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Awaab's Law Phase 2: Ten Hazards in November, Ten More Expected in 2027

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Guest insight from PM+, Rank 1 framework partner for Damp and Mould Surveys.

Awaab's Law is arriving in stages. From 30 November 2026, ten hazard categories will sit within its investigation and repair timescales rather than one. A third stage expected in 2027 looks set to bring in ten more, leaving overcrowding as the only hazard in the Housing Health and Safety Rating System (HHSRS) that falls outside the regime altogether.

A good deal has been written about the principle of Awaab's Law. Rather less has been written about which hazards land on which date, which is the part social landlords need in order to plan. That is what this article sets out.

What is already in force?

Phase 1 began on 27 October 2025 under the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025. It brought two things within statutory timescales: significant damp and mould hazards, and all emergency hazards of any type, overcrowding excepted.

Phase 2 leaves the timescales themselves alone. What changes is the number of hazards they apply to.

The timescales

These have applied to damp and mould, and to emergency hazards, since October 2025.

Duty

Deadline

Emergency hazard: investigate and complete the relevant safety work

Within 24 hours of becoming aware

Investigate a potential significant hazard

Within 10 working days of becoming aware

Provide a written summary of the investigation to the tenant

Within 3 working days of the investigation concluding

Complete the relevant safety work

Within 5 working days of the investigation concluding

Begin, or take steps to begin, supplementary preventative work

Within 5 working days of the investigation concluding, or within 12 weeks where that is not reasonably practicable

Three points tend to get missed. Relevant safety work has to be completed inside five working days, whereas supplementary preventative work only has to begin. The written summary is owed whether or not a hazard is found, and it must set out what the investigation found, what action is required, the target timescales and who to contact. Where the safety work cannot be completed in time, the landlord must secure suitable alternative accommodation for the household at the landlord's expense.

Day zero is the day the landlord becomes aware. These are maximum timeframes, not targets.

What comes into scope on 30 November 2026?

From that date, Awaab's Law applies to significant hazards in the following categories:

  • Damp and mould growth (already in scope from Phase 1)

  • Excess cold

  • Excess heat

  • Falls on the level, which under the revised HHSRS now also captures falls associated with baths

  • Falls on stairs and steps

  • Falls between levels

  • Structural collapse and falling elements

  • Fire and explosions

  • Electrical hazards

  • Domestic hygiene, which now combines three previously separate hazards: food safety, domestic hygiene/pests/refuse, and personal hygiene/sanitation/drainage

All emergency hazards remain in scope regardless of category, other than overcrowding.

For the latest official requirements, see the Government's Awaab's Law Phase 2 guidance for social landlords.

Presence of a hazard is not the same as a significant hazard

This is the point to labour with your teams. A hazard falling into one of the categories above does not automatically trigger Awaab's Law. The test is whether it presents a significant risk of harm, which turns on the severity of the risk, the likelihood of harm and the circumstances of the household, including the vulnerability of the people living there. The same defect in two properties can produce two different answers.

Somebody has to make that call, often quickly, on the strength of a phone call or a visit. Whether they make it well depends on training and on what information they can see at the time.

The HHSRS itself changed in June 2026

If you compare hazard lists across different sources at the moment, they will not agree with each other. There is a reason for that. The HHSRS was revised with effect from 23 June 2026, cutting the number of assessable hazards from 29 to 21 by merging related categories rather than removing any.

Inspection templates, surveyor briefing notes and repairs categorisation built around the old 29 hazards are now out of date. That mattered relatively little in June. It matters rather more from November, when hazard categorisation starts to carry statutory deadlines.

What is expected in 2027?

The Government has said Phase 3 will extend Awaab's Law to all remaining HHSRS hazards apart from overcrowding, and that it is expected in 2027.

Read against the revised 21-hazard HHSRS, that points to the following coming into scope:

  • Flames, hot surfaces and similar

  • Collisions, entrapment and ergonomics

  • Asbestos and manufactured mineral fibres

  • Lead

  • Radiation

  • Indoor air pollutants, now a single hazard combining what were carbon monoxide and fuel combustion products, uncombusted fuel gas, biocides, and volatile organic compounds

  • Water supply

  • Entry by intruders

  • Noise

  • Lighting

Those ten, plus the ten in scope from November 2026, plus crowding and space (excluded from Awaab's Law altogether) account for all 21 hazards.

A caveat is needed here. The Government has not yet published Phase 3 regulations or confirmed a commencement date, and has described its approach to implementation as test and learn, so the detail may shift. The breakdown above is our reading of what "all remaining hazards apart from overcrowding" means against the revised HHSRS. Treat it as a planning assumption and check the regulations when they appear.

