Awaab's Law Phase 2 explained

Phase 1 of Awaab's Law was about damp and mould. Phase 2 is mostly about temperature — and temperature is the one hazard you can see coming.

Awaab's Law was introduced through the Social Housing (Regulation) Act 2023, after the death of two-year-old Awaab Ishak. It places statutory, time-bound duties on social landlords: once a hazard is a significant risk of harm, a legal clock starts. Phase 1 has been live since 27 October 2025. Phase 2 is expected in 2026, and it widens the law well beyond damp.

The headline new hazards — excess cold and excess heat — are the ones a sensor already watches.

When does Phase 2 start?

• Phase 1 — live since 27 October 2025. Emergency hazards made safe within 24 hours; significant damp and mould investigated and acted on to fixed timescales.
• Phase 2 — expected in 2026. Duties extend to a wider range of HHSRS hazards beyond damp and mould.
• Phase 3 — expected in 2027. The law is expected to cover the remaining HHSRS hazards apart from overcrowding.

What Phase 2 adds

Phase 2 brings a broader set of HHSRS hazards into scope, where they present a significant risk to a tenant's health or safety:

• Excess cold and excess heat
• Falls — on stairs, between levels, and around baths
• Structural collapse and explosions
• Fire and electrical hazards
• Domestic and personal hygiene, and food safety

The Phase 1 principle still applies: once a hazard is a significant risk, the clock starts, and deadlines run on working days. What changes is what counts. A failed boiler in winter stops being a routine repair and becomes a potential excess-cold case with a deadline attached. A loose stair rail starts a falls timescale. An overdue electrical check carries exposure it didn't a year ago.

Why Phase 2 is harder

The Phase 1 hazard sat inside a process landlords already had — damp and mould lived in repairs. The new ones don't. Excess cold, structural risk and hygiene failures land across building safety, compliance, asset management and housing officers, not one team. Volumes rise. Several statutory clocks can run at once.

But the harder part is earlier than any of that. It's knowing.

Damp shows itself. It marks a wall, a ceiling, a window reveal — eventually someone sees it or smells it. Excess cold doesn't. A home can sit below a safe temperature for weeks, through a vulnerable winter, with nothing visible and no complaint. And the clock only starts when the landlord becomes aware. If awareness depends on a report, you start the statutory clock already behind the hazard.

Temperature is the hazard you can see coming

Excess cold and excess heat are just temperature over time. A sensor reading every few minutes knows a home crossed the line on the day it did — logged, dated, and impossible to lose. The shift from reactive to proactive that the whole sector keeps naming stops being an aspiration and becomes literal:

• You become aware on day one — the hazard surfaces when conditions appear, not when a complaint arrives, so the clock starts on your terms, inside the window.
• The written summary builds itself — the investigation record the law asks for is the timeline already kept: when the risk appeared, what was done, when it cleared.
• You can triage by vulnerability — the same reading means different urgency in different homes, and continuous data lets you tell a watch from an emergency.

What to do before 2026

• Know which reports start a clock — a cold home or a heating failure now carries a deadline, not just a job number.
• Track every hazard in one place — deadlines run on working days and several can run concurrently.
• Build the audit trail by default — investigation, written summary, works and follow-up on one timeline, ready on demand.
• Instrument for temperature now — it is Phase 2's headline hazard, and the one you can monitor continuously rather than wait to be told about.
• Account for vulnerability — hold who lives where alongside the readings, so triage reflects risk, not just numbers.

The point

Phase 1 taught the sector how demanding a single statutory clock can be. Phase 2 runs several at once — and puts temperature at the centre of them. Damp you find on a wall. Cold you can only find by measuring. The landlords who cope will be the ones who can see the hazard before it's reported, with the evidence already written.

You can't pause the clock. With temperature, you don't have to wait for it to start.