EliteShiresProperty Services

Landlord law

HHSRS for landlords: the 21 hazards that replaced the 29

HHSRS, checked October 2026: since 23 June 2026 councils rate 21 hazards, not 29, in High, Medium and Low bands. What a Category 1 hazard means and costs.

Key takeaways

  • The HHSRS is how councils rate hazards in a home under Part 1 of the Housing Act 2004. Since 23 June 2026 it has 21 hazards, down from 29, after a government review.
  • The ten lettered bands (A to J) have gone. A score of 1,000 or more is now the High band and a Category 1 hazard, which the council must act on.
  • Councils can serve improvement notices and prohibition orders, or take emergency action. Since 22 June 2026 they can also fine up to £7,000 for a Category 1 hazard you could reasonably have removed.
  • Ignoring an improvement notice is a criminal offence. For offences on or after 1 May 2026 the civil penalty is up to £40,000, and rent repayment orders reach two years' rent.
  • Most hazards councils find are ordinary repairs. We fix heating, plumbing, electrics, ventilation, doors and trip hazards. We do not diagnose damp, and we refer that on.
In this guide

The Housing Health and Safety Rating System (HHSRS) is the method councils use to assess hazards in homes under Part 1 of the Housing Act 2004. Since 23 June 2026 it rates 21 hazards, not 29, in High, Medium and Low bands. A High score is a Category 1 hazard, and the council must act. Checked October 2026.

Many guides still list 29 hazards and the bands A to J. Both were replaced by the Housing Health and Safety Rating System (England) (Amendment) Regulations 2026 (SI 2026/571). This guide explains the current system, how councils use it, and which hazards are ordinary repairs. We are EliteShires Property Services, on Kenton Lane in Harrow. We carry out repairs and maintenance for landlords across Harrow, Kenton, Stanmore and Edgware.

What is the HHSRS, and who uses it?

The HHSRS is a risk assessment tool for councils, set out in the Housing Health and Safety Rating System (England) Regulations 2005. It applies to every home, rented or owned. In practice councils use it mostly on private lets, which is where most of their housing enforcement happens.

An environmental health officer inspects the whole property, including the garden and outbuildings. They look for any defect in design, layout, repair or maintenance. For each defect they ask two questions. How likely is harm needing medical attention over the next 12 months? And how bad would that harm be?

The assessor scores the risk for the most vulnerable age group for that hazard, not the people living there now. GOV.UK's example is that someone aged 65 or over is more likely to fall down the stairs (landlord guide, updated 16 September 2026). So a steep staircase can score badly even if your tenant is a fit 30-year-old.

Inspections usually follow a tenant complaint. Referrals can also come from children's services, adult social care, the police or a GP surgery, and some councils inspect as part of a licensing scheme. GOV.UK's landlord guide says landlords need not train as assessors. They do need to keep their homes free of Category 1 hazards.

What changed in the HHSRS in 2026?

A government review simplified the system, and the new version applies to council inspections that began on or after 23 June 2026 (SI 2026/571, with the start date corrected by SI 2026/629). The main changes are:

