A guide for compliance officers & housing managers
Awaab's Law explained: what does it mean for you?
Awaab's Law came into force on 27 October 2025 under the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025. This page sets out the statutory timeframes, what counts as a 'significant' or 'emergency' hazard, the evidence the Housing Ombudsman expects, and the compensation patterns from the year before commencement.
Phase 1 deadlines
The timeframes, and what each one runs from.
Only the investigation deadline is measured from awareness. Everything after it runs from the day the investigation concludes, and those windows run concurrently rather than one after another. Reading them from the wrong date is the most common way a compliant response is recorded as a late one.
Emergency hazards
Where the hazard poses an imminent and significant risk of harm, it must be investigated and the safety work completed within twenty-four hours. Clock hours, not working days.
Investigate the hazard
A significant damp or mould hazard must be investigated and the investigation concluded within ten working days.
Issue the written summary
The resident receives a written summary of the findings: the hazard identified, the action proposed, and the timeframe for it. It is not required where every necessary work — making the home safe and preventing recurrence — is finished inside the same three days.
Complete the safety work
Where the investigation finds a significant hazard, the work to make the property safe must be completed — not merely started — within five working days. This window runs alongside the three-day summary, not after it.
Supplementary preventative works
Work to stop the hazard recurring must also be begun within those five working days. Where it cannot be, it must start as soon as possible and be physically started within twelve weeks — counted from the same event, not from the five-day mark.
01What is Awaab's Law?
Awaab's Law is the colloquial name for the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025. It came into force on 27 October 2025, introduced by Section 42 of the Social Housing (Regulation) Act 2023, which amended the Landlord and Tenant Act 1985 by inserting new sections 10A and 10B.[1][2]
It is named in memory of two-year-old Awaab Ishak, who died in December 2020 from prolonged exposure to mould in a social housing flat in Rochdale. The coroner ruled that Awaab's death was a direct consequence of his landlord's failure to act on repeated reports of damp and mould.[26]
The law applies to social homes as defined in Regulation 2 of the 2025 Regulations — leases let by registered providers of social housing. It does not yet apply to the private rented sector; that extension is provided for by Section 60 of the Renters' Rights Act 2025 but awaits separate commencement regulations.[1][4]
Phase 1 (in force since 27 October 2025) covers damp and mould hazards and all emergency hazards. Phase 2 (from 30 November 2026) will extend the regime to additional HHSRS hazards including excess cold and heat, falls, structural collapse, explosions, fire and electrical hazards, and domestic and personal hygiene and food safety. Phase 3 (during 2027) will extend it to all remaining HHSRS categories except overcrowding.[18][45]
02The 10-day investigation deadline
Under Regulation 6 of the 2025 Regulations, where a social landlord becomes aware of a potential significant hazard, the landlord must complete an investigation within 10 working days.[5]
The MHCLG guidance is explicit: 'The day the landlord becomes aware of a potential hazard is counted as day zero, with day one of timeframes commencing the following working day.' The clock starts the moment the landlord becomes aware — typically when the tenant first reports the issue, but earlier if the landlord could reasonably have known through inspections, prior complaints, or contractor visits.[19][23]
The investigation must be carried out by a competent person — 'a person with the skills and experience necessary to determine whether the social home is affected by a significant or emergency hazard', in the reasonable opinion of the landlord. The test is skills and experience; the guidance does not require a formal qualification.[17]
Investigations may be conducted remotely or in person. The guidance states landlords 'should make an informed decision on the most appropriate method based on the specific circumstances.' Where the investigation involved no physical inspection and no preventative work has yet begun, a tenant may request one — and Regulation 7 then requires a 'renewed' investigation including a physical inspection to be completed within 10 working days beginning the day after the request. Note the anchor: that second clock runs from the tenant's request, not from the earlier investigation.[19][32]
If the landlord comes to believe the hazard is in fact an emergency, the 24-hour clock in Regulation 5 applies and supersedes the 10-day deadline. It is measured in clock hours rather than working days, and within it the landlord must both complete the investigation and complete any safety work it identifies. It runs from the moment the landlord has reasonable grounds to believe there is an emergency hazard — or, where it is the investigation that identifies one, from the investigation completing.[17][29]
03Written findings: format & deadline
Within 3 working days of completing the investigation, the landlord must provide a written summary of findings to the tenant. This requirement is set out in Regulation 9 of the 2025 Regulations and elaborated in Section 6 of the MHCLG guidance.[6][20]
This window runs concurrently with the 5-working-day deadline for the safety works, not after it. Both are measured from the same event — the investigation concluding — so a landlord who waits for the works to finish before writing to the tenant will usually have missed the summary deadline while still inside the works deadline.[20]
The duty falls away if the job is finished first. The MHCLG guidance states: 'If all required works (both to make the home safe and prevent the problem recurring) are completed to address a significant or emergency hazard before the end of the 3 working day period, a written summary will not be required.' Note how much that exemption asks for: not the safety works alone, but the supplementary preventative works too, all completed inside three working days. It will rarely apply, and a landlord relying on it should be able to evidence the completion date of every element.[20]
