Awaab's Law Record-Keeping: What Evidence You Must Produce and When

Of all the practical compliance challenges Awaab's Law creates, record-keeping is the most persistent. Housing associations that investigate and remediate hazards on time still face Housing Ombudsman findings of maladministration when they cannot produce evidence that they did so. The repair work happened; the evidence did not survive.

This post covers what Awaab's Law requires you to record, at what stage, and in what form. It is intended for housing officers and compliance managers who are building or reviewing case-management processes.

For the full compliance workflow covering the six deadline stages, see our dedicated step-by-step guide to Awaab's Law compliance. For the enforcement context — how the Housing Ombudsman uses this evidence — see our guide to Awaab's Law and Housing Ombudsman enforcement.

Why Record-Keeping Is Not Optional

The Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025 (SI 2025/1042) do not set out detailed record-keeping obligations in the same way they set out deadline obligations. But the regulatory framework makes evidence-keeping unavoidable in practice.

The Housing Ombudsman is the primary enforcement mechanism. When a complaint reaches the Ombudsman, the investigation is evidence-led: the Ombudsman requests documentary proof of each stage. If you cannot produce it, the stage is treated as not completed.

The Housing Ombudsman Annual Complaints Review 2024-25 is explicit that maladministration findings frequently arise not from repair failures but from record-keeping failures: a landlord who cannot demonstrate when they were aware, when they investigated, and when they made the property safe is treated as non-compliant even if the work was done correctly.

Stage 1: Awareness Record

What you must record at the point of awareness:

• Date and time of receipt (not when it was processed — when it arrived)
• Channel: phone, email, online portal, in-person report, solicitor letter, housing officer observation during a visit
• Who received the report: named officer or role (if an out-of-hours answering service took the initial call, the call record should be preserved)
• Description of the hazard as the tenant described it — not your initial classification, the tenant's description
• Property address, flat/unit number, and tenant name
• The report itself, wherever possible: email screenshot, portal submission reference, letter scan

Why this form matters: A Housing Ombudsman investigation will focus on the awareness record to determine day zero. If the only record you have is a job raised in your repairs system on a Monday when the report came in on the Friday before, the Ombudsman will treat the Monday as day one — giving you a later start. If you cannot show awareness at all, you have no baseline for any of the subsequent deadlines.

Common failures:

• Logging the awareness event when a housing officer picks up the report, not when it arrived
• Having no audit-proof channel record for phone reports (a contemporaneous note from the receiving officer is the minimum; a call-log export from your telephony system is better)
• Using editable fields for awareness dates in case management systems, allowing backfill

Stage 2: Investigation Record

What you must record at investigation:

• Date of attendance on site — not when the contractor was instructed, when they attended
• Name and role of the person who conducted the assessment (internal housing officer, specialist damp surveyor, or named contractor)
• Written findings document: what was observed, what assessment was made, what the likely cause is, what remediation is required
• Photographs with embedded timestamps (or a contemporaneous photograph log with date and time)
• Any measurement records: damp readings, thermal imaging data if taken, surface temperature records
• The recommendation arising from the investigation: what works need to be done and in what order

Why the investigation record must be written: A contractor visit reference number or a job code is not an investigation record. It shows someone attended; it does not show what they found or what assessment was made. The Ombudsman needs to see the content of the investigation, not just evidence that an attendance occurred.

Common failures:

• Holding investigation findings only in the contractor's system (not retrievable on demand for Ombudsman requests without engaging the contractor again)
• Using only photographs without a written assessment to accompany them
• Not distinguishing between the initial attendance and the investigation conclusion date — for complex cases, these can be different days

Stage 3: Written Summary to Tenant

What you must produce and retain:

• The document or message sent to the tenant: the actual letter, email, or portal message — not a log entry that says "summary sent"
• The date it was sent
• Confirmation that it contains the three required elements: (a) what the investigation found, (b) what action the landlord will take, and (c) the expected timeframe

Why a copy of what was sent matters: "We sent a letter on 15 October" without a retained copy of the letter is difficult to defend if the tenant disputes it or if the Ombudsman asks to see the content. The content is what matters — the three required elements must be in it.

