Awaab's Law requirements and deadlines

The complete breakdown

Understanding Exactly What You Need to Do, When You Need to Do It, and What Happens If You Don’t

When Awaab’s Law comes into force on 27 October 2025, it won’t just change how you handle damp and mould complaints. It will fundamentally alter the relationship between social landlords and tenants, creating legally enforceable rights where previously there were only good intentions.

The word “requirements” might sound bureaucratic, but these aren’t administrative hurdles. They’re promises to families like Awaab Ishak’s that when they report problems in their homes, something will actually happen – quickly.

The Reality Check

Right now, if a tenant reports mould on a Monday, there’s no legal requirement for you to even acknowledge it, let alone fix it.

From October 2025, you’ll have:

10 working days to investigate and report back, or
If it’s dangerous (an Emergency), 24 hours to investigate and make it safe, or find alternative accommodation for the residents.

That’s not just a change in process – it’s a complete transformation of expectations.

The Two-Track System That Changes Everything

Awaab’s Law creates two distinct pathways for dealing with reported hazards – Emergency or Significant – and is now person-centred, requiring landlords to consider the tenant’s health, vulnerabilities, and circumstances.

Getting this distinction right is absolutely crucial. Make the wrong call, and you could find yourself in breach of legal requirements within hours rather than days.

Emergency Hazards – 24 Hours to Investigate and Make Safe

What makes something an emergency?

An emergency hazard isn’t just “quite serious” or “needs doing soon”. It’s something that poses an immediate risk to health and safety that cannot wait.

Examples:

A family with young children reporting extensive black mould covering bedroom walls
Severe damp causing structural damage that could affect building safety
Mould growth so severe it’s causing immediate respiratory problems
Water ingress creating dangerous electrical hazards

The key word here is “immediate.”
If someone could be harmed by staying in the property overnight, it’s probably an emergency.

Your Emergency Obligations:

Within 24 hours: Investigate the hazard and take action to make the property safe
Within 3 working days: Provide a written summary of your investigation and actions taken
If you can’t make it safe: Offer suitable alternative accommodation immediately

Significant Hazards – 10 Working Days to Investigate

The broader category that captures most issues, Significant hazards include anything that poses a real risk to health and safety but doesn’t require immediate action.

This will be the majority of your Awaab’s Law cases.

Typical Scenarios:

Persistent condensation causing mould growth in bathrooms
Damp patches that are worsening but aren’t immediately dangerous
Ventilation problems leading to humidity issues
Early-stage mould requiring professional assessment

Your Significant Hazard Obligations:

Within 10 working days: Complete a thorough investigation of the reported hazard
Within 3 working days of investigation: Provide a written summary of findings
Within 5 working days of investigation: Begin any necessary remedial works
If works can’t begin within 5 working days: Works must physically start within 12 weeks maximum

The Critical First Assessment: Getting It Right from Day One

The most important decision you’ll make under Awaab’s Law happens within hours of receiving a report, not days.

How you categorise that initial report determines everything that follows.

When Someone Reports a Potential Hazard

Immediate response (same day)
You can’t just log the complaint and deal with it next week. You need to review the information immediately and make an initial assessment — is this potentially an emergency or significant hazard?

Example:

Someone calls on Monday morning about mould in their child’s bedroom.
By the end of Monday, you need to have decided whether this needs a 24-hour response or a 10-working-day investigation.

The Evaluation Criteria You Need to Consider

The regulations require you to review the information “against the resident’s specific circumstances.”

Key factors include:

Vulnerability of residents: young children, elderly people, those with respiratory conditions
Severity and extent: how bad the problem is and how much of the property it affects
Location within the property: bedrooms are more critical than storage areas
Immediate risk: could staying in the property overnight cause harm?
Tenant’s description: are they reporting health symptoms or just property damage?

Making the Call

You’ll need clear internal policies and properly trained staff. The decision between emergency and significant hazard has legal consequences.

It is the responsibility of the social housing provider to decide whether the risk is emergency, significant, or falls outside Awaab’s Law consideration.

If an issue was foreseeable, it would be seen as preventable.

Practical approach:
If you’re unsure, treat it as an emergency. It’s better to respond within 24 hours unnecessarily than to take 10 days when you should have taken one.

Investigation Requirements That Actually Mean Something

Let’s talk about what “investigation” means under Awaab’s Law – because sending someone round for a quick look will not suffice.

The Investigation Standard You’ll Need to Meet

Proper Expertise

The investigator must understand:

Different types of damp and their causes
How to identify mould species and health implications
Building pathology and why problems occur
What constitutes a health hazard under HHSRS
How to assess risk based on occupant vulnerability

Thorough Assessment

Investigations must identify the problem, its causes, and how to fix it properly.

They should cover:

Type and extent of hazards present
Root causes (not just symptoms)
Risk level considering the occupants
Required actions to eliminate the hazard
Prevention measures

Proper Documentation

Everything must be recorded.
You need written summaries and supporting evidence for complaints or legal challenges.

The Reality of Investigation Timescales

Ten working days sounds like plenty – until you break it down:

Day 1–2: Arrange appointment with tenant and qualified investigator
Day 3–4: Conduct site investigation
Day 5–7: Analyse findings, determine causes, specify required works
Day 8–10: Write report, review findings, issue to tenant

No contingency is built in – missed access or lab delays must be accounted for in your process. Delay is not acceptable.

Written Reports: What Tenants Actually Need to Know

The written summary isn’t just bureaucracy; it’s a potential legal document used in Ombudsman complaints or court proceedings.

