Awaab's Law: What Social Landlords Need to Prepare for Before 30 November 2026

Awaab’s Law has already changed how social landlords respond to serious hazards. Since October 2025, emergency hazards and significant damp and mould hazards have been subject to legally enforceable investigation and repair timescales.

The next phase significantly widens that responsibility. From 30 November 2026, the requirements are due to extend to a broader range of significant hazards, bringing more everyday property-condition and repairs issues within scope where they pose a serious risk to a tenant. For landlords, preparation therefore needs to go beyond updating a policy. Triage, repairs capacity, contractor escalation, case management and tenant communication all need to work within the statutory timescales.

What changes on 30 November 2026?

Phase 1 of Awaab’s Law came into force on 27 October 2025, covering all emergency hazards except overcrowding and damp and mould hazards presenting a significant risk of harm.

Under the government’s Phase 2 guidance for social landlords, the significant-hazard requirements are due to extend from 30 November 2026 to excess cold and heat, falls, structural collapse, fire and explosions, electrical hazards and domestic hygiene. This means more problems traditionally handled through responsive repairs, compliance or asset-management processes may also need to be considered through the Awaab’s Law framework.

It doesn’t mean that every broken socket, cold room or trip hazard automatically becomes an Awaab’s Law case. The requirements depend on the seriousness of the hazard and the circumstances of the people living in the home. Landlords still need to assess whether there is a significant or emergency risk rather than treating the name of the repair as the determining factor.

At the time of writing, the Phase 2 amendment regulations remain subject to Parliamentary approval, although government guidance continues to prepare landlords for implementation on 30 November.

Which hazards are added in Phase 2?

The additional significant hazards are:

The government has published separate Phase 2 hazards guidance to help landlords make these assessments. It uses a “reasonable landlord” test when distinguishing significant and emergency hazards, while recognising that professional judgement and individual circumstances remain important.

That distinction is likely to matter particularly for hazards such as excess cold and heat. The same property condition can affect households differently depending on factors such as age, health and vulnerability, so a standard repairs classification may not always provide enough information to make the right decision.

What deadlines will landlords need to meet?

The basic statutory process remains demanding. The timescales are maximum periods rather than targets to wait for where quicker action is reasonably required.

Where an investigation identifies an emergency hazard, relevant safety work must be completed as soon as reasonably practicable and within 24 hours. For significant hazards, the home must be made safe within five working days after the investigation concludes.

The requirements also distinguish between making the property safe and addressing the underlying cause. If further preventative work is needed to stop the hazard recurring, landlords generally need to begin that work within five working days. Where this is not reasonably practicable, they must take steps within that period to arrange the work, which must then begin as soon as reasonably practicable and within 12 weeks. Where the home cannot be made safe within the applicable timeframe, suitable alternative accommodation may also need to be provided until the necessary safety work has been completed.

What has Phase 1 taught landlords?

Landlords preparing for Phase 2 now have something they did not have before Phase 1: evidence about how Awaab’s Law works operationally. The government's Phase 1 Test and Learn research found that implementation had already prompted stronger governance, escalation and focus on serious hazards. However, it also exposed pressures around staffing, systems, contractor costs and the coordination of more complex cases.

Triage emerged as particularly important. Where landlords used structured assessments and identified household vulnerability early, cases could be prioritised more effectively. Poorer triage was associated with fragmented responses, repeat reporting and short-term fixes.

The research also found a move towards end-to-end case management rather than treating each repair as an isolated task. This can provide clearer ownership from initial report through investigation, safety work and longer-term remediation, although it depends on having enough workforce capacity and supporting systems. Those lessons become more important as Phase 2 brings a much wider range of hazards into the process.

Get triage and escalation right

One of the biggest operational risks is assuming that the Awaab’s Law clock starts only when a specialist team formally accepts a case. Instead, the legal duties begin when the landlord becomes aware of a potential significant or emergency hazard. Awareness may come from the tenant, but it can also arise when an issue is reported by a third party, noticed by another part of the organisation or identified through a managing agent. Landlords must therefore have robust procedures for reporting and escalating potential hazards.

This raises practical questions across the organisation. Does the contact centre know which information to capture when somebody reports a cold home? Can a housing officer escalate an electrical or structural concern found during an unrelated visit? Does a repairs contractor know what to do when the condition they find is more serious than the original job description suggests?

Household circumstances also matter. Phase 1 research found that vulnerability information was sometimes incomplete, inconsistently recorded or difficult for staff to use when making decisions. Before November, landlords should therefore test the journey from first contact to triage, not just the specialist inspection process that follows it. A well-designed procedure is of limited value if important information never reaches the people responsible for applying it.

