Who Does Awaab's Law Apply To?
Before diving into what Phase 2 covers, it is worth being clear on scope. Awaab's Law applies strictly to social housing let by a Registered Provider (RP), which includes:
- Local authorities (LAs)
- Housing associations (HAs)
- Arms-length management organisations (ALMOs)
Importantly, it also applies to property that is leased by the Registered Provider, even where that property remains privately owned by a landlord. So if your organisation is leasing privately owned stock and acting as the landlord in practice, Awaab's Law obligations apply to you.
However, accommodation that is privately owned where the property agent remains the landlord and is secured on a licence as nightly paid accommodation by the LA sits outside the current scope of Awaab's Law. We will return to this point later in the blog, because while that stock may be exempt today, the direction of travel is clear.
A Quick Recap: What Phase 1 Covered
Awaab's Law was introduced through the Social Housing (Regulation) Act 2023, following the tragic death of two-year-old Awaab Ishak from prolonged exposure to mould in his family's social housing home. It established legally enforceable timescales for investigating and resolving hazards that pose a risk to residents' health and safety.
Phase 1, which came into force on 27 October 2025, focused on:
- All emergency hazards, requiring investigation and action within 24 hours
- Significant damp and mould hazards, with fixed timescales for investigation and repair
For significant (non-emergency) hazards, the statutory framework requires landlords to follow a clear sequence:
|
Step |
Timescale |
|
Investigate the hazard |
Within 10 working days |
|
Provide written summary to tenant |
Within 3 working days of investigation |
|
Begin repair work |
Within 5 working days of investigation |
|
Complete longer-term repairs |
Within 12 weeks |
These timescales do not change in Phase 2, but the number of hazard types they apply to grows considerably.
What's New in Phase 2: The Hazards Now in Scope
From 30 November 2026, the fixed response deadlines extend beyond damp and mould to cover a much wider range of Housing Health and Safety Rating System (HHSRS) hazard categories. These include:
Excess Cold and Excess Heat
Properties with inadequate heating, poor insulation or defective boilers that expose tenants to dangerously low indoor temperatures now fall within scope. Excess cold is one of the most prevalent Category 1 hazards in social housing stock and is linked to respiratory disease, cardiovascular events and increased mortality, particularly among elderly tenants and young children. As climate change drives more extreme summer temperatures, excess heat is also now a recognised and regulated risk.
Electrical Hazards
Faulty wiring, overloaded circuits and unsafe electrical installations are now subject to the same statutory response timescales. Many of these hazards are already part of existing electrical safety compliance programmes, but Awaab's Law now adds legally enforceable response times on top of existing duties.
Fire Hazards
Fire risks, including inadequate fire detection, blocked escape routes and combustible materials, are brought into the Awaab's Law framework. These are closely linked to existing fire safety compliance regimes, but landlords must now ensure they can evidence investigation and resolution within the prescribed timescales.
Structural Collapse
Structural defects that present a significant risk to occupants, including subsidence, unstable walls or failing roofs, are now in scope. These hazards often require specialist assessment and longer-term remediation programmes, making early identification and proactive asset management critical.
Falls
This category includes defective stairs, inadequate guarding, damaged flooring, trip hazards and unsafe access routes. Falls are a leading cause of serious injury in the home, particularly for older residents, and now carry the same statutory response obligations as damp and mould.
Domestic and Personal Hygiene, and Food Safety
Hazards related to sanitation, pest infestations and conditions that compromise basic hygiene standards are also brought within scope. These can overlap with damp and mould cases, but now carry their own independent compliance obligations.
Why Phase 2 Is a Bigger Operational Challenge
Phase 2 is not simply "more of the same." The nature of these new hazard categories fundamentally changes how landlords need to respond, and which teams need to be involved.
For many social landlords, Phase 1 compliance largely sat within repairs, property services and damp and mould teams. Phase 2 demands a much broader, whole-organisation response. Compliance will now rely on coordinated working across:
- Housing and repairs teams
- Asset management and compliance functions
- Contact centres and out-of-hours services
- Contractors and specialist surveyors
- Safeguarding and customer service teams
The government's message is clear: social housing landlords must be able to identify, investigate and resolve serious hazards within prescribed timescales, while maintaining robust records throughout the process. This is as much a cultural shift as an operational one.
