Quick answer: Awaab's Law Phase 2 is confirmed for November 2026. Phase 1 (October 2025) covers damp and mould specifically. Phase 2 extends the statutory investigation and remediation timeframes to a wider range of HHSRS hazards — building on the June 2026 HHSRS overhaul which reduced hazard categories from 29 to 21 and introduced biocides as a formal Indoor Air Pollutants hazard. Phase 3 follows in 2027. For contractors on social housing frameworks, Phase 2 means the rapid response, compliant equipment and documentation standards that currently apply to mould remediation will shortly apply across a much wider range of housing hazards.
Awaab's Law Phase 1 has been in force since October 2025. It requires social landlords to investigate damp and mould within 14 days, issue a remediation plan within a further 14 days, and complete emergency mould remediation within 7 days of confirming an emergency hazard. For maintenance contractors on social housing frameworks, those timeframes define the operational standard they must deliver.
Phase 2, confirmed for November 2026, expands the scope of the legislation significantly.
What Phase 2 changes
Phase 2 extends the Awaab's Law statutory timeframes beyond damp and mould to a wider range of hazards under the Housing Health and Safety Rating System (HHSRS). The June 2026 HHSRS overhaul is the regulatory foundation Phase 2 builds on — 29 hazard categories consolidated into 21, with new baseline indicators for each hazard and a simplified High/Medium/Low scoring system replacing the previous A–J bands.
Under Phase 2, hazards currently managed under general landlord repair obligations — including indoor air quality, structural defects, heating failures, excess cold and ventilation failures — are expected to come within the same statutory investigation and remediation timeframes that currently apply only to damp and mould.
The practical implication for contractors is significant: the rapid mobilisation, compliant equipment and auditable documentation that are currently required for mould remediation work will shortly be required for a much broader range of maintenance and remediation tasks across social housing stock.
The Indoor Air Pollutants hazard — biocides in scope
One of the most significant changes in the June 2026 HHSRS overhaul — which Phase 2 builds on — is the reclassification of biocides as a formal housing hazard. Under the revised HHSRS, uncombusted fuel gas, biocides, carbon monoxide and volatile organic compounds are now assessed together under a single Indoor Air Pollutants hazard category.
This means that biocidal products used incorrectly in mould remediation — including products that are misclassified as 'non-toxic' or 'safe' — can now contribute to a scoreable HHSRS hazard in their own right. A High score (Category 1) triggers the local authority's statutory duty to act. From 15 August 2026, updated GB CLP classifications also come into force. See: Biocide labelling compliance → HHSRS 2026 overhaul →
Phase 3 — expected 2027
Phase 3 is expected to extend the requirements to virtually all remaining HHSRS hazard categories, with the exception of overcrowding. By 2027, the statutory timeframe framework will cover the full range of housing hazards assessed under the revised 21-category HHSRS system.
Social housing landlords and their supply chain contractors should be planning now for a framework where the rapid response standards introduced by Awaab's Law Phase 1 apply across the full range of housing hazards by 2027.
What contractors should do before November 2026
- Review framework contract scope — check whether your current social housing maintenance framework contract covers the hazard categories that Phase 2 will bring within statutory timeframes. Gaps in scope could leave the landlord exposed.
- Equipment readiness beyond mould — Phase 2 hazards include heating failures, structural defects and indoor air quality. Equipment readiness for rapid response across a broader range of remediation tasks needs to be in place before November 2026.
- Documentation systems — the documentation standard required to evidence Awaab's Law Phase 1 compliance — equipment used, method applied, completion date — will apply to Phase 2 hazards. Build the documentation habit now.
- Biocide COSHH assessments — review all biocide COSHH assessments before 15 August 2026. The Indoor Air Pollutants hazard classification under HHSRS 2026 makes this more urgent, not less.
Related guidance
Awaab's Law Phase 1 — full guidance for maintenance contractors →
HHSRS 2026 — what the overhaul means for contractors →
Biocide labelling compliance →
Awaab's Law legislation page →
Social housing hub →
H-Class extraction — mould remediation standard →
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