Awaab's Law Is Coming to Private Renting: The Timescales Landlords Would Have to Prove

On 9 October 2026 the Ministry of Housing, Communities and Local Government opened a consultation on extending Awaab's Law to private rented tenancies in England, and to supported housing, temporary accommodation and care leaver accommodation occupied under licence. It closes at 11.59pm on 18 December 2026 and runs to 64 numbered questions. Nothing changes for private landlords yet. The powers sit in sections 60 and 61 of the Renters' Rights Act 2025, neither of which is in force as of 12 October 2026, and the document says the earliest feasible start date is 2027. What the consultation does fix, from today, is the shape of the record trail a private landlord will one day have to produce.

What is actually being proposed

The government is not writing a new regime. The consultation says it will "use the Awaab's Law requirements for social housing as a starting point" and that the aim is "not to seek to establish stronger or weaker Awaab's Law requirements" for private tenancies, but to make them work for a sector where most landlords own one or two properties and have no repairs team.

So every question is framed against what social landlords already have to do. Phase 1 of the social sector rules took effect on 27 October 2025 for damp and mould and all emergency hazards. Phase 2, due on 30 November 2026 subject to parliamentary approval, adds electrical, fire, cold, heat, falls, structural and hygiene hazards. Phase 3 in 2027 picks up the rest. Our guide to the Phase 2 written summary describes the model now proposed for private renting.

For the private sector, the impact assessment assumes three phases in 2028, 2029 and 2030. Question 30 asks respondents to pick 2027, 2028, 2029 or later. Question 31 asks whether the Private Rented Sector Landlord Ombudsman, expected in 2028, should be running first.

The timescales on the table

Each deadline is put to respondents as the social housing figure plus one shorter and one longer option. The social figure is labelled "in line with social housing requirements", which is as close as the document gets to a default.

Step	Social housing rule today	Options in the consultation
Investigate a potential significant hazard (Q11)	Within 10 working days of becoming aware	5, 10 or 15 working days
Written summary of findings to the tenant (Q15)	Within 3 working days of the investigation concluding	1, 3 or 5 working days
Make a significant hazard safe (Q18)	Within 5 working days of the investigation concluding	3, 5 or 10 working days
Start further preventative works (Q19)	Within 5 working days, or take steps and start within 12 weeks (Q20)	3, 5 or 10 working days
Emergency hazards (Q23)	Investigate and make safe as soon as practicable and within 24 hours	12, 24 or 48 hours

Question 20 asks whether a landlord who cannot start works within 5 working days should be allowed to take steps, such as booking a contractor, and begin within 12 weeks. Question 21 lists the expected difficulties: finding trades, rural locations, and tenants not giving access. Whichever figures are chosen, each deadline runs from a date the landlord will have to evidence: becoming aware, concluding the investigation, sending the summary, starting works.

Which hazards, and which homes

The default scope is every hazard in the Housing Health and Safety Rating System except overcrowding, which mirrors social housing. The updated HHSRS took effect on 23 June 2026 and cut the hazard list from 29 to 21. Question 4A lets respondents who disagree pick hazards in or out one at a time.

The threshold is the same as social housing: significant hazards and emergency hazards, the latter posing an imminent and significant risk. Question 8 asks whether a hazard should be assessed on severity alone, as HHSRS does, or with the actual occupants' circumstances taken into account, as social landlords must.

Two exclusions are proposed. Question 5 would leave out hazards caused by the tenant's own breach of contract, with guidance making clear this does not let a landlord dismiss damp and mould as a lifestyle issue. Question 6 deals with leasehold flats where the freeholder controls the defect: exclude those hazards, or require the leaseholder landlord to take reasonable steps to get the freeholder to act.

Part 2 uses section 61 of the Act, which covers accommodation occupied under licence rather than a tenancy. Three types are named: supported housing, temporary accommodation for homeless households, and care leaver accommodation. For each, respondents are asked whether the investigation, written summary and alternative accommodation requirements should match tenancies or be modified. Question 54 asks whether other licensed accommodation should be added.

Investigation and the written summary

An investigation does not have to be a visit. The document says that "unless the tenant requests it, landlords are not required to physically inspect the property" and that photos and videos "allow for remote investigations in some circumstances". Question 12 asks who should carry it out: any person the landlord judges competent, a two-stage process with a specialist follow-up, or someone holding a specific qualification.

Question 14 asks whether a written summary should be required at all, and Question 16 lists the contents being considered: whether a significant or emergency hazard was found, what further action is needed, the reasons where no action is needed, a target timescale, and contact details. That is the same list social landlords must meet from 30 November 2026.

