Awaab's Law Phase 2 Is Coming: Which Landlords Are Most Exposed

In short

Phase 2 of Awaab's Law starts during 2026. The government has confirmed the year but not yet the month. It adds excess cold, excess heat, fire safety, hygiene hazards (live pest infestations, piled-up waste) and structural collapse to the hazards that trigger the 24-hour and 10-working-day legal deadlines. The landlords most exposed already have weak records on heating, fire safety and structural repair.

How Phase 2 widens the law

Phase 1 (in force from 27 October 2025) covers two categories:

• Emergency hazards, an immediate risk of significant harm: 24 hours to investigate
• Significant hazards: 10 working days to investigate, then 5 working days to finish the safety work once the investigation ends, with a written summary sent within 3 working days of the investigation (that window runs alongside the works window)

Phase 1 was kept deliberately narrow: damp and mould (the original Awaab Ishak case) plus anything meeting the emergency definition. Phase 2 widens it a lot.

New hazard categories in scope from 2026:

• Excess cold. Heating that cannot properly warm living rooms and bedrooms in winter: broken boilers, missing radiators, failed district heating, thermal-comfort failure under HHSRS.
• Excess heat. Poor ventilation, dangerous heat build-up through glass, or no cooling where households are heat-vulnerable.
• Fire safety. Smoke alarms, fire doors, escape routes, cladding hazards, failures in shared areas.
• Hygiene hazards. Live pest infestations, waste that keeps piling up, sanitation failures.
• Structural collapse. Subsidence, dangerous cracking, falling masonry, failing parapet walls.

A landlord told about any of these must investigate within 24 hours (emergency) or 10 working days (significant), finish the safety work within 5 working days of the investigation ending, and send a written summary within 3 working days of the investigation. The summary window runs alongside the works window.

Where the exposure sits

The landlords most likely to be named first in Phase 2 cases combine three things:

1. A weak complaint-handling record already.
2. A specific weakness in one of the Phase 2 categories (often heating or fire safety).
3. Large stock, so reports flow in at volume.

You do not have to guess where your landlord sits. An independent review of complaint-handling for 2024-25 published a list of every landlord whose complaints were upheld at 75% or more, around 120 of them. You can look your landlord up on that list. Landlords already failing the easier Phase 1 standard are the most likely to surface again on the new hazard types.

What is likely to drive the first named case

Three of the Phase 2 categories carry the most risk.

Heating in winter. Excess-cold complaints peak from November to February, and many landlords still have backlogs of boiler upgrades and district-heating work. The most likely first named Phase 2 case: a winter boiler failure filed as "significant" rather than "emergency", then not investigated within 10 working days.

Fire safety in buildings under repair. Many post-Grenfell remediations are still running. While contractors are on site, everyday fire-safety repairs, smoke alarms, fire doors, signage, sometimes slip down the list. A reported fire-safety hazard left for 10 working days during remediation is a strong candidate for a first Phase 2 finding.

Pest infestations. Hygiene cases are the most likely to attract Awaab's Law action AND the parallel Section 82 Environmental Protection Act route. A tenant reporting a live rat infestation after commencement may pursue both: the Awaab's Law breach against the social landlord, and the Section 82 case in the Magistrates' Court against the freeholder.

What tenants should do now

In social housing with a hazard outside Phase 1 that Phase 2 will cover? Build the file now.

1. Send the first written report to your landlord today. Use the words "I am reporting a hazard that I expect to fall within Phase 2 of Awaab's Law from commencement". That puts the landlord on notice and starts the paper trail.
2. Keep dated photos and a diary. Record the hazard week by week. If it gets worse, that is evidence in itself.
3. Get medical evidence early. It matters most in excess-cold and fire-safety cases.
4. Save every response. Acknowledgements, missed inspections, contractor visits that fixed nothing. All of it feeds a later claim. Call us free on 0800 030 4669.

Where Support for Tenants fits

We expect claims to rise as Phase 2 lands and tenants find their landlord missed deadlines on the new hazard types. No upfront cost. You only pay if you win, and the fee comes out of the compensation, not your pocket. If you don't win, you pay nothing. We will give you an honest assessment on the first call.

Read the full Awaab's Law explainer | Free call: 0800 030 4669

Sources: Awaab's Law, National Housing Federation; Landlords with a maladministration rate of 75% or higher, 2024-25, Housing Ombudsman Service.

Support For Tenants is a trading name of Cyntex Group Ltd, authorised and regulated by the Financial Conduct Authority as a Claims Management Company. FRN 1020217. Registered in England and Wales.