HHSRS Hazards and Awaab's Law Phase 2

If you manage social housing in England, HHSRS is the framework that decides whether something in a property counts as a hazard — and since Awaab's Law arrived, it is also the framework that decides whether a repair report starts a statutory clock.

Two things changed in 2026. The hazard list itself was consolidated in June, and from 30 November a larger slice of it carries statutory repair deadlines. This post covers what HHSRS hazards are, what changed, and which ones matter most to a social landlord right now.

What HHSRS Is

The Housing Health and Safety Rating System is the risk-assessment framework introduced under the Housing Act 2004. Rather than listing minimum standards a property must meet, it assesses the risk of harm a particular deficiency poses to an actual or potential occupier.

Section 2(1) of the Act defines a hazard as:

any risk of harm to the health or safety of an actual or potential occupier of a dwelling or HMO which arises from a deficiency in the dwelling or HMO or in any building or land in the vicinity

That framing matters. The same physical defect can be a serious hazard in one property and a minor one in another, depending on who is likely to be affected and how badly. A steep staircase without a handrail scores differently in a family home than in a single-occupancy flat.

Category 1 and Category 2 Hazards

Assessed hazards fall into one of two categories. Section 2 of the Act defines a category 1 hazard as:

a hazard of a prescribed description which falls within a prescribed band as a result of achieving, under a prescribed method for calculating the seriousness of hazards of that description, a numerical score of or above a prescribed amount

A category 2 hazard is the same thing scoring below that threshold. In plain terms: the assessment produces a numerical score, and the score decides the category.

The practical difference is enforcement, and it sits in two separate sections. Section 5(1): "If a local housing authority consider that a category 1 hazard exists on any residential premises, they must take the appropriate enforcement action in relation to the hazard." Section 7(1), by contrast, says the listed provisions "confer power on a local housing authority to take particular kinds of enforcement action" for a category 2 hazard. So: a duty on category 1, a power on category 2. For a social landlord, that distinction sits alongside — not instead of — the Awaab's Law duties, which run on their own trigger and their own clocks.

What Changed in June 2026

HHSRS carried 29 separate hazard descriptions from 2006 until this year. That list was consolidated.

The Housing Health and Safety Rating System (England) (Amendment) Regulations 2026 (SI 2026/571) amend Schedules 1 and 2 of the 2005 Regulations. Regulation 8 works mainly by omission and insertion, with one substitution: reg 8(k) replaces "the dwelling or HMO" with "a building" in paragraph 29, broadening structural collapse and falling elements — a Phase 2 hazard — beyond collapse of the dwelling itself. Regulation 1 states:

These Regulations come into force on 23rd June 2026.

Regulation 8 works mainly by omission and insertion. It omits thirteen paragraphs — "omit paragraphs 5, 6, 9 and 10", "omit paragraphs 15, 16 and 17", "omit paragraphs 19 and 20", "omit paragraph 24", "omit paragraphs 26 to 28" — and inserts five new consolidated descriptions in their place:

New paragraph	Heading (verbatim)	Replaces
4A	Indoor Air Pollutants	5 Biocides, 6 Carbon monoxide and fuel combustion products, 9 Uncombusted fuel gas, 10 Volatile organic compounds
14A	Domestic Hygiene	15 Domestic hygiene, pests and refuse, 16 Food safety, 17 Personal hygiene, sanitation and drainage
18A	Falls on the level	19 Falls associated with baths etc, 20 Falling on level surfaces etc
23A	Fire and explosions	24 Fire, 27 Explosions
25A	Collisions, Entrapment and Ergonomics	26 Collision and entrapment, 28 Position and operability of amenities etc

On the count of 21: neither the instrument nor its Explanatory Note states a number — the Note says only that it "amalgamates some of those descriptions". 21 is arithmetic on the operative text above: 29 as made, minus the 13 omitted, plus the 5 inserted. We give the derivation rather than the bare figure because the counting convention is not the source's; new paragraph 14A alone carries six sub-paragraphs that were previously spread across three numbered descriptions.

One merger people get wrong: paragraph 25, "Flames, hot surfaces etc", is not omitted and not consolidated. It survives unamended. What merged under the fire heading was paragraph 24 (Fire) with paragraph 27 (Explosions). The underlying risks did not go away; the list that describes them got shorter.

⚠️ If you hold a document, a tool or a policy that lists 29 HHSRS hazards, it predates 23 June 2026. That includes a good deal of guidance still circulating online, and a fair number of internal procedure documents. Check the source date before relying on any enumeration.

The table above gives the omissions and insertions verbatim from regulation 8, which is what you need for a mapping exercise. We are not reproducing the full renumbered list of surviving descriptions here: secondary summaries of the consolidation disagree with one another on headings, and if you are re-labelling your own categories you should work from the amended Schedule 1 directly on legislation.gov.uk rather than from any summary — including this one.

A Note On The "Four Hazard Groups"

You will see HHSRS descriptions presented in four groups — physiological, psychological, protection against infection, protection against accidents. That grouping is worth understanding, but it is worth knowing where it comes from: it is a feature of the HHSRS Operating Guidance, not of the Regulations. Schedule 1 as made is a flat list of 29 numbered descriptions carrying no four-group headings. The amending instrument does not introduce that grouping either, though it does give each inserted paragraph its own heading — "Indoor Air Pollutants", "Domestic Hygiene", "Falls on the level", "Fire and explosions", "Collisions, Entrapment and Ergonomics".

We have removed the grouped enumeration that previously appeared here. It listed "domestic and personal hygiene, food safety, sanitation and drainage" as separate members — the exact paragraphs 15, 16 and 17 that regulation 8 omitted and merged into 14A — which is precisely the pre-June-2026 enumeration this post warns against.

