy efficiency standards for rental properties’. However, they have not explicitly called for mandates on insulation standards.
News Coverage:
AAP News - “Heat-safe rentals pushed to protect from quiet killer”. The NSW Net Zero Commission recommended mandatory ceiling insulation for tenancies, noting that rental and social housing lacked legal protections against extreme indoor heat. By: Poppy Johnston | 21 April 2026 - Read the article here.
9News - “Like a pizza oven: NSW renters trapped in dangerously hot homes”. NSW tenants reported living in homes where internal temperatures reached over 40 degrees, with one renter comparing her uninsulated apartment to a "pizza oven" during a summer heatwave. By: Emily McPherson | 8 April 2026 - Read the article here.
ABC News - “How to improve the energy efficiency in older Australian homes”. Energy experts highlighted that installing or upgrading ceiling insulation remains one of the most cost-effective ways to improve thermal comfort and reduce energy bills in older, draughty Australian homes. By: Rhiannon Shine | 8 March 2026 - Read the article here.
The Guardian - “Rental properties 3C hotter indoors, survey of Australian tenants over summer finds”. Better Renting reported that rental homes ran noticeably hotter than outdoor conditions over summer, with NSW renters experiencing the highest indoor temperatures and humidity levels of any state monitored. By: Cait Kelly | 19 March 2024 - Read the article here.
Where to go to learn more:
(2026) Summer Survey | Sweltering Cities - This survey report detailed the prevalence of heat-related health issues, higher energy prices and inadequate housing insulation. Read the full report here.
(2026) Boiling Point: NSW renters pushed to the limit by unsafe indoor heat | Better Renting - This report highlighted how NSW renters, impacted by uninsulated and poor-quality housing, were exposed to sustained, dangerous indoor heat that caused severe physical and mental health issues. Read the full report here.
(2025) Insulation | YourHome - This fact sheet focused on home insulation principles and guidance for energy-efficient building design. View the fact sheet here.
(2025) Understanding and measuring energy hardship in Australia | Energy Consumers Australia - This report outlined how a growing number of households struggled to afford basic energy needs and identified that renters are disproportionately affected. Read the full report here.
Residential Tenancies Act 2010 (NSW) - Read the full Act here.
Human Perspective:
Penelope is a renter in NSW whose shared apartment becomes extremely difficult to live in during summer. During hot weather, sunlight streams through the windows while the walls and ceilings radiate stored heat. Temperatures remain high late into the night, making it difficult for her to sleep. Penelope’s rental property is poorly insulated, making it challenging to regulate indoor temperatures. As a result, she uses multiple fans during the day. However, she and her housemates still find it difficult to cool their apartment as the fans merely circulate hot air rather than effectively reducing her apartment temperature. Penelope also owns an air conditioner but rarely uses it due to the high running costs. Without adequate insulation, the cool air escapes quickly, and the air conditioner has to work overtime. Money is already tight, so she can’t afford the additional cost to maintain a comfortable temperature. Penelope often feels uncomfortable and unwell, with the heat exacerbating her existing migraine condition due to the inability to adequately cool her home. In the summer, she often feels nauseous, faint, and dehydrated, causing her migraines to become more frequent and severe. She also developed a painful heat rash. Over time, she feels stuck in a home she can’t properly cool or afford to change, resulting in a health burden due to extreme indoor heat. If only her rental had proper insulation, she could stay safe, comfortable and cool in her own home.
To protect the anonymity of those involved, this is a fictionalised account drawn from an amalgamation of real-life stories, experiences and testimonials gathered during the research process for this brief. Any resemblance to actual individuals is purely coincidental.
Conflict of interest/acknowledgment statement:
N/A.
