12/08/2026
The Government has now published its long-awaited guidance on Phase 2 of Awaab’s Law, providing greater clarity on the statutory obligations that will apply to social landlords from 30 November 2026.
Whilst Phase 1 focused primarily on damp and mould alongside emergency hazards, Phase 2 represents a significant expansion of the statutory regime. Registered providers and local authorities will need to ensure that their compliance systems are capable of identifying, assessing and responding to a much wider range of hazards within the newly prescribed statutory timescales.
A reminder of Awaab's Law Phase 1
Since October 2025, social landlords have been required to comply with strict statutory deadlines when notified of significant damp and mould hazards that a reasonable landlord would make safe within 15 working days, if it poses a risk of harm to the occupier’s health or safety. They must also comply with deadlines for other hazards identified under the Housing Health and Safety Rating System (HHSRS) (except for overcrowding), if they count as emergency hazards posing an imminent and significant risk of harm to tenants which a reasonable landlord would make safe within 24 hours.
These duties include investigating reported hazards, keeping tenants informed throughout the process, carrying out relevant safety works within prescribed timescales and, where necessary, providing suitable alternative accommodation. They apply when the hazard arises from a deficiency in the social home or other building or land for which the landlord is responsible.
These requirements marked a significant shift away from the established position where response times were largely governed by general repairing obligations and an assessment of reasonableness when determining how long remedial works should take.
The references to a reasonable landlord above shouldn’t be forgotten. If a reasonable landlord would not be able to make something safe within 24 hours (emergency hazards) or 15 working days (significant hazards), then it would fall outside scope (for example if large scale structural work was required). The work may still be required to comply with other legislation, but the Awaab’s timescales would not apply.
The changes under Awaab's Law Phase 2
From 30 November 2026, the statutory framework will extend beyond damp and mould to cover a broader range of hazards identified under the HHSRS. Government guidance confirms that the additional categories include:
- Excess cold;
- Excess heat;
- Falls;
- Structural collapse and explosions;
- Fire;
- Electrical hazards; and
- Domestic and personal hygiene and food safety hazards.
The guidance confirms that landlords are required to triage hazards on a case-by-case basis, taking into account tenant’s unique situations and vulnerabilities (including the age and physical and mental health of the tenants), as what constitutes an emergency or significant hazard for one household may not be the same for another.
These hazards will become subject to the same statutory response framework that currently applies to damp and mould, meaning landlords will need systems capable of identifying whether reported defects fall within the expanded scope of Phase 2 of Awaab’s Law.
As a reminder of the statutory response framework:
- Emergency Hazards must be investigated and made safe within 24 hours. Where this is not possible, suitable alternative accommodation must be provided where required
- Significant hazards must be investigated within 10 working days of the landlord becoming aware of the issue
- Following the investigation, landlords must provide the tenant with a written summary of the finding within three working days. Helpfully, the Government’s Phase 2 guidance includes a precedent written summary document that landlords can adapt when communicating the outcome of an investigation to tenants
- Any further works required to prevent a significant risk of harm should commence within five working days of the investigation being completed, albeit there is a 12-week backstop
Practical advice - the importance of effective triage
One of the key themes emerging from the Government’s guidance is the importance of robust triage processes. Many reports received by landlords will not neatly identify a particular HHSRS hazard. Instead, frontline staff will need to gather sufficient information to determine whether the reported issue could amount to a prescribed significant or emergency hazard requiring a statutory response. A clear audit trial will also be vital.
The guidance encourages landlords to adopt clear escalation procedures, ensure staff receive appropriate training and maintain accurate records demonstrating how decisions have been reached. Effective triage will be critical in ensuring that statutory deadlines begin promptly and that appropriate investigations are commissioned without delay.
Preparing for compliance
Although Phase 2 does not come into force until the end of November, landlords should already be reviewing whether their existing processes are fit for purpose.
For many organisations, Phase 2 will require greater collaboration between housing management, repairs teams, surveyors and legal services than has previously been necessary.
Increased regulatory expectations
Failure to comply with Awaab’s Law may expose landlords not only to regulatory intervention but also to complaints, civil claims and reputational damage. The Government’s guidance reinforces that landlords should be taking proactive steps now rather than waiting until the legislation comes into force.
Looking ahead
With implementation now only a few months away, social landlords should use the publication of the Government’s guidance as an opportunity to review existing procedures, and policies, and ensure their organisations are prepared for the expanded obligations that will apply from 30 November 2026. The Government’s guidance is comprehensive and intends to pre-empt any practical questions which may arise when a landlord assessing a notification under Awaab’s Law after 30 November 2026.
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