Awaab’s Law Phase 2

The essentials to getting it right

Awaab’s Law represents one of the most significant changes to housing management, repairs and property safety in the social housing sector. It places clear legal duties on social landlords to investigate and respond to emergency and significant hazards within defined timescales, with a particular focus on ensuring that residents are not left living in unsafe homes.

Phase 1 came into force on 27 October 2025 and applies to emergency hazards and damp and mould hazards that present a significant risk of harm. Phase 2 will come into force on 30 November 2026 and will extend the regime further, bringing seven additional hazard categories into scope and creating a much broader operational challenge for landlords.

For Boards, Councillors, Executives and senior leaders, Awaab’s Law should not be viewed simply as a repairs compliance requirement. It is a test of whether the organisation can identify risk, act quickly, communicate effectively, engage residents, manage contractors, understand vulnerability and evidence that homes are safe.

At the heart of this is resident engagement. Awaab’s Law is not just about meeting statutory timescales; it is about listening to residents, understanding the lived experience of unsafe homes and ensuring that residents are involved from the first report through to final resolution. Landlords that fail to engage residents properly may meet some technical requirements, but still fail to build trust, understand risk or deliver the right outcome.

What is happening?

Phase 2 will come into force on 30 November 2026. It will significantly widen the scope of Awaab’s Law by extending the significant hazard requirements to seven additional hazard categories:

Phase 2 hazard category: What this means in practice

• Excess cold: Homes that are unsafe because they cannot be adequately heated or retained at a safe temperature.
• Excess heat: Homes that present a significant risk because of overheating.
• Falls: Falls on the level, falls on stairs and falls between levels.
• Structural collapse and falling elements: Risks from structural instability or building elements that may collapse or fall.
• Fire and explosions: Fire and explosion hazards within the scope of the landlord’s responsibilities and relevant Awaab’s Law requirements.
• Electrical hazards: Electrical faults or unsafe electrical conditions that present a significant risk of harm.
• Domestic hygiene: Hygiene-related hazards, including personal hygiene and food safety issues.

This means Awaab’s Law Phase 2 will move well beyond damp and mould and into a much wider property safety environment. Issues that may previously have been treated as routine repairs may now require urgent risk assessment, investigation and action where there is a significant risk of harm.

For example, a failed heating system, an overheating home, unsafe stairs, a serious trip hazard, unsafe electrics, fire or explosion risk, structural defect, pest infestation linked to disrepair, drainage failure, unusable bathroom or serious hygiene-related defect may all need to be assessed through the lens of Awaab’s Law.

The practical implication is significant. Landlords will need to ensure that frontline teams, repairs operatives, surveyors, compliance teams and contractors understand the Phase 2 hazard categories, the relevant thresholds, the resident’s circumstances and the evidence required to demonstrate that the organisation has acted within statutory timescales.

The timeline

Awaab’s Law is being implemented in phases, with the scope widening over time.

Phase: Timing: Scope

• Phase 1: From 27 October 2025. Applies to emergency hazards and to damp and mould hazards that present a significant risk of harm.
• Phase 2: From 30 November 2026. Extends the significant hazard requirements to seven additional hazard categories: excess cold, excess heat, falls, structural collapse and falling elements, fire and explosions, electrical hazards, and domestic hygiene.
• Phase 3: 2027, date to be confirmed. Extends requirements to the remaining hazards under the Housing Health and Safety Rating System, excluding overcrowding.

The direction of travel is clear. Social landlords need to be ready for a much wider statutory repair and safety framework, with stronger expectations around speed, evidence, communication, resident engagement and resident protection.

The statutory response requirements

Awaab’s Law is not only about identifying hazards. It also requires landlords to act within clear statutory timeframes.

Landlords must investigate potential emergency hazards and, where an emergency hazard is identified, complete relevant safety work as soon as reasonably practicable and within 24 hours of becoming aware of the hazard.

For potential significant hazards, landlords must investigate within 10 working days of becoming aware of the issue. Where the investigation identifies a significant hazard, the landlord must provide the tenant with a written summary of the findings within 3 working days of the conclusion of the investigation and complete relevant safety work within 5 working days.

Where works are required to prevent a significant or emergency hazard recurring, landlords must begin, or take steps to begin, those supplementary preventative works within 5 working days of the investigation concluding. If those works cannot begin within that period, they must begin as soon as reasonably practicable and within 12 weeks.

