Part of the VHL Group, Trusted Since 1992
Part of the VHL Group, Trusted Since 1992
Awaab’s Law came into force on 27 October 2025. But if your housing association or local authority has been focused solely on damp and mould compliance, there is a significant expansion coming that directly affects your heating, gas, electrical and structural obligations – and the clock is already running.
Here is what is changing in 2026, what it means for your maintenance and compliance programme, and the practical steps you should be taking right now.
Awaab’s Law is named after two-year-old Awaab Ishak, who died in 2020 from a severe respiratory condition caused by prolonged mould exposure in his family’s housing association flat in Rochdale. His parents had reported the problem repeatedly over three years. Nothing was done.
The legislation, introduced under the Social Housing (Regulation) Act 2023 and enforced through the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025, creates legally binding timeframes within which social landlords must investigate and resolve reported hazards in tenants’ homes.
The legislation, introduced under the Social Housing (Regulation) Act 2023 and enforced through the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025, creates legally binding timeframes within which social landlords must investigate and resolve reported hazards in tenants’ homes.
This is not guidance. It is not best practice. It is law and tenants can now take their landlord directly to court for breach of contract if the requirements are not met.
Since 27 October 2025, all social landlords housing associations, local authorities, and registered providers have been legally required to meet the following timeframes:
Emergency hazards (for example: dangerous electrical faults, major leaks, severely damaged external doors or windows):
Significant damp and mould hazards:
Landlords who fail to comply face legal action from tenants, regulatory enforcement from the Regulator of Social Housing, and in serious cases, unlimited fines.
This is the part that many housing providers have not fully prepared for.
In 2026, the government will extend Awaab’s Law to cover a significantly wider range of hazards including several that sit directly within the scope of mechanical and electrical maintenance contracts. The hazards being added include:
The same mandatory investigation and make-safe timeframes will apply to all of these hazards once Phase 2 comes into force.
For social landlords, this means a boiler failure in an occupied property is no longer just a responsive repair request – it becomes a potential Awaab’s Law emergency with a 24-hour legal clock attached. A gas appliance without a valid CP12, a property running on a failing heating system, an EICR overdue — all of these carry legal exposure that did not exist before October 2025.
Phase 3, due in 2027, will extend the law to all remaining Housing Health and Safety Rating System (HHSRS) hazards, completing the full regulatory framework.
The fundamental shift Awaab’s Law creates is moving social housing compliance from a reactive model to a proactive one. Under Phase 2, waiting for a tenant to report a heating failure and then scheduling a repair is no longer an adequate approach if that failure constitutes a significant risk of harm.
The practical implications for housing associations and local authorities are significant:
Annual gas safety certificates (CP12) must be maintained with zero lapses. Under Phase 2, a property with an expired CP12 and a tenant reporting a heating failure or gas concern is a potential emergency hazard with a 24-hour response requirement. Gaps in your CP12 programme are not an administrative issue – they are a legal liability.
Heating system failures in occupied properties need emergency-level response protocols. If a tenant reports no heating during cold weather and the property contains vulnerable occupants — elderly residents, young children, someone with a respiratory condition — that failure is likely to meet the threshold for an emergency hazard under Awaab’s Law Phase 2. Your response protocol needs to reflect this.
Planned Preventative Maintenance contracts become compliance infrastructure, not just cost control. A boiler that is regularly serviced and inspected is far less likely to fail without warning. A heating system on a PPM programme with documented service records provides the paper trail that demonstrates a landlord’s proactive approach which is exactly what the Regulator of Social Housing will look for in any investigation.
Digital record-keeping is no longer optional. Awaab’s Law requires landlords to keep clear records of all compliance attempts, all correspondence with residents, all contractor visits, and the reasons for any delays. If your records are incomplete, you cannot defend yourself. If your contractor does not provide instant digital reporting, you cannot meet this requirement.
Vulnerability matters. The legislation specifically requires landlords to consider the vulnerabilities of occupants when assessing risk. A heating failure that might be moderate-risk for a healthy adult becomes a potential emergency for an elderly resident or a family with a young child. Your maintenance team and your contractors need to understand and apply this standard.
