Implementing Awaab’s Law: The Opportunities And Challenges

INTRODUCTION  

The Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025, known as Awaab’s Law represents a significant shift in the regulatory environment for social housing providers in England. A law named after two-year-old Awaab Ishak who tragically died in 2020 after exposure to damp and mould in his home.  

The purpose of the law is to ensure that tenants live in safe, healthy homes, free from hazards. Implementation is phased over three stages, with the first phase as of 27th October 2025, the second phase in 2026 and the third phase in 2027. The phases are as follows:  

• Phase 1: All emergency hazards and all damp and mould hazards 
• Phase 2: Hazards where they present a significant risk of harm (excess cold and excess heat, falls, structural collapse and explosions, fire and electrical hazards, domestic and personalhygieneand food safety)  
• Phase 3: All remaining Housing Health and Safety System (HHSRS) hazards apart from overcrowding 

Last week, MHCLG released the guidance for social landlords. Our review of the guidance shows that it aligns with the consultation released in June this year as well as providing some clarity on the phased roll out.  

IMPLEMENTING AWAAB’S LAW  

Awaab’s Law requires social landlords to investigate and address hazards within strict statutory timeframes. The legislation mandates that landlords must respond to complaints, carry out investigations, and complete necessary repairs within clearly defined periods. This also requires adjusting the approach when the hazard poses a significant risk to a vulnerable resident.  

On the face of things, Awaab’s Law is relatively simple with key changes to already improved damp, mould and emergency processes. It also benefits from detailed guidance to ensure that there is consistency across delivery for all social tenancies. However, in a practical sense, it switches elements of responsive repair from being a transactional service to a deeper, case management process. It also moves damp, mould and emergency processes into the world of compliance, likely cross cutting operational responsibilities and reporting. 

Complying with Awaab’s Law has been made challenging because the final guidance was published just 10 days before implementation.  

Key challenges in delivering Awaab’s Law include:  

• Systems capability – the switch from transactional responses to a case management approach for damp, mould and emergency repairsrequired. 
• Training,resourcingand recruitment – with the period between consultation, June 2025, and implementation of October 2025, organisations have struggled to meaningfully recruit additional resource and deliver training during the summer months.  
• Data – without a sufficient period of testing, some organisations are yet toestablishthe quality of data generated as a result of the changed process.  

Alongside this, for some organisations bureaucratic sign off processes for policy, process and system change means that there has been a time lag to delivery.  

ASSURANCE OF DELIVERY  

For leaders, executives, Boards and Lead Members, it is important that they seek continual assurance on meeting the requirements of Awaab’s Law to implementation. Unfortunately, day one of implementation will not result in full compliance for most organisations so leadership should prepare to challenge and scrutinise delivery over the next months and years. Leaders may want to draw on their experiences with implementation of the Housing Ombudsman Complaint Handling Code as way of monitoring delivery.  

Performance reporting should start to be developed at a very early stage, leaders will want to understand firstly what performance reporting is telling them about implementation, then utilise information for lessons learned and finally have a long term plan to use data outcomes to better understand their stock.  

THE OUTCOMES OF THE CHANGES  

Awaab’s Law ultimately seeks to ensure that tenants live in safe, healthy and hazard free homes, it also seeks to standardise the sector response to hazards. This enables tenants to have clarity on what they should be able to expect from their landlord, which is supported by accountability through a complaint’s procedures, the Housing Ombudsman Service and housing conditions claims.  

There may be other unintended outcomes of Awaab’s Law, which may include claim farming and a lack of capacity across the sector to respond. I will personally be interested to see how in delivering against Awaab’s Law organisations are able to address root causes of damp and mould across homes or whether the approach will develop a cycle of reporting and re-reporting for tenants.