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From 27 October 2025, social landlords in England must meet fixed timescales to investigate and make safe emergency hazards within 24 hours and tackle significant damp and mould to set deadlines. Requirements are being phased to more hazards in 2026 and again in 2027. Breach creates a contract claim route for tenants because the new rules are implied into tenancy agreements. Meanwhile, Housing Disrepair remains exempt from FRC until October 2028—so your costs strategy still matters. (GOV.UK, kain-knight.co.uk, blog.anthonycollins.com)
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Regulations (the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025) were laid on 25 June 2025 and are due to come into force on 27 October 2025 (subject to Parliamentary approval). The policy position for Phase 1 is settled. (GOV.UK)
Phase 1 scope (from 27 Oct 2025):
• All emergency hazards (make safe within 24 hours)
• Damp & mould hazards that present a significant risk of harm, to fixed timescales
The law implies these terms into social tenancies, enabling breach of contract actions if landlords fail. (GOV.UK)
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Per government response and draft guidance, social landlords must:
• Emergency hazards: Investigate and take action to make safe as soon as possible and within 24 hours. If they can’t make safe, they must secure suitable temporary accommodation within that window. (GOV.UK)
• Significant hazards (incl. damp & mould in Phase 1):
o Investigate within 10 working days of becoming aware;
o Provide a written summary within 3 working days of the investigation concluding;
o Make safe within 5 working days of the investigation concluding;
o Begin further works within 5 working days (or take steps to begin), and if not possible, works must physically start within 12 weeks;
o Complete within a reasonable period and keep tenants updated. (GOV.UK)
Alternative accommodation duty: If the home can’t be made safe in time (5 working days, or 24 hours for emergencies), the landlord must secure suitable temporary accommodation at its expense. (GOV.UK)
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• 2026: Adds significant hazards including excess cold/heat, falls, structural collapse/explosions, fire/electrical, domestic hygiene/food safety. (GOV.UK)
• 2027: Extends to the remaining HHSRS hazards (except overcrowding), when significant. (GOV.UK)
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• Applies to: Almost all social housing let by registered providers (local authorities and PRPs) under a tenancy. Not to licences/long leaseholds/owner-occupiers. (GOV.UK)
• Defence: A landlord has a defence if it took all reasonable steps but could not comply for reasons beyond its control (see LTA 1985 s.10A(5) as inserted). (GOV.UK)
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• Housing claims (including disrepair) remain outside FRC; Parliament has noted housing is excluded from the 2023 FRC roll-out across fast/intermediate tracks. (UK Parliament)
• In June/July 2025, the Ministry of Justice confirmed (to HLPA) that the housing exemption from FRC will be extended to October 2028, with a review then. (Practitioner updates report this; formal rule updates to follow.) (kain-knight.co.uk, blog.anthonycollins.com)
Practical upshot: For HDR, your hourly rates/e-Bills still matter—Awaab’s Law provides clean breach points that support necessity, urgency and proportionality in your costs narrative.
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1. Clearer liability hooks
Missed statutory times = contract breach. Your pleading can track the clock: awareness → investigation → written summary → make safe → begin works → start by 12 weeks → completion. (GOV.UK)
2. Better evidence from the landlord
Landlords must record and communicate investigations, decisions and timepoints. Their records often prove delay and risk—use them. (GOV.UK)
3. Stronger costs justification
Risk-to-health plus 24-hour and 5-day thresholds back urgent inspections, repeat visits and expert input—fertile ground for defending Grade A supervision and key disbursements. (GOV.UK)
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• Diary 27 Oct 2025 (Phase 1) and the 2026/2027 expansions. Align Scott Schedules with each timepoint; add a “Time-Limit Breach” column. (GOV.UK)
• Evidence early: humidity data, photos, medical indications of risk; show why a hazard is significant/emergency. (GOV.UK)
• Plead the statutory timetable and request records (investigation start/finish, written summaries, works orders, contractor attendance). (GOV.UK)
• Press alternative accommodation where the home can’t be made safe within the 5-day/24-hour windows. (GOV.UK)
• Costs: serve running schedules and, where appropriate, seek payments on account—you have crisp breach dates supporting urgency and proportionality.
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No—social landlords only (registered providers). Government indicates separate reforms for the private sector via the Renters’ Rights agenda. (GOV.UK)
Yes for Phase 1 policy: the regs are laid and the government response fixes these timescales for 2025 go-live; final guidance before October may clarify operation details. (GOV.UK)
Because the terms are implied into tenancies, tenants can sue for breach of contract; courts can order repairs, compensation, and costs. (GOV.UK)
Awaab’s Law sits alongside existing duties; if HHSRS or other laws set a shorter time, the shorter applies. (GOV.UK)
No. Housing disrepair remains exempt; the exemption is being extended to Oct 2028 per MoJ communication to HLPA. (kain-knight.co.uk, blog.anthonycollins.com)
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• Bills & e-Bills that track the timetable: We lift the landlord’s own timestamps into your necessity/proportionality narrative.
• Rate defence & disbursements: We justify Grade A supervision, emergency attendances, multiple inspections and expert fees against the 24-hour / 5-day windows.
• Negotiation to closure: Points of Dispute/Reply, payments on account, and assessments—we push until every penny is paid.
• FRC-aware strategy: With HDR FRC now delayed to 2028, we keep you on the optimal route and ready for any rule changes. (kain-knight.co.uk, blog.anthonycollins.com)
CTA: Send us a live HDR file. We’ll map Awaab’s Law breaches, draft the Bill, and return a recovery plan within one working day.
First HDR Bill drafted free. info@dmdcosts.co.uk
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Sources / updates
• Draft landlord guidance & commencement (laid 25 June; in force 27 Oct 2025): timescales, scope, process. (GOV.UK)
• Government response confirming 10 working days, 3 working days summary, 5 working days to make safe, begin within 5 days / start ≤ 12 weeks, 24-hour emergencies, alt-accommodation duty, and 2026/2027 phases. (GOV.UK)
• Housing disrepair FRC exemption continuing to Oct 2028 per MoJ communication (practitioner reports). Also note current exclusion of housing from FRC. (UK Parliament)