It is worth being specific about the connection between Awaab’s Law Phase 2 and gas safety, because it is one of the most direct compliance implications for social housing providers.
The hazards being added in 2026 explicitly include explosion hazards and the government’s guidance makes clear this encompasses gas-related risks including leaking pipework, unserviced boilers and appliances that have not been maintained to Gas Safe standards.
This means:
The same logic applies to electrical hazards. Properties with overdue Electrical Installation Condition Reports (EICRs), or where tenants have reported electrical faults that have not been resolved, are exposed under Phase 2 in a way they were not under Phase 1.
With Phase 2 coming into force in 2026 and Phase 3 to follow in 2027, the time to prepare is now not when the first complaint arrives under the expanded framework.
Audit your CP12 compliance across your entire portfolio. Every property should have a valid, in-date Landlord Gas Safety Record. Any gaps need to be addressed immediately – not at the next available appointment slot.
Review your emergency response protocols for heating and electrical failures. Your existing responsive repair SLAs may not be sufficient to meet the 24-hour emergency requirement under Phase 2. Your maintenance contractor needs to be able to respond within those timeframes, with the documentation to prove it.
Check your PPM programme covers all Phase 2 hazards. Planned Preventative Maintenance is the most effective way to prevent Awaab’s Law emergencies before they happen. A boiler that is serviced annually is less likely to fail. An electrical installation that is tested on schedule is less likely to develop dangerous faults.
Ensure your contractors provide instant digital reporting. Written summaries of investigations must be provided to tenants within 3 working days. Your contractors need to issue job reports on completion, not days or weeks later.
Brief your team on vulnerability assessment. Every engineer visiting a social housing property should understand the obligation to flag vulnerability and your back-office team should have a protocol for escalating jobs where tenants have declared a vulnerability.
VHL Mechanical works with housing associations, local authorities, and ALMOs across London to deliver the gas, heating, electrical and planned maintenance services that underpin Awaab’s Law compliance.
Our service model is built around the requirements the legislation demands:
We currently support Hillingdon Council, Christian Action Housing Association, and a number of London-based housing providers with planned and reactive maintenance across their residential portfolios.
| PHASE | DATE | HAZARDS COVERED |
| Phase 1 | 27 October 2025 | Emergency hazards + significant damp and mould |
| Phase 2 | 2026 | Adds: excess cold/heat, electrical, fire, gas/explosion, structural, falls, hygiene |
| Phase 3 | 2027 | All remaining HHSRS hazards (excluding overcrowding) |
If you are a housing association, local authority, or ALMO looking to review your heating, gas or electrical compliance programme ahead of Awaab’s Law Phase 2, our team is available to discuss your requirements and carry out a free site survey.
Malika Khan is Head of Business Strategy, Commercial Systems & Technology at VHL Mechanical, where she leads the commercial systems and compliance technology programme across heating, gas safety, and mechanical maintenance contracts for social housing, local authorities, and commercial estates across London. She works directly with housing associations, ALMOs, facilities managers, and procurement teams on the operational systems that underpin Awaab’s Law readiness, CP12 compliance, and SLA-backed delivery.
VHL Mechanical is a Gas Safe registered, ISO 9001 certified contractor based in Harrow, serving social housing providers and commercial clients across Greater London. We are approved to operate under multiple social housing procurement frameworks.
Areas We Cover
West London: Ealing, Hillingdon, Uxbridge, Harrow, Wembley, Brentford, Acton, Southall, Hayes, Ruislip
North London: Barnet, Enfield, Haringey, Islington, Camden, Hampstead, Finchley, Edgware, Tottenham
Central London: Westminster, Kensington, Chelsea, Mayfair, Paddington, Marylebone, Pimlico, Waterloo, Lambeth
East London: Ilford, Stratford, Hackney, Tower Hamlets, Romford, Barking, Walthamstow
South London: Croydon, Bromley, Lewisham, Greenwich, Wandsworth, Merton