Housing Association Compliance Checklist 2026: Awaab's Law, Complaint Handling, and Phase 2 Preparation

For housing associations and registered providers, 2026 is a year of layered compliance obligations. Awaab's Law Phase 1 has been in force since October 2025. The Housing Ombudsman's statutory Complaint Handling Code has been mandatory since April 2024. Phase 2 of Awaab's Law is expected to come into force later in 2026.

This checklist covers the practical compliance requirements across all three areas. It is written for compliance officers, housing managers, and chief executives at providers under 5,000 units who need a single reference for their current obligations.

For the statutory background on each area, see The Complete Guide to Awaab's Law, The Housing Ombudsman Complaint Handling Code Guide, and our dedicated guide to Awaab's Law Phase 2 hazard categories and preparation steps.

Section 1: Awaab's Law Phase 1 — Damp, Mould, and Emergency Hazards

Phase 1 has been in force since 27 October 2025 under the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025 (SI 2025/1042). Every registered provider must have the following in place.

1a. Awareness Recording

Every channel through which tenants can report a hazard (phone, portal, email, in-person, solicitor correspondence) feeds into a logged awareness record with a datetime stamp captured at point of receipt — not backfilled later
The awareness record includes: date and time, channel, receiving officer, property address, and description of the hazard as reported
The awareness datetime is the start of the compliance clock — all subsequent deadlines calculate from this event
The system does not allow the awareness date to be modified after the record is created

1b. Hazard Classification

The responsible officer makes a classification decision within the same working day as awareness: emergency, significant damp/mould, or not in Phase 1 scope
Classification for emergency hazards immediately triggers the 24-hour pathway
Non-emergency damp/mould assessments default to "significant" until the investigation confirms otherwise
Classification rationale is documented in the case record

1c. Investigation — 10 Working Days from Awareness

The investigation is completed (assessment conducted and documented) within 10 working days of the awareness event
Working days are calculated correctly: weekends and England and Wales bank holidays excluded
The investigation file contains: date of attendance, assessor name, written findings, photographs with timestamps, damp readings where applicable, and remediation recommendation
"Contractor visited" is not a sufficient investigation record — findings must be documented in writing

1d. Written Summary — 3 Working Days from Investigation

A written summary is sent to the tenant within 3 working days of the investigation being completed
The summary contains: what was found, what action the landlord intends to take, and the expected timeframe
A dated copy of the actual summary sent (not just a record that a summary was sent) is filed in the case record
The written summary deadline is tracked separately from the investigation deadline — it is not a sub-task of the investigation

1e. Make-Safe Works — 5 Working Days from Investigation

Works to make the hazard safe are completed within 5 working days of the investigation
"Make safe" means reducing the hazard to below significant-risk level — full remediation may follow
Evidence of make-safe works is in the case record: contractor attendance record, dated, tied to the specific case
If works cannot begin within 5 working days, the reason and any interim mitigation steps are documented

1f. Supplementary Works — Begin Within 5 Working Days, Physically Started Within 12 Weeks

Where further works are required beyond the immediate make-safe, steps to begin them are taken within 5 working days of the investigation concluding (the operative duty per GOV.UK guidance)
If steps to begin cannot be taken within 5 working days, the work is physically started within the 12-week longstop, with the reason for the delay documented
Evidence of start of supplementary works is in the case record: works specification, contractor instructions (dated), site attendance evidence
Expected and actual completion dates are tracked

1g. Emergency Hazard Pathway — 24 Hours

All staff who receive reports know that emergency hazards require same-day escalation
Investigation and make-safe are both completed within 24 calendar hours of awareness for emergency hazards
Emergency cases are flagged immediately in the tracking system and assigned to someone who can attend that day — they cannot be handled through standard scheduling

1h. Audit Trail

The complete case record — awareness event, classification, investigation, written summary, make-safe works, supplementary works — can be produced for any case (open or closed) within one hour
The record does not require assembly from multiple systems: case management, email, shared drive, contractor records
The format of the case record is suitable for production in response to a Housing Ombudsman information request

Section 2: Housing Ombudsman Complaint Handling Code

The Housing Ombudsman's Complaint Handling Code has been a statutory requirement since April 2024. The Code requires a two-stage complaint process with specific response deadlines at each stage.

