Excess cold, and the clock that starts on 30 November

Most heating systems in England will be switched on within the next six weeks. A few weeks after that, on 30 November 2026, the second phase of Awaab's Law comes into force, and excess cold becomes a hazard that carries a statutory deadline rather than a service standard (Ministry of Housing, Communities and Local Government, 2026).

The timing is worth sitting with. Phase 1 dealt with damp and mould, which build slowly and get reported unevenly through the year. Cold does not behave like that. It arrives everywhere on the same night, and the reports arrive with it.

What Phase 2 adds

The first phase, in force since 27 October 2025, put fixed timescales on damp, mould and emergency hazards. Phase 2 widens the duty to a further set of hazards drawn from the Housing Health and Safety Rating System: excess cold and excess heat, falls on the level, on stairs and between levels, structural collapse and explosions, fire and electrical hazards, and domestic and personal hygiene and food safety hazards, where any of them present a significant risk of harm.

A third phase in 2027 is expected to bring in the remaining HHSRS hazards apart from overcrowding.

The clock, in plain terms

The deadlines are the same ones Phase 1 established, applied to a longer list.

An emergency hazard, one a reasonable landlord would make safe within 24 hours, has to be investigated and made safe within 24 hours of the landlord becoming aware of it. A boiler failure in a flat with a frail resident in December is that.

For a significant hazard, the landlord has 10 working days from becoming aware to investigate. Within 3 working days of the investigation concluding, the tenant gets a written summary of what was found. Relevant safety work starts within 5 working days of the investigation concluding. Supplementary preventative work also starts within that 5 working days, or, where that is not reasonably practicable, as soon as it is and in any case within 12 weeks.

Where the work cannot be done inside those windows, the landlord has to secure suitable alternative accommodation for the household at its own expense until the home is safe.

Every one of those obligations is dated. None of them can be evidenced after the fact by someone remembering roughly when the call came in.

Why cold concentrates the problem

Cold weather is not a background risk. The UK Health Security Agency's first cold mortality report, published on 18 February 2026, associated 2,544 deaths in England with cold weather across three cold episodes between November 2024 and January 2025. A single six-day period in early January accounted for 1,630 of them (UK Health Security Agency, 2026).

For a landlord, the operational consequence is clustering. A week of hard frost produces twenty reports of a cold flat in the same few days, and each one starts its own 10 working day clock on the day it was received. The organisations that will struggle are not the ones with the worst heating plant. They are the ones that cannot say, in December, which report came in on which day and who picked it up.

What to have straight before the first cold week

Three things, and none of them are new work.

Know the state of the heating plant. Communal boilers, heat interface units, electric storage heaters, the last service date and the next one. If a system fails in week one of the cold, the question of whether it was serviced will be asked.

Know the repair history flat by flat. A property with three cold reports over two winters is a different case from a first report, both operationally and if it is ever examined.

Have one dated route in. A report that arrives by phone, by email and through a caretaker is three chances to lose the date the clock started on.

Where SAMRISK fits

Awaab's Law is procedural as much as physical. Investigate on time, write down what you found, tell the tenant, book the work, prove it was done.

In SAMRISK a reported hazard is a dated incident with an owner and a deadline attached to it, not a note in an inbox. The heating plant sits on the building's maintenance schedule, so the service records exist before anyone asks for them, and the statutory dates land on the compliance calendar as dates on a screen. The written summaries, photographs and sign-offs live with the building's other documents, so the account of what happened assembles itself.

The buildings will be exactly as cold on 30 November as they were the week before. What changes is how quickly you have to answer for them, and how much of the answer you can produce without going looking.