Awaab's Law Phase 2: Hazard Categories, Expected Timescales, and What to Prepare

Awaab's Law Phase 1 has been in force since 27 October 2025, covering emergency hazards and significant damp and mould. Phase 2 is expected to follow in 2026 — extending the same statutory deadline regime to a further set of HHSRS hazard categories that currently sit outside the compliance requirement.

This post sets out which hazard categories Phase 2 is expected to cover, what the timescales are likely to be, and what housing associations should be doing now to prepare.

Important note on dates: At the time of writing, the GOV.UK guidance for social landlords confirms Phase 2 is expected in 2026 but does not state a specific month or date. Secondary legislation confirming the Phase 2 commencement date has not been published as of June 2026. All references to "expected 2026" below should be understood in that context — follow GOV.UK for updates.

For the full statutory framework covering Phase 1, see The Complete Guide to Awaab's Law. For a breakdown of which hazard types already have phase coverage, use the Phase Checker tool.

What Phase 2 Covers

Phase 2 extends Awaab's Law to a set of HHSRS hazard categories beyond damp, mould, and emergency hazards. The GOV.UK guidance published alongside the Regulations sets out the expected Phase 2 scope as the following grouped categories, "where they present a significant risk of harm":

GOV.UK Phase 2 hazard grouping	HHSRS hazards this covers
Excess cold and excess heat	Excess cold; excess heat
Falls associated with baths etc., on level surfaces, on stairs and between levels	Falls associated with baths/steps; falls on level surfaces; falls on stairs and ramps; falls between levels
Structural collapse and explosions	Structural collapse and falling elements; explosions
Fire and electrical hazards	Fire; electrical hazards
Domestic and personal hygiene and food safety	Domestic hygiene, pests and refuse; personal hygiene, sanitation and drainage; food safety

The left column reproduces the groupings as the GOV.UK guidance lists them; the right column maps each grouping to the underlying HHSRS hazard profiles it relates to, to help with caseload classification.

Emergency hazards from any HHSRS category were already in scope from Phase 1 — the 24-hour window for investigation and make-safe applies to any hazard posing an immediate risk, regardless of category.

What Timescales Are Expected

GOV.UK guidance states that Phase 2 timescales are expected to follow the same framework as Phase 1:

• Investigation: 10 working days from awareness
• Written summary to tenant: 3 working days from investigation completion
• Make-safe works: 5 working days from investigation completion
• Supplementary works: begin, or take steps to begin, within 5 working days of investigation completion; 12-week longstop for physically starting the work if the 5-working-day window cannot be met

The same working-day rules apply: deadlines run on working days excluding weekends and England and Wales bank holidays.

The deadline calculator already supports these timescales across all hazard types — you can use it now for Phase 1 cases and it will apply the same logic to Phase 2 cases.

Why Phase 2 Is the Significant Step Change

Phase 2 matters more than Phase 1 for most housing associations — not because Phase 1 was unimportant, but because Phase 2 dramatically expands the population of cases with statutory deadlines.

Falls are the most common cause of serious injury in the home. Housing associations managing properties with stairs, level-change hazards, or bathrooms with unsafe fittings will see a significant increase in deadline-tracked cases.

Electrical hazards and fire are already tracked through separate electrical safety obligations (EICR requirements, smoke alarm regulations), but Phase 2 adds the Awaab's Law deadline framework on top of existing requirements for any case that meets the HHSRS threshold.

Excess cold was one of the highest-volume pre-Phase 1 repair categories for social landlords and was deliberately excluded from Phase 1 scope. Under Phase 2, cold-related complaints (inadequate heating, uninsulated properties, boiler failures in cold weather) will trigger the investigation and make-safe deadlines.

To illustrate: a housing association managing 500 units and currently tracking 20-40 active damp and mould cases under Phase 1 could see that number rise to 80-150 active deadline-tracked cases once Phase 2 brings in falls, excess cold, and the other categories above.

What to Prepare Now

The preparation window before Phase 2 commencement should be used for four things:

1. Audit your current caseload for Phase 2 hazard types

Pull a list of all current open repair cases and filter by hazard type. How many involve falls-associated risks, excess cold, electrical concerns, or fire-related issues? That is a rough proxy for your Phase 2 caseload increase.

The phase checker maps HHSRS hazard categories to phase scope — use it to classify each category in your current caseload.

2. Check whether your current tracking system can scale

If you are currently managing Phase 1 compliance with a spreadsheet or general property management software, assess whether that approach scales to a caseload that is 2-4x larger. Specifically:

• Can someone check all open cases for deadline proximity in under 10 minutes each morning?
• If a Housing Ombudsman information request arrives for a case closed 8 months ago, can you produce the full case record within an hour?
• Can the system handle concurrent cases in multiple Phase 2 hazard categories without confusion between the different timescale frameworks?

If any of those answers is "no", Phase 2 is the point where the spreadsheet approach breaks.

3. Train your repairs team on the Phase 2 categories

Your housing officers need to be able to identify a Phase 2 hazard on first contact. That means knowing, for example, that a tenant call about a broken stair handrail is potentially a statutory-deadline case under Phase 2 (falls associated with stairs), not just a routine repair job.

Preparing a simple hazard-classification reference — which categories are now in scope, what the triggering threshold is for each — is the training investment that prevents day-zero misclassification errors once Phase 2 comes in.

4. Review your awareness-recording processes

Phase 1 surfaced a consistent compliance failure: providers were starting the compliance clock from when a job was raised in the system, not when the report was first received. Under Phase 2, with a larger caseload, this gap becomes more expensive.

Before Phase 2 commencement: verify that every channel through which tenants can report a hazard (phone, portal, email, in-person visit, solicitor letter) feeds into a logged awareness record with a datetime stamp that reflects when the report was received, not when a housing officer processed it.

What Phase 3 Adds After Phase 2

Phase 3, expected in 2027, extends Awaab's Law to the remaining HHSRS hazard categories not covered by Phases 1 or 2. That includes asbestos, carbon monoxide and fuel combustion products, lead and radiation, entry by intruders, noise, water supply, collision and entrapment, and others.

After Phase 3, every hazard category under HHSRS will carry statutory deadline obligations. If you are making decisions about compliance systems now, it is worth building for Phase 3 scope rather than just Phase 2 — the system you adopt in 2026 will need to handle the full HHSRS spectrum within 12-18 months.

Tracking Phase 2 Compliance

HazardClock is being built to handle Awaab's Law compliance across all three phases — deadline calculation, proximity alerting, and audit trail generation for any HHSRS hazard category. The free tools on this site cover individual cases now; the full caseload product is in development.

Join the waitlist to get early access and be notified when HazardClock launches.

For the immediate compliance checklist covering your current Phase 1 obligations, work through the compliance checklist.

This is general guidance for UK social housing providers, not legal advice. The Phase 2 commencement date has not been confirmed at the time of writing — always check GOV.UK for the current published commencement date before planning implementation. The regulatory requirements set out above derive from GOV.UK guidance and the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025.

Sources

• Awaab's Law: Guidance for social landlords — GOV.UK
• Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025 (SI 2025/1042) — legislation.gov.uk
• Housing Act 2004 — legislation.gov.uk