CPD module: How to comply with Awaab’s Law

From when it comes into force on 27 October, Awaab’s Law will require social landlords in England to respond to reports of damp and mould in social housing within fixed timeframes. The legislation is due to be extended in 2026 to other health hazards such as excess heat and cold. A further extension, in 2027, is planned to include all of the remaining hazards defined by the Housing Health and Safety Rating System (HHSRS) (England) Regulations 2005. Housing providers must adapt their processes to comply with this new law.

They should assess the health risks from damp and mould in their homes, investigate any cases identified, produce written summaries of their findings, and carry out any necessary emergency and major works, within the set timeframes prescribed by the law.

Social landlords must identify and support customers who are most vulnerable to the health hazard of damp and mould. This requires a degree of innovation, which could include the use of video remote assessments, sensors in properties, and a culture of speaking directly with customers about hazards in their homes.

Housing providers must provide robust evidence of compliance with Awaab’s Law for every single case of damp and mould reported to them. This requires fit-for-purpose IT infrastructure, clarity on how compliance is measured internally, and comprehensive staff training both in record-keeping and in the identification of hazardous damp and mould.

Housing providers can learn lessons from ensuring compliance with the initial Awaab’s Law damp and mould requirements to prepare for the planned extensions of the law to other health hazards.

This CPD module, in association with safety technology specialist Aico, will look at how housing providers can ensure compliance with Awaab’s Law for damp and mould and how these strategies might be applied to other health hazards when the law is extended in the next couple of years.

Awaab’s Law has introduced some clear timescales for responding to reports of damp and mould, and these timescales will soon apply to other health hazards, too. From 27 October, housing providers will have to:

• Investigate reports of damp and mould within 10 days of becoming aware of them
• Carry out emergency works on any identified hazards within 24 hours
• Produce a written summary of the investigation and its findings within three days
• Carry out any necessary works to make the property safe within five days
• Carry out any necessary major works within 12 weeks

While these requirements will initially apply to damp and mould, the government plans to introduce similar timeframes for other health hazards. From 2026, these requirements are expected to be extended to excess cold and excess heat, falls, structural collapse, fire, electrical hazards and explosions, and hygiene hazards. From 2027, the law is expected to be extended further to cover the remaining hazards defined by the HHSRS regulations, with the exception of overcrowding.

While the government is yet to announce the specific timeframes for these other health hazards, the approach to damp and mould compliance, outlined below, is designed to ease the incorporation of requirements for other health hazards as and when they are introduced.

Housing providers should already be in a good position to meet the requirements of Awaab’s Law.  Places for People (PfP) has looked closely at its own customer-driven processes and, where possible, has ensured the law is incorporated into existing processes. Care has been taken to ensure these processes are kept as simple as possible for customers and colleagues.

For many housing providers, it is clear the introduction of Awaab’s Law will bring about changes to several areas of their business. Compliance with Awaab’s Law may also involve the creation of new processes and approaches to record-keeping.

For example, a key requirement of the legislation is to provide written findings from damp and mould investigations. Previously, surveyors have provided largely technical reports. To ensure these reports are accessible to our customers, staff are now being trained to provide high-level summary findings in clear language. These summaries outline what their investigations have found and what needs to be done to fix any problems.

In preparation for Awaab’s Law coming into force, PfP has also created a new process for treating damp and mould health hazards. It has set up a dedicated team to respond quickly to damp and mould health hazards and undertake damp and mould washes to eliminate any immediate risk.

Damp and mould is a well-known health risk which can affect the airways, lungs, eyes and skin.

It can cause serious illness and, in the most severe cases, death, as in the tragic case of Awaab Ishak for whom Awaab’s Law is named. Concerns about damp and mould and the unpleasant living conditions they create can also affct people’s mental health.

While damp and mould can affect everyone, some people are more vulnerable or at greater risk of suffering from the more severe health consequences of damp and mould. This includes people with certain health conditions, children and older adults.

In order to assess the health risks of damp and mould, housing providers must know their homes and their customers. Social landlords should be proactive in identifying damp and mould, communicating meaningfully with their customers about how they are mitigating potential risks, and taking steps to reach customers who are less likely to contact them.

Damp and mould, and the risk of it, can be identified through stock conditions surveys, and through targeting properties which are most at risk. At PfP, homes that are rated Energy Performance Certificate Band D or below are more than twice as likely to experience damp and mould. Damp and mould is also more likely in previously affected properties.

These higher-risk properties can be fitted with temperature and humidity monitors, which can transmit data to landlords. When PfP identifies risks, customers are contacted for feedback and offered a survey.

Technology will thus go a long way to help us understand the performance of these homes. But this cannot be understood without first having an understanding of your customers.

Every customer is different and has different support needs. Some customers want to speak to us and frequently flag any issues they face. Others, on the other hand, are less likely to reach out about their concerns or want to have people carrying out surveys in their home.

PfP has a clear ‘don’t-walk-by’ culture that applies to all of our colleagues. This is supported by smaller patch sizes for our community housing managers, to ensure they can keep in touch more regularly with their customers and carry out more frequent visits.

We also carry out regular Healthy Homes checks alongside gas safety checks. A Healthy Homes check includes identifying any necessary repairs in a property, while also checking whether properties are safe, warm and free of damp and mould. As part of the process, we will take photographs which can subsequently be fed back to surveyors.