If you want to see how a given hazard maps to the Awaab's Law phases, the phase checker covers the assignments.

Which HHSRS Hazards Awaab's Law Covers

This is where HHSRS stops being a background framework and starts driving statutory deadlines.

Phase 1, in force now, covers damp and mould growth, plus emergency hazards. "Emergency hazard" is wide but not unlimited — regulation 3(2) of SI 2025/1042 requires that for an emergency hazard "the risk of harm is not associated with a lack of adequate space for living and sleeping (or either of those things)", so it reaches every prescribed hazard except crowding and space.

Phase 2, from 30 November 2026, extends the same timescales to a wider set. The GOV.UK collection lists them 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

That list maps onto the amended Schedule 1 through the draft Amendment Regulations, reg 3(3)(c)(ii), which names the prescribed paragraphs directly — "paragraph 2, 3, 14A, 18A, 21, 22, 23, 23A or 29 of Schedule 1" (excess cold, excess heat, domestic hygiene, falls on the level, falls on stairs, falls between levels, electrical hazards, fire and explosions, structural collapse), alongside damp and mould.

"Fire and explosions" carries a statutory carve-out. Regulation 3(3)(b) inserts a definition of "excluded fire hazard" — 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 3(3)(c)(i) inserts "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. GOV.UK's Phase 2 guidance states the effect: "Awaab's Law applies to fire hazards within individual flats and homes which are not currently covered by the FSO." Communal fire hazards in blocks of flats go the other way — they can start a 24-hour emergency clock today and are carved out from 30 November 2026.

Phase 3 will extend the requirements to, in GOV.UK's words, "the remaining Housing Health and Safety Rating System (HHSRS) hazards, excluding overcrowding". No commencement date has been set for Phase 3. The Phase 1 landlord guidance said it would follow in 2027; the Phase 2 guidance gives no year.

So the direction of travel is that HHSRS and Awaab's Law converge: eventually almost the whole framework carries statutory repair deadlines rather than only enforcement exposure.

For the confirmed Phase 2 date and its draft-regulation status, see Awaab's Law Phase 2 confirmed for 30 November 2026.

The Threshold That Actually Matters

There is a trap here worth naming, because it catches people who know HHSRS well.

Awaab's Law does not key off the category 1 / category 2 distinction. Its trigger is whether a hazard presents a significant risk of harm, which is its own test. A hazard can be relevant to Awaab's Law without a formal HHSRS scoring exercise having been carried out, and the ten-working-day investigation clock starts from the point of awareness — not from the point at which someone completes an assessment.

In practice that means you cannot wait for a formal HHSRS score before starting the clock. The classification decision has to be made quickly, on the information available, and recorded. A written triage rule — decided in advance, applied consistently, and recorded — is what makes that defensible. For a worked version of that rule, see triaging Awaab's Law Phase 2 hazards.

Common Questions

How many HHSRS hazards are there? SI 2026/571 does not state a number. Counting the operative amendments — 29 descriptions as made, 13 omitted by regulation 8, 5 inserted — gives 21 since 23 June 2026. Sources published before that date will say 29.

What is a category 1 hazard? One whose assessed score reaches or exceeds the prescribed threshold in section 2 of the Housing Act 2004. Local authorities "must take the appropriate enforcement action" on category 1 hazards (section 5(1)); for category 2 hazards section 7(1) confers a power rather than a duty.

Does a category 2 hazard start an Awaab's Law clock? Possibly. Awaab's Law runs on whether the hazard presents a significant risk of harm, not on the HHSRS category. Do not use the category as your Awaab's Law trigger.

Which HHSRS hazards does Awaab's Law cover? Damp and mould plus emergencies now; excess cold, excess heat, falls, structural collapse, fire and explosions, electrical hazards and domestic hygiene from 30 November 2026 — with FSO-regulated communal fire hazards carved out; the remainder except overcrowding at Phase 3, with no commencement date set (the Phase 1 guidance said 2027).

What To Do With This

If you are preparing for Phase 2, the HHSRS angle gives you two concrete jobs:

1. Check your hazard reference material is post-June 2026. Any list of 29 is out of date, and if it is embedded in a triage form or a training pack it will quietly produce wrong answers.
2. Map your own repair categories onto the Phase 2 hazards, not onto HHSRS as a whole. Seven groupings drive your statutory deadlines from 30 November; the rest of the framework does not, yet.

Work through the case lifecycle with the compliance checklist, and see the Awaab's Law Phase 2 readiness plan for the week-by-week version.

Keeping hazard classifications, phase assignments and statutory clocks aligned across a live caseload is the problem HazardClock is being built to solve — join the waitlist for early access.

This is general guidance for UK registered providers and social landlords, not legal advice. HHSRS assessment is a technical exercise — where a formal rating is required, use a competent assessor. Always confirm the current hazard descriptions against the amended Regulations.

Last reviewed: 30 September 2026.

Sources

• Housing Health and Safety Rating System (England) (Amendment) Regulations 2026 (SI 2026/571) — legislation.gov.uk
• Housing Act 2004, section 2 (category 1 and 2 hazards) — legislation.gov.uk
• Housing Act 2004, section 5 (category 1 hazards: general duty to take enforcement action) — legislation.gov.uk
• Housing Act 2004, section 7 (category 2 hazards: powers to take enforcement action) — legislation.gov.uk
• HHSRS (England) Regulations 2005, Schedule 1 as made — legislation.gov.uk
• Hazards in Social Housing (Prescribed Requirements) (England) (Amendment) Regulations 2026, reg 3 — legislation.gov.uk
• Awaab's Law in the social rented sector — GOV.UK