Awaab's Law: What is it and what property managers and surveyors must know by October 2025

Guest article written by Ella Green and Kat Cusack at RPC

Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025, which was introduced in section 42 of the Social Housing (Regulation) Act 2023 and is known as "Awaab's Law", is due to come into force on 27 October 2025.  Awaab's Law seeks to ensure safer housing conditions for tenants by holding landlords to account.

It is particularly important for property managers and surveyors to be aware of this legislative reform and to have a plan in place by October 2025. This article therefore sets out the key requirements and steps to be considered.

Background

Awaab's Law is named after two-year-old Awaab Ishak who tragically died in 2020 due to a respiratory condition caused by prolonged exposure to damp and mould in his home, despite repeated complaints from his family and health professionals to the housing association.

The inquest into Awaab’s death exposed flaws in existing legislation and prompted the government to introduce better protection for tenants and hold landlords to account for failing to address dangerous living conditions.

The Law

In February 2025, Angela Rayner, Deputy Prime Minister and the Secretary of State for Housing, Communities and Local Government, introduced Awaab's Law to parliament.

Ms Rayner confirmed that Awaab's Law will come into force for social rented housing from October 2025. She also stated that the government would use new powers in the Renters Rights Bill to extend Awaab's Law to the private sector.

In summary, Awaab's Law seeks to protect tenants from dangerous health and safety hazards including damp and mould, asbestos and domestic and personal hygiene hazards (amongst others). It gives tenants the right to demand repairs to ensure their homes are safe and provides a legal obligation on landlords to investigate and repair health hazards within strict time limits.

Phase 1 – Mould, damp and emergency hazards (From October 2025)

The government will introduce time limits and other statutory requirements on social landlords in respect of mould, damp and "emergency hazards".

An emergency hazard is defined as one that poses "an imminent and significant risk of harm" to the health or safety of the tenant. An ‘imminent and significant risk of harm’ is defined as "‘a risk of harm to the occupier’s health or safety that a reasonable social landlord with the relevant knowledge would take steps to make safe within 24 hours".

The requirements include:

1. Emergency hazards must be investigated and remediated within 24 hours of being reported to the social landlord.

2. Social landlords must investigate reports of damp or mould within 14 days.

3. A written report summarising the findings of the investigation must be provided to the tenant within 48 hours and no later than 14 days after the tenant's complaint.

4. If a hazard is identified which is a significant risk to health and safety, the repairs must be carried out within 7 days of the report being issued.

5. If the repairs cannot be completed within the prescribed time limits, the social landlord must offer the tenant alternative accommodation.

Phase 2 – Expansion of hazards (from 2026)

Statutory time limits will be introduced for other types of "significant hazard" including excess cold, health and hygiene risks, and fire, electrical faults and explosions.

A significant hazard is defined as a "significant risk of harm" to the health or safety of a tenant. A "significant risk of harm" is defined as "a risk of harm to the occupier’s health or safety that a reasonable lessor with the relevant knowledge would take steps to make safe as a matter of urgency".

Phase 3 – All remaining hazards (By 2027)

Awaab's Law will be extended to include all remaining hazard in the Housing Health & Safety Rating System (except overcrowding). This includes (amongst others) protection against accidents and protection from: asbestos and manufactured mineral fibres, biocides, carbon monoxide and fuel combustion products.

Property managers

Awaab's Law will first apply to social housing landlords, but it is expected to be extended to private landlords by the Renters' Rights Bill.

Property managers acting on behalf of landlords should prepare for the upcoming regulation by taking proactive steps now.

Property managers should educate their landlord clients on their obligations under Awaab's Law. Mindful of the order in which the phases are being rolled out, property managers may wish to prioritise those properties where a risk of mould or damp has been identified.

Checks should be made generally to ensure that inspections of all social housing properties have been carried out as required by the lease and if any have been missed, these should take place as soon as possible to minimise the risk of a claim being pursued by the tenants. Property managers should consider increasing the frequency of inspections of properties where there is higher risk of a hazard occurring (such as older buildings) and instruct staff to use pre-prepared checklists to help identify the early signs of damp and mould.

Landlords and/or their managing agents must have appropriate policies and systems in place to ensure oversight of their clients' properties and that they are able to enable their clients to meet the strict statutory deadlines.

This includes implementing a system that allows tenants to report hazards and enables property managers to quickly and easily access these reports and respond to tenants within the required timeframes. Property managers should also make suitable arrangements with reliable surveyors and contractors to ensure they can carry out inspections and emergency repairs expeditiously and in accordance with the deadlines.

The only defence to an allegation of breach is that the landlord used "all reasonable endeavours" to avoid the breach. Proving this this will be fact specific but may include situations such as where the landlord or managing agent has been unable to gain access to a property or obtain the necessary approvals or specialist materials and/or contractors for works. The onus will be on the landlord and may in turn fall to the managing agent if responsibility lies with them under the terms of the property management agreement.

Property managers should keep detailed evidence of their actions and decision making in case they are required to prove that they/the landlord have used "all reasonable endeavours" should a breach of the regulations occur. This includes retaining a comprehensive log of all inspections, actions taken and communications with third parties such as tenants, surveyors and contractors which includes dates and times in order to demonstrate compliance with timescales at each stage.

Surveyors

Surveyors' workload is likely to increase as a result of Awaab's Law and their role will become vital in identifying and reporting on hazards. Therefore, surveyors should educate themselves on landlords' requirements under the legislation.

Surveyors will need to conduct thorough investigations into reports of damp, mould and other hazards. This includes having a good understanding of the Housing Health & Safety Rating System and using modern technology to detect hazards.

Surveyors will also need systems in place to prioritise inspections of "emergency hazards" and to ensure that reports are provided quickly as delays could result in the landlord breaching the statutory time limits.

Good record-keep and comprehensive reports will also be vital for surveyors since a landlord may rely on surveyor's advice if it is accused of breaching the requirements. Thorough reports and notes could also assist surveyors in defending a claim from a disgruntled landlord who has been penalised.

Conclusion

In summary, with Awaab’s Law coming into force from October 2025, property managers and surveyors must act now to ensure that they have robust systems in place for identifying, responding to, and remediating hazards such as damp and mould within strict statutory timeframes. Proactive and thorough inspections, clear record-keeping, and prompt communication will be essential to demonstrate compliance and avoid liability as these new obligations take effect.

This article has been written by Reynolds Porter Chamberlain LLP "RPC" and the opinions and views stated in this article are those of RPC and not Howden Insurance Brokers Limited (“Howden”). Howden is an insurance broker and is not authorised or regulated to advise on the guidance notes regarding Awaab's Law. Howden shall not (i) owe or accept any duty, responsibility or liability to you or any other person; and (ii) be liable in respect of any loss, damage or expense caused by your or any other party’s reliance on this article.