Awaab’s Law was named after Awaab Ishak, a two-year-old boy who died in December 2020 from a respiratory condition linked to prolonged exposure to mould in his rented home. The new law is being delivered in three phases. It went live for the social housing sector and its supply chain in October 2025 and, on 30 November 2026, Phase 2 comes into effect. This second phase goes beyond damp and mould extending to a wider range of hazards including excess cold, excess heat and falls. Unlike the initial emergency hazards, these new Housing Health and Safety Rating System (HHSRS) hazard categories are far more likely to be rooted in the fabric of the building itself and, for many social housing landlords, this is a cause for concern as confidence in their readiness remains low.
CONFIDENCE GAP
Research from Housemark reveals a confidence gap with just 4% of social landlords describing themselves as “very prepared” for the expansion of Awaab’s Law Phase 2. The data, collected in May 2026, found that while landlords consider themselves somewhat prepared, more than a quarter (27%) are unprepared to some degree. While the findings suggest the social housing sector is making progress in responding to Phase 1 (80% of landlords agree they have invested in the skills and capacity to deliver Awaab’s Law effectively), Phase 2 presents a different challenge, shifting the focus from operational delivery to asset performance and management.
DEFINING DEFICIENCIES
The HHSRS Operating Guidance states that anything less than a baseline indicator – building measures designed to address common health related housing deficiencies found across the housing stock – is a deficiency. It says: ‘A deficiency occurs when any element of the building fabric fails to meet the optimum condition or baseline indicator for that element to prevent, avoid or minimise risk from a hazard. What is the optimum will vary over time...Deficiencies may be due to the design or construction of the building, its age, modification, or lack of maintenance over time.’ This immediately calls stock condition and specification standards into question.
BUILDING IN COMPLIANCE
Appropriate product specification is vital for eliminating risk and achieving long-term compliance. Many of the Phase 2 HHSRS hazard categories – excess cold, excess heat, falls and security – are, for example, linked to fenestration products. In fact, the HHSRS assessment uses a window as one of its primary working examples when scoring a fall hazard. Cold bridging at a tired window frame, or a failed sealed unit, will appear on the same damp and mould report each winter if left unchecked. However, a like-for-like replacement may be a missed compliance opportunity. Replacing a failed window with another poorly specified one may resolve the immediate issue, but it does nothing to stop it recurring, or to guard against other Phase 2 hazards.
PRIORITISE SPECIFICATION
Specification decisions made years, even decades ago, are quietly driving a lot of today’s hazard reports. To fully comply with Awaab’s Law, registered providers must prioritise window and door specification as a compliance priority and part of an overall asset management strategy. In practice, this means using the correct glass specification and adequate openings to manage excess heat, implementing restrictors and PAS 24 multi-point locking systems for fall prevention and security, and balancing U-values with trickle ventilation to combat excess cold and condensation. The sector has proved it can move fast on process. Phase 2 asks a different question: whether the buildings themselves are ready. Closing that specification gap now, rather than discovering it hazard by hazard or during the 10-day investigation window, is the only way to safeguard residents and achieve long-term compliance. To make the move from reactive maintenance to proactive preparation for compliance, asset managers and specifiers must focus on four key areas:
• Audit stock: Identify properties with older or poorly performing windows and doors, prioritising upper-floor flats and homes with vulnerable tenants.
• Review specification against approved documents: Cross-reference existing and replacement products with Building Regulations specifically Parts F, K, L and O.
• Review the evidence trail: Ensure documentation is catalogued and accessible for verification at short notice.
• Stress test your supply chain: Confirm component suppliers and fabricators can deliver compliant products within the statutory Awaab’s Law timescales rather than planned maintenance schedules.
For detailed technical guidance and a complete readiness checklist for housing providers, download the white paper: Awaab’s Law & The Windows And Doors Specification Gap online. profile22.co.uk