How to Comply with Awaab's Law: A Step-by-Step Guide for Housing Associations

Social housing providers across England are required to comply with Awaab's Law since Phase 1 came into force on 27 October 2025. The statute sets maximum timeframes for each stage of a hazard case — but the timeframes alone do not tell you what to do. Between "hazard reported" and "case closed," there are six distinct steps, each with its own deadline and evidence requirement.

This guide covers the compliance workflow in sequence. It is written for repairs managers, compliance officers, and housing officers at registered providers, ALMOs, and housing associations operating under 5,000 units.

For the full regulatory context, see The Complete Guide to Awaab's Law. For an assessment of which cases fall under Phase 1, see What Counts as a Significant Hazard Under Awaab's Law.

The Regulatory Basis

Awaab's Law is delivered through the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025 (SI 2025/1042), which came into force on 27 October 2025. The Regulations apply to social landlords as defined under the Social Housing (Regulation) Act 2023 — registered providers, local authorities in their landlord capacity, and ALMOs.

The GOV.UK guidance is explicit on one point: these are maximum timeframes, not target times. Providers should act as quickly as circumstances allow — the deadlines are a legal floor, not a productivity benchmark.

Phase 1 covers two categories: emergency hazards (any type) and damp/mould hazards presenting a significant risk of harm. All other HHSRS hazards are out of scope until Phase 2.

Step 1: Record Awareness — Day Zero

The compliance clock starts when the landlord becomes aware of the hazard — not when they verify it.

Awareness means any credible communication from a tenant, contractor, housing officer, or third party indicating a potential hazard exists. The source of awareness does not matter: phone call, email, app report, housing officer observation during a routine visit, a letter from a solicitor. The moment of awareness is day zero.

Why this matters operationally: if your current process records cases when a housing officer opens the job rather than when the report was received, you are starting the clock late. If the report came in at 4pm on a Friday and was logged Monday morning, the clock still started Friday.

What to record at awareness:

• Date and time of receipt
• Channel (phone, email, portal, on-site observation, etc.)
• Name of the staff member who received or processed the report
• Description of the hazard as reported (not yet assessed)
• Property address and tenant name

The compliance checklist walks through the full case lifecycle — the awareness stage is the entry point.

Step 2: Classify the Hazard

Within the same working day as awareness, the responsible officer should make an initial classification:

Emergency hazard? — A hazard posing an immediate risk of significant harm. Examples: gas leak, complete loss of heating in cold weather, structural collapse risk, severe mould causing immediate respiratory risk. → Skip to Step 3 with a 24-hour total deadline for both investigation and safety work.

Significant damp/mould hazard? — Mould affecting sleeping areas, a child's bedroom, a room the household regularly uses, or any presentation where the Housing Ombudsman's published guidance on severity would classify it as significant risk. → Standard Phase 1 pathway applies: 10 working days to investigate.

Not within Phase 1 scope? — Other HHSRS hazards (falls, excess cold in mild conditions, noise, etc.) fall outside Phase 1. These still carry obligations under the Landlord and Tenant Act 1985 Section 11 and the Housing Act 2004. Log them and handle via your standard repairs process. They become Awaab's Law-in-scope when Phase 2 regulations come into force.

If you are uncertain whether a particular damp/mould presentation constitutes a significant risk, use the Phase Checker to assess the hazard type and phase.

Step 3: Investigate — Within 10 Working Days

Deadline: The investigation must be completed within 10 working days of awareness.

Working days exclude weekends and all England and Wales bank holidays. The deadline calculator calculates this automatically — enter the awareness date and hazard type, and it accounts for bank holidays correctly.

Investigation means an on-site assessment that establishes:

• The nature and likely cause of the hazard
• Whether it presents a significant risk of harm
• What remedial works are needed and in what sequence
• Whether any immediate safety steps are required before full remediation

Common mistake: treating "contractor booking" as the investigation completion date. The investigation is complete when the assessment is done and documented — contractor scheduling comes after.

Document what goes into the investigation file:

• Date of attendance
• Name of assessor (internal officer or specialist contractor)
• Findings in writing — not just a contractor job code
• Photographs with timestamps
• Any measurements (e.g., damp readings)
• Recommendation for works

If the investigation reveals an emergency component (for example, mould severity is greater than initially assessed), immediately escalate to the emergency pathway.

Step 4: Send the Written Summary — Within 3 Working Days of Completing the Investigation

Deadline: A written summary must reach the tenant within 3 working days of the investigation being completed.

This is a separate, distinct deadline that runs from investigation completion — not from awareness. Many providers miss it because they focus on the investigation window and treat the summary as an afterthought.

