Awaab's Law Phase 2: what changes for social landlords
Phase 2 expands the deadline framework from damp and mould plus emergency hazards to a much wider range of HHSRS categories. The shift demands new systems, training, and capacity across every social landlord.
Phase 1: in force since 27 October 2025
Phase 1 of Awaab's Law — formally the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025 (SI 2025/1042), made under section 10A of the Landlord and Tenant Act 1985 (inserted by section 42 of the Social Housing (Regulation) Act 2023) — came into force on 27 October 2025, establishing the first legally binding timescales for social housing landlords to address hazards reported by tenants.
Phase 1 covers two categories of hazard: significant hazards (limited at this stage to damp and mould) and emergency hazards(any HHSRS hazard category capable of being classed as an emergency, where there is an imminent and significant risk of harm). The damp-and-mould scope reflects the hazard category directly linked to the death of two-year-old Awaab Ishak in Rochdale in December 2020. His death, caused by prolonged exposure to mould in his family's housing association flat, led to a Prevention of Future Deaths report that highlighted systemic failures across the social housing sector and ultimately drove Parliament to legislate.
Under Phase 1, registered providers of social housing became subject to five statutory deadlines, set out in SI 2025/1042, governing the response to any in-scope hazard reported by a tenant:
Phase 1 represented a fundamental shift. For the first time, social landlords faced statutory deadlines rather than vague “reasonable time” obligations. The Regulator of Social Housing and the Housing Ombudsman were given enhanced enforcement powers, and non-compliance now carries serious regulatory consequences including Regulatory Notices, compensation orders, and reputational damage through published findings.
Many housing associations and local authority housing departments invested heavily in damp & mould response teams, triage processes, and case management systems to meet Phase 1 requirements. Those investments were essential — but they addressed only one significant-hazard category. Phase 2 changes the landscape entirely.
What Phase 2 adds: seven hazard categories
Phase 2 of Awaab's Law commences in 2026 and brings a significantly wider range of hazard categories under the same five-deadline statutory framework that already applies to damp and mould and to emergency hazards. The additional categories are drawn from the Housing Health and Safety Rating System (HHSRS), which has been the statutory risk assessment framework for housing conditions in England since 2006.
The following HHSRS hazard categories will become subject to Awaab's Law deadlines once Phase 2 commences:
Excess cold
Properties where inadequate heating, poor insulation, or defective boilers expose tenants to dangerously low indoor temperatures. Excess cold is one of the most prevalent Category 1 hazards identified in social housing stock and is linked to respiratory disease, cardiovascular events, and increased mortality — particularly among elderly tenants and young children. Reports of heating failure or chronic cold conditions will need the same urgency currently applied to damp and mould.
Excess heat
Properties that overheat due to poor ventilation, inadequate shading, or design flaws — a growing concern as climate change drives more frequent and intense heatwaves. Social housing stock built in the 1960s and 1970s, particularly high-rise blocks with large single-glazed windows and no cross-ventilation, is especially vulnerable. Reports of dangerous overheating will fall under the statutory timescales.
Falls (stairs, level, between levels, baths)
A broad category encompassing falls on stairs, falls on the level (trips on uneven flooring or damaged floor coverings), falls between levels (windows, balconies, or landings without adequate guarding), and falls in baths (absence of grab rails, slippery surfaces). Falls are the single largest cause of home accidents in England. Robust processes will be needed for trip hazards, defective handrails, missing balustrades, and similar risks.
Structural collapse and explosions
The risk of the building structure or individual structural elements failing — walls, roofs, chimneys, ceilings, load-bearing structural elements — and the related risk of explosions arising from gas leaks, defective ventilation, or accumulation of combustible gases. Cracking walls, sagging ceilings, loose render, unstable chimney stacks, suspected gas leaks, or ventilation defects will trigger the 24-hour investigate-and-make-safe obligation where there is an imminent risk, and the 10-working-day investigation requirement otherwise.
Fire
Fire safety in residential premises is already heavily regulated under the Regulatory Reform (Fire Safety) Order 2005 and the Fire Safety Act 2021, but Phase 2 adds a housing-condition dimension. Where a tenant reports a fire hazard arising from the condition of the property — defective fire doors, non-functional smoke alarms, inadequate means of escape, faulty wiring posing an ignition risk, or combustible materials in communal areas — the statutory timescales will apply.
