In the second of a series of blogs on new regulations in the homelessness sector, Homeless Link Associate Consultant Becky Elton explains how Awaab's Law impacts supported housing providers.

Awaab's Law is already in force - Phase 1 took effect on 27 October 2025 and Phases 2 and 3 follow in 2026 and 2027. It sets fixed timescales for social landlords to investigate and resolve hazards in their tenants' homes, with tenants able to take legal action if landlords fail to comply.

The Renters' Rights Act 2025 provides for Awaab's Law to be extended to the private rented sector in a future phase, meaning it will eventually apply to all supported accommodation providers. No date has been confirmed for this.

If you provide supported housing, it's worth getting to grips with Awaabs Law even if not all of your accommodation is technically in scope yet. The timescales are tight, the record-keeping expectations are detailed, and the scope of hazards covered is about to get much wider.

Why this matters

In December 2020, two-year-old Awaab Ishak died from a respiratory condition caused by prolonged exposure to mould in his family's social housing flat. His parents had reported the problem repeatedly over several years, but their landlord didn't act and was found to have acted in a “dismissive and discriminatory” way towards residents. Awaab's Law, introduced through the Social Housing (Regulation) Act 2023, is the direct result of that failure.

The law doesn't create new obligations to maintain properties as landlords already had those. What it does is remove any ambiguity about how quickly you need to act. There are now fixed, legally binding deadlines for investigating and resolving hazards, and tenants can complain to the Housing Ombudsman and ultimately take their landlord to court for breach of contract if those deadlines aren't met.

Implementation timeline for social landlords

Phase 1 (from 27 October 2025): Social landlords must address all emergency hazards within 24 hours. “Hazards” are defined in the Housing health and safety rating system (HHSRS). Significant damp and mould hazards must be investigated within 10 working days, made safe within 5 working days of the investigation, and supplementary work physically started within 12 weeks. If the property cannot be made safe in time, the landlord must offer suitable alternative accommodation at their own expense. Landlords must also keep clear records of all attempts to comply, including correspondence with tenants and contractors.

Phase 2 (from October 2026): Requirements expand to cover excess cold and heat, falls, structural collapse, fire, electrical hazards and explosions, and hygiene hazards. The same timescales apply. This significantly increases the volume of repairs subject to a statutory clock.

Phase 3 (from 2027): Awaab's Law will extend to all remaining HHSRS hazards where they present a significant risk, excluding overcrowding.

Who does it apply to right now, and who's next?

This is where it gets complicated for supported housing, because your accommodation doesn't sit neatly in one legal category.

Awaab's Law currently applies to social housing occupied under a tenancy and let by a registered provider. It applies to supported accommodation occupied under a tenancy. It does not currently apply to supported accommodation occupied under a licence, or to accommodation in the private rented sector.

For many Homeless Link members, that means you could have some properties where Awaab's Law already applies and others where it doesn't, depending on the tenure type and who the landlord is. A Registered Provider letting self-contained supported flats on assured tenancies is already in scope. A charity running a hostel where residents occupy under licence agreements is not - yet.

But here's the important point: the direction of travel is clear. Phase by phase, the range of hazards is expanding. The Renters' Rights Act will eventually extend the same requirements to the private rented sector. And even where Awaab's Law doesn't currently apply, landlords still have existing legal duties to keep properties safe and free from hazards. Treating Awaab's Law timescales as good practice across all your stock makes practical sense as it protects residents, it protects you, and it means you won't be scrambling to catch up when the scope widens.

What the timescales actually look like

When a landlord becomes aware of a potential hazard, whether through a resident report, a routine inspection, or a contractor flagging something, the clock starts. The assessment isn't based on a theoretical worst case like a full HHSRS assessment. It's person-centred: you consider the actual tenant, their health, their vulnerabilities, and their circumstances. Damp and mould that might score as a Category 2 hazard under HHSRS could still be a significant hazard under Awaab's Law if, say, the tenant has a respiratory condition or there are young children in the household.

For emergency hazards (anything posing an imminent and significant risk), you must investigate and make safe within 24 hours.

For significant hazards (currently damp and mould; expanding from October 2026), you must investigate within 10 working days, provide the tenant with a written summary of findings within 3 working days of completing the investigation, make the property safe within 5 working days, and start any further remedial work within 12 weeks.

If you can't make the property safe within those timescales, you must offer suitable alternative accommodation at your own cost until it is safe.

The challenges for supported housing providers

Supported housing brings specific pressures that make Awaab's Law compliance harder to deliver, not because the principle is wrong, but because the operating context is more complex.

Mixed property types. Many providers manage a mix of self-contained flats, shared houses, and hostel-style accommodation. The hazards you're dealing with, and how quickly you can fix them, vary hugely across these settings. Resolving a damp problem in a self-contained flat is a different proposition from tackling it in a shared building with multiple residents, communal areas, and potentially limited access to individual rooms.

Contractor access and capacity. Smaller providers often don't have in-house repairs teams. If you rely on external contractors, meeting a 24-hour emergency deadline or a 5-day make-safe window depends on their availability, not just your processes. Building a reliable contractor network and having backup options is essential.

Alternative accommodation. If a property can't be made safe in time, you must offer the tenant somewhere else to stay. In supported housing, that's not straightforward. Your residents may have support needs that mean moving them to a standard temporary let isn't appropriate. You need to think now about what "suitable alternative accommodation" realistically looks like for your client group.

Getting access. In some supported housing settings, getting access to carry out inspections or repairs can be difficult, residents may be may not be available or willing to let you in, or there may be safeguarding considerations. The government guidance is clear that you need to record all attempts to access and comply, and that you have a defence if you've taken all reasonable steps but were unable to complete the work for reasons beyond your control. Good record-keeping is your protection here.

The licence question. If some of your residents occupy under licence rather than tenancy, Awaab's Law doesn't currently apply to those arrangements. But that distinction shouldn't change how seriously you treat hazard reports. Licence holders still deserve safe accommodation, and you still have duties under other legislation. The reputational, safeguarding, and regulatory consequences of ignoring a serious hazard are the same regardless of tenure type.

Cost. Faster response times, more surveying, better record-keeping, alternative accommodation provision, and contractor availability all cost money. There is no dedicated government funding for implementation. For providers already operating on thin margins, this is a real pressure, particularly as Phase 2 significantly increases the volume of hazards in scope.

What should you be doing now?

Phase 1 is live. Phase 2 arrives in October 2026. Even if some of your stock isn't technically in scope yet, now is the time to get your systems and processes ready.

  • Review your current approach to hazard reporting, investigation and repairs against the Awaab's Law timescales. If you're not already meeting them, work out what needs to change - staffing, contractor arrangements, triage processes, record-keeping.
  • Check your contractor contracts to make sure they can deliver within the required timescales and work out a contingency for when they can't.
  • Make sure frontline staff understand the timescales and know how to identify and escalate hazards, particularly as the scope expands beyond damp and mould in October 2026.
  • Get your record-keeping in order. The law requires you to keep clear records of all attempts to comply, including correspondence with residents and contractors. If you can't meet a deadline, a good record of what you did and why is your defence.
  • Think about what suitable alternative accommodation looks like for your residents and how you'd provide it at short notice.
  • Read the government's guidance for social landlords and the HHSRS guidance, and make sure your teams are familiar with both.

Whether Awaab's Law applies to all of your stock today or not, the standard it sets is the right one. Residents in supported housing deserve the same speed and seriousness of response to hazards as anyone else. Getting there early is better than being forced there later.

You can find more detail on Awaab's Law, along with guidance on the other regulatory changes affecting supported housing, on our regulation of homelessness services page.