Triaging Awaab's Law Phase 2 Hazards

From 30 November 2026, Awaab's Law Phase 2 extends the statutory repair timescales across seven further hazard categories. That makes one decision far more consequential than it used to be: is this report a significant hazard, or an ordinary repair?

Get it right and the process works. Get it wrong in the cautious direction and you flood a small team with statutory casework. Get it wrong the other way and a clock has been running for ten working days without anyone knowing.

The good news is that you are not left to invent the test. GOV.UK published triage guidance alongside the Phase 2 announcement, and it is more practical than most regulatory guidance manages to be.

The Test Is What A Reasonable Landlord Would Do

The GOV.UK triage guidance frames the question as:

would a reasonable landlord make the hazard safe in 24 hours (for an emergency hazard) or 15 working days (for a significant hazard)?

That is a useful reframing. You are not being asked to score a hazard, or to run an HHSRS assessment, or to predict what an Ombudsman will say. You are being asked whether a competent landlord, looking at this report, would treat it as something that has to be made safe quickly.

The guidance is explicit that the test is external to your own circumstances:

focus on what a notional 'reasonable landlord' would do, rather than factoring in their own considerations (for example, budget or staff availability)

This matters more for small providers than large ones, because the temptation is sharper. If you have one surveyor and a two-week backlog, "we could not have got there faster" feels like a relevant fact. Under this test it is not. Capacity is a resourcing problem to solve separately — it is not an input to the classification decision.

What You Are Weighing

Three factors run through the guidance.

Likelihood and severity together. The assessment considers "the likelihood of harm materialising and the potential severity of that harm in the specific circumstances". A low-probability risk of serious harm and a high-probability risk of minor harm are different cases, and neither is settled by the hazard type alone.

Who actually lives there. The guidance requires landlords to "factor in the tenants' circumstances, including the age and physical and mental health". The same defect is a different hazard in different households. A failed boiler in November is a different case for a household with an infant or an elderly resident than for a fit adult sharer.

That vulnerability is not a precondition. This is the point most often misread:

A tenant does not necessarily have to have a specific vulnerability for a hazard to be deemed a significant hazard: some hazards can pose a danger to anyone

So vulnerability escalates the assessment; its absence does not exclude a hazard.

The guidance also says landlords should "generally take any reports of vulnerabilities at face value" — you are not expected to demand medical evidence before the clock starts, and building an evidence-gathering step into triage would defeat the purpose.

Temporary Measures Count

One practical point worth surfacing, because it changes how teams plan. A reasonable landlord may use interim measures to make a situation safe while scheduling the permanent repair.

That is not a loophole; the permanent works still have to happen within their own windows. But it does mean the question at triage is "can this be made safe" rather than "can this be fully fixed", and temporary heating, a stair repair pending replacement, or isolating a circuit are all legitimate ways of meeting the make-safe obligation while the substantive work is scheduled.

For how the make-safe and supplementary-works clocks relate to one another, see our step-by-step guide to complying with Awaab's Law.

Building A Triage Rule You Can Actually Run

The guidance covers the hazards one at a time, each with a definition, an assessment framework separating significant from emergency from out-of-scope, vulnerability factors, prompt questions and worked scenarios. That structure is worth copying for your own procedure.

For each of the seven Phase 2 categories, write down:

1. What it looks like in your stock. Generic definitions do not help the person triaging at 4pm. "Excess cold" means something specific in your 1960s low-rise with electric heating.
2. What pushes it to emergency. Which presentations go straight to the 24-hour route rather than the 10-working-day one.
3. What is out of scope. Equally important, and usually missing. If your team cannot say what is not a significant hazard, everything becomes one. For fire this is a statutory carve-out rather than a judgement call — see below.
4. The vulnerability prompts. A short list of what to ask about the household, phrased so a call handler can ask it naturally.
5. A worked example each way. One report that is a significant hazard and one that is not, with the reasoning. People calibrate off examples far faster than off definitions.

Then the operational questions, which are the ones that actually determine whether the rule survives contact with a busy week:

• Who classifies? Name the role, not the person.
• How fast? The investigation clock runs from awareness, so a classification sitting in a queue for three days has already spent three days of it.
• Who deputises? The single most common failure is that the person who makes these calls is on leave.
• Where is the decision recorded? A triage decision that is not written down is not evidence, and the reasoning is what an Ombudsman will ask about.

Fire Needs Its Own Branch In The Rule

"Fire and explosions" is the one Phase 2 category where the instrument itself removes cases from scope, so a triage rule that routes every fire report into Awaab's Law will be wrong.