Make sure systems and contractors are ready

Phase 2 doesn't depend solely on repairs teams. Delivering within the required timescales can involve contact centres, housing management, surveyors, compliance teams, asset management, contractors, IT systems and temporary accommodation.

Phase 1 research identified workforce shortages in areas such as surveying and specialist trades, alongside increasing contractor costs and limitations in how different IT systems worked together. Landlords also reported concerns that the wider scope of later phases could bring considerably more responsive repair activity within statutory timescales.

For landlords using external repairs and maintenance providers, contractor arrangements should therefore form part of the readiness review. Reporting routes, escalation requirements, appointment times, specialist capacity, KPI reporting and access to information may all affect the landlord's ability to respond.

Thornton & Lowe's work around social housing repairs procurement and contract management focuses on making sure specifications, performance measures and day-to-day supplier management work together. Existing repairs contracts may need to be reviewed against the operational demands created by Phase 2, particularly where current SLAs or escalation arrangements were designed before Awaab’s Law.

The same question applies to in-house delivery. Where a landlord operates or is developing a DLO, it needs enough capacity, management information and specialist access to respond consistently rather than simply shifting the pressure from an external contractor to an internal team.

Communication and records matter

Awaab’s Law places formal requirements around written information, but effective communication is also an operational necessity. A written summary may be required within three working days of an investigation concluding. Depending on the case, this needs to explain whether a significant or emergency hazard was found, what action is required and the target timeframe for starting and completing that action. The Phase 2 guidance includes a template to support consistent summaries.

Phase 1 research found that tenants did not always receive written inspection summaries and that fragmented communication made it harder for them to understand commitments or escalate concerns. Conversely, clear updates and visible progress could improve confidence even where a case was complicated or took longer to resolve fully.

Good record keeping should also support the people delivering the service. Staff need to be able to establish when the problem was first reported, what household circumstances were known, which investigations have taken place, what work has been completed and which actions remain outstanding. That becomes increasingly difficult if information sits across separate repairs, CRM, housing-management and contractor systems. Phase 2 readiness should therefore include checking whether teams can follow a case from beginning to end without having to reconstruct the history manually.

What should landlords do before 30 November?

With Phase 1 already operating, preparation for Phase 2 should focus on whether current processes can cope with a substantially wider range of potential cases. Before 30 November, landlords should:

• Map the new hazards into existing processes. Identify where excess cold and heat, falls, structural, electrical, fire and hygiene concerns are currently reported and managed.
• Review triage guidance. Make sure frontline staff understand when an ordinary repairs report may indicate a potential significant or emergency hazard.
• Check vulnerability information. Establish whether relevant household information is current and available to the people who need it.
• Test escalation routes. Include contractors, managing agents, housing officers and other staff who could become aware of a potential hazard.
• Review case-management systems. Confirm that investigation, written-summary, remediation and follow-on dates can be recorded and monitored reliably.
• Assess repairs capacity. Consider surveyors, specialist trades, materials, emergency response and the likely effect of more cases falling within fixed timescales.
• Review contractor arrangements. Check whether specifications, SLAs, reporting and performance-management processes support the landlord's obligations.
• Plan for alternative accommodation. Make sure responsibilities and practical arrangements are clear where a home cannot be made safe in time.
• Test tenant communications. Written summaries, updates and explanations of next steps should be clear and consistent.
• Report readiness upwards. Boards and senior teams should understand outstanding gaps, capacity pressures and the investment needed to address them.

The government's Test and Learn findings provide an important warning here. Pressure to demonstrate compliance can encourage organisations to concentrate on completing individual stages rather than resolving the underlying problem. Phase 2 preparation should therefore test whether services can achieve a lasting repair, not simply whether the statutory clock can be stopped.

How Thornton & Lowe can support social landlords

Awaab’s Law is ultimately a legal obligation for social landlords, and organisations should take appropriate legal and technical advice on their specific responsibilities. Thornton & Lowe's role is focused on the operational and commercial services that sit around delivery. Our social housing consultancy services include procurement, outsourced contract management, supply-chain management and support with in-house service models.

If Phase 2 preparation highlights problems with repairs capacity, contractor performance, KPIs, supply chain resilience or the structure of an existing service, we can help landlords review how those arrangements work in practice. That may involve strengthening contract management, preparing for a repairs procurement exercise or considering how an in-house or hybrid delivery model could be improved. With the scope of Awaab’s Law widening, the immediate priority is making sure the services behind the policy are capable of responding when tenants need them.