Awaab's Law Phase 2: What's Changing

Phase 1 of Awaab's Law has been in force since October 2025, covering damp, mould, and emergency hazards. Phase 2, in force from 30 November 2026, expands the same statutory timescale framework to a further set of 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

The GOV.UK collection lists the Phase 2 hazards 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)

Those groupings map onto Schedule 1 as amended through reg 3(3)(c)(ii) of the draft Amendment Regulations, which names the prescribed paragraphs directly — "paragraph 2, 3, 14A, 18A, 21, 22, 23, 23A or 29 of Schedule 1" — alongside damp and mould growths:

GOV.UK grouping	Amended Schedule 1 paragraph	Typical Reports
Excess cold	Para 2	Broken boilers, failed insulation, inadequate or unusable heating systems
Excess heat	Para 3	Overheating in summer, no means of ventilation or shading
Falls on the level	Para 18A	Uneven flooring, trip hazards, falls associated with baths, showers or toilets
Falls on stairs etc	Para 21	Loose or missing stair rails, broken steps, poorly lit stairways
Falls between levels	Para 22	Unsafe balconies, missing or defective window restrictors
Electrical hazards	Para 23	Faulty wiring, exposed or damaged sockets, overloaded circuits
Fire and explosions	Para 23A	Missing or broken smoke alarms inside a dwelling, gas explosion risk — subject to the carve-out below
Domestic hygiene (including personal hygiene and food safety)	Para 14A	Pest infestations, blocked drains, sewage issues, inadequate facilities for storing, preparing or cooking food
Structural collapse and falling elements	Para 29	Cracked walls, subsidence, loose render or falling masonry

Paragraphs 14A, 18A and 23A are the consolidated descriptions inserted by SI 2026/571 on 23 June 2026. The retired names — "falls associated with baths etc", "falling on level surfaces etc", "food safety", "personal hygiene, sanitation and drainage", "fire", "explosions" — now sit inside them. Explosions merged with fire under para 23A, so an explosion risk is triaged through the fire route and picks up the carve-out below; it is not part of structural collapse.

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

Phase 2 only applies in England. If you manage social housing elsewhere in the UK, see our guide on whether Awaab's Law applies in Scotland and Northern Ireland.

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.

Fire has a statutory carve-out. The draft Amendment Regulations reg 3(3) define an "excluded fire hazard" as fire risk that "arises from a deficiency in a FSO-regulated part of a building that contains two or more sets of domestic premises", and place it outside the definition of "relevant hazard". GOV.UK confirms: "Awaab's Law requirements do not apply to fire hazards in communal areas which are already covered by the Regulatory Reform (Fire Safety) Order 2005, such as damaged fire doors, debris obstructing the means of escape or deficiencies in compartmentation", while "Awaab's Law applies to fire hazards within individual flats and homes which are not currently covered by the FSO". So a missing smoke alarm inside a flat is in scope; a blocked communal escape route in the same block is not — it goes to the Responsible Person under the Fire Safety Order.

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. For help deciding which reports cross the threshold, see what counts as a significant hazard under Awaab's Law. 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 Descriptions	Schedule 1 paragraphs
Phase 1	27 October 2025	Damp and mould growth, plus emergency hazards (any prescribed hazard except crowding and space)	1 + emergencies
Phase 2	30 November 2026 (confirmed)	Excess cold, excess heat, falls on the level, falls on stairs, falls between levels, structural collapse, fire and explosions (excluding FSO-regulated communal fire hazards), electrical hazards, domestic hygiene	2, 3, 14A, 18A, 21, 22, 23, 23A, 29
Phase 3	No date announced	Remaining HHSRS descriptions except overcrowding	4, 4A, 7, 8, 12, 13, 14, 18, 25, 25A

After Phase 3, every hazard report across the full HHSRS spectrum triggers statutory deadlines, except overcrowding, which is excluded and addressed under separate legislation. The paragraph numbers above are the post-consolidation Schedule 1 references, following SI 2026/571 (in force 23 June 2026). Of the 21 descriptions in the amended Schedule, 1 is in Phase 1, 9 come in at Phase 2, 10 are left for Phase 3, and paragraph 11 (crowding and space) is excluded from Awaab's Law altogether.

For a comprehensive overview of the current Phase 1 requirements, see The Complete Guide to Awaab's Law. For the hazard-by-hazard breakdown and the preparation steps each one implies, see our guide to Awaab's Law Phase 2 hazard categories.

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 — Timeframes for repairs (GOV.UK, Phase 1 guidance; predates the Phase 2 announcement)
• Social Housing (Regulation) Act 2023 — 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
• Poor Data Hindering Landlords' Compliance with Awaab's Law — FM Business Daily
• Annual Complaints Review 2024-25 — Housing Ombudsman