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

Direct answer

Phase 2 of Awaab's Law commences in October 2026. It adds excess cold, excess heat, fire safety, hygiene hazards (active pest infestations, waste accumulation), and structural collapse to the list of hazards that trigger the 24-hour and 10-working-day statutory deadlines. The landlords most exposed are those that 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 (immediate risk of significant harm), 24 hours to investigate
• Significant hazards, 10 working days to investigate, then 5 working days to complete the safety work after the investigation ends, with a written summary sent within 3 working days of the investigation (which runs at the same time as the works window)

Phase 1 was deliberately scoped narrowly to focus on damp and mould (the original Awaab Ishak case) and any hazard meeting the emergency definition. Phase 2 widens significantly.

New hazard categories in scope from 2026:

• Excess cold. Heating that does not adequately warm habitable rooms in winter. Includes broken boilers, missing radiators, failed district heating, and homes with thermal-comfort failure under HHSRS.
• Excess heat. Inadequate ventilation, dangerous solar gain, or absent cooling in heat-vulnerable households.
• Fire safety. Smoke alarms, fire doors, escape routes, cladding hazards, communal fire-safety failures.
• Hygiene hazards. Active pest infestations, persistent waste accumulation, sanitation failures.
• Structural collapse. Subsidence, dangerous cracking, falling masonry, parapet wall failures.

A landlord receiving a report of any of the above will have to investigate within 24 hours (if it is an emergency) or within 10 working days (if it is significant), complete 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 at the same time as the works window).

Where the exposure sits

The landlords most likely to be named first in Phase 2 cases are those that combine three features:

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 there is a high volume of reports flowing in.

You do not have to guess where your own landlord sits. An independent review of landlord complaint-handling for 2024-25 published a list of every landlord whose complaints were upheld at a rate of 75% or higher, and around 120 landlords were on it. You can look up whether your landlord appears on that published list. Landlords already failing on the easier Phase 1 standard are the most likely to surface again on the new Phase 2 hazard types.

What is likely to drive the first named case

In housing-policy terms, three of the Phase 2 categories are particularly exposed.

Heating in winter. Excess-cold complaints peak between November and February. Many landlords are still working through backlogs of boiler upgrades and district-heating retrofits. A reported boiler failure in cold weather that the landlord categorises as "significant" rather than "emergency" then fails to investigate within 10 working days, is the most likely fact pattern for the first named Phase 2 case.

Fire safety in remediated buildings. A large number of post-Grenfell remediations are still in progress. Where remediation contractors are on site, day-to-day fire-safety repairs (smoke alarms, fire doors, signage) are sometimes deprioritised. A reported fire-safety hazard that goes unaddressed for 10 working days during remediation is a strong candidate for a first Phase 2 finding.

Pest infestations. Hygiene-hazard cases are the most likely to attract both Awaab's Law action under Phase 2 AND the parallel Section 82 Environmental Protection Act route. A tenant who reports an active rat infestation post-commencement may pursue both: the Awaab's Law breach against the social landlord, and the Section 82 Magistrates' Court case against the freeholder.

What tenants should do now

If you live in social housing and you have a hazard that is currently outside Awaab's Law Phase 1 but will fall into Phase 2, prepare 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". This puts the landlord on notice and starts the audit trail.
2. Keep dated photos and a diary. Document the hazard week by week. If the hazard worsens, that is itself useful evidence.
3. Get medical evidence early. Particularly important for excess-cold and fire-safety cases.
4. Save every response. Acknowledgements, missed inspection appointments, contractor visits without action. All useful for any later disrepair claim, call us free on 0800 030 4669.

Where Support for Tenants fits

We expect a noticeable increase in disrepair claims as Phase 2 lands and tenants discover their landlord missed deadlines on the new hazard categories. On no win, no fee terms you pay nothing up front, and the solicitor's fee only comes out of your compensation if you win, never out of your own pocket. We will give you an honest assessment of your case 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.