Talking heads: Preparing for Awaab’s Law phase 2

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With phase 2 of Awaab’s Law due to come into effect from October, we asked a selection of housing leaders and subject matter experts to tell us how their organisations are preparing for this important but resource-heavy legislation.

 

Aisha Akhtar, Head of Legal Services, The Guinness Partnership

Phase 1 of Awaab’s Law, introduced on 27 October 2025, has increased accountability in the social housing sector while placing significant operational pressure on landlords. Implementation has been challenging due to tight scheduling requirements, difficulties accessing properties, and extensive documentation demands. Seasonal spikes in damp and mould cases, alongside challenges securing decant properties, have added to the strain. Larger housing associations are generally better equipped to manage these pressures, whereas local authorities often struggle with limited resources and outdated IT systems.

From October 2026, phase 2 will extend statutory response deadlines to a broader range of hazards, including excess cold and heat, fire and electrical risks, falls, structural instability and hygiene-related issues, such as poor ventilation or pest infestations. These changes will strengthen tenant protections but significantly increase compliance obligations for landlords.

Overheating is expected to be a key challenge, particularly in high-rise buildings with restricted ventilation and high solar gain. Persistent issues will require thorough investigation, mitigation and robust recordkeeping.

Landlords should prepare by reviewing housing stock data, updating procedures in line with the Housing Ombudsman’s code, improving digital case management systems, and ensuring staff are trained to capture and respond effectively to tenant-reported risks.

 

James Bradbury, Chief Investment Officer, Stonewater

As providers prepare for phase 2 of Awaab’s Law, the conversation must move beyond damp and mould and towards the wider range of hazards landlords will need to manage. These changes represent a vital step in ensuring customers live in safe, well-maintained homes, while challenging landlords to take a more proactive approach to identifying risks.

At Stonewater, we started preparing well before the legislation came into force. We brought stock condition surveying inhouse, giving us a clearer understanding of our homes and enabling us to identify hazards earlier and respond more effectively. We also established a specialist damp and mould team ahead of implementation, helping us refine processes and strengthen our response capability.

Technology, data and organisational culture will be equally important. As responsibility for a wider range of hazards grows, providers need systems that support faster responses, robust reporting and effective compliance monitoring. Frontline colleagues must also be equipped to recognise hazards and make every visit count.

While phase 2 is a significant milestone, providers must also look ahead to phase 3 and the increasing focus on compliance and building safety. The organisations that succeed will be those that see this not simply as a compliance exercise, but as an opportunity to improve safety, strengthen trust and deliver better outcomes for customers.

 

Nick Atkin, Chief Executive of Yorkshire Housing

The death of Awaab Ishak was a tragedy that should never have happened and must never be repeated. It’s raised expectations across the sector beyond damp and mould, and rightly so.

As we prepare for phase 2 of Awaab’s Law, the focus is rightly widening to cover a broader range of hazards.

The real test now is how that shift translates into day-to-day practice. Getting ready for any legislative change is rarely straightforward, particularly for housing providers managing older homes within tight budgets. Notwithstanding this, the direction is clear: the safety and wellbeing of our customers must come first.

One of the most important lessons from phase 1 is that no two situations are the same. A one-size-fits-all approach rarely works. We need to understand who’s living in each home, their health, their circumstances and how they engage with us, so we can respond in a way that truly works for them.

This is where better use of data becomes critical. At Yorkshire Housing, we’re embracing data and AI to better understand the condition of our customers’ homes, so we can spot issues and act earlier. As a sector, we already hold a wealth of information about our homes and customers. Using that insight effectively will be essential to getting this right.

 

Lysa Nicely, Head of Property and Building Safety, Hexagon Housing Association

Our preparations for phase 2 of Awaab’s Law are focused on hazards: how they’re identified, recorded, escalated and resolved. Awaab’s Law isn’t just about meeting timescales – it’s about recognising hazards early, acting quickly and making safety everyone’s responsibility.

We’re strengthening our core systems, so hazards are clearly recorded, categorised and visible across teams. Enhanced data quality, audit trails and alignment between housing, repairs and compliance systems will create a single version of the truth and support faster, more informed decision-making.

To support consistent delivery, we’re embedding structured workflows within our systems for each hazard. These provide colleagues with clear prompts, defined actions and escalation routes from the point a concern is raised. Alongside this, we’re developing resident-facing literature and templates to ensure our approach is transparent, communication is consistent, and residents understand what to expect when they report a hazard.

We’re also retraining colleagues to strengthen early identification, accurate logging and timely escalation. Hazards must be recognised and acted upon at the first point of contact, regardless of which team receives the report.

Just as importantly, we’re reaffirming accountability. Hazard management cannot sit with one team alone; it must be embedded across the organisation to deliver safe homes and consistent outcomes.

