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Diagnosing Damp Before Enforcing Deadlines

14th January 2026

Andy Cameron-Smith

What Awaab’s Law is revealing about skills, systems and the limits of compliance. 

The introduction of Awaab’s Law has brought renewed urgency to how damp and mould are managed in social housing. While the issue itself is longstanding, the statutory timeframes now attached to it are reshaping operational behaviour across the sector. Early indications suggest that compliance alone will not resolve the problem. Instead, the legislation is exposing deeper weaknesses in diagnostic capability, asset strategy and organisational readiness. 

This assessment reflects the combined professional experience of Lucy Mullineux, Senior Associate Partner at Baily Garner, and Simon Thirtle, Partner and Head of Affordable Housing at Ward Hadaway. Drawing on building surveying, asset management and housing law perspectives, their insights highlight how Awaab’s Law is interacting with existing practice, and where risks remain. 

Awaab’s Law came into force in October 2025. It requires landlords to investigate reports of damp and mould within ten working days and to complete safety works within a further five. Emergency hazards must be addressed within 24 hours. The intention is clear. Homes must be made safe quickly. However, the law also places pressure on systems that have historically struggled to move beyond reactive repair. 

Diagnosis remains the weak point 

Despite years of guidance and case law, damp and mould are still too often treated as problems to be cleaned rather than conditions to be properly understood. Visible mould frequently triggers remediation without sufficient investigation into cause. This leads to repeated interventions that fail to resolve underlying moisture imbalance. 

Practice still relies heavily on non-invasive testing methods and simplified categorisation of damp. In reality, causes are often linked to fabric defects, alterations over time, poorly integrated retrofit measures or inadequate ventilation. Without a robust diagnostic process, even well-intentioned compliance risks becoming superficial. 

Awaab’s Law allows time for follow on works after immediate safety measures. The value of this provision depends on whether landlords use that period to identify and address root causes rather than closing cases prematurely. 

Legal clarity, operational reality 

From a regulatory perspective, Awaab’s Law continues a longer trajectory of strengthening landlord accountability. Previous legislative changes, including the Housing Health and Safety Rating System and the Homes (Fitness for Human Habitation) Act, have all contributed to gradual improvements in housing standards. 

However, the gap between regulatory expectation and delivery capacity remains significant. Responding to damp and mould at scale requires skilled assessment, specialist contractors and coordinated follow on works. For many providers, annual expenditure linked to damp and mould is already material and expected to rise further. 

The legislation does recognise practical constraints. Defences exist where access cannot be gained, but inspections and engagement attempts must still take place. Repeated access failures can also indicate wider vulnerability, including hoarding or mental health needs. This reinforces the need for damp and mould responses to be integrated with tenancy support rather than treated as isolated technical tasks. 

Early impacts and emerging pressures 

Initial feedback from housing providers suggests a notable increase in reported damp and mould cases, in some instances by up to 50 per cent compared with the previous year. This appears linked to increased tenant awareness ahead of implementation rather than a sudden deterioration in stock condition. 

While many organisations had prepared, the rise has highlighted pressure points in triage. Determining hazard severity requires skill and confidence. Some landlords have responded by defaulting to rapid mould cleaning within 24 hours, regardless of risk level, to avoid breaching statutory timescales. 

While understandable, this approach carries risk. Cleaning alone does not prevent recurrence and may create a false sense of resolution if not followed by investigation and preventative works. 

Behaviour versus building performance 

Resident behaviour continues to feature in damp and mould discussions. Evidence from site inspections consistently shows that building related factors are almost always present. Moisture problems are rarely attributable to behaviour alone. 

This distinction matters. Over emphasis on lifestyle explanations can delay effective intervention, undermine trust and overlook the cumulative health impacts of prolonged exposure, particularly for children, older people and those with respiratory conditions. Proper diagnosis must therefore begin with the building, not the occupant. 

Ventilation, energy and unintended consequences 

Ventilation is increasingly recognised as central to damp and mould prevention, yet it has historically been undervalued. As homes become more airtight through energy efficiency upgrades, poorly designed or insufficient ventilation can worsen moisture problems rather than resolve them. 

There are positive signs. More landlords are adopting integrated retrofit approaches that consider insulation, heating and ventilation as a single system. This reflects a growing focus on long term performance rather than minimum compliance. 

However, the energy affordability crisis remains unresolved. Awaab’s Law cannot address underheating driven by high energy costs. This remains a structural issue that continues to influence moisture risk in occupied homes. 

From reactive response to planned prevention 

Perhaps the most significant shift prompted by Awaab’s Law is cultural. Increasingly, providers are reviewing asset management strategies to prioritise prevention. This includes using void periods to address known damp risks, coordinating planned works and investing in measures designed to last a decade or more. 

This approach aligns with our perspective at Healthy Homes Hub. Prevention reduces repeat costs, improves resident health outcomes and supports more sustainable asset management. It also recognises that damp and mould are indicators of how well homes perform over time. 

Practical steps for housing providers  

  1. Strengthen frontline capability to triage, assess and escalate damp and mould appropriately. 

  2. Treat mould removal as an interim safety measure, not a resolution. 

  3. Embed ventilation, heating and fabric improvements within a whole home strategy. 

  4. Use access challenges as signals for wider tenancy support needs. 

  5. Shift investment towards planned, preventative works that reduce long term health and financial risk. 

Awaab’s Law sets firm expectations. Meeting them sustainably depends less on speed alone and more on skill, coordination and a clear understanding of how homes actually work. 

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