Where relevant safety work cannot be completed within the required timeframe, the landlord must secure suitable alternative accommodation for the household at the landlord’s expense until the safety work has been completed.

These timeframes should be treated as maximum limits, not target response times. Where the risk to the resident or household requires faster action, landlords should act more quickly.

Why Phase 2 is a bigger operational challenge

Phase 1 has rightly focused significant attention on damp, mould and emergency repairs. Phase 2 is different because it affects a much wider range of services and property risks.

It will require coordination across the whole housing service. :

• Repairs and maintenance.
• Customer contact and triage.
• Asset Management and Compliance teams.
• Contractor management.
• Complaints and disrepair.
• Resident engagement and vulnerability data.

This means Awaab’s Law Phase 2 is not just a repairs issue. It is a whole-organisation safety, assurance and service delivery issue.

The key question for landlords is not simply whether they have a policy in place. The real question is whether their operating model can consistently identify, respond to, evidence and resolve hazards within statutory timescales while keeping residents properly informed, involved and supported.

Resident engagement is key and must run through the whole process

One of the most important principles of Awaab’s Law is that residents must not be passive recipients of a repair process. They must be listened to, believed, kept informed and involved from the moment they report a concern through to final resolution and learning.

Effective resident engagement starts at first contact. The way the landlord responds to the initial report will often determine whether the risk is properly understood. Staff need to ask the right questions, listen carefully to what the resident is saying, understand the impact on the household and identify whether there are any vulnerabilities or circumstances that increase the level of risk. This is particularly important because residents will often describe the lived experience of a hazard before the organisation fully understands the technical cause. A resident may not use the language of “significant hazard” or “emergency hazard”, but they may describe cold rooms, unsafe electrics, persistent leaks, unusable facilities, trip risks, fire safety concerns or conditions that are affecting their health and wellbeing. The organisation needs to translate that resident experience into the right risk assessment and response.

Resident engagement should also include clear information about tenants’ rights under Awaab’s Law, how to report concerns, what timescales apply and how the landlord will keep residents updated from initial triage through to completion.

Resident engagement also needs to continue throughout the case. Residents should know what has been identified, what action will be taken, when it will happen, who is responsible and what they should do if the situation worsens. Written summaries and updates should be clear, accessible and meaningful. They should not be treated as a procedural requirement alone, but as an important part of maintaining trust, reducing anxiety and ensuring residents understand how the issue is being managed.

The end of the process is just as important as the beginning. Landlords should confirm with residents that works have been completed, that the home has been made safe and that any follow-on actions are understood. Where appropriate, post-completion contact should be used to check whether the issue has genuinely been resolved and whether the resident has confidence in the outcome.

Resident feedback should also inform organisational learning. Complaints, dissatisfaction, repeat repairs, missed appointments, poor communication and resident experience should be reviewed alongside technical compliance. A landlord may meet a timescale but it will still fail the resident if communication is poor, disruption is unmanaged or the underlying issue returns.

For Boards, Councillors and Executives, the key question is not only whether the organisation is meeting Awaab’s Law timescales. It is whether residents feel listened to, informed, safe and respected throughout the process.

How organisations should be preparing

Social landlords must be preparing now. The organisations that are most ready will be those that have moved beyond policy drafting and are testing how their systems, people, contractors, resident engagement and governance arrangements work in practice.

Preparation should include the following.

1. Undertake a readiness gap analysis

Landlords should assess their current arrangements against the current Awaab’s Law requirements and the Phase 2 hazard categories.

This should test whether the organisation can:

• Identify a potential Awaab’s Law case at first point of contact.
• Record the case correctly.
• Assess risk and vulnerability.
• Understand the resident’s experience and household circumstances.
• Trigger the correct timescales.
• Allocate ownership.
• Complete inspections and safety works.
• Communicate with the resident in writing.
• Keep the resident updated throughout the process.
• Track follow-on works.
• Confirm completion with the resident.
• Evidence completion and closure.
• Report performance, risk and resident experience to senior leaders.

2. Build a clear operating model

Awaab’s Law requires more than a policy statement. Landlords need a clear operating model that sets out what happens from first report to final closure.

This should include:

• First contact questions.
• Resident engagement expectations.
• Triage criteria.
• Significant hazard and emergency hazard escalation routes.
• Inspection requirements.
• Resident communication standards.
• Safety works and temporary mitigation.
• Follow-on works.
• Alternative accommodation arrangements where required.
• No-access procedures.
• Case closure checks.
• Post-completion resident contact.
• Quality assurance.
• Management oversight.
• Learning from resident feedback.

