Awaab's Law Phase 2: What Changes When It Commences
Phase 2 expands Awaab's Law beyond damp and mould to cover all 29 HHSRS hazard categories. Here's everything landlords need to know before Phase 2 commences.
When Awaab's Law came into force in October 2025, it applied to a specific set of hazards — primarily damp and mould — with strict statutory deadlines for social housing landlords. Phase 2, commencing in 2026, significantly expands the scope of the legislation. Understanding what changes is critical for every registered provider in England.
What is Phase 2?
Phase 2 of Awaab's Law extends the statutory investigation and remediation deadlines introduced in Phase 1 to cover all 29 hazard categories under the Housing Health and Safety Rating System (HHSRS). Where Phase 1 focused primarily on damp, mould, and condensation, Phase 2 brings heating failures, structural hazards, fire risks, electrical safety issues, pest infestations, and a range of other property conditions within scope.
This represents a fundamental expansion of landlords' obligations. Under Phase 2, the same statutory framework that already applies to damp and mould — 24-hour investigation and safety works for emergencies, 10 working days to investigate significant hazards, 3 working days for the written summary, 5 working days to make the home safe, and a 12-week backstop on additional preventative works to begin — will apply to any hazard that falls within the HHSRS framework.
The 29 HHSRS hazard categories now in scope
The Housing Health and Safety Rating System covers a broad range of hazards that affect residents' health and safety. Once Phase 2 commences, all of the following will be subject to Awaab's Law deadlines:
Physiological requirements: damp and mould growth, excess cold, excess heat, asbestos and manufactured mineral fibres, biocides, carbon monoxide and fuel combustion products, lead, radiation, uncombusted fuel gas, volatile organic compounds.
Psychological requirements: crowding and space, entry by intruders, lighting, noise.
Protection against infection: domestic hygiene, pests and refuse, food safety, personal hygiene, sanitation and drainage, water supply for domestic purposes.
Protection against accidents: falls associated with baths, falls on the level, falls associated with stairs and steps, falls between levels, electrical hazards, fire, flames and hot surfaces, collision and entrapment, explosions, position and operability of amenities.
What the deadlines mean in practice
The same statutory deadline structure from Phase 1 applies under Phase 2:
24-hour emergency response: Where any HHSRS hazard poses an imminent and significant risk of harm to a resident, landlords must investigate the hazard and complete any required safety works within 24 hours of becoming aware. This is the same standard that already applies to emergency damp and mould cases under Phase 1.
10 working days — investigation: For all significant hazards, landlords must complete a full investigation within 10 working days, beginning the day after the hazard is reported. The investigation must determine whether the home is affected by a significant hazard and what work is required.
3 working days — written summary, 5 working days — make safe, and a 12-week backstop: Within 3 working days of the investigation finishing, the landlord must give the tenant a written summary under Regulation 9. The home must then be made safe within 5 working days of the investigation. Where additional preventative works are needed to stop the hazard from coming back, those works must begin within 12 weeks at the latest, with completion in a reasonable timeframe.
Why Phase 2 is a significant operational challenge
Phase 1 required landlords to build dedicated workflows for damp and mould. Phase 2 requires those same systems to cover the full breadth of HHSRS hazards — fire safety checks, heating and boiler failures, structural repairs, pest management, electrical faults, and more.
For housing associations and local authorities managing large stock, this means:
Triage systems must be upgraded. Your 24-hour emergency triage process needs to cover all hazard types, not just damp and mould. Every report must be assessed for whether it triggers the emergency or significant hazard clock.
Contractor capacity must be reviewed. The 5-working-day safety-works deadline and the 12-week backstop on additional preventative works require contractor availability across a much wider range of trade types. Electrical contractors, structural engineers, heating engineers, and pest control providers all need to be within scope of your delivery timescales.
Documentation must scale. The evidence log, inspection records, and written summary templates that suffice for damp and mould cases need to work equally well for a boiler failure in January or a structural crack in a load-bearing wall.
The Regulator's enforcement expectations
The Regulator of Social Housing has been clear that Phase 2 compliance will be assessed as part of its Consumer Standards regime. Landlords that fail to meet the expanded deadlines risk formal investigation, public censure, and in the most serious cases, enforcement action including special administration.
The Housing Ombudsman will continue to investigate complaints involving Phase 2 hazards and can order compensation, systemic reviews, and public findings of severe maladministration where landlords fail to comply.
How to prepare before Phase 2 commences
Ahead of Phase 2 commencement, the following steps are priorities for every registered provider:
1. Review your hazard triage process. Does it cover all 29 HHSRS categories? Does every team member — including repairs operatives and contact centre staff — know how to classify a report as emergency or significant?
2. Audit your contractor network. Do you have contracts in place that guarantee the response times Phase 2 will require across all trade types?
3. Update your templates and documentation. Written summary templates, inspection forms, and evidence logs built for damp and mould cases need to be adapted to cover the full HHSRS scope.
4. Train your staff. All frontline staff who receive, classify, or manage repair reports need to understand the Phase 2 expansion and the consequences of missing statutory deadlines.
5. Test your systems. Run a tabletop exercise across a range of Phase 2 hazard scenarios before Phase 2 commences to identify gaps in your processes.
Summary
Phase 2 of Awaab's Law is the single most significant expansion of social landlords' statutory repair obligations in a generation. The Phase 2 commencement is approaching. Organisations that have already built robust Phase 1 compliance processes are well-placed — but the expanded scope requires deliberate preparation across triage, contracting, documentation, and training.