First published in Estates Gazette
On 27 October 2025, the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025, otherwise known as “Awaab’s law”, came into force – aimed at ensuring social landlords investigate and fix hazardous issues in rental properties.
This law follows the tragic story of two-year-old Awaab Ishak, who died from a respiratory condition in December 2020 caused by extensive mould in the one-bedroom flat he lived with his parents.
In short, Awaab’s law requires social landlords to fast-track investigations and undertake relevant work, rectifying emergency hazards (such as mould). Implemented timelines include investigating and beginning safety work on emergency hazards within 24 hours; investigating any potentially significant hazards within 10 working days of becoming aware of them; and beginning or taking steps to begin any further required works within five working days of the investigation concluding, if a significant or emergency hazard is identified.
If steps cannot be taken to begin work in five working days this must be done as soon as possible, and work must be started within 12 weeks. Social landlords must also now produce a written summary of investigation findings and provide this to the named tenant within three working days of the investigation concluding.
It is worth noting that Awaab’s law doesn’t currently apply to the private rented sector, raising questions for many. While it is anticipated the regulations will apply to this sector at some point in 2026, we’re yet to have clarity on when.
Unintended consequences?
In principle, these regulatory standards are difficult to disagree with. However, the industry-wide impact of such legislation may not be immediately obvious.
The pressure on social landlords to deliver new high-quality affordable housing has never been greater. What could be seen as an unintended impact of Awaab’s law is the diversion of the limited and already stretched resource held by social landlords, which may otherwise have been used for new affordable housing, towards existing stock.
While not a direct result of Awaab’s law, the landlord responsible for the mould in Awaab’s case lost the government grant it received for new development. In an official government statement, Michael Gove, housing secretary at the time, explained the decision by stating the landlord would not receive more taxpayer money “until they use the money they already have to improve housing”.
Aside from their own reserves, there is a risk to new-build funding and that can only mean fewer new affordable homes. When one looks at the cases referred to the Housing Ombudsman, damp and mould is still a huge issue and there are major social landlords with cases against them.
If they are large, developing landlords, but their procedures here don’t improve, will grants be withdrawn? What will the overall impact on new development be? Could we see a hidden negative impact on the delivery of the government’s 1.5m new homes target?
Getting your house in order
One concern of the new requirements is how quickly landlords, particularly large landlords, can adapt their procedures to be compliant. In most cases referred to the ombudsman, there is commonly a failure to respond to a complaint. In one case, a stage 1 response to a complaint was replied to after 103 days rather than the three-day requirement in the housing association’s policy. This is not unusual when looking through these cases.
There are often issues in correctly identifying causes of problems, or then instructing contractors to undertake the required works; and it may be difficult to get a contractor to undertake an inspection and works at short notice.
All of this is about communication and systems. There are often poor records evidencing an inspection or the follow-up procedure. If records are poor, it is difficult for a landlord to raise a defence that it took all reasonable steps to comply.
In order to comply with Awaab’s law, it is evident landlords with large housing stock must adopt intelligent IT systems. Housing association officers are often overworked with large caseloads. It is easy to see how an issue can slip through the net without systems which track maintenance issues.
This is also essential for landlords to demonstrate they have done everything they can – for example, they may have problems accessing a property but without the evidence to show this, the landlord will always be on the back foot.
If work cannot be completed in time, then the landlord has to find suitable alternative accommodation for the occupiers while works are completed. There are large waiting lists for affordable housing, so what spare stock will be available to accommodate this need?
To be compliant, social landlords should be proactive in managing their stock to avoid building hazard issues, including identifying properties which need upgrading urgently. They must have a clear system for record keeping, which provides repair and complaint tracking, and ensure communication with customers is clear and regular. It’s also vital to provide staff with proper training to ensure officers are well equipped and educated on the new standards and associated timelines.
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