Awaab’s Law Phase 2 and HHSRS Reform | Awaab Comply
Guest commentary by Danny Bird. Regulatory details and timing updated by Awaab Comply on 26 October 2026; the author’s wider practical commentary is retained.
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’s death after prolonged exposure to mould drove important legislative change. The Social Housing (Regulation) Act 2023 introduced the statutory basis for Awaab’s Law, with the 2025 Regulations setting out the prescribed response requirements from 27 October 2025.
The 2025 Regulations – The Legal Foundation
The requirements are implied into the relevant social housing tenancy agreements through section 10A of the Landlord and Tenant Act 1985. They give tenants a contractual route to challenge a landlord’s failure to meet the prescribed requirements.
Phase 1 (in force since 27 October 2025) sets clear timeframes for two things.
These are all emergency hazards and damp and mould hazards presenting a significant risk of harm, where the conditions for the law to apply are met.
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.
For potential emergency hazards, investigation and any required relevant safety work must be completed as soon as reasonably practicable and within 24 hours of awareness. Where safety work cannot meet the deadline, the landlord must secure suitable alternative accommodation at its expense.
Potential significant damp and mould hazards must be investigated within 10 working days of awareness. A written summary is due within 3 working days of the investigation concluding, and relevant safety work within 5 working days where a significant hazard is identified. Supplementary preventative work has a separate start requirement; a 12-week backstop concerns its start, not completion of every repair.
Phase 2: expansion from 30 November 2026
Phase 2 comes into force on 30 November 2026. It extends the significant-hazard requirements to further hazards; it does not introduce emergency-hazard duties for the first time. Landlords must continue to meet their existing safety and repairing obligations before that date.
Excess cold and excess heat
Falls, including falls on stairs, on level surfaces, between levels and associated with baths
Structural collapse
Fire and explosions
Electrical hazards
Domestic hygiene, including personal 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 2026 HHSRS reform is a separate change from the Phase 2 expansion. Government HHSRS guidance published in June 2026 describes the revised assessment process and 21 potential hazard categories, reduced from 29 through amalgamation. An HHSRS assessment is not interchangeable with deciding whether a hazard is significant or an emergency under Awaab’s Law.
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.
Paper-based working is not prohibited by Phase 2. The practical challenge is whether the chosen process produces timely, reliable evidence and supports clear decisions. Digital inspection and reporting tools can help reduce the delay between a visit and a reviewed report.
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
Proactive safety management can support earlier intervention. The statutory response clocks are triggered by awareness of a potential hazard, rather than by a blanket requirement to install sensors.
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 expands the significant-hazard response framework from 30 November 2026. HHSRS reform changes the assessment framework separately. Landlords need to understand both, while continuing to meet existing duties for hazards that fall outside the current Awaab’s Law scope.
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.
From on-site evidence to a report in minutes
Awaab Comply helps inspectors capture findings, measurements and photographs on a phone or tablet during a visit, then generate a downloadable report in minutes. The inspector should review the report promptly. This supports evidence gathering and reduces time spent writing up afterwards; the landlord remains responsible for triage, competent assessment, tenant communication, safety work and meeting the applicable deadlines.
Book a free Awaab Comply demo ↗ or contact our team.
Guidance and review date
Regulatory wording checked on 26 October 2026 against GOV.UK’s Phase 2 guidance for social landlords. Read the guidance alongside the regulations when deciding how the requirements apply to a case.
