Awaab’s Law Phase 2: The 2025 Regulations, HHSRS Reform and What It Means for Social Housing Landlords

This is a guest article written by Awaab Comply’s Danny Bird.

As a safety and repairs consultant, specialising in Awaab’s Law, I am a regular keynote speaker on the subject.

This is my practical view on what the 2025 Regulations, the Phase 2 expansion, and the parallel reform of HHSRS really mean for social landlords and housing associations.

Awaab Ishak died in a home where damp and mould were persistently ignored. That tragedy directly drove legislative change, leading to amendments to the Social Housing (Regulation) Act 2023, the introduction of Awaab’s Law, and the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025, which came into force on 27 October 2025.

The 2025 Regulations – The Legal Foundation

The Regulations insert an implied contractual term into every social housing tenancy agreement in England (under section 10A of the Landlord and Tenant Act 1985). Tenants now have a direct contractual right to timely investigation and remediation of prescribed hazards.

Phase 1 (in force since 27 October 2025) sets clear timeframes for two things.

Emergency hazards where there is an immediate risk of serious harm, and damp and mould cases where there is a real risk to health.

The key point is this: the clock starts as soon as the landlord becomes aware. That could be from a tenant report, a referral, or something picked up through inspection. It does not wait for the case to be logged properly or passed to the right team.

Under Phase 1, the timeframes are clearly defined. For emergency hazards, landlords are expected to investigate as soon as reasonably practicable, typically within 24 hours. Where there is an immediate risk of serious harm, the priority is to make the property safe within that same period, or provide suitable alternative accommodation where that cannot be achieved.

For significant damp and mould, the approach is more structured. The landlord must investigate within 10 working days of becoming aware of the issue, provide the tenant with a written summary of the findings within 3 working days of completing that investigation, and take any necessary remedial action to make the property safe within 5 working days where it is reasonably practicable to do so.

Phase 2 (within 2026) Major Expansion

Government guidance confirms that Phase 2 will extend these same statutory timeframes to a broader range of significant hazards. These fall into key groupings: thermal risks such as excess cold and heat; falls on stairs, level surfaces and in baths or showers; fire and electrical risks; structural hazards; and domestic hygiene and food safety.

In practice, this is where the real paradigm shift begins. Damp and mould has driven most of the sector’s response so far, but Phase 2 applies the same expectations across a much wider and more complex risk profile, where approaches are often less consistent and less embedded.

Many of these hazards sit with different teams or are not managed in a coordinated way at all. Assets, repairs, fire safety and housing management often operate separately, with different systems and different approaches to risk. Phase 2 forces that into alignment by applying the same statutory timeframes across all of them.

The challenge is straightforward but significant. Landlords will need to manage multiple hazard types with the same pace, consistency and evidence, without gaps between teams or reliance on individual judgement.

HHSRS Reform

The Housing Health and Safety Rating System (HHSRS) is being streamlined from 29 to 21 hazard categories through the Housing Health and Safety Rating System (England) (Amendment) Regulations 2026, which come into force on 23 June 2026. The changes introduce a simpler High, Medium and Low banding approach to assessment, which in practice is often translated into a traffic light view of risk to communicate severity and urgency more clearly.

The reformed HHSRS should be used as a structured risk assessment tool. It supports more consistent prioritisation, but it does not replace professional judgement, thorough evidence gathering, or the need to take account of individual tenant vulnerability.

The Critical Importance of Effective Investigation

The new requirements place significant weight on the quality and speed of the initial investigation. This is where compliance is either established or exposed, and it directly underpins tenant safety.

In practice, many organisations still rely on fragmented, siloed processes that are heavily dependent on individuals rather than systems. That creates inconsistency at exactly the point where consistency matters most.

I am currently working with Awaab Comply on the Phase 2 rollout of their inspection app, and I am also a shareholder in the business, which is worth being clear about. The reason I am involved is because it is focused on a genuine gap in how investigations are carried out.

The expectation now is that investigation is structured, evidence is captured in real time, and outputs are clear and defensible. Products like Awaab Comply are starting to use AI to support that, helping turn what is captured on site into something consistent and usable, rather than leaving it to be written up later and open to interpretation.

But the bigger point is this. The time for paper-based inspections and writing reports up afterwards is gone. It is too slow, too inconsistent and too open to challenge. It will not stand up under Phase 2.

AI will be a big part of what comes next. Not as a replacement for professional judgement, but as a way of strengthening it by improving consistency and making decisions easier to evidence.

An effective investigation still comes down to getting the basics right. Clear triage, strong evidence, a joined up understanding of risk, and clear communication with the tenant. Technology supports that. It does not replace it.

Root Cause & Professional Judgement

Good investigation is about understanding root cause, risk, and the right intervention.

Too many organisations still fall into the cycle of treating symptoms rather than causes. Clean the mould, repaint the wall, close the case, and six months later it is back again. Under Awaab’s Law, that is not defensible.

If it would not be good enough for you or your family, it is not good enough for your residents.