The Regulations specify that the written summary must include:
- Whether the investigation identified a significant or emergency hazard, and what the hazard is[20]
- If action is required, what that action is, with a target timeframe for beginning and completing it[20]
- If no action is required, that fact and the reasons why[20]
- Information on how to contact the landlord[20]
The MHCLG guidance is clear that written summaries 'are intended to support respectful and empathetic communication with tenants.' Target timeframes set in the summary are not themselves legally binding, but landlords must take reasonable steps to keep tenants informed about the timing and progress of works.[20]
Summaries can be delivered electronically, in person, by leaving at the home, or by first-class post. The 3-working-day deadline refers to the date sent — not the date received. Landlords are encouraged to keep delivery records.[20]
The Housing Ombudsman's Spotlight on damp and mould report identified the quality of written communication to residents as systemic — call-for-evidence responses showed 'an immense frustration and sense of unfairness' at the information landlords provide about condensation and mould.[27]
04Making safe: 5 working days & the 12-week longstop
Finding the hazard is not the end of the duty. Two further obligations follow the investigation, and both are measured from the day it concludes — the same event that starts the 3-working-day written summary. All three run concurrently, not one after another.[30][31]
Where the investigation identifies safety work in relation to a significant hazard, Regulation 11 requires that work to be completed 'within the period of 5 working days beginning on the day after the day on which the relevant investigation is completed'. Note the verb: completed, not begun. The duty falls away only in defined circumstances — where the work needs a third party's consent and the landlord has exhausted all reasonable endeavours to obtain it, or where a later investigation concludes there is no significant hazard or no safety work to do. Where the landlord instead complies with the temporary rehousing provisions, the work must be completed as soon as reasonably practicable thereafter.[30]
Making a home safe is not the same as stopping the hazard coming back. Work to prevent recurrence must also be begun within those same 5 working days. Where it cannot be, Regulation 13 sets the longstop: it must be physically started 'before the end of the period of 12 weeks beginning with the day after the day on which the relevant investigation … is completed'. The 12 weeks run from the investigation concluding, not from the expiry of the 5 working days — reading it from the 5-day mark quietly awards a week of slack that does not exist.[31]
For an emergency hazard the position is different again: under Regulation 5 the safety work must be completed within 24 clock hours, and the preventative work still carries the 12-week longstop.[29][31]
This is the stage where a compliance record most often falls apart. The investigation date is the anchor for three separate deadlines, so a case file that does not record precisely when the investigation concluded cannot evidence compliance with any of them.
05The reasonable lessor test
Regulation 3 of the 2025 Regulations defines 'significant risk of harm' through an objective test — not the landlord's subjective view:[3]
“A 'significant risk of harm' is defined in the regulations as 'a risk of harm to the occupier's health or safety that a reasonable lessor with the relevant knowledge would take steps to make safe as a matter of urgency.' Note: the full Regulation 3 definition adds '(but not within 24 hours)' — the qualifier that distinguishes significant hazards from emergency hazards, which require action within 24 hours.”
MHCLG guidance, Section 3.2[17]
Three elements matter:
- 'Reasonable lessor' — the standard is what a reasonable social landlord would conclude, not what your individual organisation actually concluded. Pleading 'we didn't think it was that bad' is not a defence.[3]
- 'Relevant knowledge' — the MHCLG guidance defines this as 'the knowledge that the social landlord has, or reasonably ought to have, about the health and circumstances of the occupier.' Pleading ignorance does not lower the bar.[24]
- The test is forward-looking — the assessment is what a reasonable landlord should have concluded on the available evidence, not whether harm actually occurred.[3]
Government guidance emphasises that resident vulnerability is part of the test. A hazard that might not be 'significant' for a healthy adult may well be for an infant, an elderly resident, or someone with respiratory conditions. The guidance is explicit that 'a tenant does not necessarily have to have a specific vulnerability for a hazard to be deemed a significant hazard: some hazards can pose a danger to anyone.'[17][33][24]
The MHCLG guidance also sets out a reasonable endeavours defence under Section 10A(5) of the Landlord and Tenant Act 1985: a landlord has a defence to non-compliance if they prove they took all reasonable steps to comply but were unable to for reasons genuinely beyond their control. The four worked examples given are: awaiting Building Safety Regulator approval, denied tenant access, unavailable specialist contractors, or unavailable alternative accommodation.[22]
06What counts as objective evidence
The 2025 Regulations don't prescribe a single investigation methodology. The MHCLG guidance states that landlords 'should use properly qualified specialists to investigate where relevant,' and that environmental monitoring systems 'help identify early signs of damp and mould.'[17]
“Environmental monitoring systems empower social landlords to take proactive responsibility for the health of their properties and tenants. By continuously tracking environmental conditions, these systems help identify early signs of damp and mould. Risk notifications generated by environmental monitoring systems, indicating the potential for damp and mould to develop, do not, in themselves, mean that a landlord has been made aware of a current hazard. A projected risk is not the same as the actual presence of damp and mould within the property. However, consistent readings that indicate potential issues should prompt timely investigation and intervention, preventing hazards before they escalate.”
