By Daniel Brito, managing director of Legal Futures Associate National Claims
Brito: Phase 3 on the horizon
The next phase of Awaab’s Law will test much more than how quickly social landlords can complete repairs.
From 30 November 2026, Awaab’s Law phase 2 will extend statutory requirements beyond significant damp and mould to a much wider range of hazards in social homes. These include excess cold and heat, falls, structural collapse, fire and explosions, electrical hazards and domestic hygiene risks where they pose a significant risk.
The government’s phase 2 guidance for social landlords makes clear that landlords will need to do more than complete repairs within a set timeframe. They will also need to identify potential hazards, understand the level of risk and make sure the right action is taken quickly.
So, while 30 November is an important legal deadline, it is also a practical test of how well repairs teams, housing officers, contractors, complaints teams and internal systems work together.
Phase 2 significantly broadens the requirements
Phase 1 came into force in October 2025, introducing specific requirements for emergency hazards and significant damp and mould. Phase 2 brings a much wider range of significant hazards within the same framework.
Under the new requirements, landlords will generally have to investigate a potential significant hazard within 10 working days of becoming aware of it. If the investigation confirms a significant hazard, relevant safety work must then be completed within five working days of the investigation ending.
Emergency hazards have a much shorter timeframe. They must be investigated and made safe as soon as reasonably practicable and within 24 hours of the landlord becoming aware of them. If the necessary safety work cannot be completed in time and the home cannot be made safe, the landlord must arrange suitable alternative accommodation at its own expense.
Importantly, these are maximum timeframes. The government’s guidance makes clear that landlords may need to act sooner depending on the circumstances.
This makes getting the initial assessment right particularly important. A repairs service needs to look beyond the type of fault when deciding how urgently to respond. A heating failure, electrical problem or damaged floor may require a different approach depending on the level of risk it poses to the people living in the property.
Looking beyond the type of repair
This is one of the more significant changes behind the Awaab’s Law phases.
Social housing repair systems are often organised around the type of work required, whether that is plumbing, heating, electrical work, structural repairs or general maintenance. Under Awaab’s Law, landlords also need to consider the potential harm caused by the problem.
Similar repair issues do not always carry the same level of risk. A broken heating system, for example, may be more urgent during cold weather or where someone in the household is particularly vulnerable to low temperatures. Damaged flooring might be a relatively straightforward repair in one home but present a serious fall risk in another. The response therefore needs to reflect the circumstances in the property, not just the type of repair reported.
The government’s guidance on triaging phase 2 hazards reinforces this approach. It uses a “reasonable landlord” test to help determine whether a hazard should be treated as significant or as an emergency.
That makes the information collected when a problem is first reported particularly important. A report that simply says “heating not working” or “floor damaged” may not give a repairs team enough information to understand how serious the situation is. Asking the right questions at the start could make the difference between a routine repair and an issue that needs to be escalated quickly.
Why previous repairs matter
Awaab’s Law phase 2 also makes the history of a property more important when assessing a new report.
Government guidance recommends keeping accurate information about properties and residents, along with clear records of investigations, communications and action taken under the legislation.
In practice, that information may sit in several different places. A tenant could report the same problem through a contact centre, an online repairs system, a housing officer and a formal complaint. Contractors may also hold records of previous visits or repairs that did not resolve the issue.
If those reports are viewed separately, it can be easy to miss a pattern.
Recurring damp is a good example. Repeatedly cleaning mould or repairing damaged plaster may deal with what is visible without resolving a leak, ventilation problem or another underlying cause. More extreme cases, including reports of mushrooms growing on walls, show how serious, persistent damp can become when the source of the problem remains unresolved.
The same applies to other types of disrepair. Repeated electrical faults, recurring heating failures or several reports about the same structural issue may all suggest that a more fundamental problem needs attention.
An effective social housing repair service therefore needs to consider what has happened in the property before, rather than treating each new report as a completely separate issue.
Compliance depends on the whole repairs process
Much of the discussion around Awaab’s Law understandably focuses on the deadlines: 24 hours, 10 working days and five working days.
But meeting those deadlines consistently depends on what happens throughout the repairs process.
Contact-centre teams need to know which questions to ask when a tenant reports a problem. Repairs staff need to know when an issue should be escalated. Contractors need a clear way to report new concerns they discover while they are in a property.
Housing teams need access to relevant information about the household, and records need to show when the landlord first became aware of the potential hazard.
There is also a difference between making a home safe and completing the repair. In some cases, a temporary fix may be needed first, with permanent work following later. Landlords need to keep track of both stages to make sure the underlying problem is fully resolved.
This means effective social housing repairs and maintenance increasingly depend on having the right information available at the right time.
Phase 3 is already on the horizon
Phase 2 is not the final stage. Phase 3 is planned for 2027 and is expected to bring the remaining hazards covered by the Housing Health and Safety Rating System into scope, with the exception of overcrowding.
For landlords, this makes it important to think beyond the November deadline. Building processes solely around the hazards covered by phase 2 could mean having to change them again when phase 3 arrives.
Instead, the focus should be on creating a repairs service that can identify and respond to risk consistently. That means having the right information about the property and household, understanding previous repair issues, recognising when a problem needs to be escalated and keeping a clear record of what action has been taken.
This is perhaps the bigger change behind Awaab’s Law. The deadlines are important, but the legislation is also raising expectations around how landlords identify problems and respond to tenants when something goes wrong.
From 30 November 2026, completing the repair will only be part of the picture. Landlords will also need to show that they recognised the risk quickly, understood the circumstances and took appropriate action.
For social landlords preparing for phase 2, getting those processes right now should also put them in a stronger position for what comes next.
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