Awaab’s Law Phase 2: What it covers and what housing providers should be doing now

Phase 1 of Awaab’s Law came into force in October 2025. Most social landlords spent the preceding months scrambling to get contact centre scripts in order, key processes defined, and supporting software tested and ready. Some were ahead of the game, many were not (based on the conversations the Made Tech team have had over the last few months).

Phase 2 is coming later in 2026. And it’s going to be harder.

Not just because there are more hazard categories. But because the nature of those hazards means the way providers have to respond is fundamentally different. The teams involved, the processes required, and the decisions that need to be made won’t map neatly onto anything most housing organisations already have in place.

Here’s what you need to know.

What is Awaab’s Law?

Awaab’s Law was introduced through the Social Housing (Regulation) Act 2023 following the death of two-year-old Awaab Ishak from prolonged mould exposure.

The regulations require landlords to investigate hazards in their tenants’ homes, provide written updates,  and commence any required follow-on works within strict timeframes.

Phase 1 brought damp and mould, and emergency hazards into scope. For emergency hazards, most providers already had a process of sorts – typically an emergency “make-safe” process. Phase 1 largely added formal timeframes and documentation obligations around something that already existed (to a greater or lesser extent – depending on the provider) 

Phase 2 extends those same obligations to a wider set of hazard categories from the Housing Health and Safety Rating System (HHSRS). A firm implementation date has not yet been confirmed – it is subject to secondary legislation – but government guidance points to later this year. Phase 3, covering the remaining HHSRS hazards, follows in 2027.

Which hazards does Phase 2 cover?

Hazard category	Examples
Excess cold	Inadequate heating, poor insulation, heating system failure
Excess heat	Properties that cannot be adequately cooled
Falls – stairs, baths, and level surfaces	Structural defects, inadequate handrails, uneven surfaces
Structural collapse and explosions	Subsidence, structural instability, gas safety failures
Fire and electrical hazards	Electrical faults, fire spread risks, inadequate detection
Domestic and personal hygiene, food safety	Pest infestation, inadequate sanitation, drainage failures

What Phase 2 means for social landlords

1. The admin burden is going to get heavier

The government estimated that Phase 1 would cost the social housing sector £129 million in additional staffing alone. When providers were consulted on whether that figure was accurate, 63% said it was an underestimate.

That’s before Phase 2 adds five new hazard categories to the workload.

Providers who have found Phase 1 stretching their capacity are about to take on more work. For each of these new hazard categories, the same work is required: investigations actioned and recorded, timeline documentation, written tenant communication, and remediation planning.

The Housing Ombudsman’s caseload tells the same story. Determinations rose 30% in 2024-25, and over 40% of all compensation ordered that year related to failures around damp and mould – hazards that have been in scope for years. If the sector is still struggling with the original obligations, adding five more hazard categories without a step-change in how cases are managed will only make the situation worse.

If you’re already feeling the weight of Phase 1 compliance, Phase 2 doesn’t give you breathing room. It raises the floor.

2. These hazards aren’t all your repairs team’s problem

Damp and mould – however complex – is something most repairs and maintenance teams had some version of a process for. There were SLAs. There were contractor relationships. There was at least a general sense of who owned it.

Excess cold, structural instability, domestic hygiene failures – these don’t sit cleanly in a repairs workflow. They’re more likely to land with building safety teams, compliance functions, or neighbourhood and housing offices. Some will require specialist contractors. 

The people who got your social landlord through Phase 1 may not be the right people for Phase 2. And the people who are the right people may not know that yet.

3. Preparing for Phase 2 needs an operational owner

The cross-functional nature of Phase 2 means the preparation work doesn’t belong to any one team by default. Designing a process that spans repairs, building safety, compliance, neighbourhood housing, and specialist contractors — and then standing it up so it actually runs — is a substantial piece of work in its own right.

It needs someone who owns it. Not governance oversight. A named lead whose job is to design the process, get the right people across it, and make sure it runs consistently once Phase 2 lands.

Without that, the reality is you’ll find yourself trying to pull it all together at the last minute. Processes that haven’t been properly designed. Teams that haven’t been properly briefed. Cases that fall through the gaps because nobody agreed who was responsible.

With Phase 2 adding five new hazard categories, there are simply more things that can slip. More places where an unclear process means a missed deadline. More cases where the wrong team owns the response — or nobody does.

Phase 2 is more complex than Phase 1. The cost of not having a clear owner this time is higher.

4. You’ll need policies that might not exist yet

Some of the hazards in Phase 2 will force decisions that providers haven’t had to make at scale before.

The most significant is relocation. When a property is assessed as presenting a serious risk from excess cold, structural instability, or fire, what happens to the tenant? What are your criteria for a temporary move? What’s the process for managing that, communicating it, and evidencing it?

At the volume that Phase 2 is likely to generate, an improvised approach won’t hold.

What to do before Phase 2 arrives

You don’t need to wait for a confirmed implementation date to start preparing. The hazards are known. The direction is set. Here’s where to focus now:

• Audit your team structure. For each Phase 2 hazard category, who in your organisation would own the response? Is that clear? Do they know?
• Identify your process gaps. Where Phase 1 required you to build a new process, Phase 2 will require more. Map what you have. Name what you don’t.
• Define your relocation criteria. Don’t leave this until a case forces the issue. A short internal policy – what triggers a relocation, how it’s approved, and how it’s documented – will save significant time and protect you legally.
• Assign a programme lead. Ideally, someone with the authority to convene the right teams and the mandate to make process decisions.

How Made Tech’s case management software helps

The thread running through all of this is coordination. Phase 2 compliance isn’t just an operational challenge – it’s an organisational one. The right people need to know what they’re responsible for. Cases need to be tracked across teams and contractors. Deadlines need to be visible. Evidence needs to be captured consistently.

Our Hazard Case Management software is built for exactly this. It gives housing providers a single place to manage hazard cases from ‘becoming aware’ through to resolution – tracking deadlines, coordinating across teams, capturing tenant communication, and generating the audit trail that Awaab’s Law requires. It integrates with existing housing management and repairs systems, or works standalone.

If you’re thinking about how to get your organisation ready for Phase 2, we’d be happy to show you what that looks like in practice and share what we’ve learnt from phase 1. 

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