Deadly data: poor systems led to Awaab’s Law, and they’re not being changed quickly enough. But here’s a way forward
On October 27, 2025, Awaab’s Law comes into force for the social rented sector in England – mandatory reporting will be required by May 2026 in Scotland. The law requires investigation of damp and mould within 48 hours in an emergency situation, and a report submitted to the tenant within three days of the investigation concluding. In the words of the government: “It is unacceptable for social landlords to assume that the cause of a hazard, such as damp and mould, is due to the tenant’s ‘lifestyle’”.
48 hours and three days – that’s not long to deliver. But it’s yet another piece of legislation arriving in response to tragedy that could have been prevented. And that’s why, essentially, patience has run out.
Named after Awaab Ishak, a two-year-old boy who died in 2020 from a respiratory condition brought on by mould on the walls in his home, these new regulations are putting the onus on housing organisations to act. Awaab’s parents had repeatedly complained about their living condition, but their pleas were ignored.
As a result of the outcry caused by this case, legislation was introduced through the Social Housing (Regulation) Act 2023, and inserted into tenancy agreements. All social landlords must meet the requirements in the Hazards in Social Housing (Prescribed Requirements) (England) Regulations 2025. This means that tenants can take legal action against landlords for a breach of contract if the terms are not adhered to.
For decades, local authorities had relied on housing officers and maintenance teams filing in spreadsheets, often based on tenant complaints. But it wasn’t working, and it particularly didn’t work in the case of Awaab Ishak. Siloed systems meant that data covering repairs, asset management, housing management, contractor logs and mobile workforce tools weren’t joined together.
New tools layered on outdated processes
The pattern of behaviour, according to Kirsty Duncan, account director at technology provider Netcall, is that housing providers, despite good intentions, often default to reactive, disconnected solutions when it comes to damp and mould”. She adds: “Too many landlords are layering new tools on top of outdated processes. But these responses often fail to tackle the root cause: disjointed systems, fragmented data, and a lack of end-to-end visibility.”
While many social housing landlords are moving to comply, ongoing fragmentation of those data systems is making it challenging. Adding a mould and damp interventions dashboard could just be yet another silo. And when systems don’t speak to each other, that’s working blind.
“Housing providers, despite good intentions, often default to reactive, disconnected solutions when it comes to damp and mould”
The solution is working out what, or who, a whole Housing Management System exists for. According to Patrick Chauvin, chief officer for safety, assets and sustainability at 39,000-home Stonewater, it’s obvious. “We focus on the assets, the homes, because we own them. But the biggest part of the equation here is the residents.”
Kirsty Duncan recommends jotting down the user journey experienced by those living in housing properties. This will, most crucially, highlight the systems and technology involved. Because the routes for complaints will be one of three options: online, by phone or via a neighbourhood officer. Then, how is the tenant informed about next steps by the housing company? What about communication to confirm completion of the work? Then have you checked back to see that the problem hasn’t returned?
This brings out the internal touchpoints. So that, according to Duncan, you should end up with a process diagram covering customer service, repairs, compliance, asset management. Which would reveal duplicate logging, lack of handovers, missed updates or decision making that doesn’t account for everyone involved as it’s being put to paper. The clearer picture that emerges is the foundation for a connected system.
Automating escalation ahead of a legal deadline
But the next step is not just appointing more people. David Lewis, executive group director of property services at 109,000-home L&Q, is right when he says about the new legislation that: “There are just real challenges around supply chain and capacity, both in-house… and externally.”
A well-built data system, however, can make this work. You can programme in proactive tenant comms when a hazard has been reported, automatic escalation ahead of a legal deadline, and the scheduling of future actions and notification around recurring issues. Which gets around the resource problem.
Predictive analysis is also possible. Wolverhampton Homes ran a pilot of 100 homes, identified on the basis of weather and flood patterns. They added information on previous reports, damp and mould complaints and repair histories. Then they produced a list of properties at risk using AI. It was 98% accurate in predicting issues within their portfolio.
“Housing providers can take a smarter, more proactive approach to tackling damp and mould”
According to Sam Dugmore, Wolverhampton Homes systems development and support manager: “By combining an AI’s ability to quickly analyse large volumes of data with the local insight gathered by teams on the ground, housing providers can take a smarter, more proactive approach to tackling damp and mould. For us, this new way of working has helped us to take more targeted action and get better outcomes for tenants.”
James Reseigh, director of neighbourhoods at 40,000-home LiveWest, believes that even with the help of technology, new legislation challenges the capacity of organisations to respond. That’s because the legislation covers a range of potential building defects – not just damp and mould. “When you look at those 29 hazards, it’s really hard to produce a report that can be automated,” he says.
Collaboration as a new way of working
Hence not just a new system, but a new way of working could be the answer. In other words, collaboration with other providers. The Future Homes Consortium comprises 20 landlords sharing data on repair demand. The 80,000-home Riverside group is part of the Greater Manchester Housing Partnership, with links with 10 local authorities in the city region: “We’re happy to share data”, says Ian Gregg, executive director of asset services at Riverside.
Meanwhile, a new data model is being devised by Housing Associations Charitable Trust with the National Housing Federation. This allows users to record, track and respond to health and safety issues caused by damp and mould in social-rented homes. The National Housing Federation introduces the proof of concept by outlining: “Structured data is essential if you want to use AI or automation tools in the future. This data model gives you the solid foundation you need.”
It has to because there’s more required from housing organisations. In 2026 regulation will be expanded to cover excess cold and heat, slopes and stairs, structural collapse, explosions, fire plus electrical hazards and domestic hygiene and food safety. In 2027 this will include all Housing Health and Safety Rating System hazards apart from overcrowding.
The government wants to see compliance, rather than your data systems. But you need the right management tools and databases in place to achieve that.
Do get in touch if you would like to talk through your situation and data requirements – you can drop a message to: ed.mcculloch@atendco.com
