Blog Single

Phase 2 lands on 30 November 2026. Here’s what’s actually changing, and what a genuinely ready programme has in place before the deadline arrives — set out against the same ten questions in our Retrofit Readiness Check.

A quick recap: what Awaab’s Law already requires

Awaab’s Law introduced fixed, enforceable timescales for social landlords to investigate and act on hazards in their homes, named after Awaab Ishak and brought in under the Social Housing (Regulation) Act. Its first phase centred on the hazard that prompted it — damp and mould — requiring landlords to investigate reported cases and act within set windows, rather than at their own discretion.

What Phase 2 actually changes

Phase 2 widens that same fixed-timescale approach beyond damp and mould to seven more hazards: excess cold, excess heat, falls, structural collapse, fire and explosions, electrical hazards and domestic hygiene. The clock is the one that has applied to damp and mould since October 2025. An emergency hazard must be investigated and made safe within 24 hours. A significant hazard must be investigated within 10 working days, with a written summary for the resident within three working days of that, and safety work done within five working days. Phase 3 will bring in the remaining HHSRS hazards, apart from overcrowding.

For anyone running a retrofit programme, that overlap with Phase 2 is direct rather than incidental. Excess cold and excess heat are retrofit issues first — a fabric or ventilation problem before they’re a compliance one — which means a well-run PAS 2035 programme is now also a big part of how a landlord actually stays compliant, not just a separate workstream running alongside it.

What “ready” actually means before 30 November

We built a short self-assessment for exactly this — The Retrofit Readiness Check — because most programmes we see don’t fail on effort. They fail because a handful of foundational questions were never asked out loud. Run through these before the deadline, not after.

Compliance & risk

Do you know which PAS 2035 role — Coordinator, Assessor, Designer or Evaluator — is accountable if something goes wrong on a given programme, and could you name that person today? Fragmented outsourcing often means no single individual is genuinely answerable when compliance is questioned, which is precisely the gap Awaab’s Law is designed to close.

And practically: if a resident raised a damp, mould, cold or heat complaint tomorrow, could you produce the evidence trail an investigation would ask for? This isn’t paperwork for its own sake — it’s what protects the resident and the organisation at the same time.

Delivery & coordination

Has every property in the programme had a proper whole-dwelling survey, or are some relying on desktop assumptions? Missing or outdated surveys are one of the most common causes of mid-programme delay — and a delayed fix is exactly what a Phase 2 timescale won’t forgive.

If your coordinator, assessor and designer sit in three different companies, who actually resolves it when their recommendations conflict? That’s where avoidable delay tends to start, and it’s worth knowing the answer before a hazard clock is already running, not after.

Funding & programme planning

Do you know exactly which funding route each phase of work depends on, and its real closing date? Funding windows are closing faster than most programmes can comfortably absorb, and a compliance deadline doesn’t pause for a funding gap.

Outcomes & assurance

When a measure is complete, how will you actually know the real improvement — to warmth, to damp, to ventilation — matches what was modelled? And who signs that off independently of the team that designed it? Self-marked homework is still homework; an auditor or regulator will draw the same conclusion.

How WRAP Retrofit approaches this in practice

This is the same structure our own team works to. Our Retrofit Coordinator, Dan Rooke, describes it as reasoning forward from a measures interaction matrix — a table inside PAS 2035 that sets out which measures work safely alongside each other, which need to happen first, and which shouldn’t be combined at all — rather than approving retrofit measures one at a time as requests come in.

“It’s understanding which measures that you propose are appropriate to work alongside another one, and which ones you shouldn’t do, which ones you should get in early, which one is actually part of the sequencing plan as part of your medium-term improvement plan.”

— Dan Rooke, Retrofit Coordinator

That sequencing, plus named roles and an independent sign-off at the end, is what turns “we did the work” into something you could actually stand behind if a regulator asked to see it tomorrow.

Take the full ten-question self-assessment, The Retrofit Readiness Check, free. Or if you’d like a second look at your programme before 30 November, get in touch: 020 8050 5107 / info@wrap-retrofit.com.