Electrical hazards
Defective electrical installations, exposed wiring, overloaded circuits, damaged sockets, and outdated consumer units. Although periodic electrical inspections are already required (typically every five years), Phase 2 means tenant reports of electrical hazards — sparking sockets, frequent circuit-breaker trips, visible damage to wiring — will trigger the deadline framework. The 24-hour emergency response obligation applies where the hazard poses an imminent risk of electrocution or fire.
Domestic and personal hygiene and food safety
Conditions that prevent occupants from maintaining basic domestic and personal hygiene or from preparing and storing food safely — including kitchens that cannot be kept hygienic because of layout or persistent disrepair, defective washing or sanitary facilities, and severely compromised food storage where the landlord is responsible for fixed appliances. Wider hygiene hazards (pest infestations, drainage and sewage failures, contaminated water supply) remain out of Phase 2 scope and are expected to come into scope under Phase 3 in 2027.
The expanded scope of HHSRS categories under statutory deadlines
It is important to understand the scale of this expansion. Phase 1 brought one significant-hazard category (damp and mould) under statutory deadlines, alongside emergency hazards across all categories. Phase 2 adds a much wider set of significant-hazard categories — covering many of the most common Category 1 and high Category 2 hazards identified in social housing stock across England.
Excess cold, falls, fire and electrical hazards are among the most prevalent Category 1 hazards in the social rented sector. Phase 2 therefore subjects many of the most prevalent serious housing defects to binding remediation timescales. Landlords who built their Phase 1 compliance around a narrow damp-and-mould workflow will find that approach wholly insufficient for Phase 2.
The HHSRS assessment methodology will remain the technical basis for evaluating whether a reported condition constitutes a relevant hazard. Housing officers, surveyors, and repairs teams will need to be proficient in HHSRS scoring across all of the newly covered categories — not just damp and mould.
What social landlords must do before Phase 2 commences
The Phase 2 commencement date in 2026 is approaching. Organisations that have not yet begun preparing face a genuine risk of non-compliance from day one. The following actions are essential.
Conduct a full stock condition audit
If your organisation has not carried out a comprehensive stock condition survey within the last two years, this must be an immediate priority. Assess every property in your portfolio against the full range of HHSRS categories Phase 2 will cover — going beyond damp and mould to heating systems, thermal performance, electrical installations, structural integrity, fire safety provisions, fall risks, and hygiene-related conditions. The purpose is twofold: identify properties that already contain Category 1 or high Category 2 hazards so remediation can be programmed proactively before tenants report them, and establish a baseline dataset that informs your ongoing compliance monitoring.
Review and update triage processes
Your existing repairs triage was likely designed around Phase 1 — identifying and fast-tracking damp and mould reports. Phase 2 requires a much broader triage capability. Every incoming repair request or tenant complaint must be assessed against all covered hazard categories. A tenant reporting that their heating has stopped working in January is not raising a routine repair — they are reporting a potential excess cold hazard that may require emergency response within 24 hours if temperatures are dangerously low. A tenant reporting a loose handrail on a communal staircase is reporting a falls hazard. Your triage system must identify these triggers accurately and escalate them into the correct compliance workflow.
Invest in staff training
Comprehensive training is not optional — it is a regulatory expectation. The Regulator of Social Housing and the Housing Ombudsman have both made clear that ignorance of the law’s requirements will not be accepted as a defence. Training should cover, at minimum: HHSRS assessment methodology across all Phase 2 categories; the five SI 2025/1042 statutory deadlines and when each clock starts; emergency response protocols and how to identify imminent risk; documentation standards for the written summary of investigation findings (Reg 9 of SI 2025/1042); and tenant communication at each stage of the remediation timeline.
Upgrade your case management systems
Many social landlords implemented case management workflows for Phase 1 that track damp and mould cases through the SI 2025/1042 deadline framework. Those systems must now expand to accommodate all Phase 2 hazard categories. Key requirements include automated deadline tracking for each category with escalation alerts; classification of incoming reports by HHSRS category at the point of logging; integrated document management for written summaries of investigation findings, inspection reports, and tenant correspondence; management dashboards showing real-time visibility of open cases and compliance rates; and integration with your asset management system. If your current housing management system cannot support these requirements, you should be evaluating alternatives now.
