Awaab's Law: Your Questions Answered

Awaab’s Law Phase 2 introduces requirements covering a wider range of hazards, including excess cold and heat, falls, fire and electrical hazards, domestic hygiene, and structural hazards. In our recent webinar, ‘Awaab’s Law Phase 2: What to expect’, our panel of experts answered attendees’ questions to provide practical insights into how these hazards should be identified, how landlords should prepare their teams and systems, and what to consider when meeting the new requirements from 30th November 2026.

Watch the full webinar on demand here.

We received more questions than we could answer during the webinar, so we followed up with a dedicated podcast featuring Jordan Brown, Head of Consultancy, Ben Davidson, Head of Surveying Services, and Stewart Kerr, Principal Consultant.

This blog compiles the key questions and answers from both sessions to provide a practical resource for housing providers preparing for Awaab’s Law Phase 2.

Awaab’s Law investigations and timescales

Q: What is considered an investigation under Awaab’s Law?

A: An investigation under Awaab’s Law can take different forms depending on the information available, and it does not always require a surveyor to visit the property.

For example, if a resident reports that they have no heating or hot water and the cause is already clear, the initial contact with the resident and subsequent repair may form part of the investigation. However, where the underlying cause is unclear, such as with a damp and mould report, a surveyor or appropriately competent contractor may need to visit the property to establish what is causing the hazard.

It is important to note that the person carrying out the investigation must have the appropriate competence and capability for the issue they are assessing. Simply sending someone to the property does not mean an investigation has been completed if they do not have the skills to identify or assess the hazard.

Q: When does the Awaab’s Law investigation timeframe begin?

A: The Awaab’s Law timeframe begins when the landlord becomes aware of a potential hazard, including when an employee or contractor identifies a hazard while visiting a property.

This means organisations need to make sure frontline staff and contractors understand what they must report and how quickly that information needs to reach the appropriate team.

For example, if a housing officer enters a property and identifies visible mould, that information needs to be reported rather than waiting for the officer to return to the office or for another appointment to be arranged.

Q: Have the Awaab’s Law timescales changed for Phase 2?

A: The Awaab’s Law timescales do not change between Phase 1 and Phase 2.

Phase 2 extends the requirements to additional hazards, but the existing timeframes continue to apply. This means organisations need to understand not only which hazards are covered, but also how those hazards will be identified, categorised, investigated, managed, and evidenced within the required timescales.

No access and alternative accommodation

Q:How does no access affect Awaab’s Law deadlines?

A: No access does not mean landlords can simply stop acting, but reasonable attempts to gain access can affect how the requirements apply where access cannot be obtained.

Landlords should make reasonable attempts to gain access using different communication methods, days and times where appropriate. These attempts should be properly recorded, including what was tried and when.

Where access cannot be obtained despite reasonable attempts, landlords need to be able to demonstrate the steps they have taken and continue working towards gaining access. Depending on the circumstances, this may include involving other teams, contacting next of kin where appropriate, identifying support needs or pursuing legal routes to gain access.

The key is to maintain a clear evidence trail. A record showing that repeated attempts were made, rather than simply recording ‘no access’, provides a much stronger basis for demonstrating how the case was managed.

For further expert insights into overcoming no access issues, head over to our dedicated blog, 'No Access and Awaab's Law: Challenges and practical lessons', here.

Q: What evidence should landlords keep when they cannot gain access?

A: Landlords should keep clear records of all attempts to gain access, the communication methods used, the dates and times of attempts, any responses received and the action taken afterwards.

Evidence is particularly important for complex cases because organisations may need to demonstrate not only that they identified a hazard, but also what they did when circumstances prevented them from resolving it immediately.

Awaab’s Law should not be treated as a process where a case can simply be closed because access was refused. Organisations need to show that they continued to manage the risk and took reasonable steps to resolve the issue.

Q: What triggers the requirement to provide temporary alternative accommodation?

A: The requirement to provide suitable alternative accommodation can be triggered when a landlord cannot meet the relevant requirements for addressing a hazard within the required timeframe.

Alternative accommodation needs to be suitable for the individual or household, taking factors such as location, size and circumstances into account. For a short period, this could potentially be hotel accommodation, while a longer-term situation may require more suitable temporary housing.

The fundamental principle is that landlords must either remove the hazard or remove the resident from the hazard where the requirements for alternative accommodation are triggered. 

Understanding Phase 2 hazards

Q: What is classed as excess cold under Awaab’s Law?

