Six months of Awaab’s Law: how are landlords faring?

Housemark’s recent survey of 154 social landlords shows that seven in 10 meet Awaab’s Law deadlines more than 90% of the time, demonstrating strong early compliance. Results vary significantly, however, due to differences in definitions, capacity and internal processes.  

The same survey shows a wide variation in hazard identification. For example, almost half of social landlords identified between zero and 10 emergency hazards, while others reported over 150, which suggests inconsistent interpretation.

Meanwhile, a 14% rise in empty properties in December 2025 reflects the holding of more voids for decants and longer repairs, while significant damp and mould cases rose between November and December. 

“Readiness for Phase 1 has varied across the sector. Larger housing associations may have been better placed due to stronger digital tools and more established compliance structures”

Operationally, preparing for and delivering Phase 1 has been demanding. Many social landlords report pressure on repair teams, complex scheduling requirements, tenant access issues and onerous documentation. Seasonal surges in damp and mould cases have added to the strain, and finding decant properties when deadlines could not be met has been a logistical challenge.

Readiness for Phase 1 has varied across the sector. Larger housing associations may have been better placed due to stronger digital tools and more established compliance structures. Local authorities are more likely to have entered Phase 1 with fewer resources and older IT systems.

To date, only a small number of tenant disputes have reached the point of litigation, so we don’t yet know which types of organisations were least prepared – this will become clearer as more cases progress through the system.

Financially, some social landlords had hoped the Affordable Homes Programme (AHP) would ease financial pressures, but AHP funding is intended for capital development rather than ongoing operational or compliance costs. Increased grant funding may indirectly free internal budgets, but the AHP does not provide a dedicated mechanism for absorbing Awaab’s Law‑related expenditure. 

Perhaps surprisingly, excess heat has emerged as one of the first reported cases, and this seems set to become a significant compliance challenge. It shows that overheating is being treated as an emergency hazard, rather than a design flaw or comfort issue.

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 damp and mould. Glazed, high‑rise developments face particular risks, as restricted window openings mean flats may have a tendency to overheat 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, turning thermal safety into one of the most complex new compliance areas.

These early overheating cases show how Phase 2 will broaden compliance demands and highlight the need for much closer integration between asset design, building regulations and operational safety obligations.

Social landlords had three years to prepare for Phase 1, but Phases 2 and 3 are set to follow rapidly, at a time when many organisations are still learning lessons from early implementation and putting them into practice. The changes required from Phase 1 may not be fully implemented, and already further changes are on the way.  

“Providing adequate training for staff and resources also remains critical. While many social landlords have started upskilling staff, the Housing Ombudsman continues to highlight recurring preventable failings”

Commencing in 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. It is also possible that following consultation, the government may change the hazards included in each stage. 

Preparation is key, and 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. Government and sector guidance stress that proactive preparation is vital.

Providing adequate training for staff and resources also remains critical. While many social landlords have started upskilling staff, the Housing Ombudsman continues to highlight recurring preventable failings. Phase 2 of Awaab’s Law requires expertise in fire safety, electrical diagnostics, structural risk and now thermal safety. Organisations that make the required changes now will be better positioned to meet statutory deadlines and avoid enforcement action.

With Phases 2 and 3 coming soon, legal risk under Awaab’s Law seems set to increase. Tenants can seek redress when deadlines are missed through complaints or legal claims. It is important for social landlords to keep comprehensive, defensible records for every stage of investigation and repair. Advice services are already highlighting Awaab’s Law in disrepair claims, and some early injunctions have been sought.

Since the legislation’s rollout began, there has been meaningful progress, reinforced by early data showing that most social landlords are meeting deadlines, most of the time. With capacity pressures, inconsistent definitions, rising decants and emerging risks, especially excess heat, there is still much work to do and focus is needed.

As Phase 2 expands the scope of hazards, social landlords must be ready to embed rigorous, end‑to‑end compliance systems across all hazard types, invest early in capacity and skills, and ensure that safety is prioritised from design through to long‑term occupation.

The government has said the next phase of Awaab’s Law will roll out during 2026, but there is still no start date, and no statutory guidance, even in draft form. This creates unwelcome uncertainty at a time when social landlords need clear and timely direction. They must align asset strategies, procurement plans, training programmes and compliance systems with the wider hazard list, but without a timetable, this is difficult.

Phase 2 guidance is needed as soon as possible to give social landlords time to prepare in a structured and proactive way. Those who embed compliance best practice now will be better placed to protect tenants, mitigate legal risks and maintain public confidence.

Suzanne Gregson, housing litigation partner, Anthony Collins