The model must be simple enough for frontline staff to use, but strong enough to evidence compliance and support a positive resident experience.

3. Use the Phase 2 hazards guidance and clarify thresholds

Landlords should ensure their Awaab’s Law procedures reflect the latest Phase 2 guidance and the separate hazards guidance annex published to support the triaging of hazards.

This is important because Phase 2 includes hazards where the threshold between a routine repair, a significant hazard and an emergency hazard may be more difficult to judge. Organisations should therefore develop clear internal guidance, escalation routes and quality assurance so that staff make consistent, defensible and resident-focused decisions.

4. Strengthen resident vulnerability data

Resident vulnerability data will be central to effective delivery. A hazard cannot be assessed properly without understanding who lives in the home and how the issue may affect them.

A defect that may be inconvenient for one household could be serious or urgent for another. Age, disability, respiratory conditions, mobility issues, pregnancy, children, mental health, frailty or other household circumstances may all affect the level of risk.

Landlords should therefore review how vulnerability information is captured, updated, shared and used in operational decision making. This must be done through respectful and effective engagement with residents, ensuring that residents understand why information is being collected, how it will be used and how it will help the landlord respond appropriately.

5. Review contractor readiness

Many landlords will rely heavily on contractors to deliver Awaab’s Law compliance. However, accountability remains with the landlord.

Organisations should review whether contracts, specifications, KPIs and operational arrangements are aligned with Awaab’s Law requirements.

This should include:

• Emergency attendance requirements.
• Specialist trade availability.
• Out-of-hours response.
• Evidence standards.
• Photo records.
• Resident communication expectations.
• Escalation processes.
• Completion reporting.
• Follow-on works management.
• Quality assurance.
• Resident satisfaction and feedback.
• Performance reporting.

If contractor arrangements are not aligned, landlords may find themselves exposed even where the failure sits within the supply chain. Contractors must understand that resident engagement is part of effective delivery, not an optional add-on.

6. Improve case management and systems

Awaab’s Law will test whether repairs and housing management systems are fit for purpose.

Systems need to be able to track:

• Date and time of first report.
• Hazard category.
• Risk assessment.
• Vulnerability considerations.
• Inspection deadline.
• Safety works deadline.
• Written summary deadline.
• Follow-on works.
• Resident updates.
• Contractor actions.
• No-access attempts.
• Evidence and photographs.
• Closure checks.
• Resident confirmation and feedback.

Where systems cannot do this easily, organisations may need manual controls, dashboards or interim tracking arrangements until system improvements are delivered.

7. Strengthen governance and assurance

Boards, councillors and Executives need clear visibility of Awaab’s Law readiness and performance.

Reporting should go beyond simple averages and include:

• Number of Awaab’s Law cases.
• Cases by hazard type.
• Emergency cases.
• Compliance with statutory timescales.
• Overdue cases.
• Repeat hazards.
• Cases involving vulnerable residents.
• No-access cases.
• Contractor performance.
• Complaints and disrepair overlap.
• Quality assurance findings.
• Resident feedback and satisfaction.
• Communication failures.
• Lessons learned.

The most important question is not simply “Are we compliant?” but “How do we know, and what are residents telling us about their experience?”

The essentials to getting it right

There are several essentials that will determine whether organisations succeed.

Clear ownership

Every case needs clear ownership. Awaab’s Law cases must not drift between teams, contractors or systems. There must be a named owner responsible for ensuring the case is progressed, communicated and closed properly.

Effective first contact

The first conversation with the resident is critical. Customer contact teams need the right training, scripts, questions and escalation routes to identify potential hazards early.

They also need to listen carefully and take the resident’s account seriously. Residents are often the first and most important source of information about the seriousness and impact of a hazard.

Risk-led triage

Cases need to be assessed based on the hazard, the home and the household. This requires good information, skilled decision making and clear criteria.

Resident engagement from beginning to end

Resident engagement must be built into every stage of the Awaab’s Law process. This means listening properly at first contact, understanding the impact on the household, keeping residents informed during investigation and works, supporting access, explaining decisions clearly, confirming completion and using resident feedback to improve services.

The strongest landlords will not see communication as a separate administrative task. They will see engagement as central to risk management, trust, safety and successful delivery.