Alternative accommodation

Social landlords who cannot make a home safe in time must secure suitable temporary alternative accommodation at their own expense. The consultation is openly doubtful about carrying that across. It records "concerns about the feasibility" for landlords with very small portfolios and notes that accommodation "would therefore need to be in a hotel or bed and breakfast". Questions 25 to 27 ask for a level of support and for the benefits and risks, including rent increases.

How it would be enforced

Awaab's Law works by implying a term into the tenancy. Section 60 of the Renters' Rights Act 2025 rewrites section 10A of the Landlord and Tenant Act 1985 so that it applies to dwelling-houses in England let for under seven years, not only social housing leases. Section 61 inserts new sections 10C and 10D for regulated licences, enforceable "only through actions for breach of that implied term", with a defence where the licensor used all reasonable endeavours. Both sections are prospective as of 12 October 2026.

For tenants, the route is a claim for breach of contract. The document says the court can order the repairs, order compensation and award some legal costs. Once the Landlord Ombudsman exists, it "will have the power to order landlords to take an action, issue an apology and/or award financial compensation".

Councils are not proposed as enforcers of the timescales. They keep their HHSRS powers, including the duty to act on category 1 hazards and the Renters' Rights Act penalty of up to £7,000, and Awaab's Law "will complement, rather than replace, local authority enforcement of poor housing conditions". The social sector defence, that a landlord took all reasonable steps but was prevented by factors outside its control, is the model for private landlords. A defence of that kind is proved with contemporaneous records or not at all.

Where this sits with the PRS Database and Decent Homes

The consultation does not mention the Private Rented Sector Database. Registration opens on 15 December 2026 and requires the gas safety record, the EICR and the EPC per property, as set out in our guide to the PRS Database. Those standing documents show an installation was in order before a hazard was reported. Awaab's Law adds the second layer: what happened after the report. The glossary confirms an updated Decent Homes Standard will apply to private rented homes from 2035. A landlord will eventually be measured against both, and the paperwork for both lives in the same property logbook.

The records a private landlord would have to produce

Strip the consultation back to evidence and the sequence is fixed regardless of which numbers win.

1. The dated report. The email, portal message or call log that shows when you became aware. The document notes a landlord "will often be informed of a potential hazard as a result of a complaint from a tenant". If the report was by phone, your same-day note is the record.
2. The investigation record. Who looked, when, by what means (visit, video call, photos), and the conclusion.
3. The written summary. A copy of what you sent the tenant, with the send date, covering the five items at Question 16.
4. Contractor evidence. Booking confirmations and quotes, the proof you took steps within the short window even if works started later.
5. Completion evidence. The invoice, any certificate (an electrical minor works certificate, for example), and dated photographs.
6. Access evidence. Every request for access and every refusal, because the reasonable steps defence turns on it.

If the hazard is electrical, the EICR and its codes show whether the defect was known before the tenant reported it. For fire hazards in an HMO, the same applies to the fire risk assessment record.

What tenants should keep

Tenants are the other party to the implied term and will be the ones bringing the claim. Report in a form that dates itself, keep the landlord's reply, photograph the hazard before anything is touched, and keep whatever summary arrives. If none arrives within the period eventually set, that absence is itself the evidence.

How to respond

Respond online at the MHCLG consultation hub, by email to awaabslawconsultation@communities.gov.uk, or by post to Awaab's Law Consultation, Private Rented Sector Strategy, Security & Standards Division, MHCLG, 3rd Floor, Fry Building, 2 Marsham Street, London SW1P 4DF. You do not have to answer every question. Part 1 is private tenancies, Part 2 is licences, Part 3 is costs, and Question 64 is open to anyone. The deadline is 11.59pm on 18 December 2026.

Frequently asked questions

Does Awaab's Law apply to private landlords now?

No. As of 12 October 2026 it applies only to social housing in England. Sections 60 and 61 of the Renters' Rights Act 2025, which extend it to private tenancies and licences, are not yet in force. The consultation says the earliest feasible date is 2027, and its impact assessment assumes phases in 2028, 2029 and 2030.

What timescales are proposed for private landlords?

Investigate within 5, 10 or 15 working days; written summary within 1, 3 or 5 working days; make safe within 3, 5 or 10 working days; emergency hazards within 12, 24 or 48 hours. The middle figure in each case is the current social housing rule.

Which hazards would be covered?

The proposal is all 21 HHSRS hazards except overcrowding, at the significant and emergency thresholds. Hazards caused by the tenant's own breach of contract would be excluded.

Would councils enforce the deadlines?

Not as proposed. Enforcement would be through the implied tenancy term, so a tenant's claim in court and, from 2028, the Landlord Ombudsman. Councils keep their HHSRS powers, including fines of up to £7,000.

Does it cover lodgers, supported housing or temporary accommodation?

Part 2 of the consultation asks whether licences for supported housing, temporary accommodation for homeless households and care leaver accommodation should be covered, and whether other licensed accommodation should be added. No decision has been made.