Awaab's Law Phase 2: What's Changing in 2026 and How to Prepare

Phase 1 of Awaab's Law has been in force since October 2025, covering damp, mould, and emergency hazards. Phase 2, expected in 2026, expands the same statutory timescale framework to 13 additional HHSRS hazard categories. For housing officers at smaller providers, this is the step change that turns deadline tracking from a manageable task into a genuine operational challenge.

Here is exactly what Phase 2 adds, how it affects your caseload, and what you can do now to prepare.

What Phase 2 Adds: Hazard by Hazard

According to GOV.UK guidance, Phase 2 extends Awaab's Law to the following HHSRS hazard categories:

Hazard Group	Specific Categories	Typical Reports
Excess cold and heat	Excess cold, excess heat	Broken boilers, failed insulation, inadequate heating systems, overheating in summer
Falls	Falls associated with baths, falling on level surfaces, falling on stairs, falling between levels	Loose stair rails, uneven flooring, missing grab rails, broken steps
Structural	Structural collapse and falling elements, explosions	Cracked walls, subsidence, unsafe balconies, gas leaks
Fire and electrical	Fire, electrical hazards	Faulty wiring, missing smoke alarms, blocked fire exits, overloaded circuits
Hygiene	Domestic hygiene (pests and refuse), personal hygiene (sanitation and drainage), food safety	Pest infestations, blocked drains, sewage issues, non-functioning kitchens

Use the Phase Checker tool to look up any specific HHSRS hazard and see which phase covers it.

The Timescale Framework

Current GOV.UK guidance indicates Phase 2 hazards will follow the same statutory timescales as Phase 1:

• Emergency hazards: investigate and make safe within 24 hours
• Significant hazards: investigate within 10 working days of the report
• Written summary to tenant: within 3 working days of investigation concluding
• Safety works: complete within 5 working days of investigation concluding
• Supplementary preventative works: begin within 5 working days, physically start within 12 weeks

The exact timescales will be confirmed when Phase 2 regulations are laid in Parliament. Monitor GOV.UK's Awaab's Law guidance page for updates.

Why Phase 2 Is the Operational Step Change

Phase 1 covers one hazard type (damp and mould) plus emergencies. Most small providers have been able to absorb this within existing processes — a dedicated spreadsheet column, a manual calendar check, perhaps the free deadline calculator for working-day calculations.

Phase 2 changes the arithmetic. Consider a provider managing 2,000 units with 200 open repair cases at any time:

• Under Phase 1, a proportion of cases involve damp/mould hazards that trigger statutory deadlines.
• Under Phase 2, that proportion could rise significantly. Falls are the most common cause of home injury in England. Heating failures spike every winter. Electrical hazards are flagged regularly in routine inspections.

That could mean substantially more cases with statutory deadlines running simultaneously — each against working-day rules that exclude weekends and bank holidays, each requiring an investigation, a written summary, safety works, and supplementary works within specific timeframes.

The question is not whether your team knows the deadlines. It is whether your tracking system can reliably manage that volume without something falling through. A March 2026 FM Business Daily report found poor data is already hindering landlords' compliance with Phase 1.

What You Can Do Now: A 4-Step Preparation Checklist

Phase 2 is roughly seven months away. That is enough time to prepare — not enough time to recover if you start late.

1. Audit your current hazard reporting categories

Pull a report of all repair cases logged in the last 12 months. Classify each one against the HHSRS categories. How many would have triggered Phase 2 deadlines? This gives you a realistic estimate of the volume increase you can expect.

If your current repairs logging system does not capture hazard type at the HHSRS category level, fixing that is the first priority. You cannot track deadlines you cannot categorise.

For a practical framework for managing compliance today, see How Small Housing Associations Can Comply Without Enterprise Software.

2. Test your tracking system against Phase 2 volume

Take your current Phase 1 tracking process (spreadsheet, software, or manual) and simulate the projected Phase 2 volume. Can it handle the additional cases? Specifically:

• Can you reliably calculate working-day deadlines for 100+ concurrent cases?
• Will your alert system (if any) flag approaching deadlines across all hazard types?
• Can you produce an audit trail for any case within 30 minutes?

If the answer to any of these is "probably not," you have seven months to fix it.

3. Brief your repairs team on the new categories

Housing officers and repairs coordinators need to know which report types will trigger statutory deadlines once Phase 2 comes into force. A tenant reporting a loose stair rail triggers falls-related timescales. A report about a non-functioning boiler triggers excess cold timescales. The classification must happen at the point of report — not days later when someone reviews the case.

Create a reference card mapping common report types to HHSRS hazard categories and Phase 2 timescales. The Phase Checker tool can serve as this reference.

4. Plan your evidence capture process

Phase 2 hazards will require the same evidence trail as Phase 1: dated reports, inspection findings, contractor instructions, completion confirmations, and tenant communications. If your evidence capture is currently inconsistent for damp/mould cases, it will not improve when the volume increases.

Standardise the evidence checklist now. The compliance checklist covers the full case lifecycle from report to closure — use it as a template for your internal process.

The Three Phases at a Glance

Phase	In Force	Hazard Categories	Count
Phase 1	October 2025	Damp and mould, emergency hazards	1 + emergencies
Phase 2	Expected 2026	Falls, fire, electrical, excess cold/heat, structural, explosions, hygiene	13
Phase 3	Expected 2027	All remaining HHSRS (except crowding/space)	14

After Phase 3, every hazard report across the full HHSRS spectrum triggers statutory deadlines. The total number of hazard categories covered will be 28 of 29 (overcrowding is excluded and addressed under separate legislation).

For a comprehensive overview of the current Phase 1 requirements, see The Complete Guide to Awaab's Law.

This is general guidance, not legal advice. Phase 2 dates and timescales are based on current GOV.UK guidance and may change when regulations are laid in Parliament. Always confirm against the latest GOV.UK guidance.

Sources

• Awaab's Law: Guidance for social landlords — GOV.UK
• Social Housing (Regulation) Act 2023 — legislation.gov.uk
• Poor Data Hindering Landlords' Compliance with Awaab's Law — FM Business Daily
• Annual Complaints Review 2024-25 — Housing Ombudsman