A: Excess cold can include circumstances where a home has inadequate heating or insulation, or where the heating system does not allow the resident to adequately control the temperature.

This could include a defective heating system, a lack of insulation or a system that does not allow the resident to control the temperature effectively.

Organisations should consider how the heating system operates in practice rather than simply whether a heating system exists.

Q: What is classed as excess heat under Awaab’s Law?

A: Excess heat can occur where a resident cannot adequately control the temperature of their home, for example because of an issue with the heating system or controls.

Excess heat under Awaab’s Law relates to the condition and operation of the home rather than simply hot weather. A heatwave does not, by itself, mean a property has an excess heat hazard under Awaab’s Law.

Landlords should consider whether residents can control the heating and whether the property is operating as it should.

Q: Does pest control come under Awaab’s Law?

A: Yes. Pest and refuse issues fall within the domestic hygiene hazard covered by Awaab’s Law Phase 2.

The presence of pests does not automatically mean a hazard will meet the relevant threshold, so organisations need to consider the circumstances and the risk presented. Staff visiting properties should understand what they need to report and how concerns should be escalated.

Q: How should food hygiene and personal hygiene hazards be managed?

A: Food and personal hygiene hazards should be assessed by considering whether the facilities required for residents to live safely and hygienically are available and usable.

For food hygiene, this could include whether residents have adequate facilities and space to prepare and clean food. For personal hygiene, this could include access to functioning bathroom, toilet, hot and cold water and other essential facilities.

The challenge can become more complex where a resident's circumstances, vulnerability or the way they use their home affects their ability to use those facilities.

In these cases, landlords should consider the individual circumstances, make reasonable adjustments where appropriate and work with relevant teams to provide support.

Q: What is considered a serious but not immediate fire risk?

A: A serious fire risk can include hazards such as significant hoarding, exposed electrical wiring or defective fire doors that could increase the risk of fire or prevent safe escape.

The exact risk will depend on the circumstances of the property and the hazard identified. Fire safety responsibilities can also overlap with other legislation, including fire safety and building safety requirements.

Where someone identifies a serious safety risk, the focus should be on addressing the risk rather than simply determining which regulatory timeframe applies. Organisations should act as quickly as reasonably possible to keep residents safe.

Q: Are tree roots covered under Awaab’s Law as a trip hazard?

A: Tree roots can be relevant to Awaab’s Law where they create a fall-on-level hazard, but the circumstances of the property and the risk to residents need to be considered.

For example, an exposed tree root crossing a path or driveway may create a clear trip risk. However, a root located elsewhere in a garden may present a different level of risk depending on how the area is used.

Other factors, including the resident's circumstances and any restrictions on the landlord's ability to alter the tree or land, may also need to be considered.

Vulnerability, safeguarding, and resident circumstances

Q: How does Awaab’s Law interact with safeguarding responsibilities?

A: Awaab’s Law does not replace or change existing safeguarding responsibilities, but landlords may need to consider additional support where a resident's circumstances affect how a hazard can be managed.

For example, where hoarding prevents essential repairs from being completed, the organisation should not simply close the case. It should consider what support is available, make appropriate referrals and document the steps taken.

This means the response may need to involve several parts of the organisation, rather than being treated solely as a repairs or asset management issue.

Q: How is resident vulnerability considered differently under HHSRS and Awaab’s Law?

A: HHSRS and Awaab’s Law consider vulnerability differently because HHSRS assesses hazards against defined vulnerable groups, whereas Awaab’s Law considers the circumstances of the individual resident or household affected.

HHSRS uses a defined approach to assess the likelihood and potential outcomes of hazards for a specified vulnerable group. Awaab’s Law is concerned with the circumstances of the actual resident or household living in the property.

This distinction is important when staff are assessing and responding to hazards because an Awaab’s Law case should not simply be treated as an HHSRS assessment.

Q: What happens when a resident’s circumstances affect their ability to heat or use their home?

A: Where a resident's circumstances contribute to a hazard, landlords should still consider what reasonable support or adjustments may be appropriate rather than assuming there is no landlord responsibility.

For example, where a resident cannot afford to use their heating system, replacing the entire heating system would not necessarily be a reasonable response. However, the organisation should consider whether the resident needs support with fuel poverty, income or safeguarding and signpost or refer them to appropriate services.

The key consideration is what the organisation has done to understand the circumstances, support the resident and manage any risk.

