Stop managing damp. Start managing risk
The next phase of Awaab’s Law isn’t about repairs. The question regulators will ask is whether you can prove what you knew, and when.
Housing providers, operators and agents are being warned not to view Awaab’s Law solely through the lens of damp and mould, as new requirements coming into force later this year expand legal duties to a much broader range of housing hazards.
Inventory Base is warning that many organisations may be preparing for the wrong challenge, with compliance still widely treated as a repairs issue despite regulators increasingly viewing it as a question of risk management, evidence and accountability.
The warning comes as government housing data reveals that while damp remains a significant issue, it is far from the most common serious hazard found in homes.
In 2024, an estimated 940,000 homes contained Category 1 fall hazards on stairs, compared with approximately 635,000 homes affected by excess cold and 155,000 homes with Category 1 damp hazards.
According to Inventory Base, these figures highlight how the next phase of Awaab’s Law will fundamentally change the way housing providers identify, assess and respond to risk across their portfolios.
The first phase of Awaab’s Law established strict response times for social landlords, including investigating emergency hazards within 24 hours, investigating significant damp and mould within 14 days, and beginning repairs within seven days once a hazard has been confirmed.
However, the next phase extends those principles to a far wider range of hazards, including excess cold and heat, fire and electrical risks, structural hazards, falls, hygiene issues and food safety concerns.
Inventory Base believes this represents a significant shift away from reactive complaint-led housing management towards continuous risk monitoring and evidence-based compliance.
The warning also comes as the sector faces imminent changes to the Housing Health and Safety Rating System. The HHSRS (England) (Amendment) Regulations 2026 comes into force on 23 June, simplifying hazard descriptions from 29 to 21 categories, replacing the existing A-J banding with three bands – High, Medium and Low – and renaming classes of harm to make them easier to explain to landlords and tenants.
Recent housing data also highlights the continuing scale of housing quality challenges across England. In 2024, approximately 2.27 million homes failed the minimum Housing Health and Safety Rating System standard, while nearly four million homes failed the Decent Homes Standard overall. Damp problems affected an estimated 1.4 million homes, the highest level recorded in recent years.
Inventory Base expects three major shifts to emerge over the coming years:
- Property inspections to become increasingly digital and evidence-driven.
- Risk assessments to evolve from periodic inspections into continuous monitoring of property condition.
- Compliance reporting becomes more closely tied to auditable operational data rather than narrative assurance.
Organisations that invest now in stronger inspection processes, property intelligence and compliance reporting will be better placed to meet future regulatory expectations.
Sián Hemming-Metcalfe, Operations Director at Inventory Base, commented:
“Damp and mould have been the catalyst for change, but Awaab’s Law is rapidly becoming something much bigger. There’s still a perception in some parts of the sector that this is primarily a damp and mould regulation, but that’s a dangerous misunderstanding. The direction of travel is clear: housing providers will increasingly be expected to prove they identified risks, assessed them correctly and acted within a defensible timeframe.
The real challenge isn’t repairs, it’s visibility. You can’t respond to a hazard within regulatory timeframes if you don’t have accurate information about the condition of a property, the risks present and a clear record of when those risks were identified. As regulators, residents and legal teams place greater emphasis on evidence, organisations need to be able to demonstrate what they knew, when they knew it and what action they took.
Those that adapt early won’t just reduce compliance risk. They’ll gain something far more valuable: visibility across their portfolios. In an environment increasingly shaped by regulation, resident scrutiny and legal accountability, that visibility will be the difference between proactive management and permanent firefighting.”
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