Critically, the statutory clock starts the moment anyone in your organisation, or an agent acting on your behalf, becomes aware of a potential hazard. That means triage processes, contact centre scripts and contractor workflows all need to be aligned and ready.
What the Updated Phase 2 Guidance Says
On 13 July 2026, the Ministry of Housing, Communities and Local Government published its Phase 2 guidance for social landlords, considerably more detailed than the original Phase 1 guidance. Rather than simply restating the timescales, it explains how landlords should apply the regulations in practice, including:
- How to categorise hazards under the HHSRS framework
- How to determine when statutory timescales begin, i.e. the moment of awareness
- How to record decisions and demonstrate reasonable endeavours to gain access
- When to arrange alternative accommodation (at the landlord's expense) if the property cannot be made safe within the required timescales
The guidance also includes a hazards annex to support landlords in triaging the new categories consistently and correctly.
What About Privately Owned Stock? Why Now Is the Time to Act Broadly
As noted above, accommodation sourced through the private sector on a licence basis, where the property agent remains the landlord, currently sits outside the scope of Awaab's Law. For local authorities using nightly paid, privately owned accommodation, the legal obligations do not yet apply to that stock.
But the direction of travel is clear. The Renters' Rights Act 2025 has set out a timeline for extending Awaab's Law principles to the private rented sector, with similar enforceable timescales for private landlords expected in the early 2030s. That may feel distant, but the operational groundwork takes time to build.
More importantly, the case for rolling out consistent hazard management practices across all stock does not rest on legal obligation alone. Local authorities have a duty of care to the residents they house, regardless of tenure type. Applying the same standards of hazard identification, investigation and resolution across your entire portfolio, whether it falls within Awaab's Law today or not, is simply good practice. It protects residents, reduces risk and means your organisation will not be scrambling to catch up when regulation does arrive.
The organisations best placed for Phase 3 and beyond will be those that did not wait to be told.
What About Phase 3?
Phase 2 is not the final step. In 2027, Awaab's Law is expected to extend to all remaining HHSRS hazards (apart from overcrowding), completing the full statutory framework. This means the organisations investing now in robust hazard management processes, data quality and cross-team coordination will be best placed to absorb Phase 3 without significant disruption.
How Access Adam Housing Supports Phase 2 Compliance
Meeting the demands of Phase 2 requires more than good intentions. It requires systems that can track statutory deadlines across a growing range of hazard types, coordinate action across teams and contractors, and build the audit trail that regulators and the Housing Ombudsman will expect to see.
Access Adam Housing is designed to support social landlords through exactly this kind of regulatory change. From hazard logging and triage through to repairs management, the platform gives housing teams the visibility and control they need to stay compliant and to prove it.
As Awaab's Law continues to expand, having a connected, compliance-ready housing management system is not a nice-to-have. It is a necessity.
Key Dates at a Glance
|
Phase |
Date |
Scope |
|
Phase 1 |
27 October 2025 |
All emergency hazards + significant damp and mould |
|
Phase 2 |
30 November 2026 |
+ Excess cold/heat, fire, electrical, structural, falls, hygiene |
|
Phase 3 |
2027 (expected) |
All remaining HHSRS hazards (excluding overcrowding) |
Next Steps for Social Landlords
If you have not already, now is the time to:
-
Clarify your scope: identify which properties in your portfolio fall within Awaab's Law and which do not, and consider applying consistent standards across all stock regardless
-
Review your triage processes: ensure repairs teams can identify and categorise all Phase 2 hazard types
-
Audit your contractor and out-of-hours arrangements: can you mobilise specialist trades within the required timescales for electrical, structural and fire hazards?
-
Strengthen your record-keeping: the statutory clock starts at awareness, so every report needs to be logged immediately and consistently
-
Train your teams: Phase 2 compliance is a whole-organisation responsibility, not just a repairs function
-
Review your housing management system: can it track deadlines, evidence action and generate audit trails across all the new hazard categories?
Access Adam Housing helps social landlords manage compliance with Awaab's Law across all phases, from hazard reporting and triage to repairs and contractor management. Find out more about how Access Adam Housing supports safer homes.
Sources: Ministry of Housing, Communities and Local Government (MHCLG) Phase 2 Guidance, July 2026 | Social Housing (Regulation) Act 2023 | GOV.UK Awaab's Law Collection
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