Four filings and a declaration: what an MTD year actually looks like
Key takeaways MTD replaces one annual return with four quarterly updates and a Final Declaration. The quarterly updates are summaries, not mini tax returns....
Key takeaways
Most repair obligations are judged on outcome. Did you fix it, and was the fix adequate. Awaab’s Law is different, and the difference is the whole point of it: it is judged on the clock.
That single change turns a maintenance function into an evidence function. A landlord who fixed a hazard quickly but cannot show when it was reported and when someone attended is in a materially worse position than one who was slower and documented everything.
Here is what phase 2 adds during 2026, why the timestamp requirement reaches further into your systems than it first appears, and where the private sector currently stands.
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Phase 1 commenced for social landlords on 27 October 2025, covering damp and mould as significant hazards along with all emergency hazards. Phase 2 arrives during 2026. Phase 3 in 2027 extends the regime to all remaining hazards under the Housing Health and Safety Rating System.
The staging is deliberate. It starts with the hazard category that caused the law to exist, then widens until it covers the full HHSRS range, by which point effectively any serious housing hazard carries a statutory timescale.
Excess cold and excess heat. Falls. Structural collapse. Fire and electrical risks.
Excess cold is the one that will generate the most volume, because it is seasonal, widely reported, and often entangled with the same building fabric problems that produce damp. A heating failure in December is now a clocked obligation rather than a routine job.
Falls is the one most likely to catch operators out, because it covers hazards that are easy to log as low priority: a loose handrail, uneven steps, poor stair lighting. Those tickets have historically sat in a general queue, and phase 2 gives them a deadline.
Fire and electrical bring the regime alongside existing certification duties, which means the EICR is no longer just a document to renew. It is evidence about a hazard category with a response clock attached.
The obligation runs from the point a hazard is reported. That makes the report time a legally significant fact, and it is usually the least reliable data point in a maintenance system.
Consider how reports actually arrive. A phone call to a housing officer. A message to a caretaker. An email to a shared inbox. A comment during an unrelated visit. Each of those is a start point for the clock, and most organisations capture none of them with a timestamp.
A ticket created three days after a tenant first mentioned the problem starts the clock in the wrong place, and the only record of the real start is the tenant’s account. In a dispute, that account is the evidence and yours is absent.
So the practical requirement is not faster contractors. It is capturing the moment of report, from every channel, with a time attached.
Four data points, reliably captured, for every hazard report.
When it was reported and through which channel. When it was assessed and what the assessment concluded. When a contractor attended. When the work was verified complete, ideally with the tenant confirming.
A kanban board with no dates on it satisfies none of that. Neither does an email thread, because threads record when messages were sent rather than when work happened.
For approved housing bodies and local authorities managing thousands of units, the aggregate matters too: not only can you evidence one case, but can you report performance against the timescales across the stock.
No implementation date for the private rented sector has been announced. The Renters’ Rights Act 2025 contains the legal hooks to extend Awaab’s Law to private landlords, but the commencement has not followed.
Shelter has suggested 2027 as the earliest plausible date, and several legal commentators agree that 2027 is the realistic floor rather than a firm expectation. The private version is expected to mirror the social housing sequence, starting with damp, mould and emergency hazards before widening.
For private landlords the sensible reading is that this is coming, that the shape is already visible in the social housing phases, and that the systems change it requires, timestamped hazard reporting, is worth having regardless. Our Awaab’s Law guide tracks the position as it develops.
Rentalize timestamps a hazard report at the point of capture, across channels, and holds assessment, attendance and completion against the same record. The elapsed time the obligation is measured in is therefore a reported number rather than something reconstructed from emails.
That sits in Rentalize Core for social landlords and housing bodies, alongside Renters’ Rights Act compliance for the wider English regime.
If you would like to see the hazard clock running against real tickets, you can book a 20 minute walkthrough, or look at pricing.
Excess cold and excess heat, falls, structural collapse, fire and electrical risks, added during 2026 to the damp, mould and emergency hazards already covered by phase 1.
Phase 1 commenced for social landlords on 27 October 2025. Phase 2 follows during 2026 and phase 3 in 2027 extends it to all remaining HHSRS hazards.
Not yet. The Renters’ Rights Act 2025 contains the hooks to extend it, but no implementation date has been announced. 2027 is widely considered the earliest plausible date.
The obligation is measured in elapsed time from the point a hazard is reported, so a maintenance record without reliable report and attendance times cannot evidence compliance even where the work was done promptly.
When the hazard was reported and through which channel, when it was assessed and what was concluded, when a contractor attended, and when the work was verified complete.
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