Draft regulation 3(3)(b) inserts:

"excluded fire hazard" means a prescribed hazard where the risk of harm— (a) is associated with exposure to uncontrolled fire and associated smoke and fumes, and (b) arises from a deficiency in a FSO-regulated part of a building that contains two or more sets of domestic premises

and regulation 3(3)(c)(i) puts "that is not an excluded fire hazard" into the opening words of sub-paragraph (a) of the definition of "relevant hazard" ("is a prescribed hazard where—") — above both the significant and the emergency limb. The Phase 2 guidance states the effect:

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.

Awaab's Law applies to fire hazards within individual flats and homes which are not currently covered by the FSO, for example, issues with broken or missing smoke alarms.

So the triage question for a fire report is not "how serious is it" first — it is where is the deficiency. Inside the dwelling, Awaab's Law timescales apply. In an FSO-regulated communal part of a building containing two or more dwellings, they do not, and the report belongs on the Fire Safety Order route to the Responsible Person. If your stock is largely flatted, this branch will carry real volume.

Note the direction of travel: a communal fire hazard can start a 24-hour emergency clock under Phase 1 today. From 30 November 2026 the carve-out takes it out of Awaab's Law. That is a change in the wrong direction for a triage script written before the instrument was published.

Where Triage Goes Wrong

Four patterns worth designing against:

• Classifying at the point of processing rather than receipt. Day zero is awareness. If a Friday report is classified on Monday, two working days are gone before anyone has looked at it.
• Sending every fire report down the Awaab's Law route. The excluded-fire-hazard carve-out is a statutory exclusion, not a severity judgement.
• Using the HHSRS category as the trigger. Awaab's Law runs on significant risk of harm, not on whether something scores as a category 1 hazard. See HHSRS hazards and Awaab's Law Phase 2 for why the two tests are not the same.
• Letting capacity leak into the judgement. Covered above, and the guidance is unusually direct about it.
• Recording the outcome but not the reasoning. "Classified as significant" tells an investigator nothing. "Classified as significant: failed heating, November, household includes a resident aged 82" tells them everything.

Common Questions

What counts as a significant hazard under Awaab's Law? One where a reasonable landlord would make the property safe within 15 working days — considering the likelihood and severity of harm and the circumstances of the household. The 15 working days is a threshold test, not a deadline you count against. GOV.UK puts it plainly: "The assessment of whether a reasonable landlord would make the hazard safe within 15 working days determines whether the hazard falls within the scope of Awaab's Law." The draft amending regulations put the figure into the definition of "significant risk of harm" in regulation 3 of SI 2025/1042, not into any of the procedural regulations. The deadlines you actually have to meet are separate provisions — 10 working days to investigate (reg 6(4)), 3 to issue the written summary (reg 9(2)), 5 to complete relevant safety work (reg 11(2)) — and they do not sum to 15 by design: reg 11(2) runs from the day the investigation actually completes, not from the reg 6(4) deadline, and reg 6(2)(b) allows the investigation window to be extended where the lessee asks for a physical inspection. See the step-by-step guide for the full set.

Do I need an HHSRS assessment before starting the clock? No. The clock runs from awareness. Waiting for a formal assessment would consume the investigation window.

Does the tenant have to be vulnerable? No. Vulnerability is a factor that can escalate the assessment, but some hazards are significant for anyone.

Can I take account of my own resourcing? No. The guidance directs you to what a notional reasonable landlord would do, explicitly excluding your own budget and staff availability.

Does a temporary fix satisfy the obligation? It can satisfy the make-safe obligation while the permanent works are scheduled within their own windows.

Getting Ready

Triage is the control point for the whole Phase 2 process. Everything downstream — deadlines, evidence, Ombudsman exposure — depends on the classification being made quickly, consistently, and on the record.

If you have not yet written your rule down, that is the highest-value thing to do before 30 November. Our Phase 2 readiness plan sets out where it fits in the wider preparation, and the compliance checklist walks the case lifecycle the classification feeds into.

Once a report is classified, the deadline arithmetic should be automatic — that is what HazardClock is being built to handle, so the judgement stays with your team and the counting does not. Join the waitlist for early access.

This is general guidance for UK registered providers and social landlords, not legal advice. Classification decisions turn on the facts of each case. Phase 2 commencement is stated as at the date of this post and the amending instrument was in draft at that time — always confirm the current position against the GOV.UK Awaab's Law collection.

Last reviewed: 14 October 2026.

Sources

• Awaab's Law Phase 2: Guidance to support triaging of hazards — GOV.UK
• Awaab's Law Phase 2: Guidance for social landlords — GOV.UK
• Awaab's Law in the social rented sector — GOV.UK
• Hazards in Social Housing (Prescribed Requirements) (England) (Amendment) Regulations 2026, reg 3 — legislation.gov.uk