CPD: Awaab’s Law Phase 2, why competence is crucial

Following the initial phase of Awaab’s Law coming into force on 27 October 2025, a new statutory duty was placed on social housing providers to investigate and repair damp, mould and emergency hazards within strict timeframes.

Introduced through the Social Housing Regulation Act 2023, the legislation was named in memory of two-year-old Awaab Ishak, who tragically died in 2020 of health complications linked to prolonged exposure to household mould.

Its purpose is to deliver safer, healthier homes through a legal framework that directly affects project specifications, management of remedial works and the shared responsibilities of clients, consultants and contractors.

CPD for the first phase of Awaab’s Law can be found here.

From November 30 2026, the scope of that initial legislation will encompass other serious hazards such as excess cold or heat, falls, structural collapse, fire safety, electrical risks and hygiene issues.

And from 2027, the government plans to extend Awaab’s Law to the remaining Housing Health and Safety Rating System (HHSRS) hazards, excluding overcrowding, where they meet the statutory definition of a significant or emergency hazard.

From the end of November, Awaab’s Law will be extended to cover the following additional hazards where they present a significant risk of harm to occupants:

By bringing these hazards into the scope of Awaab’s Law, the legislation will help deliver safe homes for residents.

While some issues such as structural collapse, falls, electrical hazards and fire have an obvious risk of injury, others are less clear.

Living in a cold home can have a significant impact on health, particularly for those with existing health conditions. The death rate rises about 2.8% for every degree Celsius drop in the external temperature for those living in the coldest 10% of homes.

Conversely, heat stress can exacerbate underlying illnesses, including cardiovascular disease, diabetes, mental health and asthma, and can increase the risk of accidents and transmission of some infectious diseases.

Likewise, domestic hygiene includes pest control, which plays a vital role in preventing the spread of pathogens and bacteria.

The legislation means that when social landlords become aware of a potential hazard, they must use all available information to determine if the problem is potentially a significant or emergency hazard and, if so, complete an investigation within specific timeframes.

In most cases, the countdown will start from the day after the landlord has become aware of a potential hazard.

However, in the case of an emergency hazard, landlords must investigate and undertake relevant safety work within 24 hours of becoming aware of the issue, rather than necessarily completing all permanent repairs within that period.

Housing associations are expected to act quickly according to the circumstances, with Awaab’s Law setting out the maximum timeframe for resolution.

The timescales also vary geographically. In England, potential significant hazards should be investigated within 10 working days. A written summary of findings should be provided within three working days, and issues made safe within five working days of the investigation concluding.

Landlords must begin, or take steps to begin, supplementary preventative works within five working days of the investigation concluding.

Where it is not reasonably practicable to start the physical works within that period, they must begin as soon as possible and no later than 12 weeks after the investigation concludes.

Where a landlord cannot make a property safe within the required timeframe, they must offer suitable alternative accommodation to the affected residents until it is safe for them to return.

In Scotland, reports of damp or mould should be investigated within 10 working days, with a written summary provided to the tenant within three days of the investigation’s completion.

Any necessary repairs should commence within five working days and be completed within 20 working days of commencement.

For social landlords in Wales, hazards with an assessed likelihood of imminent harm should be investigated within 24 hours and remedied within a further 24 hours.

Hazards with no assessed likelihood of imminent harm should be investigated within 10 working days and remedied within a further five working days.

If, despite best endeavours, the hazard cannot be remedied within the time scales, a written summary plan should be produced within five working days.

While urgency is key to ensuring hazards are removed from homes in a timely fashion, meeting deadlines should not take priority over lasting solutions.

Competence is crucial. Simply removing visible mould growth will not necessarily deal with the problem.

Exposure to damp and mould can adversely affect health through mould spores, allergens, irritants and other biological contaminants associated with damp environments.

Effective remediation must therefore address both the existing mould contamination and the underlying moisture conditions that allow it to develop.

Residents are more likely to have respiratory problems as a result of living continuously in damp, poorly ventilated conditions, and these conditions are almost always signalled by the presence of mould.

Understanding the root cause of the issue informs appropriate remediation. A structured assessment of the building fabric, ventilation provision and patterns of occupation should follow the processes set out in BS 5250 and the JPS22, resulting in a full property report, prepared by a competent surveyor.

Trained and qualified professionals should be tasked with distinguishing between condensation, penetrating damp and rising damp, and identifying whether timber has begun to decay or shows signs of insect activity.

When excess moisture becomes trapped in a property, the best outcomes are normally achieved through a combination of measures including heating, insulation and ventilation.

In this instance, remediation may include repair of defects that emerge in service, upgrades to ventilation where performance in use is below design intent, insulation improvements at cold spots and correction of rainwater disposal.

Drying out periods may be required and hidden timbers should be inspected if there is suspicion of ongoing decay. Monitoring can confirm that relative humidity and internal temperatures are within a healthy range.

Where a fault within the fabric of the property is the cause of mould growth, the problem will need to be assessed on a case-by-case basis.

Meeting deadlines should not take priority over lasting solutions. There are growing concerns around how effectively Awaab’s Law is being put into practice, with professionals hearing too many examples of mould simply being cleaned rather than the underlying causes of dampness being properly diagnosed and resolved.

Pressure to meet timescales has led some housing associations to bring specialist services in-house, sometimes without the necessary technical expertise or experience.

Ineffective diagnosis and remediation can allow underlying problems to persist, putting tenants at risk and making further works in the future unavoidable.

Damp and moisture specialists have the right expertise in place that ensures timely action, avoids repeat costs and reduces the risk of statutory deadlines being missed.

If landlords fail to appoint competent specialists, they remain responsible for non-compliance under Awaab’s Law.

Opting for swift, easy repairs over a detailed, expert assessment can result in a range of consequences.

If the root cause of the issue isn’t dealt with, the problem will likely continue to return, increasing costs and potentially affecting relationships with residents, as well as possibly putting tenants’ health at risk.

Demonstrable technical competence is essential when investigating and remediating housing hazards.

The Property Care Association’s Certificated Surveyor in Timber and Dampness in Buildings (CSTDB) qualification is designed to test not only theoretical knowledge, but also practical understanding, diagnostic reasoning and professional judgement – going significantly beyond a simple multiple-choice assessment.

Candidates must undertake three written examinations, two professional interviews and a timber identification assessment – and that level of scrutiny is intentional.

Consumers are reliant on surveyors to diagnose complex issues within people’s homes, often involving health concerns, significant expenditure and difficult technical decisions.

In many cases, the difference between condensation, penetrating damp, structural moisture movement or timber decay is not always straightforward. A qualification process should reflect that complexity.

The PCA’s view is simple: competence matters. A surveyor should not only understand building moisture in principle, but also be able to explain their reasoning, justify recommendations and demonstrate a broad understanding of buildings, defects and remedial options.

Ultimately, higher standards are not a barrier to the industry; they are part of protecting consumers and improving confidence in the sector.

Awaab’s Law must deliver safer, healthier homes, not simply faster repairs.

James Berry is chief technical officer at the Property Care Association (PCA)