Establish contractor capacity
Phase 2 will generate a significant increase in repairs and remediation works that must complete within statutory deadlines. Excess cold cases will require heating engineers and insulation contractors. Electrical hazards will require qualified electricians. Structural issues will require structural engineers and specialist building contractors. Falls hazards may require adaptations, handrail installations, and flooring replacements. Review existing contractor frameworks, secure additional capacity where needed, and establish call-off arrangements that guarantee response times consistent with the statutory deadlines. For the 24-hour investigate-and-make-safe obligation in particular, you need contractors who can attend at very short notice across all relevant trades.
Review complaints and escalation procedures
The Housing Ombudsman has signalled it will take a robust approach to complaints about Phase 2 hazards. Review your internal complaints procedures so that complaints related to any covered hazard category are identified, escalated appropriately, and resolved within both the statutory remediation timescales and the Ombudsman’s complaint-handling expectations. A tenant whose heating has been broken for three weeks in winter should not need to navigate a multi-stage complaints process before their case receives urgent attention.
Audit recommendations: a practical checklist
The following checklist summarises the key audit actions social landlords should complete before Phase 2 commences:
- Complete a full stock condition survey covering all Phase 2 HHSRS categories across your entire portfolio.
- Identify and programme proactive remediation for all existing Category 1 hazards in the newly covered categories.
- Map your current triage and repairs workflow against each Phase 2 hazard category and identify gaps.
- Deliver HHSRS training to all frontline staff, surveyors, and repairs coordinators covering the full range of Phase 2 categories.
- Test your case management system’s ability to track deadlines across multiple hazard categories simultaneously.
- Review contractor capacity and establish framework agreements or call-off contracts for all relevant trades.
- Update tenant communication templates to cover all Phase 2 categories — emergency response letters, written summary of investigation findings templates (per Reg 9 of SI 2025/1042), and completion notifications.
- Brief your Board or senior leadership team on Phase 2 requirements and the organisation’s readiness position.
- Establish a Phase 2 readiness project with clear milestones, accountable owners, and regular progress reporting.
The cost of non-compliance
The consequences of failing to meet Phase 2 deadlines are severe. The Regulator of Social Housing can issue Regulatory Notices requiring immediate corrective action. The Housing Ombudsman can order compensation payments to affected tenants, publish findings of maladministration, and issue Complaint Handling Failure Orders. In the most serious cases, the Regulator can exercise its powers to appoint managers or transfer management of an organisation's housing stock.
The Renters' Rights Act 2025 (Royal Assent: 27 October 2025) raises the maximum civil penalty for failure to comply with an Improvement Notice from £30,000 to £40,000 since 1 May 2026. Civil penalties are imposed by local authorities as an alternative to prosecution and apply alongside the Regulator and Ombudsman enforcement routes specific to social housing.
Tenants may also bring civil claims directly against the landlord for breach of the implied tenancy term in section 10A of the Landlord and Tenant Act 1985 (inserted by section 42 of the Social Housing (Regulation) Act 2023). This contractual route is separate from the regulator, Ombudsman, and local-authority civil-penalty regimes above and exposes landlords to damages, costs, and injunctive relief.
Beyond regulatory sanctions, the reputational damage from published findings of non-compliance can be devastating. Housing associations depend on their regulatory standing to access funding, attract investment, and maintain positive relationships with local authorities and tenants. A pattern of Awaab's Law non-compliance could fundamentally undermine an organisation's viability.
Phase 2 is closer than you think
Phase 2 of Awaab's Law represents the most significant expansion of housing condition regulation in a generation. The shift from a single significant-hazard category to a comprehensive framework covering excess cold and heat, falls, structural collapse and explosions, fire, electrical hazards, and domestic and personal hygiene and food safety demands a step change in how social landlords manage their housing stock.
Organisations that treat Phase 2 as a routine policy update will be caught out. Those that recognise it for what it is — a fundamental transformation of landlord obligations — and invest in the systems, training, and processes needed to comply will be well positioned. The work starts now.