The death of Awaab Ishak in 2020 changed social housing in Britain. The two-year-old’s death from prolonged mould exposure in a Rochdale Boroughwide Housing flat exposed a system in which tenants’ complaints went unanswered for years. The legislative response, known as Awaab’s Law, is now reshaping the obligations of every social housing landlord in England.

For most of the conversation since 2023, Awaab’s Law has been associated with damp and mould. But the framework it creates extends well beyond those two hazards, and fire safety is now formally on the timetable. Phase 2 of the law brings fire hazards explicitly within scope from 30 November 2026.

This guide explains what Awaab’s Law actually requires, how it overlaps with the Fire Safety Act 2021 and the Building Safety Act 2022, and the practical steps landlords should be taking now to be ready for the November deadline.

What Awaab’s Law is, and what it isn’t

Awaab’s Law is the common name for the regulations made under section 10A of the Landlord and Tenant Act 1985, as inserted by the Social Housing (Regulation) Act 2023. It places duties on social housing landlords to investigate and remedy specified hazards within strict timescales.

The first phase, in force since 27 October 2025, covers damp and mould plus emergency hazards of any kind. Key timescales under the current regulations:

  • Emergency hazards (those presenting an immediate risk to health or safety): landlords must investigate within 24 hours and either remedy or make safe within 24 hours of the investigation.
  • Significant damp and mould hazards: investigate within 10 working days, complete works within a further 5 working days unless the hazard is more complex, in which case a written plan with timescales must be provided.
  • Routine hazards: landlords must provide a written summary of findings and a timetable for works within set windows.

These are tenancy-law duties, enforceable by tenants in the county court. Failure to comply is not a regulatory wrist-slap: it’s a breach of contract with the tenant, and damages follow.

Fire safety: explicitly in scope from 30 November 2026

Two of the 29 Housing Health and Safety Rating System (HHSRS) hazards relate directly to fire safety: Hazard 24 (fire) and Hazard 25 (flames, hot surfaces and materials).

Fire-related defects have been partially within Awaab’s Law since day one. Any defect creating an immediate risk to life (a fire alarm that’s offline, a fire door that doesn’t latch, breached compartmentation, a failed AOV) qualifies as an emergency hazard, and has carried the 24-hour investigation and 24-hour remedy clock since October 2025.

From 30 November 2026, phase 2 goes further. Fire joins the named hazard groups (alongside excess cold and heat, falls, structural collapse, electrical hazards and hygiene hazards), meaning significant fire hazards that fall short of an emergency acquire statutory clocks of their own: investigation within 10 working days, a written summary of findings within 3 working days of the investigation concluding, safety works within 5 working days, and any supplementary works begun within 12 weeks. A third phase, due in 2027, is expected to extend the framework to all remaining HHSRS hazards except overcrowding.

The implication is significant. A social housing landlord cannot wait three working days for their fire alarm contractor to mobilise. They cannot put a faulty smoke detector on a routine maintenance schedule. The clock starts when the landlord becomes aware of the hazard (through a tenant complaint, a routine inspection, or a monitoring system), and the response time is measured from that point.

How Awaab’s Law layers on top of existing fire safety duties

Fire safety duties for residential landlords already exist under three primary frameworks. Awaab’s Law doesn’t replace them: it adds an enforceable accountability layer on top.

The Regulatory Reform (Fire Safety) Order 2005. The foundational duty. It requires every “responsible person” (in social housing, typically the landlord or property manager) to undertake and maintain a suitable and sufficient fire risk assessment, to implement its recommendations, and to keep fire safety provisions in working order. The Fire Safety Act 2021 clarified that the Order applies to the structure, external walls and individual flat entrance doors of multi-occupied residential buildings, closing a post-Grenfell loophole.

The Building Safety Act 2022. For higher-risk buildings (residential buildings of at least seven storeys or 18 metres, with at least two residential units), the Act imposes additional duties on the Accountable Person, including registration with the Building Safety Regulator, the production of a Safety Case Report, and ongoing assessment of building safety risks. Awaab’s Law operates alongside these duties: the BSA sets the standing safety case, while Awaab’s Law governs the response when something goes wrong.

The Fire Safety (England) Regulations 2022. Made under section 156 of the Building Safety Act, these require, for multi-occupied residential buildings over 11 metres, quarterly checks of fire doors in communal areas and annual (best-endeavours) checks of flat entrance doors, plus routine checks of lifts and other key firefighting facilities in high-rise buildings, and the provision of evacuation and fire safety information to residents.

Where Awaab’s Law changes the picture. The earlier frameworks tell the landlord what to do. Awaab’s Law tells them how fast to do it when a tenant reports a problem, and gives the tenant a direct legal route if it isn’t done. For fire safety, the compliance question is no longer just “is the fire alarm system maintained to BS 5839?” It’s also: “when a tenant reports that their smoke detector isn’t working, can we prove we investigated within 24 hours and rectified within 24 hours of that investigation?”

Five things social housing landlords should be doing now

  1. Re-baseline your fire risk assessments. If your most recent FRA is more than 12 months old, or pre-dates the Building Safety Act, it should be reviewed by a competent assessor. A current, defensible FRA is the foundation on which Awaab’s Law compliance rests.
  2. Audit your reactive fire-safety response times before 30 November. Pull the data from your CAFM or maintenance system. What’s your actual median time from tenant report to engineer attendance for a faulty smoke detector? For a failed AOV? If those numbers are not consistently inside 24 hours for emergency hazards, and inside the 10-working-day investigation window for everything else, your operational model needs adjusting now, not in November.
  3. Tighten the chain between tenant complaints and the fire-safety contractor. The most common cause of slow response is friction in the reporting chain: tenant reports to housing officer, housing officer logs a maintenance ticket, ticket sits in a queue, ticket eventually reaches the contractor. Each step adds delay. Direct, automated escalation pathways for fire-safety hazards are now a compliance requirement, not a nice-to-have.
  4. Document everything. Awaab’s Law shifts the burden of proof. If a tenant brings a claim, the landlord must demonstrate they investigated and remedied within the regulatory timescales. That means timestamped reports, photographic evidence, engineer attendance records, and clear written communication with the tenant. If you can’t prove it happened on time, the court will assume it didn’t.
  5. Train your housing officers on hazard classification. The 24-hour clock starts when the landlord becomes aware of an emergency hazard, and that awareness reaches the landlord through their housing officers. A housing officer who treats a “the smoke alarm keeps beeping” call as a routine maintenance issue rather than an emergency hazard exposes the landlord to liability. Officers need clear, written guidance on which fire-safety defects are emergency hazards by default.

How Gemini AMPM works within this landscape

Gemini AMPM operates reactive fire-safety maintenance contracts across landmark UK residential portfolios, including the Unity Building in Liverpool and four high-rise towers in Tower Hamlets. Our service-level commitments for reactive fire-safety call-outs are calibrated against Awaab’s Law’s emergency-hazard timescales, with documented evidence of attendance, work performed, and any further remedial recommendations.

If your fire-safety maintenance contracts pre-date the current compliance landscape, or you’re unsure whether they meet the response-time bar, we can review your existing arrangements and identify the gaps before the November deadline. Get in touch or call 0330 043 0080.

This article is general guidance and does not constitute legal advice. Social housing landlords should consult their legal advisers and fire-safety specialists on their specific circumstances. References to Awaab’s Law reflect the regulations in force and the phase 2 commencement date confirmed by government; the framework expands further in 2027 and compliance plans should be kept under regular review.