Awaab’s Law Phase 2: Very important regulatory changes social landlords may have missed

The publication of the amended Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025, which come into force on 30 November 2026, has understandably focused attention on the expansion of Awaab's Law to a wider range of hazards. However, a closer review of the regulations reveals several important legal changes that have received remarkably little public attention.

While much of the sector messaging has focused on the addition of new hazard categories, social landlords should be aware that the amendment regulations go further than simply widening the scope of Awaab's Law. They also alter some of the key legal definitions underpinning the regime. 

1. The definition of a 'significant hazard' has changed

One of the most significant amendments has been largely overlooked.

Under the version of the regulations coming into force on 27 October 2025, a significant hazard was linked to a risk that a reasonable person with relevant knowledge would:

‘take steps to make safe as a matter of urgency (but not within 24 hours)’. 

From 30 November 2026, that wording is replaced with a new test:

‘make safe within 15 working days (but not within 24 hours)’. 

This is more than a drafting change.

The original definition relied upon a relatively subjective assessment of what constituted a matter of urgency. The amended wording introduces a much more objective benchmark based on a defined timeframe. 

In practice, landlords may find that the question becomes:

• Would a reasonable landlord make this safe within 24 hours?
  • If yes, it is likely to be an emergency hazard.
• Would a reasonable landlord make this safe within 15 working days?
  • If yes, it is likely to be a significant hazard.

This shift could have important implications for triage processes, record keeping and evidencing categorisation decisions. 

2. The definition of an ‘emergency hazard’ has also changed

A smaller but still notable amendment has been made to the emergency hazard definition.

The previous wording referred to a reasonable person who would:

‘take steps to make safe within 24 hours’.

The amended regulations remove the words:

‘take steps to’. 

The legal test is therefore now framed around whether a reasonable landlord would actually make the hazard safe within 24 hours. 

This mirrors the change to the significant hazard definition and creates a more clearly defined distinction between 24-hour and 15-working-day hazards.

3. Phase 2 expands the hazards within scope

The headline policy change remains the extension of Awaab's Law beyond damp and mould.

From 30 November 2026, significant hazards will also include those associated with:

• Excess cold
• Excess heat
• Domestic hygiene
• Falls on level surfaces
• Falls on stairs and ramps
• Falls associated with baths
• Electrical hazards
• Explosions
• Structural collapse and falling elements. 

This represents a substantial widening of the regime and will require many landlords to revisit their existing repairs categorisation frameworks. 

For many organisations, cases previously managed solely through repairs policies may now need to be assessed through an Awaab's Law lens.

4. Fire hazards are not being brought fully into Awaab's Law

One of the more surprising changes in the amendment regulations is the introduction of the concept of an ‘excluded fire hazard’. 

The regulations specifically exclude certain fire hazards where the risk arises from parts of a building already regulated by the Regulatory Reform (Fire Safety) Order 2005. 

These can include:

• Common parts
• Building structure
• External walls
• Certain doors between flats and common parts. 

This appears designed to avoid overlap between Awaab's Law obligations and existing fire safety legislation. However, landlords should be careful not to assume that all fire-related hazards sit outside the regime. Detailed legal review of individual cases may be required. 

5. Awaab's Law timeframes remain largely unchanged

Despite the amended definitions, the core statutory process remains broadly the same.

Landlords must still:

• Investigate significant hazards within 10 working days.
• Provide findings within 3 working days.
• Complete relevant safety works within 5 working days of concluding the investigation.
• Investigate and make safe emergency hazards within 24 hours.

Accordingly, the amendments do not create an additional repair period. Rather, they use the concept of 15 working days within the legal definition of a significant hazard itself. 

Why landlords should pay attention

In our view, the most important takeaway is not the addition of cold, heat, falls or electrical hazards. It is the fact that the amendment regulations have fundamentally altered the legal test used to determine whether a hazard is ‘significant’. 

Surprisingly, this definitional change has received relatively little attention within sector briefings, webinars and updates, which have tended to focus on the expansion of hazard categories. While the new hazards are important, the revised wording may ultimately have a greater impact on operational decision making, case triage and legal defensibility. 

What landlords should do now

Before November 2026, social landlords should consider:

1. Reviewing hazard triage frameworks.
2. Updating Awaab's Law policies and procedures.
3. Revising staff training materials.
4. Reviewing repairs categorisation matrices.
5. Updating legal compliance and audit documentation.
6. Ensuring contractors understand the distinction between 24-hour and 15-working-day hazards. 

The sector has understandably concentrated on the arrival of Phase 2. However, landlords would be well advised not to overlook the quieter but potentially more significant amendments embedded within the regulations themselves. 

For more information, please get in touch or visit our Awaab's Law Hub.