An effective investigation needs to bring together building pathology, environmental conditions, property history, occupancy patterns, and tenant vulnerability to reach a clear and evidenced conclusion. It is this combination that turns assessment into something that can stand up to scrutiny, rather than a repeat visit waiting to happen.

An A&E Triage Analogy

Good triage is similar to an Accident and Emergency department. If everything is treated as urgent, then nothing is. The job is not just to respond; it is to decide who needs to be seen immediately and who can safely wait.

In housing, we are not always good at making that call. There is a tendency to treat everything as high priority to avoid getting it wrong, or to move cases along without making a clear decision on risk. It feels safer in the moment, but it creates more noise instead of more control. The cases that really matter start to look the same as everything else.

But it is not the cases that matter, it is the people behind them. Every missed or delayed decision has a direct impact on someone living in a home that may not be safe or healthy.

This is not about downgrading risk or doing less. It is about being honest about risk, making a clear call early, and protecting capacity for the households that need it most. That means accepting that not every case is the same and being able to explain why.

And this is where it breaks down in practice. Cases do not get managed, they get passed around. One visit becomes three, different people form different views, photos are taken, notes are added, but the core question is never answered.

There is activity, but no direction. Everyone has been involved, but no one has taken ownership or made a clear call on what is actually wrong and what needs to happen next.

Under Awaab’s Law, that is exactly what gets exposed. Not a lack of effort, but a lack of clear, defensible decision making at the point where it matters most.

Moving to Proactive Safety Management with IoT

We can no longer afford to be purely reactive. Phase 2 moves the expectation from response into early identification and prevention.

That is where technology starts to matter. IoT devices such as sensors for temperature, humidity, moisture and air quality allow landlords to identify conditions that are likely to lead to hazards before they present visibly or are reported by the tenant. For Phase 2 in particular, this creates a real opportunity to be proactive, identifying risk earlier and intervening before it escalates into a statutory breach.

Traditionally, these solutions have been used in a more compliance-led way, based around fixed installation and periodic interaction rather than continuous, action-led insight. There is now a shift happening in how this space is developing. I am particularly excited about what Auro are doing with Myco. It moves beyond simple monitoring and starts to turn environmental data into something you can actually act on, giving landlords a clearer and more defensible view of risk across their stock.

But we do not need more data. We are already drowning in it. The real value is not the sensor itself, it is what organisations do with the information. Used well, environmental monitoring supports predictive maintenance, targeted intervention and stronger assurance. Used poorly, it just creates more noise without improving decision making.

This is where integration becomes critical. When insight feeds directly into operational systems such as Plentific or Salesforce, it supports earlier triage, clearer prioritisation and a more controlled end to end response, rather than fragmented case handling.

Through large scale system implementations and service transformation programmes, I have seen first hand how technology can improve visibility, prioritisation, reporting and compliance when it is properly embedded into operational processes, rather than treated as a standalone solution. Technology should support professional judgement, not replace it.

Organisations that get this right will not just respond faster. They will be able to show control. And that is where the real advantage sits.

What This Really Means

Awaab’s Law Phase 2, the 2025 Regulations, and the reform of HHSRS represent a fundamental shift in how housing risk is understood and managed. Hazards such as excess cold, falls, fire risk and domestic hygiene have long existed within the HHSRS framework, but the difference now is that the law requires timely, evidence‑based action against those risks within defined timeframes. What was previously a matter of professional judgement and good practice is now a clear statutory duty, underpinned by expectation, scrutiny and enforcement.

In practice, this raises the bar on how organisations operate. Those that will succeed are the ones that can demonstrate control: joined-up systems across teams, consistent application of HHSRS as a structured risk framework, and decision making that is evidenced, recorded and capable of standing up to challenge. This includes using tools such as IoT to support earlier identification of risk, but always with professional judgement and tenant vulnerability at the centre of the final decision.

The expectation is no longer that landlords try to do the right thing. It is that they can show they did the right thing, at the right time, for the right reason. Safety outcomes now matter more than intent or effort.

Conclusion

One of the key lessons I have taken from damp and mould taskforces and regulatory recovery programmes is that organisations rarely fail because people do not care.

More often, failure comes from the way organisations are set up. Information sits in different systems, responsibilities are unclear, and early warning signs are either missed or not acted on. The issue is usually visible somewhere, but no one has a complete view, and no one takes clear ownership of the outcome.

Phase 1 was challenging, but it was relatively narrow in focus. Phase 2 is different. It is broader, more complex and far more cross-cutting. It brings multiple hazards, teams and systems into scope under the same statutory pressure, and it will test whether organisations can operate in a coordinated and controlled way at scale.

This is not just about compliance. It is about readiness. Organisations need to be prepared for that shift, because the complexity already exists. The legislation is simply exposing it.

For me, the principle is simple. Every home should be assessed with the same level of care, professionalism and urgency you would expect for a member of your own family. That means understanding the root cause, making a clear call on risk, and following that through to a safe and lasting resolution.

So my closing thought is this. Be prepared.

I say that as an Aston Villa fan, fresh from our European triumph. It is a simple message, but one that travels. And in this context, it applies just as much to housing as it does to football.