Strong communication

Residents need clear, timely and accessible communication. Written summaries should explain what has been found, what will happen next, when works will be completed and who to contact if circumstances change. Landlords must also take reasonable steps to keep tenants informed about the timing and progress of required work until completion.

Evidence discipline

If it is not recorded, it will be difficult to evidence. Landlords need strong records of decisions, inspections, works, resident contact, photographs, no-access attempts and completion.

Contractor control

Contractors must understand that these are statutory requirements, not ordinary response targets. Performance needs to be actively managed.

Contractors should also be clear on expectations around resident communication, respect, appointment keeping, evidence, escalation and post-completion feedback.

Quality assurance

A case should not be closed just because an operative attended. Closure should confirm that the hazard has been made safe, follow-on works are understood, the resident has been updated and evidence is complete.

Where appropriate, closure should also include confirmation from the resident that the issue has been resolved and that they understand any remaining actions.

Learning and prevention

The best landlords will use Awaab’s Law to identify patterns, prevent recurrence and improve services, rather than simply responding case by case.

Resident feedback should be central to this learning. Complaints, dissatisfaction, repeat contact and poor communication should be treated as important warning signs, not simply service noise.

Challenges that may affect delivery

Awaab’s Law Phase 2 will create a number of delivery challenges for social landlords.

Data quality

Poor property data, incomplete repair histories and weak vulnerability records may lead to poor decisions, missed risks and inconsistent prioritisation.

Understanding thresholds

Phase 2 will require landlords to make consistent judgements about whether a hazard is significant or an emergency. This will require competent staff, clear guidance, training, quality assurance and effective escalation routes.

System limitations

Many existing repairs systems were not designed to manage statutory hazard timescales, written summaries, risk flags, resident engagement and evidence requirements.

Workforce capacity

Phase 2 may increase demand for surveyors, inspectors, specialist trades, heating engineers, electricians, fire safety specialists, structural engineers and drainage contractors.

Contractor capacity

Contractor availability may become a significant challenge, particularly where multiple landlords are competing for the same specialist resources.

Inconsistent decision making

Without clear criteria and training, similar cases may be treated differently across teams, patches or contractors.

No-access cases

No-access will need careful management. Landlords will need to show that they acted reasonably, persistently and proportionately, particularly where there is a known risk to the household. Good resident engagement will be critical. Many access issues can be resolved through clear communication, flexibility, trust and understanding the resident’s circumstances.

Communication failures

Poor communication can undermine resident trust, increase complaints and create regulatory exposure, even where the technical repair response is adequate.

Competing priorities

Awaab’s Law Phase 2 will compete with existing pressures around damp and mould, building safety, decarbonisation, disrepair, voids, planned investment and day-to-day repairs demand.

Governance blind spots

Boards, councillors and Executives may receive high-level performance reports without understanding the seriousness of individual overdue cases, repeat hazards or risks affecting vulnerable households. They may also miss the resident experience if reporting focuses only on compliance data and not on what residents are saying about communication, disruption, trust and outcomes.

Risk of assumptions about resident behaviour

Landlords should be careful not to assume that hazards such as damp, mould, pests, hygiene issues or poor internal conditions are caused by tenant lifestyle. The starting point should be to listen, investigate, understand the evidence and act where the landlord is responsible.

What excellence looks like

Excellence means that residents are listened to, risks are understood, action is taken quickly and homes are made safe.

In practical terms, excellence looks like this:

A resident reports a problem once. The landlord asks the right questions, understands the household circumstances, assesses the risk, explains what will happen next, keeps the resident updated, completes the required works, checks that the home is safe and learns from the resident’s experience.

A technically compliant response is not enough if the resident feels ignored, confused or unsupported. Awaab’s Law should drive a culture where residents are treated as partners in identifying risk, resolving hazards and improving services.

At Board, Councilor and Executive level, excellence means being able to answer:

• Do we know which homes and households are most at risk?
• Can we identify Awaab’s Law hazards at first point of contact?
• Can we evidence compliance with statutory timescales?
• Are our contractors ready and accountable?
• Are vulnerable residents being prioritised appropriately?
• Are residents being kept informed and supported throughout the process?
• Are we learning from complaints, disrepair claims and repeat repairs?
• Are we listening to what residents are telling us?
• Are we preventing recurrence?
• Can we assure ourselves that residents are safe?