What Your Written Summary Must Include

Clear findings: Explain in plain language
Honest risk assessment: State clearly if there is a health risk
Specific action plan: Detail what will be done, when, and how
Safety advice: Give practical guidance for staying safe

The Three Working Day Rule

You have three working days from completing the investigation to provide the written summary.

If an assessment is completed Wednesday, the written report must be delivered by the following Monday.

Repair Timescales: When “As Soon As Possible” Becomes Legally Binding

Once you confirm a hazard exists, new legal timeframes begin.

For Significant Hazards

5 working days: Work must begin
12 weeks maximum: If work can’t begin in 5 days, it must physically start within 12 weeks
Reasonable time: Work must be completed within a reasonable timeframe

“Begin work” means physical work starting on site, not scheduling or ordering.

For Emergency Hazards

24 hours: Make the property safe OR provide alternative accommodation

You don’t have 24 hours to fix everything – just to make it safe.

Examples:

Immediate professional cleaning and dehumidification for severe mould
Isolating power for damp-related electrical hazards
Temporary structural supports

What “Reasonable Time” Means in Practice

Factors influencing reasonableness:

Complexity of works
Occupant vulnerability
Severity of hazard
Seasonal constraints
Contractor and material availability

Guidance: If you wouldn’t accept the timescale for your own family, it’s probably not reasonable for your tenants either.

What’s Actually Covered: Broader Than You Might Think

Awaab’s Law isn’t limited to obvious mould cases.

Category 2 hazards under HHSRS are included
Communal areas and gardens under landlord responsibility are covered

Examples:

Persistent condensation in communal halls
Mould in shared laundry rooms
Damp in communal storage
Ventilation issues affecting multiple units

Excluded (for now): Cladding and “Acts of God” like flood damage.

Looking Ahead to 2026

The government intends to extend Awaab’s Law beyond damp and mould, aligning it with the Housing Health and Safety Rating System (HHSRS), which covers 29 hazards including excess cold, fire, carbon monoxide, falls, and overcrowding.

Providers putting systems in place now will be well prepared when wider requirements arrive.

Record Keeping: Your Protection and Their Rights

Good record keeping is both your defence and your tenant’s evidence.

What Records You Need to Maintain

Initial Reports and Assessments

Date, time, and method of report
Tenant details and description
Risk categorisation
Decision rationale
Immediate actions

Investigation Documentation

Investigator qualifications
Site reports, photos, and measurements
Findings and analysis
Risk assessments
Recommended remedial actions

Communications and Actions

All tenant correspondence
Proof of written summaries
Contractor schedules and updates
Completion certificates
Alternative accommodation records

Data Protection Considerations

Investigations may involve health data, which is special category data under GDPR.

Key considerations:

Lawful basis for processing
Tenant consent and transparency
Data minimisation
Strong security
Retention limits

Integrated IT systems should also enable cross-referencing with the Pre-Action Protocol for Housing Conditions Claims to show systematic compliance.

What Happens When Things Go Wrong

Awaab’s Law creates real legal consequences for non-compliance.

How Tenants Can Enforce Their Rights

Housing Ombudsman Complaints

Compensation payments
Orders for remedial works
Mandatory staff training or policy changes
Public reporting of failures

Court Proceedings

Breaches may be treated as breach of contract under tenancy agreements

Regulatory Intervention

The Regulator of Social Housing can launch investigations for systemic failure

How to Avoid Enforcement Action

Clear policies and consistent application
Proper training for all staff
Reliable contractor relationships
Ready systems before October 2025

The Essentials You Need in Place

Qualified investigators
Emergency response contractors
Rapid response repair teams
Integrated IT systems

How PfH’s Frameworks Can Help

Through our Compliance Solutions Framework, PfH connects housing providers with specialist contractors ready to meet Awaab’s Law requirements.

Damp and Mould Specialists Ready to Respond

Our framework includes contractors specialising in damp and mould investigation, treatment, and prevention – pre-vetted to meet 10-day investigation requirements.

Find damp and mould specialists here

Awaab’s Law – Additional Resources:

Delivered By

Bradley Hughes – PfH Category Manager for Materials
Ben How – Head of Retrofit and Sustainability, Frankham Group

Frankham Group are one of the top-ranked Damp and Mould surveyors on the PfH Compliance Solutions framework for social housing providers.

About Ben How

Ben How is a qualified surveyor and energy efficiency specialist with more than 15 years’ experience in the construction and housing sectors.

Currently Head of Retrofit and Sustainability at Frankham Group, Ben has also held senior roles as Director of Sustainability and Decarbonisation at Breyer Group and Energy & Innovation Commercial Manager at ENGIE.

His expertise spans retrofit delivery, carbon management, renewable technologies, modular and low-carbon housing, and sustainability strategy.

As a CoRE Retrofit Coordinator and certified Thermographer, Ben combines technical knowledge with commercial acumen, helping clients decarbonise housing stock and implement innovative energy solutions.

About Bradley Hughes

Bradley Hughes, MCIPS, is a seasoned procurement professional with over a decade of experience in public-sector frameworks and supply chain strategy.

As Category Manager for Materials at PfH, he has also managed categories across Fire Safety and Compliance services.

He holds Chartered Institute of Purchasing & Supply accreditation and has led operations that deliver value, efficiency, and compliance at scale.

Beyond his operational role, Bradley contributes thought leadership on sustainable procurement, best practice, and innovation in sourcing, helping clients achieve better outcomes through smarter procurement.