What it does tell you is the direction of travel. By the end of Phase 3, almost every housing hazard will carry a statutory investigation and repair clock. Processes designed narrowly around the November list will need rebuilding a year later, so there is a case for designing them now to handle any hazard report, whatever its category.

The private rented sector

The Renters' Rights Act 2025 allows Awaab's Law to be applied to privately rented homes through implied terms in tenancy agreements, enforceable by tenants through the courts or through the new Private Rented Sector Ombudsman. The Government has committed to consulting on how to do this proportionately and has not published a date. Private landlords and agents should watch for that consultation rather than assume the social housing timescales will transfer across unchanged.

What to do between now and November

With more hazards in scope, and the clock starting the moment you become aware of a potential hazard, the usual constraint is what you know about the property and the household at the point the report comes in.

Establish how good your stock condition data actually is

Awaab's Law does not require landlords to carry out Stock Condition Surveys (SCS), and it does not require you to inspect every property before November. Current, structured condition data across a portfolio does something more useful than compliance for its own sake: it tells you where the Phase 2 hazards are likely to be concentrated, so you can deal with them on your own timetable instead of the statutory one.

Test your inspection programme against the new hazard list

How reliably do your current arrangements surface issues relating to electrical safety, fire, structural defects, excess cold and heat, and fall risks? Known defects and recurring problems deserve attention before they turn into statutory triggers.

Rework triage, then train to it

The Government has published Phase 2 guidance specifically to support the triaging of hazards. Use the time before November to make sure everyone who might receive a report understands how a potential hazard is identified, recorded, dated and escalated. That includes contact centre staff, housing officers, contractors and surveyors.

“The 24-hour emergency route needs to work at four o'clock on a Friday afternoon, not only on paper.”

Make property information quick to retrieve

With deadlines measured in working days, and 24 hours for emergencies, whoever is deciding needs fast access to previous survey information, repairs and maintenance history, known defects, fire and electrical safety records, previous complaints and reports, and records of earlier investigations and remedial works. If assembling that takes two days, you have spent a fifth of your investigation window on retrieval.

Look at capacity as well as process

A wider hazard scope means more investigations, more specialist inspections and more evidenced decisions, concentrated in the months after commencement. Check that your surveying and inspection arrangements can absorb that, and that your procurement routes let you bring in specialist capacity when they cannot.

How PM+ Can Help

PM+ works with housing associations and social landlords across England, Scotland and Wales, providing surveying and property consultancy across residential portfolios. The company is RICS-regulated, Constructionline Gold accredited and SSIP registered. Its directly employed team is supported by a vetted network of self-employed surveyors, which gives it UK-wide coverage for portfolio-scale programmes while keeping reporting consistent.

Its Stock Condition Surveys give housing providers a structured picture of property condition, identify defects and inform maintenance and investment priorities. PM+ also carries out Damp & Mould Surveys, HHSRS assessments, Fire Risk Assessments, Fire Door Inspections and Housing Disrepair Surveys where a particular property or hazard needs specialist attention.

PM+ acts as the surveying and advisory partner alongside delivery contractors, providing the evidence and recommendations rather than the remedial works.

Phase 2 takes effect on 30 November 2026 and Phase 3 is expected the following year. If you are reviewing what you hold on your stock ahead of that, PM+ can discuss your surveying and inspection requirements.

Preparing for Awaab's Law Phase 2? Speak to PM+ about Stock Condition Surveys and specialist property inspections across your housing portfolio.

This article provides a general overview of Awaab's Law and is not legal advice. Phase 3 scope and timing are not yet confirmed in regulations. Social landlords should refer to the Regulations and the latest Government guidance when determining their specific legal obligations.

About the author

PM+

PM+ | Project Management & Building Consultancy for Social Housing and Retail

At PM+, we specialise in providing trusted Project Management and Building Consultancy services to the Social Housing and Public Sectors. Our mission is clear: to help landlords deliver safer, healthier homes while ensuring transparency, accountability, and measurable outcomes in everything we do. Our work is grounded in the belief that every tenant deserves to live in a warm, dry, and safe home and we see it as our duty to help make that a reality. We are proud to support social landlords across the UK in meeting their legal, regulatory, and moral responsibilities.

PM+ brings innovation to the challenges facing social housing. As part of our Awaab’s Law compliance, Disrepair and Damp & Mould Surveys work, we deploy advanced Fabric and Environmental Monitoring, delivering real-time insights into the conditions that affect tenants’ daily lives.

In support of the Warm Homes Social Housing Fund (WH:SHF), our Retrofit Improvement Measurement service provides robust validation and precise data to support retrofit project planning, funding applications, and post-works assurance.

Our team of experienced surveyors and project professionals work nationwide, delivering expert advice and evidence-based solutions to improve housing conditions at scale. At PM+, we’re not just providing a service, we’re part of a movement to raise standards, protect tenants, and restore trust in the housing sector.

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