Awaab's Law: The Evidence Problem Housing Providers Face

What Awaab's Law requires

Awaab's Law amends the terms of social housing tenancy agreements to include statutory timescales for investigating and repairing prescribed hazards. The requirements come from the Social Housing (Regulation) Act 2023 and apply to all registered providers of social housing, including housing associations and local authorities.

Emergency hazards must be investigated and safety work completed within 24 hours. Significant hazards must be investigated within 10 working days, with a written summary within a further 3 working days and safety work begun within 5 working days of concluding the investigation.

If the landlord cannot complete the safety work within the required timescale, they must provide suitable alternative accommodation for the household at the landlord's expense.

Phase 1, Phase 2 and Phase 3

Phase 1, in force from 27 October 2025, covers all emergency hazards and damp and mould hazards presenting a significant risk. This is already a legal obligation.

Phase 2, expected in 2026, extends coverage to significant-risk hazards including excess cold and excess heat, falls, structural collapse and explosions, fire hazards, electrical hazards, and domestic and personal hygiene and food safety hazards.

Phase 3, expected in 2027, will cover all remaining HHSRS hazards except overcrowding.

Why this changes the evidence requirement

Before Awaab's Law, the obligation was to maintain homes in a reasonable state of repair. The timescales were loosely defined and enforcement was largely complaint-driven. Now, the timescales are statutory.

This creates two practical problems. First, reactive discovery: most providers only learn about hazards when a resident reports them. The moisture path through the building envelope may have been active for months before the complaint arrives. Second, investigation evidence: 'investigate within 10 working days' requires identifying the source of the problem, not just observing its symptoms. For damp, the source is frequently in the building envelope, and investigating it from inside the property tells you where the moisture is appearing, not where it is entering.

Where thermal inspection fits

Radiometric thermal imaging can identify moisture paths, cold bridging, insulation voids and areas of anomalous heat loss in the building envelope. It works by detecting temperature differentials on the external surface, which can indicate where moisture is trapped, where insulation has failed, or where air leakage is occurring.

When a complaint triggers the investigation window, thermal imaging of the external elevation can help identify the likely source significantly faster than waiting for scaffold access. More significantly, thermal inspection across a stock can identify buildings with envelope defects before a resident reports a problem, meaning you can intervene before the statutory clock starts.

What Phase 2 means for building condition evidence

Phase 2 adds several hazard categories with direct links to the building envelope. Buildings with poor insulation, thermal bridging, or failed glazing will present as excess-cold hazards. External wall systems and cladding remain a fire safety concern, particularly for higher-risk buildings. Visual inspection from UAV can identify cracking, movement and deterioration in structural elements visible externally.

Thermal imaging can identify which properties have the worst fabric performance, helping providers triage which homes are most likely to trigger complaints under the expanded hazard categories.

Building the evidence before the complaints arrive

The most defensible position under Awaab's Law is not to respond quickly to complaints, although you must. It is to hold current evidence of building condition across your stock, so you can demonstrate that you knew about potential hazards and were already acting on them.

A structured, drone-captured condition survey of your building envelopes produces dated visual evidence, thermal evidence of moisture paths and insulation failures, graded findings by severity, prioritised action lists, and a defensible record of what was observed and when. This evidence sits in Atlas, where it can be retrieved, compared and presented to a regulator, ombudsman or court if needed.