The next phase of Awaab’s Law will come into force on 30 November 2026, significantly extending the range of hazards that social landlords in England will be required to investigate and address within prescribed timescales.
The Government has now published the regulations and supporting guidance for Phase 2, giving landlords and housing practitioners greater clarity on how the expanded regime will operate.
Phase 1, which came into force on 27 October 2025, introduced statutory requirements in relation to significant damp and mould hazards and all emergency hazards. Phase 2 represents a substantial widening of that framework.
What changes from 30 November?
From 30 November 2026, Awaab’s Law will extend the existing requirements to significant hazards involving:
- excess cold and excess heat;
- falls, including falls on level surfaces, stairs and between levels;
- electrical hazards;
- fire and explosions;
- structural collapse and falling elements; and
- domestic hygiene, including personal hygiene and food safety.
The Government estimates that implementation of Phase 2 will result in significant additional compliance costs for the social housing sector.
The expansion is important not simply because more categories of hazard will fall within the regime, but because landlords will increasingly need systems capable of identifying, triaging, investigating and responding to a much broader range of reported housing conditions.
The statutory timescales remain critical
Awaab’s Law imposes legally enforceable requirements rather than simply providing regulatory guidance.
Emergency hazards must be investigated and, where an emergency hazard is identified, relevant safety work undertaken within 24 hours followed by completion of all other outstanding repair works as soon as reasonably practicable.
The existing framework also places prescribed timescales around the investigation of potential significant hazards, the provision of written information to tenants and the commencement of relevant safety work.
Importantly, whether a hazard meets the statutory threshold requires consideration of the circumstances of the individual tenant. The question is not simply whether a particular defect exists, but the risk of harm it presents to the occupant concerned.
Information about vulnerability, health and individual circumstances may therefore be highly relevant when determining whether a reported condition amounts to a significant or emergency hazard.
What does Phase 2 mean for housing conditions claims?
For claimant practitioners, the widening of Awaab’s Law adds another important layer to the existing legal framework governing housing conditions.
Issues around when a landlord became aware of a potential hazard, how that information was assessed, what investigation followed and whether action was taken within the required period are likely to assume increasing importance.
The practical evidence may therefore extend beyond the condition of the property itself. Repair logs, complaints, inspection records, communications with tenants, triage decisions and the information held by a landlord about an occupant’s circumstances may all become relevant when considering compliance.
Awaab’s Law also sits alongside existing statutory and contractual remedies rather than replacing them. Practitioners will therefore need to consider its requirements together with the established obligations applying to the condition and fitness of rented homes.
An evolving area of housing litigation
While Phase 1 has already brought Awaab’s Law firmly into focus for housing practitioners, Phase 2 substantially broadens the circumstances in which questions around notice, investigation and compliance may arise.
Neil Smith, Solicitor Advocate with 8PP comments:
“Phase 2 significantly widens the scope of Awaab’s Law and, from a litigation perspective, the evidence around what a landlord knew, when it knew it and how it responded is likely to become increasingly important.
“For practitioners, this means looking beyond the underlying defect itself. The reporting history, inspection and repair records, the landlord’s assessment of the hazard and what it knew about the individual tenant’s circumstances may all have a bearing on whether the statutory requirements have been met.”
There remains relatively limited judicial guidance on the operation of Awaab’s Law. As the statutory regime develops and a wider range of hazards becomes subject to prescribed requirements, its interaction with housing conditions litigation is therefore an area practitioners will need to watch closely.
Phase 3 is expected in 2027, when the regime will be extended further to cover the remaining Housing Health and Safety Rating System hazards, with the exception of overcrowding.