Practical approach: A template-based system where the officer fills in the investigation findings, proposed works, and expected timescale, then generates a dated PDF that is saved to the case record, is the most defensible approach. It standardises the format and ensures a retrievable copy is created at send time.

Stage 4: Make-Safe Works Evidence

What you must record for make-safe works:

• Date works were carried out — this is the date the hazard was brought below significant-risk level, not the date the job was raised or the date the full remediation was completed
• What works were done: description sufficient to show the make-safe step is distinct from, and complete before, the supplementary works stage
• Evidence of attendance: contractor job sheet, sign-off note, works completion record

The make-safe / supplementary works distinction is audit-critical: The Regulations treat make-safe and supplementary works as two distinct obligations. Make-safe works must be completed within 5 working days. For supplementary works, the GOV.UK guidance requires the landlord to "begin, or take steps to begin" them "within 5 working days of the investigation concluding," with a 12-week longstop by which the work "must be physically started" if the 5-working-day window could not be met. If you complete all remediation in a single contractor visit, document it as two stages: make-safe (the immediate risk-reduction element) and supplementary works (the full remediation). If the file shows only one works event with no make-safe/supplementary distinction, the Ombudsman cannot verify the 5-working-day make-safe deadline was met separately.

Stage 5: Supplementary Works Records

What you must retain:

• Date supplementary works were scheduled with evidence (contractor instruction, dated)
• Date physical works started on site
• Works specification: what was done to address the underlying cause of the hazard
• Actual completion date
• Any tenant communications about the works timing

The operative duty is to begin, or take steps to begin, supplementary works within 5 working days of investigation completion; the 12-week longstop is the date by which the work must be physically started if steps could not be taken within the 5-working-day window. Retain evidence of when steps to begin were taken, when physical works started, and — if the 5-working-day window was not met — the reason for the delay and what mitigation was offered to the tenant in the interim.

How Long to Keep Records

The Regulations do not set a specific retention period for Awaab's Law case records. The relevant guidance points are:

• The Housing Ombudsman can investigate complaints received up to 12 months after the tenant's final response from their landlord's complaint process. Cases can therefore reach the Ombudsman 18-24 months after the original hazard report in some circumstances.
• Disrepair litigation has a 6-year limitation period from the date of breach (Limitation Act 1980 Section 2 in tort).

A practical minimum is 7 years from case closure. This covers the disrepair limitation period with a margin and is consistent with general document retention practice for regulatory compliance.

What "Retrievable On Demand" Means in Practice

The test the Housing Ombudsman applies is whether a provider can respond to an information request within the Ombudsman's standard information request timeframe (typically 21 days from the request). For a single case, this should mean producing the full case record — all five stages above, in a single consolidated document — within hours, not days.

If your current process requires: asking the repairs contractor to send their records, searching email threads for the tenant letter, retrieving photographs from a shared drive, and manually assembling a timeline — you will struggle to meet a 21-day information request deadline for a complex caseload, and the assembly process itself creates risk of missed or inconsistent records.

The compliance checklist walks through each stage and prompts for the evidence requirement. For a caseload of 50-200 concurrent cases where each case needs a retrievable record across all five stages, that is the core capability HazardClock is being built to provide.

Join the waitlist for early access when HazardClock launches.

This is general guidance for UK social housing providers, not legal advice. Retention periods and evidence requirements should be confirmed with your legal advisers and in line with your organisation's document retention policy.

Sources

• Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025 (SI 2025/1042) — legislation.gov.uk
• Awaab's Law: Guidance for social landlords — GOV.UK
• Annual Complaints Review 2024-25 — Housing Ombudsman
• Limitation Act 1980, Section 2 — legislation.gov.uk