Awaab’s Law Phase 2 arrives on 30 November 2026
For social landlords in England, the second phase of Awaab’s Law marks a significant shift. What started as a response to damp and mould now becomes a much broader duty to deal with serious hazards in the home quickly, consistently and with clear communication to residents.
At Greenstorm, we work with housing providers every day on retrofit programmes across their stock. Here is what Phase 2 means in practice, and how a well planned retrofit journey can help landlords meet their obligations rather than simply react to them.
A quick recap, and what is new in Phase 2
Awaab’s Law was introduced following the death of two year old Awaab Ishak in 2020, linked to prolonged exposure to damp and mould in his family’s social home in Rochdale. Phase 1 came into force on 27 October 2025, requiring social landlords to address damp and mould hazards, along with all emergency hazards, within fixed legal timeframes. Phase 2 goes much further. From 30 November, seven additional hazard categories fall within the same statutory timescales:
- Excess cold and excess heat
- Falls within the home
- Fire and explosions, and electrical hazards
- Domestic hygiene and pests
- Structural collapse and falling elements
A third and final phase is expected in 2027, extending the law to almost every remaining hazard under the Housing Health and Safety Rating System (HHSRS).
What landlords must now do
Where one of these hazards presents a significant risk of harm, landlords must work to fixed deadlines. The clock, and the duties attached to each stage, run as follows:
The only defence is showing that the landlord used all reasonable endeavours. That puts the emphasis on good records, clear processes and evidence that action was taken promptly. Many of these hazards cannot be fixed permanently by a reactive repair. A failed boiler can be replaced, but a poorly insulated, draughty home will keep generating excess cold every winter, and treating damp without addressing ventilation, insulation and heating means the problem comes back. Excess heat is a growing concern too, particularly in flats, top floor dwellings and homes with large areas of south facing glazing. This is where retrofit becomes part of the compliance conversation, not just the net zero one.
How the retrofit journey supports compliance
A whole house retrofit, delivered under PAS 2035, starts with a detailed assessment of the home. That assessment is an opportunity to identify HHSRS hazards early, before they become a resident complaint with a 10 day clock attached. Measures that can directly reduce Phase 2 hazards include:
- Fabric improvements such as loft, cavity, external or internal wall insulation, reducing heat loss and the risk of excess cold
- Heating upgrades including air source heat pumps, efficient boilers and better controls
- Ventilation such as continuous extract fans and positive input ventilation, managing moisture and overheating
- Windows, doors, solar PV and battery storage that cut draughts, improve security and lower running costs
- Electrical works and overheating assessment carried out alongside, so improving one hazard does not create another
Done well, a single planned intervention can remove several hazards from a home at once, and reduce the volume of reactive work landlords face under Awaab’s Law. For a long time, retrofit and compliance have sat in different parts of a housing organisation: retrofit driven by EPC targets and funding windows, compliance driven by repairs data, complaints and regulation. Awaab’s Law brings the two together. A home that is cold, damp, poorly ventilated or running on an unsafe electrical installation is both a retrofit opportunity and a compliance risk.
Retrofit and compliance are the same conversation
Treating a home holistically means one assessment, one plan and one programme of works that improves energy performance and removes hazards at the same time. That approach brings real benefits:
Some of the housing providers we work with have already joined up their retrofit and compliance planning. Rather than waiting for complaints to trigger the clock, they are using retrofit assessments to identify hazards early, prioritising homes by risk, and building hazard reduction into their retrofit specifications from the start. They are not treating Phase 2 as a new burden, but as confirmation that the work they were already doing is the right approach. As Phase 3 approaches in 2027, that head start will matter.
- Fewer repeat issues: fixing the cause, not the symptom, stops the same hazard reappearing every winter
- Better use of funding: retrofit funding targeted at the homes with the highest HHSRS risk, not just the lowest EPC
- Stronger evidence: a documented, planned programme supports a reasonable endeavours position
- Less disruption for residents: one coordinated visit rather than multiple reactive callouts
- Lower long term cost: planned investment reduces the volume of urgent, reactive work
What landlords should be doing now, and how Greenstorm can help
Greenstorm is a national decarbonisation solutions provider, trusted by some of the UK’s leading housing providers, local authorities and energy partners. We deliver the full retrofit journey, from assessment and design through to installation and handover, with a focus on safe, compliant and resident centred delivery. Practical steps to take now:
Review your stock data to know where your highest risk homes are, particularly for excess cold and damp. Align retrofit and compliance teams so assessments and stock condition surveys feed the same picture. Prioritise programmes by hazard, not just EPC. Use available government retrofit funding for the homes most at risk, and strengthen record keeping so evidence of planned improvement supports a reasonable endeavours position.
If you are planning for Phase 2, or thinking ahead to 2027, we would be glad to talk through how a holistic retrofit programme could support your compliance strategy.