 

Matthew Voyle, Senior Business Development Manager, SFG20 (The Industry Standard for Building Maintenance)

Phase 2 of Awaab’s Law, anticipated for October 2026, is likely to bring a far broader set of HHSRS hazards under statutory timescales and significant challenges for councils: excess cold and heat (which remain tied to tenant vulnerability), falls (one of the most common causes of home injuries), structural collapse, explosions, fire, electrical safety and hygiene risks. Crucially, these aren’t typical ‘repair desk’ issues. Rather, they’ll land with building safety, maintenance and compliance teams.

Councils must consider the practical shift. The hazards detailed in phase 2 will no longer sit in a maintenance backlog. Each case could start a legal countdown for councils, with fixed windows to investigate and remedy the issue.

The new phase could raise a few challenges for councils. First, compliance must be owned at the organisational level, with clear accountability for meeting all statutory deadlines and addressing hazards as soon as they’re reported. Second, asset registers must be accurate and up to date. Without reliable data, councils cannot prioritise risk or factor in tenant vulnerability. Lastly, evidence-gathering needs discipline. Every decision and remediation work must be documented to a standard that can withstand scrutiny from the tenant, the Housing Ombudsman and the regulator.

 

Jesse Meek, Strategic Asset and Property Consultant, Red Kite Community Housing

The first phase of Awaab’s Law focused the sector’s attention on damp, mould and condensation. Phase 2 and 3 demand something broader: a consistent, risk-based approach to identifying and resolving hazards across the full range of property safety issues.

At Red Kite Community Housing, we’ve treated this expansion as a stress test for our wider property risk management – not simply a new compliance requirement. Over the past year, we’ve invested in systems, governance and operational processes that give us greater visibility of cases, clearer accountability and stronger assurance that issues are being managed effectively.

The most important lesson from our preparation? Compliance cannot rely solely on systems or statutory timescales. Success depends on clear triage processes, understanding customer vulnerability, effective contractor relationships and the ability to intervene early – before issues escalate.

As the scope broadens, data quality and operational readiness become critical. Landlords need confidence that hazards are being identified consistently, that risks are prioritised appropriately and that customers receive timely communication throughout. This requires genuine collaboration across housing, repairs, asset management, compliance and customer-facing teams – not just referrals between siloed functions.

For us, phase 2 and 3 preparations are less about creating entirely new processes and more about embedding a proactive, risk-aware culture across the organisation. The legislation sets a higher standard, but the test is practical: are residents living in safe, healthy homes, and are concerns acted upon quickly?

The providers who get this right won’t be those with the most elaborate compliance frameworks. They’ll be the ones who’ve built organisations where identifying and resolving hazards is simply how things work.

 

Nadhia Khan, former Executive Director of Customer and Community at RBH

It’s widely recognised that dealing with the requirements of Awaab’s Law phase 2 are likely to present additional challenges for organisational processes, systems and reporting in having to deal with some hazards that haven’t traditionally been dealt with as part of a repairs service.

The greater challenge, however, comes from ensuring that organisational culture has evolved in a positive way over the last few years so that those working in customer-facing roles are confident in recognising when hazards exist and that they’re proactively taking responsibility for reporting these so that appropriate measures can be taken to guarantee the safety and security of tenants. This will require some significant training but also having up-to-date information about individual households, particularly in respect of any vulnerabilities that might exist and that this information is easily accessible to those delivering services. These were crucial learnings following the tragic death of Awaab Ishak, the little boy after whom this legislation is named, and if as a sector we’re serious about providing warm, safe homes for our tenants, then we have to be sure that the actual delivery of services on the ground match the warm words of our stated strategic objectives around the quality of our homes.

 

Cem Savas, CEO of Plentific

Phase 2 of Awaab’s Law is about more than responding quickly. The real challenge for social landlords is whether they can clearly show how a risk was identified, what information shaped decisions, who reviewed the case and what action was taken. That full evidence trail will be essential for compliance, resident trust and scrutiny from regulators and the Housing Ombudsman.

To meet phase 2 effectively, landlords need to treat data governance as an operational priority. The strongest housing providers will be those able to connect property data, workflows and resident engagement in a single joined-up model. In practice, this means moving beyond isolated reporting towards systems that support earlier hazard detection, clearer triage, faster escalation and stronger audit trails.

Technology has a key role, especially where automation reduces manual handling and integration helps teams act before risks become crises. AI, when built into governed platforms and workflows, can improve operational insight while maintaining control, transparency and data integrity. In regulated sectors like UK housing, the aim should be better decisions, stronger evidence and safer outcomes for residents.

Housing providers that see phase 2 only as a compliance deadline may struggle with the scale and complexity involved. Those that use it as a catalyst to improve data quality, operational coordination and accountability will be far better placed to comply and deliver safer homes.

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