All findings from these checks are reported back to the customer contact centre so they can book in any necessary repairs, including damp and mould washes. PfP’s contact centre staff are trained to prioritise effectively and direct reports of damp and mould to the appropriate team.

To ensure we better understand the condition of our homes, PfP has introduced customer conditions surveys. Customer conditions surveys are sent to customers via email or social media, and allow customers to share their views about their homes, and illustrate any concerns with pictures. PfP then carries out video calls with the customer to understand what needs to be fixed in their home in order to keep it healthy.

Training your staff is also key to assessing the potential health risks of damp and mould in social housing in line with Awaab’s Law. Housing providers should ensure that all of their staff are trained to fully consider the risk caused by damp and mould to the home and the customer in every single interaction they have with their tenants.

The risk of damp and mould cannot be fully understood without first understanding your customers.

People who are most vulnerable to damp and mould can be identified by staff who have regular contact with them. At Places for People, these are the community housing managers. Our community housing managers identify any additional needs our customers may have.

Their assessments determine how many times a year they visit those customers, with the frequency of these visits tailored according to the individual customer’s level of need. Each visit provides an opportunity to assess any hazardous damp and mould in the homes of our customers, particularly those who are more vulnerable due to their age or health conditions.

Following Awaab’s Law, housing providers should adjust their processes to ensure responses to damp and mould and repairs are more rapid for customers with vulnerabilities. These more rapid responses can be linked to mental health vulnerabilities, as well as those related to physical health. While Awaab’s Law requires a repair to be carried out in 28 days, repairs should be carried out more quickly if a tenant has vulnerabilities.

Virtual surveys are another useful way of identifying damp and mould in the homes of customers with vulnerabilities. PfP uses video remote assessments to conduct surveys with a surveyor supported by a customer on their mobile phone. These assessments allow customers to quickly show the surveyor any areas of their homes that may be affected. Surveyors can then assess the risk of damp and mould and agree any immediate steps with customers over the phone.

Compliance with Awaab’s Law requires housing providers to act quickly and to have a robust record of what steps they have taken to investigate and carry out repairs to fix damp and mould. It is not about achieving good average scores. Proving compliance requires evidence for each and every customer and case, and evidence that the provider has acted in time. It requires housing providers to clearly track response times in line with each of the timescales prescribed by the law.

Housing providers should ensure that their technology is capable of logging every report as an individual case and tracing them to prove compliance. Housing providers should also ensure their IT systems allow data on their homes and on their customers to be linked if this is not already the case.

All colleagues involved with damp and mould processes should be trained in record-keeping, as this will be crucial to ensuring and demonstrating compliance. All colleagues will need to be trained on how to identify the risks of damp and mould and to divert cases to the appropriate place as soon as they become aware of them.

Special consideration should be given to the establishment of a dedicated team responsible for compliance with Awaab’s Law. PfP’s approach involves a Healthy Homes team tasked with dealing with damp and mould cases. They check every case to see which stage it has reached, whether a repair has been scheduled and how compliance can be proven.

Housing providers need to be clear on how response times are measured, as well as what customers have been promised and how the outcome of that promise is recorded. PfP requires staff and contractors to take photographs before and after visiting a home.

Housing providers will not be able to prove compliance unless they are confident that every single colleague is responding to concerns about damp and mould as soon as they are reported.

Damp and mould is the first of an increasing number of health hazards to which housing providers will have to respond within fixed timeframes. The government has said it will extend the law to cover the following, starting in 2026:

• Excess cold and heat
• Falls
• Structural collapse
• Fire
• Electrical hazards and explosions
• Hygiene hazards

In 2027, Awaab’s Law is due to be extended to all of the remaining hazards defined by the HHSRS regulations, excluding overcrowding (see further reading below).

While no firm dates or details have yet been given for these planned extensions, housing providers can apply the lessons they have learned from ensuring compliance with the damp and mould requirements in order to prepare for the roll-out of Awaab’s Law to other hazards. It is crucial that every housing provider starts their preparations for these additional requirements now, even though the full details of the extension to the law are not yet available.

For example, PfP is preparing for this by looking at its repairs and maintenance processes for window and door repairs. It is analysing its performance, pinpointing the potential challenges compliance might bring and trying to resolve them now. The key principles which drove PfP’s preparation for compliance with Awaab’s Law’s damp and mould requirements can be used to prepare for these forthcoming extensions. These principles include ensuring that technological approaches are flexible, identifying further training that might be necessary for some of our colleagues and considering proactive approaches as part of our investment plan to drive down the demand for repairs.

• How is Awaab’s Law embedded in my business processes?
• How does my organisation gather evidence to prove compliance with Awaab’s Law?
• What can I do to better understand my customers?
• How can we adapt measures to tackle damp and mould for other health hazards?

Next, answer the questions below. Get all the questions correct and you will receive a certificate confirming your award of 30 CPD minutes within 10 working days via email. Get any questions wrong and you can retake the test by refreshing your web browser.

• Awaab’s Law: Draft guidance for social landlords, Ministry of Housing, Communities and Local Government
• Focus report: Understanding the condition of tenants’ homes
• Housing Health and Safety Rating System (England) Regulations 2005 – Schedule 1, UK government
  

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