MHCLG guidance, Section 3[23]
That passage is quoted in full deliberately, because its second half matters as much as its first. A sensor alert is not, by itself, the awareness that starts the statutory clock — a projected risk is not a present hazard. What the guidance does say is that consistent readings should prompt investigation. So monitoring data earns its place as the evidence that an investigation was warranted and as the record of what conditions actually were, not as an automatic trigger that puts a landlord in breach the moment a threshold is crossed.[23]
The Housing Ombudsman's published case patterns make clear that the evidential bar in contested cases is high. The Spotlight on damp and mould report concluded:[27]
“When there is a problem, effective diagnosis is critical.”
Richard Blakeway, Housing Ombudsman — Spotlight on damp and mould, Foreword[27]
The report's 142-landlord investigation found maladministration against 92 of them — nearly two-thirds. The 56% maladministration rate across 410 cases between 2019 and 2021 indicates that retrospective documentation, visual-inspection-only investigations, and diagnoses unsupported by environmental measurement are routinely upheld as failures.[27]
An investigation that has consistently held up to Ombudsman scrutiny tends to include: continuous environmental measurement (humidity, air and surface temperature) over a meaningful period, an outdoor baseline comparison, photographic evidence paired with readings, documented consideration of resident vulnerability, and an append-only audit trail timestamped at each step.[27]
07Structural vs condensation: legal test
Most damp and mould disputes turn on a single question: is the cause structural failure, or is it condensation arising from how the tenant uses the property? The MHCLG guidance is unambiguous on this point.
“It is unacceptable for social landlords to assume that the cause of a hazard, such as damp and mould, is due to the tenant's 'lifestyle'. Social landlords should not make assumptions and fail to take action or to investigate a damp and mould hazard on the basis of, for example, condensation they attribute to the tenant's 'lifestyle'. It is unavoidable that everyday tasks, such as cooking, bathing, washing and drying laundry will contribute to the production of indoor moisture. These activities are unlikely to constitute a breach of contract on the part of the tenant and, therefore, should not be a reason not to take action through Awaab's Law.”
MHCLG guidance, Section 2.4[25]
A defect in the building envelope: failed damp-proof course, defective render, missing or inadequate insulation, blocked weepholes, roof leaks, defective window seals. The MHCLG guidance specifically identifies these as in scope: 'Where a hazard is caused by a structural defect or deficiency, such as poor design or missing components, the landlord is responsible for addressing the root cause under Awaab's Law. For example, if a damp and mould hazard is found to result from the absence of ventilation or poor insulation, the landlord must take appropriate remedial action.'[17][7]
Moisture generated indoors (cooking, washing, drying clothes, showering) condensing on cold surfaces. The guidance is explicit that this is unlikely to constitute a tenant breach. A property whose ventilation or insulation is inadequate by design IS structurally inadequate, even if the immediate moisture source is the tenant.[25]
The Housing Ombudsman's Spotlight report described the systemic blaming of tenants for condensation as 'an immense frustration and sense of unfairness.' The report's recommendation, reinforced by the 2025 Regulations, is for landlords to 'adopt a zero-tolerance approach to damp and mould' — investigating each case on the evidence rather than starting from a presumption of tenant fault.[27]
08Housing Ombudsman case patterns
The Housing Ombudsman publishes annual data on the determinations it makes. The most recent figures, from the Annual Complaints Review 2024–25, provide a baseline for what enforcement looks like in the year immediately before Awaab's Law commenced.[28]
- Total compensation ordered or recommended: over £5 million across all complaint categories[28]
- More than 40% of that compensation related to handling of leaks, damp and mould[28]
- Largest single order: almost £32,000 in one case in 2024–25[28]
- In 578 cases, compensation orders exceeded £2,000 — 'more than double the average amount' per case[28]
- 71% uphold rate across all determinations[28]
The Ombudsman's 2021 Spotlight report had already reviewed 410 damp and mould cases between April 2019 and March 2021 and found 56% resulted in maladministration. Across the 142 landlords investigated in that report, maladministration was found against 92 — nearly two-thirds.[27]
These figures pre-date the statutory regime that began on 27 October 2025. With binding statutory deadlines now in force, the compensation pattern from 2024–25 represents the floor, not the ceiling, of likely future awards.[22]
09Compliance checklist (PDF)
A printable checklist for compliance officers — drawn directly from the statutory guidance and the 2025 Regulations. Day-by-day actions from awareness through to the written summary, plus the 5-working-day safety works and the 12-week longstop for supplementary preventative works, each shown against the event it is actually counted from.[1][17][21][30][31]
Day zero is the day you become aware. Day one is the next working day.
Open the case on the day the complaint arrives and the deadlines are counted from the right event, automatically.
