A landlord managing three HMOs in Leicester emailed us convinced he was already breaking Awaab's Law over a damp bedroom ceiling reported by a tenant on a Tuesday. He wasn't. Awaab's Law doesn't apply to him at all, not yet. What he'd actually forgotten about was a duty that's been sitting in place since long before Awaab's Law existed.
Awaab's Law currently applies only to social housing, since 27 October 2025. It can be extended to private landlords under the Renters' Rights Act 2025, but no commencement date has been confirmed. Private and HMO landlords are not off the hook in the meantime: existing law already requires damp and mould hazards to be fixed within a reasonable time.
Does Awaab's Law Actually Apply to Your HMO Right Now?
No, and this is worth being precise about, because a lot of the content written about this online blurs the line. Awaab's Law came into force for social landlords on 27 October 2025, setting fixed deadlines: investigate a significant hazard within 10 working days, provide a written summary within 3 working days of that, and complete safety works within 5 working days. Emergency hazards must be made safe within 24 hours.
The official government guidance is explicit that this currently applies to social housing. The Renters' Rights Act 2025 gives ministers the power to extend the same regime to private landlords, including HMOs, but that extension needs its own consultation and regulations, and as of mid-2026 no date has been set. Treat anyone telling you a firm date with real scepticism until it appears on gov.uk.
What Already Applies to Private and HMO Landlords
| Law | What It Actually Requires |
|---|---|
| Landlord and Tenant Act 1985, Section 11 | Keep the structure and installations, including those affecting damp, in repair, and act within a reasonable time of being told |
| Homes (Fitness for Human Habitation) Act 2018 | The property must be fit for habitation throughout the tenancy, not just at the start; damp and mould can make it unfit |
| Housing Act 2004, Part 1 (HHSRS) | Local authorities can assess damp and mould as a Category 1 or 2 hazard and take enforcement action independently of any tenant complaint |
| HMO Management Regulations 2006 | Requires the manager to keep the property free from damp so far as reasonably practicable |
None of these come with Awaab's Law's fixed clock, but "reasonable time" and "reasonably practicable" are not vague enough to ignore. Courts and local authority enforcement teams look at how quickly a landlord actually acted once they knew, and a landlord who sat on a written damp report for six weeks will struggle to argue that was reasonable, clock or no clock.
Why Prepare for the Extension Anyway?
This is a genuine trade opinion rather than a legal requirement: run your HMO as though Awaab's Law's timescales already applied, even though they technically don't yet. Acknowledge a damp report the day it arrives, inspect within days rather than weeks, and keep a written record of what you did and when. There are three reasons this is worth doing now rather than waiting for the regulations to land.
First, it's the standard local authorities and courts already measure "reasonable time" against informally, since Awaab's Law has reset expectations across the whole sector even where it isn't legally binding yet. Second, when the extension does commence, whenever that turns out to be, you'll already have the process built rather than scrambling. Third, and most simply, damp and mould genuinely gets worse the longer it's left, so slow-walking a report costs more to fix later regardless of what any law says.
Auditing a whole HMO at once? Our printable compliance checklist covers damp alongside EICR, fire doors and emergency lighting on one page.
Get the HMO Compliance Checklist →What Does a Defensible Response Actually Look Like?
If a tenant reports damp or mould, the practical version of "acting within a reasonable time" looks like this: acknowledge the report in writing the same day, inspect within a week wherever possible, and identify the actual cause before treating the visible symptom. Painting over mould without fixing the ventilation or leak behind it buys a few weeks at most, and a local authority officer reviewing the case afterwards will read that as evidence the underlying hazard wasn't properly addressed, not as evidence of prompt action.
Keep everything in writing: the tenant's report, your acknowledgement, the inspection findings, and what work was done and when. This is the single biggest gap we hear about from landlords after the fact. The work often did get done, but nobody can prove when, which matters considerably if a complaint reaches the Housing Ombudsman, a local authority, or court. If a damp bathroom is also raising questions about sanitary provision more broadly, our BS 6465 HMO Bathrooms: How Many Do You Need? covers that separately.
Frequently Asked Questions
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