The written summary must tell the tenant:

• What the investigation found
• What works the landlord intends to carry out
• The expected timeframe for those works

Template-based summaries help here. Prepare a summary template for each common hazard type in advance — damp, mould in bathroom, mould in bedroom, condensation, structural damp — so the responsible officer can populate and send within the deadline without recreating from scratch.

File a dated copy of what was sent, not just a record that a summary was sent. When a Housing Ombudsman information request arrives, you will need to produce the actual document.

Step 5: Complete Safety Works — Within 5 Working Days of Completing the Investigation

Deadline: Works necessary to make the hazard safe must be completed within 5 working days of the investigation being completed.

"Make safe" is not "fully resolve." It means completing the works that address the immediate risk — reducing the hazard to below significant-risk level. Full remediation (treating underlying damp, redecorating, structural repairs) may take longer.

If contractor availability makes the 5-working-day window tight:

• Treat the scheduling as urgent from the investigation completion date
• Do not rely on contractor callbacks — assign a named officer to track this
• If the make-safe works genuinely cannot begin within 5 working days, document the reason and the steps taken to mitigate the risk to the tenant in the interim

Step 6: Begin Supplementary Works — Within 5 Working Days, Physically Started Within 12 Weeks

Deadline: Where further works are required beyond the immediate make-safe (structural investigation, full replastering, damp-proofing), the GOV.UK guidance requires the landlord to "begin, or take steps to begin, any supplementary preventative work to prevent a significant or emergency hazard recurring within 5 working days of the investigation concluding." Where steps cannot be taken to begin work in 5 working days, "this must be done as soon as possible, and work must be physically started within 12 weeks."

So there are two limbs to this obligation: the operative duty is to begin (or take steps to begin) within 5 working days, and the 12-week longstop is the backstop date by which the work must be physically started if the 5-working-day window could not be met. The 12 weeks is a starting trigger, not a completion deadline; once started, the works should proceed without unreasonable delays.

The supplementary works section of the case file should contain:

• Works specification
• Contractor instructions (dated)
• Evidence of start of works
• Expected and actual completion dates

Maintaining the Audit Trail Throughout

A compliance workflow only protects you if you can evidence it. The Housing Ombudsman's Annual Complaints Review 2024-25 recorded 7,082 determinations — many cases result in maladministration findings not because the works were not done, but because the evidence was not producible at the time of the complaint investigation.

An audit-ready case record contains, at a minimum:

• Awareness event (date, time, channel, officer)
• Hazard classification decision
• Investigation report (date, assessor, findings, photographs)
• Written summary to tenant (dated copy of what was sent)
• Make-safe works (contractor attendance evidence, dated)
• Supplementary works (schedule, start evidence)
• Any tenant communication throughout the process

If your current tracking system cannot produce all of this in a single pull when a Housing Ombudsman information request arrives, that is the gap Awaab's Law has exposed.

Emergency Hazard Pathway (Compressed Version)

Where the initial classification is emergency, steps 3, 4 (implied), and 5 collapse into a single 24-hour window. The Regulations require that emergency hazards are investigated and made safe within 24 hours of awareness.

In practice: the housing officer who receives the emergency report should immediately escalate to whoever can attend and assess on the same day. Both the investigation and the make-safe work must complete within 24 hours. The timeline is tight enough that this cannot be handled through standard scheduling processes.

For the detailed emergency pathway — including what counts as an emergency hazard and how to run the compressed 24-hour cycle — see our dedicated guide on Awaab's Law emergency hazards.

What This Means for Your Current Process

Two questions worth asking about your current setup:

Can you see, right now, how many open cases are within 2 working days of any deadline? If not — if you would have to open each case individually to find out — you have a visibility gap. Deadline proximity should be visible at the caseload level, not just case by case.

If a Housing Ombudsman information request arrived today for a case closed 8 months ago, could you pull the full timeline and evidence within an hour? If that would take a day of searching, you have an evidence-accessibility gap.

The three free tools on this site — the deadline calculator, the phase checker, and the compliance checklist — cover individual cases. For managing 50–200 concurrent cases with deadline visibility and an audit trail per case, that is the full problem HazardClock is being built to address — join the waitlist for early access.

This is general guidance for UK social housing providers, not legal advice. The regulatory requirements set out above derive from the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025 and associated GOV.UK guidance — always verify against the current published guidance for your specific circumstances.

Sources

• Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025 (SI 2025/1042) — legislation.gov.uk
• Awaab's Law: Guidance for social landlords — GOV.UK
• Annual Complaints Review 2024-25 — Housing Ombudsman