2a. Complaint Process Structure

A two-stage internal complaint process is in place: Stage 1 and Stage 2
The complaint policy is published and accessible to residents
All staff who receive complaints know how to log and route them — a complaint is defined broadly (any expression of dissatisfaction, whether in writing or verbally)
Complaints are not filtered before being logged — all expressions of dissatisfaction must be accepted and processed

2b. Stage 1 Response Deadlines

Complaints are acknowledged within 5 working days of receipt
A full Stage 1 response is provided within 10 working days
If a Stage 1 response cannot be provided within 10 working days, the resident is informed and given a revised timescale (maximum extension: 10 additional working days with resident agreement)

2c. Stage 2 Response Deadlines

If the resident escalates to Stage 2, the complaint is reviewed at a senior level
A Stage 2 response is provided within 20 working days
If a Stage 2 response cannot be provided within 20 working days, the resident is informed and given a revised timescale (any extension must be no more than 20 working days without good reason)

2d. Self-Assessment

An annual self-assessment against the Complaint Handling Code has been completed and submitted to the Housing Ombudsman
The self-assessment is published on the provider's website
Any gaps identified in the self-assessment have an action plan attached

2e. Relationship with Awaab's Law Cases

When an Awaab's Law case becomes a formal complaint, the complaint-handling timeline runs in parallel with (not instead of) the repair deadline obligations
The Stage 1 response addresses both the complaint-handling failure and the underlying Awaab's Law repair status
Cases where the Awaab's Law deadline was missed are flagged for root-cause review, not just closed once remediated

Section 3: Phase 2 Preparation

Phase 2 of Awaab's Law is expected in 2026 and will extend the statutory deadline regime to a further set of HHSRS hazard categories. The GOV.UK guidance lists these as: excess cold and excess heat; falls associated with baths etc., on level surfaces, on stairs and between levels; structural collapse and explosions; fire and electrical hazards; and domestic and personal hygiene and food safety. The specific commencement date has not been confirmed at the time of writing — follow GOV.UK for updates.

3a. Caseload Assessment

A current open-case audit has been run filtering by likely Phase 2 hazard types (falls, excess cold, electrical, fire, domestic hygiene, personal hygiene, food safety, structural)
The estimated increase in deadline-tracked cases from Phase 1 to Phase 2 has been calculated
The current tracking system has been assessed against that caseload volume

3b. Staff Training

The repairs team can identify Phase 2 hazard categories on first contact
A hazard classification reference (which categories are in scope at which phase) has been prepared and distributed
Housing officers know that a stairs/falls report or an excess-cold complaint is potentially a statutory-deadline case under Phase 2

3c. Systems Review

The current tracking system can handle Phase 2 case volumes without the audit trail and deadline-calculation reliability degrading
If the current system cannot handle Phase 2 scale, a replacement evaluation has begun — implementation lead times for new tools are typically 4-8 weeks for a small provider

3d. Process Review

Awareness-recording processes cover all channels for Phase 2 hazard types (including phone intake for cold-weather heating failures, which are likely to be high-volume Phase 2 cases)
The investigation documentation template has been updated to cover Phase 2 hazard types (falls require different assessment criteria than damp/mould)
The make-safe works process has been reviewed for Phase 2 hazard types — an excess cold make-safe (e.g. temporary heating provision while a boiler is repaired) is different from a damp make-safe

Section 4: Continuous Compliance — Monthly Checks

In addition to the setup and readiness checks above, the following checks should be run monthly:

Deadline breach review: review all cases closed in the prior month — how many had a breach at any deadline stage? What was the reason? Has the root cause been addressed?
Open case proximity check: review all open cases — how many are within 3 working days of any active deadline?
Awareness timestamp audit: spot-check 5-10 recent cases — does the awareness timestamp reflect when the report was received, or when it was first processed?
Evidence completeness check: for any case closed in the prior month, verify that the full case record is producible from a single source without assembly from multiple systems

Using the Free Tools

The three free tools on this site cover individual-case compliance now:

Deadline Calculator — calculate all four statutory deadlines for any case, with working-day and bank holiday accuracy
Phase Checker — look up any HHSRS hazard to confirm which phase covers it
Compliance Checklist — work through the full case lifecycle from awareness to case closure

For managing a caseload of 50-200+ concurrent cases with automated deadline tracking, proximity alerts, and audit trail generation, HazardClock is being built for exactly this segment — housing associations under 5,000 units who need purpose-built statutory deadline compliance without the enterprise price tag.

Join the waitlist to get early access when HazardClock launches.

This checklist is general guidance for UK registered providers of social housing, not legal advice. Regulatory requirements and Housing Ombudsman guidance are subject to change — always confirm obligations against the current published guidance. The Complaint Handling Code and Awaab's Law commencement details should be verified against GOV.UK and the Housing Ombudsman's current published materials.