The precise wording of the Phase 2 regulations — and the exact list of HHSRS sub-hazards in scope — will be confirmed when the regulations are laid before Parliament. Government has indicated the statutory timeframes will mirror Phase 1: 24 hours for emergencies, 10 working days for significant hazard investigation, 3 working days for the written tenant report, 5 working days for safety works.

For Manchester landlords, Phase 2 is the moment Awaab’s Law stops being a damp-and-mould issue and becomes a whole-property compliance issue. That shift is the structural change every portfolio operator should be preparing for now.

Phase 3 — The Final SRS Expansion in October 2027

Phase 3 brings Awaab’s Law’s statutory timeframes to bear on every remaining Housing Health and Safety Rating System hazard — with one exception. Overcrowding is excluded, on the basis that overcrowding is treated as a separate regulatory issue under the Housing Act 1985 and the Housing Act 2004.

Everything else comes into scope. That includes asbestos and manufactured mineral fibres, biocides, carbon monoxide and other fuel combustion products, lead, radiation, uncombusted fuel gas, volatile organic compounds, crowding and space (where not constituting statutory overcrowding), entry by intruders, lighting, noise, food safety extensions, water supply, and personal hygiene.

By October 2027, in other words, every realistic hazard a Manchester social tenant might encounter will have a 24-hour or 10-working-day statutory clock attached to it. The cumulative effect is a fundamental rebuild of how social landlord stock condition surveys, repair triage, and contractor SLAs operate. Government has explicitly described Phase 3 as the regime to which all social landlords should be operating from October 2027 — and the implicit signal to private landlords is unambiguous. Whatever the PRS commencement date proves to be, this is the framework heading our way.

How the Renters’ Rights Act Extends Awaab’s Law to Private Landlords

The Renters’ Rights Act 2025 is the legislative vehicle through which Awaab’s Law arrives in the private rented sector. The mechanism is straightforward in concept and important to understand.

Section 10A of the Landlord and Tenant Act 1985 — the section that enables Awaab’s Law in the social sector — is being amended by the Renters’ Rights Act to bring all residential landlords within scope. Once the amending provisions are commenced, the Secretary of State has the power to make regulations imposing prescribed hazard response requirements on private landlords on the same statutory architecture as the SRS regime.

Three points matter here.

First, the statutory hook is already in place. Royal Assent on the Renters’ Rights Act was given on 27 October 2025. The enabling power for PRS Awaab’s Law is therefore live in primary legislation. Only the implementing regulations remain.

Second, the timetable is set by Government, not by Parliament. The Renters’ Rights Act gives the Secretary of State the power to commence the PRS Awaab’s Law framework when the necessary consultation and regulations are complete. Government has committed to consult on the specific timeframes, the specific hazard list, and the commencement date before issuing those regulations.

Third, the framework is settled but the dates are not. Industry guidance and trade body briefings as of mid-2026 indicate a likely PRS commencement date in late 2026 or 2027 — but until the regulations are formally laid before Parliament, no exact date can be quoted with statutory certainty. Landlords planning portfolio investments, refurbishment cycles, or compliance system upgrades should work to a 2026–2027 readiness window.

Anything that depends on a specific date being legally fixed should be deferred until the implementing regulations are laid.

The Anticipated PRS Framework — What Landlords Should Plan For

Government has signalled, repeatedly, that the PRS Awaab’s Law framework will be substantially aligned with the social sector regime. Working on that basis, every Manchester private landlord should plan around the following:

• The same five statutory clocks — 24 hours for emergency hazards, 10 working days for significant hazard investigation, 3 working days for the written tenant summary, 5 working days for safety works and the start of any further required works.
• The same two-tier hazard classification — emergency and significant — with the same vulnerability-sensitive thresholds.
• A phased hazard list — likely starting with damp, mould, and emergency hazards (mirroring SRS Phase 1) and expanding through subsequent regulations toward full HHSRS coverage.
• Mandatory written tenant communication — including the investigation summary, the explanation of works to be undertaken, and the timeline for completion.
• An accessible tenant route to enforcement — including direct legal action under Section 10A, complaint to the Private Rented Sector Ombudsman (introduced by the Renters’ Rights Act), and reporting to the local housing authority.
• Civil penalty exposure — likely under the Housing Act 2004 civil penalty regime as augmented by the Renters’ Rights Act, with penalties up to £40,000 for serious or repeat offences.
• Rent Repayment Order exposure — Rent Repayment Orders were extended by the Renters’ Rights Act to cover a wider range of housing offences, and an Awaab’s Law breach is widely expected to fall within scope.