Awaab's Law Phase 2: Hazard Categories

Awaab's Law Phase 1 has been in force since 27 October 2025, covering emergency hazards and significant damp and mould. Phase 2 comes into force on 30 November 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 covers, what the timescales are, and what housing associations should be doing now to prepare.

Awaab's Law Phase 2 comes into force on 30 November 2026. The GOV.UK Phase 2 guidance, published in July 2026, states: "From 30 November 2026, Awaab's Law will be extended to the following hazards where they present a significant risk of harm". The amending instrument — the Hazards in Social Housing (Prescribed Requirements) (England) (Amendment) Regulations 2026 — was still in draft and had not been made as a UK Statutory Instrument as at this update, so confirm the current status on GOV.UK before citing it formally.

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 descriptions beyond damp, mould, and emergency hazards. The GOV.UK collection lists the Phase 2 scope, "where they present a significant risk of harm", 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)

The draft Amendment Regulations reg 3(3)(c)(ii) put the same scope into operative terms by naming the Schedule 1 paragraphs directly — "paragraph 2, 3, 14A, 18A, 21, 22, 23, 23A or 29". Mapped across:

GOV.UK Phase 2 wording	Schedule 1 paragraph (as amended June 2026)
excess cold	2 — Excess cold
excess heat	3 — Excess heat
falls on the level (including falls on the level, falls on stairs, etc, and falls between levels)	18A — Falls on the level; 21 — Falling on stairs etc; 22 — Falling between levels
structural collapse	29 — Structural collapse and falling elements
fire and explosions	23A — Fire and explosions (excluding "excluded fire hazards" — see below)
electrical hazards	23 — Electrical hazards
domestic hygiene (including personal hygiene and food safety)	14A — Domestic Hygiene

Paragraphs 14A and 18A are the consolidated descriptions inserted by SI 2026/571 on 23 June 2026. If your internal categories still use the pre-consolidation names — "food safety", "personal hygiene, sanitation and drainage", "falls associated with baths etc" — they now sit inside 14A and 18A respectively.

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 Apply

GOV.UK guidance sets out the Phase 2 timescales, which 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. "Working day" is defined in regulation 2 of SI 2025/1042 as "any day other than— (a) a Saturday or Sunday, (b) Christmas Day or Good Friday, or (c) a day which is a bank holiday under the Banking and Financial Dealings Act 1971 in England and Wales".

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 significant-risk threshold.

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.

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 extends Awaab's Law to the remaining HHSRS hazard descriptions not covered by Phases 1 or 2, on a date GOV.UK has not yet announced. That includes asbestos and MMF, indoor air pollutants (the consolidated description covering carbon monoxide and other combustion products, biocides, uncombusted fuel gas and VOCs), lead and radiation, entry by intruders, lighting, noise, water supply, flames and hot surfaces, and collisions/entrapment/ergonomics.

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 — no Phase 3 date has been announced, but a system chosen for Phase 2 alone will need replacing when it arrives.

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. Phase 2 commences on 30 November 2026: reg 1 of the draft Amendment Regulations states "These Regulations come into force on 30th November 2026", and the GOV.UK collection says "Phase 2 will come into force on 30 November 2026". That instrument was still in draft and had not been made as a UK Statutory Instrument as at this update, so confirm its current status on GOV.UK before planning implementation against it. The regulatory requirements set out above derive from GOV.UK guidance, the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025 and the draft 2026 Amendment Regulations.

Sources

• Awaab's Law: Guidance for social landlords — Timeframes for repairs (GOV.UK, Phase 1 guidance; predates the Phase 2 announcement)
• 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 1 (commencement) — legislation.gov.uk
• 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
• Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025 (SI 2025/1042) — legislation.gov.uk
• Housing Act 2004 — legislation.gov.uk