Awaab's Law came into force in October 2025 covering damp, mould and emergency repairs. Phase 2 arrives on 30 November 2026 and extends the same mandatory response times to a much broader set of Housing Health and Safety Rating System hazards — including excess cold, excess heat, falls, structural collapse, fire and explosion, electrical hazards and domestic hygiene.

Why excess cold is the significant addition

Grouping a cold home with electrical danger and structural collapse is a deliberate statement about harm. Cold homes are associated with respiratory illness, cardiovascular strain and excess winter deaths, and the evidence for that has been solid for a long time. What is new is the enforceable timescale attached to it.

For social landlords, that means a reported cold home triggers an investigation clock. And the underlying cause of excess cold is, in most cases, exactly what an energy assessment measures: poor fabric, inefficient or uncontrollable heating, and heat loss the occupant cannot do anything about.

Where this connects to the certificate

The two regimes are converging even though they were written separately. A property with a poor EPC band and electric storage heating is, in plain terms, expensive to keep warm — which is the same thing as being at risk of an excess cold hazard.

Meanwhile privately rented homes face a C-equivalent standard by 1 October 2030 with a £10,000 cost cap. A landlord treating those as two unrelated compliance projects is doing twice the work. The measures that lift a band out of D are largely the measures that remove an excess cold hazard.

Practical steps for landlords

  • Know the current band and why. An EPC's recommendation list is a reasonable first map of what is driving heat loss.
  • Prioritise heating controls. Cheap, quick, and they address both controllability and the rating.
  • Take storage heaters seriously. In ex-council flats this is usually the single item that determines both the band and the cold-hazard risk, and it needs capital planning.
  • Document what you did and when. Both regimes reward a landlord who can show a response timeline.

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