Awaab's Law Action Plan for Landlords

Phase 2 of Awaab's Law comes into force on 30 November 2026. 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 a further set. The GOV.UK collection lists them verbatim as "excess cold, excess heat, falls on the level (including falls on the level, falls on stairs, etc, and falls between levels), structural collapse, fire and explosions, electrical hazards, domestic hygiene (including personal hygiene and food safety)". Against Schedule 1 as amended by SI 2026/571, and as named in reg 3(3)(c)(ii) of the draft Amendment Regulations, those are:

• Excess cold (para 2) and excess heat (para 3)
• Falls on the level (para 18A), falling on stairs etc (para 21), falling between levels (para 22)
• Electrical hazards (para 23)
• Fire and explosions (para 23A) — with FSO-regulated communal fire hazards carved out of scope
• Domestic hygiene, including personal hygiene and food safety (para 14A)
• Structural collapse and falling elements (para 29)

Paragraphs 14A, 18A and 23A are consolidated descriptions inserted on 23 June 2026; the retired names ("falls associated with baths etc", "food safety", "personal hygiene, sanitation and drainage", "fire", "explosions") now sit inside them, and explosions belong with fire under para 23A rather than with structural collapse.

The GOV.UK Phase 2 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: it sits in reg 9 of SI 2025/1042, which the draft Amendment Regulations do not touch, and runs for "the period of 3 working days beginning on the day after the day on which the relevant investigation is completed". 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

To audit where you currently stand across all three areas before choosing, work through the housing association compliance checklist for 2026.

Options 1 and 2 cost money directly. Option 3 costs less but requires upfront setup time — which is why starting now matters. For a timed sequence, see the Awaab's Law Phase 2 readiness plan. If you manage social housing in Scotland or Northern Ireland, see our regional guide on Awaab's Law equivalents — Scotland has its own statutory damp-and-mould timescales from 6 October 2026, made by the Investigation and Commencement of Repair (Scotland) Regulations 2026 (SSI 2026/173) — a made Scottish Statutory Instrument, signed 24 March 2026, whose reg 1 states that the Regulations "come into force on 6 October 2026". The enabling powers are in the Housing (Scotland) Acts 2001 and 2006, not the Housing (Scotland) Act 2025. 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, Phase 1 guidance; predates the Phase 2 announcement)
• Social Housing (Regulation) Act 2023 (c. 36) — legislation.gov.uk
• Awaab's Law in the social rented sector — GOV.UK collection (Phase 2 date and hazard list)
• Hazards in Social Housing (Prescribed Requirements) (England) (Amendment) Regulations 2026 (draft), reg 3 — legislation.gov.uk
• Housing Health and Safety Rating System (England) (Amendment) Regulations 2026 (SI 2026/571) — legislation.gov.uk
• Investigation and Commencement of Repair (Scotland) Regulations 2026 (SSI 2026/173) — legislation.gov.uk