Awaab’s Law Phase 2: when everyday repairs start a legal clock    

By David Guy · 15 July 2026

Phase 2 of Awaab’s Law comes into force in England on 30 November 2026. It extends the statutory timescales beyond damp and mould to a wider range of significant hazards. This includes excess cold and heat, falls, structural collapse, fire and explosions, electrical safety and domestic hygiene.

Phase 2 of Awaab’s Law may appear to be an extension of Phase 1, but in practice it is a step change in volume, complexity and risk.

A failed heating system, loose handrail, faulty window restrictor, pest infestation or electrical fault may no longer be a routine repair. Depending on the home, the likely harm, and the customer’s circumstances, it could start a legal clock.

The volume challenge

Phase 1 largely concentrated significant-hazard processes around damp and mould, alongside emergency hazards. Phase 2 focuses further into everyday repairs, housing management, compliance and customer contact.

The first person receiving the report may need to understand what has happened, who lives in the home, how vulnerability changes the risk, if the home can still be used safely, and if emergency, significant-hazard or routine arrangements apply.

Therefore, triage is more about reaching, recording and evidencing a defensible judgement.

The risk is clear: under-categorise and the landlord may miss a legal deadline or leave a customer exposed; over-categorise and emergency and significant-hazard caseloads could overwhelm surveyors, contractors, DLO teams and systems.

Early learning from Phase 1 already points to familiar pressure points: unclear thresholds, shortages of surveyors and specialist trades, rising contractor costs, weak system integration and resources being pulled from planned work into immediate compliance activity.

Phase 2 could amplify every one of those pressures.

Inspection is only the start

Compliance does not end with attendance or inspection. Landlords need clear ownership from first report through investigation, safety action, written summary, customer updates, permanent works and any supplementary work needed to prevent the hazard returning.

The key questions are: who owns the case, who monitors the clock, who decides the home is safe, who tracks the permanent fix, who updates the customer, and who knows when alternative accommodation is required?

A task-based repairs model may not be enough. Phase 2 creates a wider risk of fragmentation between diagnosis, temporary action, permanent remediation, communication and evidence.

Contractors and supply chains will feel it too

Landlords retain legal responsibility even when contractors, DLO teams or managing agents carry out inspections and works. Delivery partners will need the competence, information, escalation routes and capacity to support compliance.

That means clearer diagnostic prompts, faster specialist call-off, better information on temporary safety measures, tighter escalation rules and honest testing of capacity.

A contract clause saying a supplier will comply with legislation does not create extra electricians, surveyors, structural engineers, pest-control technicians, parts, access arrangements or temporary accommodation.

If capacity is not tested now, landlords may discover too late that their operating model works on paper but not at the volume Phase 2 creates.

The real risk is what your data can’t show you

Landlords must be able to show when they became aware of a potential hazard, what information was available, how it was categorised, who investigated, what decision was reached, what was communicated and if each required action happened in time.

If your evidence for a case is spread across separate trackers, free-text notes, manual clock calculations and contractor portals that don’t feed back into a central system, Phase 2 will expose the gaps fast.

Communication is compliance

For customers, a timely first response means little if the problem still isn’t fixed weeks later and no one’s telling them why. A landlord could hit every early deadline: attending on time, making the hazard temporarily safe, sending the written summary,  and still damage trust if the permanent work stalls or communication goes quiet afterwards.

Phase 2 compliance depends as much on clear case ownership and consistent communication between landlords, contractors, DLO teams and suppliers as it does on technical response times. 

The questions to answer now

Before November 2026, landlords and contractors should be asking:

• Can every route into the service recognise a possible Phase 2 hazard?
• Can staff distinguish routine, significant and emergency cases consistently?
• Does vulnerability information actually change the response?
• Can systems start, monitor and evidence the right clock?
• Are specialist trades and competent investigators available quickly enough?
• Who owns temporary safety work, permanent remediation and customer communication?
• Would the board see missed clocks, recurring hazards and supply-chain constraints, or just initial attendance?

Those questions need answers well before the legal deadline.

How to get Phase 2-ready

ARK can support landlords, DLOs/inhouse teams and contractors with focused Phase 2 readiness work, from a short independent health check to a full implementation programme.

Support can include readiness and capacity assessments, policy and procedure updates, triage frameworks, role-based training, contractor and supply-chain reviews, process and customer-journey mapping, systems and reporting checks, customer communication testing, scenario exercises, and executive or board assurance.

The real deadline sits well before 30 November 2026. Getting there means updating systems, revisiting contracts, training staff and operatives, stress-testing supply chains, and giving boards genuine assurance… which doesn’t happen quickly.

Phase 2 isn’t a longer list of hazards. It brings a much larger share of everyday housing services inside a legal clock, and it will soon become clear which organisations have built an operating model that can withstand that, and which have only rewritten the policy.

Contact the team