How Integra Housing can help: Awaab’s Law Phase 2 Healthcheck

Integra Housing can support social landlords to prepare for Awaab’s Law Phase 2 through a focused, practical and evidence-based Awaab’s Law Healthcheck.

The Healthcheck assesses whether the organisation is ready to identify, triage, respond to, evidence and govern the wider range of hazards that will fall within Phase 2. This includes reviewing current arrangements across repairs, compliance, asset management, customer contact, contractor management, resident vulnerability data, resident engagement, case management, governance reporting and Board, councillor and Executive assurance.

The review provides an independent view of current readiness, highlighting where arrangements are strong, where there are gaps, and where urgent improvement is required before implementation.

As part of the Awaab’s Law Healthcheck, Integra Housing would place strong emphasis on the quality of resident engagement throughout the process. The review would test whether residents are listened to at first contact, whether communication is clear and timely, whether vulnerability and household circumstances are properly understood, and whether residents are kept informed through to completion and closure.

The Healthcheck would also consider whether resident feedback, complaints, repeat contacts and dissatisfaction are being used to strengthen service design, improve contractor performance and provide meaningful assurance to Boards, councillors and Executives.

The Healthcheck Process would typically include:

Area of review: What Integra would assess

• Policy and procedure readiness: Whether policies, procedures and operating guidance reflect Awaab’s Law requirements, the Phase 2 implementation date and the Phase 2 hazard categories.
• Repairs triage and diagnosis: Whether frontline teams can identify potential significant and emergency hazards at first point of contact.
• Hazard threshold guidance: Whether teams have clear, practical guidance for deciding whether a case is routine, significant or emergency, with appropriate escalation routes.
• Resident vulnerability and household data: Whether vulnerability information is captured, updated and used effectively in risk-based decision making.
• Resident engagement and experience: Whether residents are listened to, kept informed, supported through the process, involved in confirming resolution, and whether their feedback is used to improve services.
• Case management and systems: Whether systems can track statutory timescales, actions, communications, safety works, follow-on works, resident updates and closure evidence.
• Contractor readiness: Whether contracts, KPIs, mobilisation arrangements, escalation processes and resident communication expectations are aligned to Awaab’s Law obligations.
• Operational capacity: Whether the organisation has sufficient surveyor, trade, specialist contractor and management capacity to respond within required timescales.
• Resident communication: Whether written summaries, updates and closure communications are timely, clear, accessible and properly evidenced.
• Governance and assurance: Whether Boards, councillors, Executives and senior leaders receive meaningful assurance on risk, compliance, performance, resident engagement and resident outcomes.
• Learning and continuous improvement: Whether complaints, disrepair claims, Ombudsman findings, repeat repairs, no-access cases and resident feedback are used to improve services.

The Healthcheck Report and Associated Action Plan

Integra would provide a clear and practical report setting out:

• Current level of readiness for Awaab’s Law Phase 2.
• Key compliance and delivery risks.
• Priority actions required before implementation.
• Recommendations for policy, process, systems, contractor management, resident engagement and governance.
• A practical improvement plan with clear timescales and ownership.
• Suggested Board, councillor and Executive reporting measures.
• Recommendations for strengthening resident communication and feedback loops.
• A roadmap for moving from compliance readiness to sustained service improvement.

Why this matters

Awaab’s Law Phase 2 will place greater pressure on social landlords because it extends the regime into a much wider range of property safety hazards. Getting ready requires more than a policy review. It requires confidence that the whole operating model works — from first resident contact through to triage, inspection, works completion, communication, evidence, assurance, resident feedback and learning.

Integra Housing can bring independent challenge, practical sector experience and a structured methodology to help organisations understand their current position, close gaps quickly and build arrangements that are safe, compliant, resident-focused and sustainable.

Conclusion

Awaab’s Law Phase 2 will be a major test for the social housing sector. It will test the strength of repairs services, the quality of data, the effectiveness of contractors, the maturity of governance and the ability of organisations to respond quickly when residents are at risk.

But it will also test something more fundamental: whether landlords genuinely listen to residents and act on what they are being told.

The landlords that get this right will not be those that simply update a policy. They will be those that build a reliable operating model around resident safety, risk, evidence, communication, engagement and accountability.

Awaab’s Law should therefore be seen not only as a legal duty, but as an opportunity to strengthen services, rebuild trust and deliver safer homes for residents.

Integra Housing Consultancy | Awaab’s Law Phase 2 Article | Updated July 2026