Awaab’s Law will launch with failure baked in — here’s what that means for your HDR caseload and recoverable costs

Updated: 3 October 2025 • Read time: 6–7 mins

Bottom line: From 27 October 2025, social landlords must make safe emergencies in 24 hours, investigate damp/mould within 10 working days, and issue a written summary shortly after. One major council has already said it may not comply next month. If one is saying it out loud, many more will miss quietly — and that has direct consequences for damages and costs on your housing disrepair (HDR) files. GOV.UK

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Why widespread failure is likely (and measurable)

• Statutory deadlines are hard and soon. Draft guidance sets a 24-hour emergency window and a 10-working-day investigation window for significant hazards, with written findings afterwards. GOV.UK

• Councils are signalling they’ll miss. Bristol City Council has publicly warned it might not comply with Awaab’s Law in October due to backlogs, incomplete surveys and legacy IT. Expect others in the same boat. BristolWorld

• Complaint volumes are surging. The Housing Ombudsman reports 26,901 interventions in 2024/25, with ~40% of compensation tied to leaks/damp/mould. That pressure will spike as Awaab’s deadlines bite. Housing Ombudsman

• Sector readiness remains patchy. Trade and professional updates reiterate the 24h/10-day/3-day requirements and warn landlords to mobilise now — a sign many haven’t. CIOB+1

Translation for fee-earners: deadline breaches at scale → more instructions, clearer liability paths, and a stronger case for recoverable costs caused by non-compliance.

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Awaab’s Law: the new “clock” your teams must run against

From 27 Oct 2025 (social sector day one):

• 24 hours: make safe any emergency hazard.

• 10 working days: investigate potential significant hazards (e.g., damp & mould).

• 3 working days after the investigation: give a written summary to the tenant.

• (Where confirmed significant hazards) begin relevant safety works rapidly thereafter.

Keep these in your letters: exact report time, missed deadline, and the consequence (further deterioration, repeated attendances, health impact).

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Damages vs costs — the rule that doesn’t change

Awaab’s Law accelerates repairs and underpins damages, but it doesn’t fix inter partes costs. Where costs aren’t expressly agreed, your route remains CPR 47: Bill + N252 → detailed assessment. Keep damages and costs strictly separate in any agreement/consent.

Consent wording you can lift:

(i) Damages & works: as agreed (Awaab duty referenced where relevant).

(ii) Costs: to be paid/assessed per CPR if not agreed (no prejudice to interest).

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Your 2025–27 HDR playbook (turn breaches into recovery)

1. Evidence the breach

o Timeline the report, 24h, 10-day, and 3-day milestones; capture missed steps.

o Photos, humidity/temperature, medical notes (where appropriate).

2. Pre-action letter with teeth

o Cite the specific Awaab duty breached and enclose your breach timeline.

o Put the landlord on notice re damages + costs.

3. Part 36 early (claimant)

o Once liability is stable, serve a realistic claimant 36; if beaten at judgment, you unlock 36.17 (indemnity period, interest uplifts, additional amount).

4. Negotiate damages separately

o Do not accept “inclusive of costs” unless the global genuinely beats your reasoned bill.

5. Bill/e-Bill that tells the breach story

o PD 47 compliant, phased; weave necessity narratives that tie each tranche of work to missed statutory deadlines.

6. PoDs/Replies

o When facing “duplication/excessive admin”, link repeat attendances and escalation to deadline failures (24h/10-day/3-day), not your client’s choice.

7. Cash-flow levers

o Payment on account under CPR 44.2(8);

o Default Costs Certificate if PoDs are late (21-day window).

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What proportionality looks like in the Awaab era

• Necessity: Work driven by statutory breach is not “optional”.

• Value & risk: Habitability/health risk elevates weight; Ombudsman data shows damp/mould is now a core systemic failure, not an edge case. Housing Ombudsman

• Outcome: Repairs + compo + compliance change — articulate all three when defending time.

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Expect headlines like Bristol’s — and plan for volume

A council openly warning it can’t comply next month is a canary in the coal mine. Pair that signal with Ombudsman statistics and the strict statutory timers and you get a simple forecast: more HDR claims, more breach-driven work, and more assessable costs in 2025–27. BristolWorld+1

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FAQs (quick)

Does Awaab’s Law fix costs?

No — it imposes deadlines on landlords; costs remain CPR-driven. If not agreed, go CPR 47 with Bill + N252. GOV.UK

What are the day-one deadlines?

24h make-safe for emergency hazards; 10 working days to investigate significant hazards; written summary after investigation; repairs promptly thereafter.

Are councils really going to miss?

One major council has already said it might fail next month; complaint data shows entrenched issues. Expect widespread slippage at rollout.

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Sources

• UK Government draft guidance on Awaab’s Law (deadlines & process). GOV.UK

• Bristol City Council coverage admitting likely non-compliance. BristolWorld

• Housing Ombudsman Annual Complaints Review 2024/25 (damp/mould share & interventions). Housing Ombudsman

• Professional summaries of the 24h/10-day/3-day timers. CIOB+1