Awaab’s Law Phase 2: Is Your Organisation Ready for the Next Stage? 

Awaab’s Law represents one of the most significant changes to social housing compliance in recent years. Introduced following the death of two-year-old Awaab Ishak in 2020, the legislation places legally enforceable timeframes on how social landlords respond to housing hazards. Whilst the first phase focused primarily on damp and mould, the next stage significantly widens the scope of the regime.

With Phase 2 due to take effect on 30 November 2026, housing associations should ensure legal requirements have been translated into reliable, evidence-based operational practice.

Phase 1: the starting point

Since 27 October 2025, Awaab’s Law has required social landlords in England to respond within fixed timescales to all emergency hazards and to damp and mould hazards presenting a significant risk of harm. Housing associations looking for a refresher on the first phase of the regime can read our earlier article, Are You Ready for Awaab’s Law? Social Landlords – You Must Act Now.

Potential emergency hazards must be investigated and made safe as soon as reasonably practicable and within 24 hours.

Potential significant hazards must be investigated within 10 working days. A written summary normally follows within three working days, relevant safety work must be completed within five working days of the investigation concluding, and steps towards supplementary preventative work must also begin within five working days – with physical work starting within 12 weeks at the latest.

Where a home cannot be made safe in time, suitable alternative accommodation must be provided at the landlord’s expense.

What changes on 30 November?

More hazards will fall within the regime

Phase 2 applies the significant-hazard regime beyond damp and mould to excess cold, excess heat, falls, structural collapse, fire and explosions, electrical hazards, and domestic and personal hygiene and food safety.

Reports previously handled as ordinary repairs may now trigger statutory investigation, communication, safety-work and rehousing duties.

Hazard assessment and triage become even more important

The amended definitions also sharpen triage. A significant hazard is one that a reasonable landlord, with the relevant knowledge of the resident and their circumstances, would make safe within 15 working days, but not within 24 hours.

An emergency hazard is one that such a landlord would make safe within 24 hours. Budget, staff shortages or a landlord’s own delivery constraints do not lower that objective standard.

Fire safety requires careful coordination

Fire safety requires particular care. Certain fire risks arising from deficiencies in parts of multi-occupied residential buildings regulated by the Fire Safety Order are excluded from Awaab’s Law, avoiding duplication between the two regimes.

That does not reduce existing fire-safety duties: organisations need clear routing between housing repairs, building safety and fire-safety teams, with no gaps at the boundaries.

What housing associations should do now

First, rewrite policies and workflows around hazards rather than trade categories. Contact-centre scripts should capture household circumstances, health and mobility information, the problem’s location and severity, and whether rooms or essential facilities can be used. Triage must escalate as new information emerges.

Secondly, train everyone who can receive or observe a report, not only repairs staff. Housing officers, complaints teams, contractors and out-of-hours providers must recognise potential hazards, preserve the “day zero” timestamp and pass information promptly.

Thirdly, stress-test contractor and temporary accommodation arrangements. Check 24-hour specialist cover, access to electricians and structural expertise, temporary measures, surge capacity during cold weather, authority to approve emergency spend and arrangements for suitable rehousing.

Finally, treat records and resident communication as core controls. A defensible file should show what the landlord knew and when, the resident-specific risk assessment, decisions, attempted access, completed works, safety advice, updates and reasons for delay. Dashboards should flag approaching deadlines, not merely report missed ones.

Penalties and risks of non-compliance with Awaab’s Law

Compliance is an implied term of relevant social housing tenancies. A tenant may bring a breach-of-contract claim; the court may grant appropriate relief, including orders requiring works to be carried out, together with damages and costs where applicable.

Complaints may proceed to the Housing Ombudsman, while weak systems or poor records may also engage the Regulator of Social Housing’s Safety and Quality Standard.

The statutory defence depends on proving that all reasonable endeavours were used, so evidence of compliance is nearly as important as the action itself.

Six actions for the next seven weeks

1. Map every Phase 2 hazard to an owner, triage route and escalation threshold.
2. Test repairs systems against the 24-hour, 10-working-day, 3-working-day and 5-working-day deadlines.
3. Confirm out-of-hours, specialist contractor and temporary accommodation capacity.
4. Train customer-facing staff, surveyors, contractors and complaints teams using realistic scenarios.
5. Audit resident and property data, communication templates and the evidence retained for each decision.
6. Report readiness, live exceptions and overdue actions to the board before 30 November.

What’s next for Awaab’s Law?

On 9 October 2026, the government launched a consultation on extending Awaab’s Law to the private rented sector and certain licence arrangements. The consultation, which closes on 18 December 2026, seeks views on how similar protections might apply beyond social housing. The proposals remain subject to consultation and no commencement date has yet been announced.

The consultation reflects the government’s broader focus on ensuring that serious housing hazards are identified and addressed more quickly. Although the immediate priority for housing associations is preparing for Phase 2, providers should continue to monitor developments as the scope of Awaab’s Law evolves.

For housing associations, the immediate message is simpler: Phase 2 is no longer a future project.

With Phase 2 taking effect on 30 November 2026, housing associations should now be testing whether their policies, systems and supply chains can deliver compliant responses within the required timescales. Just as importantly, they should ensure they can evidence every decision made. Early identification of gaps may help avoid regulatory scrutiny, complaints and costly remediation once the new requirements take effect.

This content is provided for general informational purposes only and does not constitute legal advice. It is not intended to address the circumstances of any individual or entity, nor should it be relied upon as a substitute for specific advice from a qualified solicitor. The information reflects the legal position as at the date specified and may be subject to change. If you require advice on a specific matter, please contact us directly.