Phase 1 of Awaab's Law took effect in England on 27 October 2025 and dealt with damp and mould. Phase 2 is due on 30 November 2026, subject to parliamentary approval of the amendment regulations, and it widens the list of hazards that carry fixed response timescales. For anyone responsible for roofs, three of the new hazards matter directly: structural collapse and falling elements, falls, and excess cold.
This article is about the evidence side. Not the legal duties, which your compliance team will already be tracking, but the practical question of what a housing provider should have on file about its roofs before the new timescales apply.
What Phase 2 changes for roofs
The Phase 1 regime set a pattern that Phase 2 extends. Emergency hazards must be actioned within 24 hours. For significant hazards, a landlord must investigate within ten working days, provide a written summary within three working days of the investigation, complete safety work within five working days, and begin any longer-term repair within twelve weeks.
Under Phase 2 that pattern reaches roofs in several ways. A loose parapet, a slipped ridge tile or a failing chimney stack is a falling-element hazard. A roof that has lost coverings or has open joints can drive excess cold in the dwellings below it. And a roof leak that has been running for a season is where the Phase 1 damp and mould cases often started.
The important detail is when the clock starts. It runs from the point the landlord becomes aware of a potential hazard. That awareness can come from a tenant complaint, from a repair operative, or from your own survey. The difference is that a survey lets you decide the order of work rather than have it decided for you by whoever reports first.
Why roofs are the weakest part of most stock condition data
Most stock condition surveys are carried out from the ground. Surveyors look up, note what they can see from the street and the garden, and record the roof as inspected as far as visible or, often, not inspected. Terraces are worse than semis because the rear slopes can only be seen from someone else's garden. Flat roofs are frequently not seen at all.
The Regulator of Social Housing's Safety and Quality Standard expects landlords to hold an accurate, up-to-date and evidenced understanding of the condition of their homes. Regulatory judgements that downgraded landlords to C3 or C4 in recent years have repeatedly cited weak stock condition coverage. Roofs are the largest single gap in that coverage for most providers, simply because of access.
Scaffolding a roof to inspect it costs more than most inspections are worth. Cherry-picker hire is cheaper but still runs to hundreds of pounds a day, needs a hard standing and closes footpaths. That is why the gap persists.
Twenty to fifty roofs on one estate, flown to a standard shot list, reviewed by a named person, delivered as component rows your asset system can import.
What a drone survey does and does not give you
A drone roof survey gives you dated, located photographs of every slope, every chimney, every gutter run and every flashing, captured in an hour per property rather than a day. Flown to a standard shot list, it produces the same coverage on every property, which is what makes the results comparable across an estate.
What it does not give you is a hazard rating. The Housing Health and Safety Rating System assesses the dwelling and the likelihood and severity of harm to an occupant. That is a competent person's judgement made with knowledge of the property and the household. A drone operator and a reviewer can tell you that four tiles have slipped at the eaves above the front door, that the ridge mortar has failed along two metres, and that the chimney flaunching is cracked. Your assessor then decides what that means under HHSRS and where it sits in your Phase 2 process.
The distinction matters for two reasons. It keeps the survey honest about what it is. And it keeps the decision about statutory clocks with you, not with a contractor's report template.
What the evidence pack should contain
If you commission aerial roof evidence ahead of Phase 2, ask for four things and be suspicious of any provider who only offers the first.
- Component rows per property. One row per roof component per UPRN: covering, structure, chimney, rainwater goods, flashings, fascias and soffits, rooflights, parapets. Material, observed condition on the scale your asset management system uses, a priority code and the photo references. This is what your asset team imports. A PDF is not.
- A photo pack that files itself. Each accepted observation as a crop, plus one annotated overview per slope, named by UPRN, roof zone and slope. Not every frame the drone captured.
- A report a person signed. With the flight details, coverage limitations, the slopes that were not seen, and a named reviewer. If the provider used AI to pre-screen imagery, the report should say so and a person should have accepted every item.
- An urgent flag process. Any item the reviewer thinks needs making safe should reach you by phone the same day it is reviewed, before the report is issued. That way a P1 item enters your process on your terms.
A sensible order of work before November
Nobody is going to survey a whole stock in twelve weeks, and you should not try. A practical sequence looks like this.
- Pull the properties your last stock condition survey recorded as roof not inspected or inspected from ground level only. That is your unknown list.
- Sort it by archetype and age. Pre-1919 terraces with slate coverings and shared chimneys carry more falling-element risk than a 2005 estate with concrete interlocking tiles.
- Fly the top of that list as estate sweeps, ten to thirty roofs a day where the properties are clustered, so the per-roof cost stays sensible.
- Feed the component rows into your asset system and let your HHSRS assessors work the P1 and P2 items through your existing hazard process.
- Keep the imagery. A re-survey in a year is worth far more if it can be compared to a baseline.
The goal is not to have surveyed everything by 30 November. It is to know where your worst roofs are, to have acted on the ones that need making safe, and to be able to show the regulator that the rest are on a plan.