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Awaab’s Law Phase 2 and HHSRS 2026: Are You Putting Tenants First?
Awaab’s Law Phase 2 and HHSRS 2026: Are You Putting Tenants First?
by Elizabeth Blend

News
by Elizabeth Blend

Housing legislation seldom stays static for very long these days. Certainly, over the last few years, there have been substantial changes in regulation of the sector, with Awaab’s Law, then the Renters’ Rights Act and most recently the long-awaited update to the Housing Health and Safety Rating System (HHSRS). This pace looks set to continue.
It would seem that housing associations and social housing providers are not all aware of the substantial nature of the changes to the HHSRS that came into effect in June 2026. Many incorrectly think that it won’t affect them, but increasingly, housing legislation is interlinked, and the HHSRS is no different. It is a fundamental building block that is directly referenced and underpins many other parts of housing legislation and regulation, not least the Decent Home Standard and Awaab’s Law, both of which are of great focus for social housing providers.
While the revised HHSRS of 23 June 2026 has not altered the underlying principles or core methodology for the assessment of risk within a dwelling, it has still introduced considerable changes, among which are alterations to the terminology around assessments and the banding used, the way they can be communicated to others, the prescribed hazards themselves and the introduction of baseline indicators as an additional factor in helping to identify deficiencies and potential hazards within a dwelling. For users of The Housing App, you may have already noted that these updates have been made and integrated into our inspection and hazard assessment digital tool, but if you want to know about the changes to HHSRS in more detail, why not also visit our HHSRS Hub, where you’ll find our recent in-depth articles and blogs as well as our free HHSRS calculator tool.
Over the last few years, it has been encouraging to see an increasing number of social housing providers recognising the need to ensure their employees understand what the HHSRS is and to facilitate training for some to be certified as competent to carry out full HHSRS assessments. It is a great way to build into an organisation’s culture a general understanding of why the quality and condition of our housing is important and helps to harness it as a proactive tool for individual properties, as well as at a strategic planning level. However, baked into the HHSRS is the expectation that assessors maintain up-to-date knowledge on the latest guidance and the system itself. Now’s the time, with these changes in force, to check and ensure – certainly for anyone carrying out HHSRS assessments – that they have the updated knowledge of these changes in order to maintain their competency to carry out assessments. If you are responsible for conducting housing inspections and think you may need training on the HHSRS updates, our e-learning Transition Training Course may be of interest.
At the start of this article, we touched on the dynamic nature of housing legislation these days. Less than a month after the HHSRS updates came into effect, there is confirmation from government of the next change on the horizon: Phase 2 of Awaab’s Law will be introduced on 30 November 2026, with the laying of the Hazards in Social Housing (Prescribed Requirements) (England) (Amendment) Regulations 2026.
While we were always aware that Phase 2 would be introduced at some point this year, the confirmation of the date really sets the pace for social housing providers to prepare for this next stage. The announcement being so soon after the HHSRS update is likely not coincidental; it is of course feasible that Phase 2 was planned to follow the implementation of the HHSRS review, given how closely linked the two pieces of legislation are. Awaab’s Law directly references the HHSRS and the prescribed hazards, so it makes sense that Phase 2 was paused until this was done first. As such, from 30 November, nine further hazards come under the prescribed timescale requirements where they are a ‘significant hazard’ (where they are an ‘emergency hazard’ they already fall under the requirements). The additional nine are as follows: Excess Cold; Excess Heat; Falling on Stairs etc; Falls on the Level; Falling Between Levels; Structural Collapse and Falling Elements; Fire and Explosions; Electrical Hazards; and Domestic Hygiene.
It’s not just a longer list of hazards with the advent of Phase 2; the government has also taken on board stakeholder feedback regarding the introduction of Awaab’s Law over these last 8 months, since 27 October 2025. (They had built in an allowance for a learning period into the phased approach.) Consequently, it has now published an updated version of its guidance for social landlords, with significant additional information for landlords. In particular, the guidance now has:
A new section clarifying expectations around communication with tenants
An expanded section on awareness, triage and categorisation of hazards – particularly helpful are the additional prompt questions provided for landlords to use with tenants, to help with triage
Greater guidance and clarity around access
Provision of a draft written summary template
A new section specifically about fire safety
A new section providing timeframes for example scenarios.
In addition to the update to the existing guidance, the government has also published an annex with guidance on triaging hazards. In this annex, each hazard has:
A clear definition
Links to relevant additional resources or guidance for that specific hazard
Information on what a ‘reasonable landlord’ might consider significant, emergency or out of scope
Information on factors relevant to the vulnerability of a tenant
Specific prompt questions for that hazard, and
Example scenarios.
This annex could be seen as the Awaab’s Law equivalent of Part 2 of the HHSRS operating guidance, something that is regularly referred to in every case when making decisions throughout the Awaab’s Law process.
Given that Awaab’s Law has been in effect for the last 8 months, most social landlords should already have their policies, procedures and systems in place. This updated and additional guidance offers reassurance that they have everything covered, or, if not, an opportunity to improve processes and responses.
For local authority colleagues who subscribe to RIAMS, there are a number of procedures and guidance documents covering both the HHSRS and Awaab’s Law, as well as the Renters’ Rights Act and other housing legislation, all easily accessible from the Housing library.
With all these updates in quick succession, it can be easy to lose track of the changes and requirements. Our HHSRS and Awaab’s Law: Essential Training for Social Housing Professionals can help if you need to become proficient with the requirements.