Leasehold, shared ownership and landlord responsibilities

Q: Does Awaab’s Law apply to leasehold and shared ownership properties?

A: Awaab’s Law does not change existing repairing obligations, so responsibility for a hazard will depend on who is responsible for the relevant part of the property.

Landlords should establish the root cause of the hazard and check the relevant lease or agreement. If the issue falls within the landlord's repairing responsibility, the landlord remains responsible. If it falls within the resident's responsibility, Awaab’s Law does not transfer that responsibility to the landlord.

This can be particularly important for leasehold properties because repairing responsibilities can vary significantly between agreements.

Systems, evidence, and training

Q: Is there a one-size-fits-all approach to documenting Awaab’s Law cases?

A: There is no single system or technology that every organisation needs to use to manage Awaab’s Law cases.

Organisations can use different systems and approaches, including existing housing management systems, asset systems or other digital and paper-based processes, provided they can capture, access and evidence the information needed.

One of the key challenges is that many housing systems are designed to manage individual repairs rather than the wider case around a resident's hazard report. Organisations therefore need to understand what information they need to capture, identify gaps in their current systems and ensure relevant systems can communicate with one another.

Q: What training should frontline teams receive when triaging hazard reports?

A: Frontline teams need enough awareness and guidance to recognise potential hazards, ask appropriate questions, identify vulnerabilities and escalate cases when necessary.

They do not necessarily need to become technical experts. Instead, organisations should give staff clear guidance, simple tools, internal thresholds and a straightforward escalation route for cases that cannot be confidently categorised.

Training should also be ongoing. Organisations can use real cases and previous categorisation errors to identify learning points, improve questions and strengthen their approach over time.

Everyone who enters residents' homes should understand their responsibility to report potential hazards, not just repairs and asset management teams.

Preparing for Awaab’s Law Phase 2

Q: How should housing providers prepare for Awaab’s Law Phase 2?

A: Housing providers should prepare for Phase 2 by testing their existing processes against the additional hazards, training staff across the organisation and learning from the failures and challenges identified during Phase 1.

Preparation should not be limited to the repairs team. Housing management, contact centres, caretakers, scheme managers, contractors, asset teams and other staff who interact with residents or properties may all play a role.

Organisations should ask:

• Can our systems identify and categorise the additional hazards?
• Do our staff know what they need to report and who they need to tell?
• Can we evidence when a hazard was reported or identified?
• Do we have clear escalation routes for complex cases?
• Do we have enough capacity to investigate and resolve cases within the required timeframes?
• What did we learn from the cases that did not meet Phase 1 timescales?
• Are we monitoring failures and acting on the reasons behind them?

The aim should not simply be to achieve a high compliance figure. Organisations need to understand where things go wrong, why they go wrong and what they are doing to prevent the same issues happening again.

Q: What are the biggest risks for organisations implementing Awaab’s Law Phase 2?

A: The biggest risks are often found in the points between teams, particularly where information about a hazard is not identified, reported or escalated quickly enough.

Organisations should pay particular attention to:

• Staff and contractors who do not recognise their responsibility to report hazards.
• Delays between a hazard being identified and the appropriate team being notified.
• Systems that track individual repairs but not the wider case.
• Unclear escalation routes for complex cases.
• Insufficient evidence showing what action was taken.
• Capacity issues when multiple cases arise at the same time.
• No-access cases where reasonable attempts are not clearly documented.

Testing these areas now can help organisations identify gaps before Phase 2 comes into force.

What does good Awaab’s Law compliance look like?

Q: How should organisations approach Awaab’s Law compliance?

A: Good Awaab’s Law compliance is about understanding and managing risk, not simply achieving a 100% compliance figure.

A strong approach includes clear processes, well-trained staff, accurate records, effective escalation and regular review of cases that did not go to plan.

Organisations should understand every failure, including those caused by factors such as no access, contractor delays or complex resident circumstances. Rather than excluding these cases from performance information, they should be recorded with appropriate context and monitored until the issue is resolved.

The most important question is not simply “Did we meet the timeframe?” but “If we did not, do we understand why, what did we do about it, and what are we changing?”

Awaab’s Law is ultimately about protecting residents from hazards in their homes. Organisations should therefore focus on building services that identify risks early, respond quickly, communicate effectively and learn when things do not go as planned.

If you have questions about preparing for Awaab’s Law Phase 2 or want to understand where your organisation may have gaps, get in touch with our team of experts.