Awaab’s Law: A Broader Legislative Shift

By David Guy · 16 July 2025

Are You Prepared Beyond Damp and Mould?

The publication of draft guidance for the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025 confirms that Awaab’s Law marks a fundamental change in how landlords must respond to property-related health risks.

While damp and mould remains central to the legislation’s origin, the scope is far wider and the implications for governance, service delivery and legal compliance are significant.

Now: 2025 Regulations

From 27 October 2025, all social landlords will be legally required to:

• Investigate and address emergency hazards within 24 hours or provide safe temporary accommodation if resolution is not possible in that time and issue a written summary to the tenant within 3 working days.
• Investigate significant risks related to damp and mould within 10 working days, issue a written summary to the tenant within 3 working days and complete safety-critical works within 5 calendar days.
• Ensure follow-on remediation is initiated within 12 weeks if the hazard cannot be fully addressed in the initial window.

Emergency Hazards: A hazard that presents an “imminent and serious risk to the health or safety” of the occupiers or visitors. Must be made safe within 24 hours, and written summary provided to the tenant within 3 working days.

Significant Hazards: Hazards that pose a significant risk to the health or safety of an occupier, but not necessarily an immediate one. These must be:

• Investigated within 10 working day
• Written summary provided to tenant within 3 working days of conclusion
• Works to make safe must begin within 5 working days
• Full repair to be completed reasonably promptly (max 12 weeks to start works if complex)

What’s Next: 2026 and 2027 Expansion

The guidance sets out a clear phased expansion of the regulations:

Phase 1 – October 2025:

• Applies to all emergency hazards
• Applies to significant risk from damp and mould

Phase 2 – 2026:

Significant hazards will extend to:

• Excess cold and excess heat
• Fire and electrical hazards
• Falls (on stairs, baths, level surfaces, etc.)
• Structural collapse and explosion
• Domestic hygiene and food safety

Phase 3 – 2027:

• Applies to all remaining HHSRS hazards (excluding overcrowding)

By 2027, the law will cover a full spectrum of health and safety risks, meaning landlords must be ready to identify, investigate, report, and remediate a broad and evolving set of housing hazards.

What Landlords Need to Do: Now

Meeting the October 2025 requirements and preparing for the phased expansion will require operational, cultural and contractual change. Here are some key steps to consider for compliance:

1. Clarify Legal Responsibilities

• Landlords must take ownership of the reporting process. Written reports to tenants must be issued by the landlord, even when the hazard is identified or made safe by a contractor.
• Establish clear internal processes and system workflows that record hazard type, inspection outcomes, legal timescales and tenant communications.

2. Strengthen Triage and Risk Categorisation

• Equip call handlers, customer service teams and technical staff to accurately identify and categorise hazards under the HHSRS framework.
• Develop triage tools and escalation pathways to distinguish emergency risks from significant or routine issues.

3. Align Contracts and Contractor Obligations

• Contractors should be contractually required to identify and escalate emergency and significant hazards identified during other works.
• Provide prompt reports, photos and access notes to support landlord compliance.
• Contractors cannot issue tenant reports, but they are essential in providing the data landlords need to fulfil their legal duties.

4. Enhance IT Systems and Record-Keeping

• Ensure repairs, asset management and CRM systems can log hazard reports and investigation timescales.
• Track deadlines for legal compliance.
• Generate and store tenant communications and reports.

Preparing for 2026 and 2027: Beyond Compliance

While the immediate focus is on damp, mould and emergency risks, landlords must plan for long-term transformation in how they manage property-related health and safety:

People:

• Upskill surveyors, housing officers and customer service teams to recognise a broader range of hazards.
• Promote organisational awareness of upcoming changes across teams.

Processes:

• Review internal policies and procedures to align with emerging legal obligations.
• Ensure routine inspections, complaint responses and responsive repairs include structured hazard assessments.

Culture:

• Promote a shift from “repairs” to “risk management” – embedding a safety-first mindset across asset and housing functions.
• Recognise that future scrutiny will increasingly focus on hazard prevention, not just post-incident response.

A Trigger for Strategic Change

The draft guidance confirms that Awaab’s Law is not a narrow regulation focused on one issue, it is a catalyst for systemic change. It demands that landlords build the capability, systems and assurance mechanisms to identify and manage serious hazards quickly, consistently and legally.

The time to act is now, not just to meet the October deadline, but to get ahead of the next phases of regulation. For many landlords, this will require investment, policy overhaul, supplier engagement, and cross-functional alignment. But the outcome, safer homes and stronger tenant protections, is worth the effort.

How We Can Help

We can help and support you through a range of tailored, end-to-end support services, including:

• Awaab’s Law compliance and risk-led asset management, including full readiness assessments, operational redesign, triage processes, and compliance reporting.
• Contractor and supply chain alignment, ensuring roles, responsibilities and legal duties are embedded in contracts and service level agreements.
• Policy and systems integration, embedding new legal requirements into internal procedures, IT systems and resident communications.
• ASAP (Asset Sustainability an Performance Tool), our in-house asset analytics platform that enables landlords to assess stock viability, prioritise investment and target homes at greatest risk, including dedicated damp and mould module.
• Interim management and leadership capacity, providing experienced professionals to fill key roles and deliver transformation from our pool of associates.
• Culture change and training, equipping teams to identify hazards, respond to risk, and embed a safety-first mindset across the organisation.
• Customer service and housing operations improvement, aligning people, processes and systems to deliver safer, more responsive services.
• Strategic and technical asset support, from stock condition surveys and decarbonisation to investment planning and governance.