What Landlords Need to Do in 2026: An Awaab's Law Action Plan

Phase 2 of Awaab's Law is expected to take effect in 2026. You have roughly six months. If your organisation is still working out how to handle Phase 1 (damp and mould) reliably, Phase 2 — which adds falls, fire, cold, heat, structural collapse, and electrical hazards — will not go well.

This is a month-by-month action plan for housing providers under 5,000 units. It assumes you are already compliant (or close) with Phase 1 and need to extend your processes to cover Phase 2 hazard categories. For the full regulatory context, see The Complete Guide to Awaab's Law. For a breakdown of exactly what Phase 2 covers, see Phase 2: What's Changing in 2026.

The Scale of the Change

Phase 1 covers one hazard category — damp and mould — plus emergency hazards. Phase 2 adds 13 hazard categories across five groups:

• Excess cold and excess heat (2 categories)
• Falls — on stairs, between levels, on level surfaces, associated with baths (4 categories)
• Structural collapse and explosions (2 categories)
• Fire and electrical hazards (2 categories)
• Domestic hygiene, personal hygiene, and food safety (3 categories)

The GOV.UK guidance applies the same deadlines to all hazard types: 10 working days to investigate a significant hazard, 5 working days to make safe, 3 working days for the written summary. Emergency hazards remain 24 hours.

The difference is volume. A provider currently managing a manageable number of damp/mould cases under Awaab's Law deadlines could see a significant increase across all Phase 2 categories. Falls alone — including trips on stairs, level-surface hazards, and bath-related incidents — are among the most common HHSRS hazards. Use the Phase Checker to see which specific hazard types fall under Phase 2.

Month-by-Month Action Plan

April–May 2026: Audit and Gap Analysis

1. Map your current hazard reports to Phase 2 categories.

Pull your repairs log from the last 12 months. For every job, ask: would this be classified as a Phase 2 hazard? A broken stair tread is a fall hazard. A faulty boiler is both an emergency hazard (carbon monoxide risk) and a cold hazard (heating failure). A missing smoke detector is a fire hazard. Reclassify your historical data to estimate the volume increase.

2. Assess your investigation capacity.

Each Phase 2 case requires a formal investigation within 10 working days. Do you have enough trained staff to handle the projected volume? If your current housing officers are already at capacity with damp/mould cases, Phase 2 requires either more staff, faster investigations, or a combination of both.

3. Review your contractor panel.

Phase 2 hazards require different trades: electricians (fire/electrical), heating engineers (cold/heat), structural engineers (collapse), and general building contractors (falls). Check your contractor agreements:

• Do your current contractors cover these specialisms?
• What are their response times? Can they attend within 5 working days of an investigation completing?
• Are their contracts structured for Awaab's Law compliance (working-day SLAs, not calendar-day)?

June–July 2026: Systems and Processes

4. Update your tracking system.

Whatever you use to track Awaab's Law cases — spreadsheet, shared calendar, or dedicated software — it needs to handle the new hazard categories. At minimum:

• Add Phase 2 hazard types to your case logging system
• Ensure working-day deadline calculations work for all categories (they use the same rules as Phase 1)
• Test your system with mock Phase 2 cases: enter a fall hazard reported on a Monday before a bank holiday and verify all deadlines are correct

Use the deadline calculator to verify your system's calculations against the correct dates.

5. Update your triage process.

Phase 1 triage is binary: is this an emergency (24 hours) or a significant hazard (10 working days)? Phase 2 triage adds complexity because the same incident can involve multiple hazard types. A tenant reports their bath panel is loose and there is visible mould around the bath sealant — that is both a fall hazard (Phase 2) and a damp hazard (Phase 1). Your triage process needs to:

• Identify all relevant hazard types per report, not just the primary one
• Apply the most urgent deadline where hazard types overlap
• Document the triage reasoning

6. Prepare written summary templates.

The written summary requirement applies to all Phase 2 investigations. You need templates for each hazard category that include: whether a hazard was identified, what actions are required with target dates, or reasons why no action is required. Three working days to produce a summary is tight if you are drafting from scratch each time.

The compliance checklist includes the written summary step for each case lifecycle stage.

August–September 2026: Training and Testing

7. Train frontline staff on Phase 2 hazard recognition.

Housing officers and repairs coordinators need to recognise Phase 2 hazards at the point of report. A tenant calling about a "draughty window" is reporting a potential excess cold hazard. A tenant mentioning "loose carpet on the stairs" is reporting a fall hazard. If the person taking the report does not flag it as an Awaab's Law case, the clock starts but nobody is watching it.

Focus training on:

• Recognising the Phase 2 hazard categories in tenant language (tenants do not say "I have an excess cold hazard")
• Understanding that the clock starts at awareness, not at logging
• Knowing which reports need same-day triage vs. next-day review

8. Run mock cases through your full process.

Create 5-10 mock Phase 2 cases covering different hazard types. Run them through your complete workflow: report → triage → investigation → make-safe → written summary → case closure. Time each step. Identify bottlenecks. Fix them before October.

9. Stress-test your contractor response.

Contact your Phase 2 contractors and confirm their availability for October onwards. If you are adding new contractors, complete onboarding before Phase 2 goes live — do not wait until the first real case arrives to discover your electrical contractor needs two weeks' notice.

When Phase 2 Goes Live

10. Phase 2 is in force — apply the same rigour as Phase 1.

From the first day, every fall, fire, cold, heat, structural, and electrical hazard report triggers the same 10-working-day investigation deadline. There is no grace period. The clock starts immediately.

In the first month, schedule a weekly review of all open Phase 2 cases. Check:

• Are deadlines being calculated correctly?
• Are investigations completing within 10 working days?
• Are written summaries going out within 3 working days?
• Are contractors attending within the make-safe window?

Correct problems while case volumes are still building — by month three, you will not have time for remedial process work.

The Capacity Question

For most small providers, the hardest part of Phase 2 preparation is the honest answer to one question: can your current team handle a substantially larger Awaab's Law caseload?

If the answer is no, you have three options:

1. Hire — additional housing officers or compliance coordinators
2. Outsource — contractor-led investigations for specific hazard types
3. Automate — replace manual tracking with systems that handle deadline calculations, alerts, and evidence storage, freeing officer time for investigations and tenant contact

Options 1 and 2 cost money directly. Option 3 costs less but requires upfront setup time — which is why starting now matters. If you want automated deadline tracking and case management without the enterprise price tag, join the HazardClock waitlist to be notified when we launch — purpose-built for providers under 5,000 units, with Phase 2 hazard categories built in from day one.

This is general guidance, not legal advice. Always confirm your compliance approach against the latest GOV.UK guidance.

Sources

• Awaab's Law: Guidance for social landlords — Timeframes for repairs in the social rented sector — GOV.UK
• Social Housing (Regulation) Act 2023 (c. 36) — legislation.gov.uk