Phase 1 of Awaab’s Law came into force on Monday 27 October 2025, marking a new era of accountability for the social housing sector. But with more changes on the way, social landlords must stay focused on what’s coming next.

The legislation has been well received by many social landlords who recognise its necessity and importance. Nevertheless, it has brought with it an enormous operational challenge. Under Phase 1 of the legislation, social landlords must respond to emergency hazards within 24 hours, investigate significant damp and mould within ten working days, issue written findings within three days, and begin remedial work within five days or within a 12‑week-long‑stop period where unavoidable. If a home cannot be made safe, alternative accommodation must be provided.

Overall, social landlords who have invested in strong digital systems have been better placed to meet the new requirements, with many reporting faster ‘triage’, clearer records and better communication with tenants. Whilst it’s too early to say, based on litigation, which types of organisations have been least prepared, larger housing associations are more likely to have stronger digital tools and more established compliance structures. Local authorities are more likely to be hampered by fewer resources and older IT systems. 

Preparing for Phases 2 and 3

Although social landlords were given a three-year lead in for Phase 1, Phases 2 and 3 of Awaab’s Law are approaching quickly. These further changes are coming at a time when many social landlords have yet to fully absorb lessons and embed new processes. 

Perhaps surprisingly, excess heat has emerged as one of the first reported cases, and thermal safety seems set to become one of the most complex new compliance areas. As Awaab’s Law is expected to extend to include excess heat in Phase 2, overheating will trigger the same legally enforceable response deadlines applied to other emergency hazards, such as damp and mould. Glazed, high‑rise developments face significant risks, as restricted window openings could mean flats are prone to overheating during warmer periods. Persistent overheating caused by design issues, such as inadequate ventilation or solar gain, may require investigation, action and auditable evidence from social landlords.

Commencing in October 2026, Phase 2 will apply the same statutory deadlines to additional hazards, including excess cold and heat, fire and electrical safety, falls, structural instability, domestic hygiene and food safety risks. In 2027, Phase 3 will extend the regime to almost all remaining Housing Health and Safety Rating System (HHSRS) hazards except overcrowding, although late changes are possible. 

Preparation is key for social landlords

There is obviously a risk of increased complaints and litigation if social landlords are unable to meet the tight timeframes set within the legislation.A proactive approach to preparation is key. Social landlords should review asset data across all hazard categories, ensure robust access and scheduling processes, adopt enhanced digital case management systems, and establish clear decanting pathways. 

Teams should review stock to ensure that good quality information is held about tenanted homes and who is living in them. All procedures should be reviewed to ensure compliance with the Housing Ombudsman’s Complaints Handling Code and tenants should be informed of social landlords’ preferred method for reporting potential hazards.

Digital case management systems should be adopted, and social landlords should ensure that IT systems are sufficiently advanced and work in conjunction with each other, so that Awaab’s Law complaints can be cross-referenced against the Pre-Action Protocol for Housing Conditions Claims.

Social landlords must also provide sufficient training and resources. For example, staff should understand that every interaction with a tenant is an opportunity to capture, verify and record key information. Alongside this, staff should be trained in the full range of Housing Health and Safety Rating System (HHSRS) hazards and how these align with Awaab’s Law.  

Key takeaways  

• Social landlords with robust digital systems are seeing clear benefits, including faster ‘triage’, better record keeping, and improved communication with tenants.
• Despite broad support for the legislation, social landlords are facing significant operational and logistical challenges, which can only be overcome through the introduction of streamlined processes and effective use of data and digital systems.
• Staying abreast of early cases and learning lessons from the implementation of the Phase 1 legislation are vital to ensure compliance in the future.
• Preparation for Phases 2 and 3 of Awaab’s Law should be well underway and social landlords must act quickly to strengthen compliance, data, IT systems, and staff training.