Support
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Disclaimers
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Reference list:
ACT Government. (n.d.). Minimum energy efficiency standards for rental homes: Information for renters. https://www.act.gov.au/__data/assets/pdf_file/0010/2602927/Tenant-factsheet-minimum-energy-efficiency-standards-for-rental-properties.pdf
Australian Council of Social Service. (2025). Heat in homes survey report 2025. https://www.acoss.org.au/wp-content/uploads/2025/03/Heat-Survey-Report-v1.0-Digital.pdf
Azdari, M. (2026, February 9). The guide to energy-efficient home construction in Australia. Owner Inspections. https://ownerinspections.com.au/articles/the-guide-to-energy-efficient-home-construction-in-australia
Better Renting. (2026a, April 7). Boiling point: NSW renters pushed to the limit by unsafe indoor heat. https://assets.nationbuilder.com/betterrenting/pages/2351/attachments/original/1775547511/Boiling_Point__NSW_SRR_25_26_findings_report_compressed.pdf#page=28
Better Renting. (2026b). Too hot to be home: NSW renters’ experiences of summer heat in apartments and high-rise buildings. https://assets.nationbuilder.com/betterrenting/pages/2252/attachments/original/1772583209/NSW_Summer_Renter_Researchers_report_1_-_Apartments_and_High-Rise_buildings.pdf
Blue Green Engineering. (n.d.). How poor insulation impacts energy efficiency in buildings. https://bluegreeneng.com.au/poor-insulation-impacts-energy-efficiency-in-buildings/
Brooke, R. (2021, June 17). Renters deserve warm homes in winter. Tenants’ Union of NSW. https://www.tenants.org.au/blog/renters-deserve-warm-homes-winter-too
Consumer Affairs Victoria, Victorian Government. (2026, April 14). New minimum energy efficiency standards. https://www.consumer.vic.gov.au/resources-and-tools/legislation/public-consultations-and-reviews/new-minimum-energy-efficiency-standards
Coulburn, L., & Miller, W. (2022). Prevalence, risk factors and impacts related to mould-affected housing: An Australian integrative review. International Journal of Environmental Research and Public Health, 19(3), 1854. https://doi.org/10.3390/ijerph19031854
CSIRO. (n.d.). Thermal insulation. https://research.csiro.au/infratech/wp-content/uploads/sites/38/2024/12/3037_ThermalInsulation_WCAG.pdf
Daniel, L., Moore, T., Baker, E., Beer, A., Willand, N., Horne, R., & Hamilton, C. (2020). Warm, cool and energy-affordable housing policy solutions for low-income renters (AHURI Final Report No. 338). Australian Housing and Urban Research Institute Limited. https://doi.org/10.18408/ahuri-3122801
Dignam, J. (2022). The cost of complacency. Better Renting. https://www.betterrenting.org.au/cost_of_complacency
Department of Climate Change, Energy, the Environment and Water. (2025). Insulation. Your Home. https://www.yourhome.gov.au/passive-design/insulation
Department of Climate Change, Energy, the Environment and Water. (2026, April 15). Heating and cooling. Energy.gov.au. https://www.energy.gov.au/households/heating-and-cooling
Dignam, J., & Barrett, B. (2022). Hot homes: Renter Researchers’ experiences of summer 21–22. Better Renting. https://drive.google.com/file/d/1P5pHlpQD-Sl-Ww28k8NnWPuNxiTy7751/view
Energy Consumers Australia. (n.d.). New research underlines need for minimum energy efficiency standards for Australia's rental properties. https://energyconsumersaustralia.com.au/news/new-research-underlines-need-minimum-energy-efficiency-standards-australias-rental-properties
European Union. (2024). Directive (EU) 2024/1275 on the energy performance of buildings. Official Journal of the European Union. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202401275
Expol Underfloor Insulation. (2025, September 25). The hidden costs of bad insulation. https://expolinsulation.com.au/hidden-costs-of-poor-insulation/
Healthy Homes for Renters. (n.d.). Healthy homes for renters. https://www.healthyhomes.org.au/
Heffernan, E., Beazley, S., McCarthy, T. J., & Sohel, M. I. (2017). Energy efficiency within mid-rise residential buildings: A critical review of regulations in Australia. Energy Procedia, 121, 292–299. https://doi.org/10.1016/j.egypro.2017.08.030
High Flow Energy. (2026, April 13). How much electricity does an aircon use. https://www.highflowenergy.com.au/how-much-electricity-does-an-aircon-use/
McLeod, B., Rice, M., Comer, J., Sands, B., Arndt, D., & Seton, N. (2024). Under pressure: The climate crunch fuelling inflation and hurting Aussie families. Parents for Climate & Climate Council. https://www.stopthebillshock.org/wp-content/uploads/2024/12/Under-Pressure_ParentsforClimate_ClimateCouncil_Report.pdf
NSW Health. (2023, November 23). Beat the heat: Heat and health. https://www.health.nsw.gov.au/environment/factsheets/Pages/beat-the-heat.aspx
Point, B. (2025, December 1). Decoding BASIX, NaTHERS, Passive House & Passivhaus. Ballast Point. https://ballastpoint.com.au/blog/decoding-sustainable-homes-basix-nathers-passive-house-and-passivhaus-explained
Renew, & Oakey, H. (2025, February 24). Renew joins the call for a better deal for renters. Renew. https://renew.org.au/advocacy/renew-joins-the-call-for-a-better-deal-for-renters/
Residential Tenancies Act 2010 (NSW) No. 42 s. 52. https://legislation.nsw.gov.au/view/whole/html/inforce/2025-08-15/act-2010-042#sec.52
Royal Australian College of General Practitioners. (2018, December). Preventing heat related disease in general practice. Australian Journal of General Practice. https://www1.racgp.org.au/ajgp/2018/december/preventing-heat-related-diseasein-general-practic
Sweltering Cities. (n.d.). Heatwave safe homes for renters. Retrieved June 30, 2026, from https://swelteringcities.org/heatwave-safe-homes-for-renters/
Sweltering Cities. (2024, December 4). Heatwaves. https://swelteringcities.org/heatwave-information/
Sweltering Cities. (2026). Summer survey 2026. https://swelteringcities.org/wp-content/uploads/2026/03/Summer-Survey-2026-report-v1.0.pdf
Tenants' Union of NSW. (n.d.). Healthy homes for renters at NSW Parliament. https://www.tenants.org.au/news/healthy-homes-renters-nsw-parliament
World Health Organization. (2018). High indoor temperatures. In WHO housing and health guidelines. https://www.ncbi.nlm.nih.gov/books/NBK535285/
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