A landlord’s ‘homework’ needs to show its workings, argues Phil Shelton, as he examines the vital need to demonstrate processes with evidence
Numbers don’t have emotions or worry about things the way we do. They don’t feel the need to defend themselves either, but they do tell you where things stand.
The Monthly Pulse from Housemark (May 2026) found that only 4% of social landlords feel “very prepared” for Awaab’s Law Phase 2.
While we are warming to the subject, let me introduce you to some other numbers. Even though 80% say they’ve invested in staff training, only 57% trust their IT systems to collect and report the compliance data these newly trained staff will need.
So it appears that landlords are preparing people to make decisions but are less confident that their systems can capture and prove those decisions.
That’s important because from 30 November, Awaab’s Law expands mandatory timelines for investigation and repair to a further seven hazard categories. These include excess cold and heat, fire safety, electrical dangers, falls, structural collapse and hygiene problems.
Landlords have 10 working days to investigate. If a major risk is identified, they are given 24 hours to make the property safe.
Ten working days; 24 hours if it is urgent
Your housing board will likely have those numbers front and centre from 30 November. But you may be more concerned about how you provide proof than about hitting those targets.
Could your team show exactly what was reported, what was investigated, what people did after decisions were made, and why? For example, if a renter, an Ombudsman investigator, or a court asked to see that information, could you quickly and correctly put it together?
The National Housing Federation (NHF) has put a price on what landlords are facing. Phase 2 compliance will cost more than £213m over the next 10 years, and the sector is not ready for the “end-to-end case-management requirement” that it brings.
There are already reports from members that more repairs are being deemed urgent. Such changes could mean resources are diverted from routine and preventative work. Also, the direction itself? “It’s still not clear and complete,” the NHF said. Still, this information isn’t enough to help landlords figure out how to use the longer list of hazards.
The clock is only half the problem
It’s interesting to note that gas safety compliance has dropped from 40% in 2024 to 31% this year, according to Housemark. Yet 82% of emergency hazards are cleared within 24 hours.
These numbers tally with our story, showing that the sector is getting faster at front-end decisions. But it’s falling behind on the paperwork that should defend those same decisions.
“You don’t rise to the level of your goals. You fall to the level of your systems,” so says James Clear in Atomic Habits.
There is no question that a landlord can meet a deadline and still fail an Ombudsman investigation if they don’t keep good records. A recent county court case shows what’s required for a good outcome.
A judge gave Stonewater a forced-access order so it could carry out a safety inspection that was overdue. The tenant had repeatedly failed to respond to access requests, despite being given plenty of notice.
Stonewater was able to provide the evidence the court required, i.e., signs that the household was vulnerable, at least 48 hours’ notice, and confirmation that the order would not be carried out if the tenant was present and actively blocking entry.
A nearly similar application had been turned down months before. The proof, not the safety risk, made the difference. One landlord could show an evidence trail; the other one couldn’t.
Forced access is a last resort and, in most cases, will never get to a courtroom. But this story leads back to my question… If someone challenges a decision, can you show what you did, when, and why?
Phase 2 and STAIRs
The Housing Ombudsman has now made it harder to avoid this question. Its updated plan, which came out before STAIRs, says that from October 1, 2026, private registered providers must share details about their management, funds, stock, performance, and services.
Tenants will be able to make formal requests for information starting in April 2027. Landlords will have 30 calendar days to reply.
Put Phase 2 and STAIRs side by side, and you are being asked for the same thing from two directions:
- Awaab’s Law wants evidence that a hazard was investigated and acted on within the timescale
- STAIRs wants evidence that the landlord’s information is accurate, complete, and retrievable on request
Both regulators are testing whether a housing provider’s knowledge of its stock and its own decisions can survive scrutiny after the fact.
The Regulator of Social Housing said much the same in its 2026 Regulatory Casework Review. That is, good quality, accurate and timely data holds governance together. In contrast, failures in data quality and usage keep turning up in cases where landlords fall short.
What’s changed is that Awaab’s Law and STAIRs now attach hard deadlines and a named regulator to that warning.
Take the readiness test
In practice, the evidence means four things:
1: The hazard record itself
2: The notices sent to the tenant
3: The log of attempted access
4: Any vulnerability considerations that shaped your approach
Miss one of these and the record doesn’t hold up, no matter how sound your decision seems to you. Many organisations aren’t set up to pass that test today. Repairs history sits in one system, safety inspections in another, resident vulnerability flags in a third, and the notices sent to a tenant in someone’s inbox or a paper file.
I’ve spent years building housing software around the way officers actually work, instead of how a process looks on paper. The real test of Phase 2 readiness is what happens when a straightforward case stops being, well, straightforward.
The disconnect between what a board thinks its systems can produce and what an officer can actually pull together on a Friday afternoon still amazes me.
I’d put the readiness question to any board this way…
Pick one property with a live access issue or a hazard under investigation right now. Ask an officer (not a manager), to pull together everything you need to meet the new obligations. Every notice sent, every attempted visit, every vulnerability consideration, every decision and who made it.
And time how long it takes.
Then ask whether that record would satisfy a district judge, or an Ombudsman investigator, or a tenant who’s just submitted a formal information request. If the answer is “it would take days” or “some of it doesn’t exist,” that’s got to change.
Four months isn’t enough time to build a whole new system from scratch. It is enough time to find out where your records can be improved before a court, a regulator, or a tenant wants to see them.
Main image: Phil Shelton is chief executive of HousingAI
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