  1. 21 hazards instead of 29. Thirteen overlapping hazards were merged into five.
  2. Three bands instead of ten. The bands A to J became High, Medium and Low.
  3. Simpler likelihood scoring. GOV.UK's guide says the 16 likelihood categories have been grouped into four bands, from very likely to very unlikely.
  4. Harm classes renamed. Classes I to IV are now extreme, severe, serious and moderate.
  5. Baseline indicators. A checklist of reasonable standards, from drainage to fire safety. Falling below one is generally treated as a deficiency to assess. GOV.UK says they are not mandatory standards.
How the 29 HHSRS hazards became 21 Five merges made by the 2026 amendment regulations. Biocides, carbon monoxide and fuel combustion products, uncombusted fuel gas and volatile organic compounds became indoor air pollutants. Domestic hygiene, pests and refuse, food safety, and personal hygiene, sanitation and drainage became domestic hygiene. Falls associated with baths and falling on level surfaces became falls on the level. Fire and explosions became fire and explosions. Collision and entrapment, and position and operability of amenities, became collisions, entrapment and ergonomics. The other sixteen hazards carried over, making 21. HHSRS FROM 23 JUNE 2026: 13 HAZARDS MERGED INTO 5 BEFORE (29 HAZARDS) NOW (21 HAZARDS) Biocides Carbon monoxide and fuel combustion products Uncombusted fuel gas Volatile organic compounds Indoor air pollutants Domestic hygiene, pests and refuse Food safety Personal hygiene, sanitation and drainage Domestic hygiene Falls associated with baths etc Falling on level surfaces etc Falls on the level Fire Explosions Fire and explosions Collision and entrapment Position and operability of amenities Collisions, entrapment and ergonomics The other 16 hazards carried over, from damp and mould to structural collapse. 16 carried over + 5 merged = 21. Source: SI 2026/571, Schedule 1 to the 2005 Regulations.
How the 29 hazards became 21. Thirteen old hazards were merged into five; the other sixteen carried over.

What are the 21 HHSRS hazards?

The 21 hazards are listed in Schedule 1 to the 2005 Regulations, as amended in 2026. The table gives each one, what it covers, and the usual fix. The last column is our practical view, not part of the law.

The 21 HHSRS hazards in England from 23 June 2026, and typical fixes

HazardWhat it coversTypical fix, and who does it
Damp and mould growthDamp, mould and dust mitesFind the cause first (a specialist or surveyor if unclear), then repair leaks and ventilation
Excess coldHomes that can't be kept warmHeating repairs, radiators, controls; insulation
Excess heatOverheatingVentilation, shading, controls
Asbestos and MMFAsbestos fibres and man-made mineral fibresLicensed or specialist contractor
Indoor air pollutantsCarbon monoxide, unburnt fuel gas, nitrogen dioxide, sulphur dioxide and smoke, timber and mould treatments, VOCsGas safety check, flue repairs, CO alarms
LeadLead pipework and old lead paintPipework replacement by a plumber; careful paint removal
RadiationMainly radon gasSpecialist testing and remediation
Crowding and spaceToo little space for the householdA management or letting decision, not a repair
Entry by intrudersWeak doors, locks and windowsLock changes, window locks, door repairs
LightingToo little natural or artificial lightElectrical work, extra lighting
NoiseNoise from outside or between homesOften a sound insulation or glazing job
Domestic hygieneFood preparation, pests, refuse, washing facilities, sanitation and drainageKitchen and bathroom repairs, blocked drains
Water supplyAdequate, clean drinking waterPlumbing repairs
Falls on the levelFalls on flat surfaces, at baths and showers, and steps under 300mmRe-laying flooring, fixing trip edges, grab rails
Falling on stairs etcStairs, steps and rampsHandrails, loose treads, stair lighting
Falling between levelsWindows, balconies, landingsWindow restrictors, balustrades, guarding
Electrical hazardsShock and burns from the installationEICR remedial work, RCD protection, a consumer unit change
Fire and explosionsFire, smoke and fumes, and explosionsSmoke alarms, fire doors, escape routes
Flames, hot surfaces etcBurns and scaldsPipe guards, hot water temperature controls
Collisions, entrapment and ergonomicsDoors, windows and fittings that trap or hit, and badly placed amenitiesDoor and window repairs, refitting
Structural collapse and falling elementsCollapse of the building or parts of itStructural engineer or roofer

Which hazards should you look at first? GOV.UK does not publish a breakdown for the new list. The phasing of Awaab's Law in social housing is a fair guide. Phase 1 covered emergency hazards and significant damp and mould. Phase 2 adds excess cold and heat, falls, structural collapse, fire and explosions, electrical and hygiene hazards.

What is the difference between a Category 1 and Category 2 hazard?

A Category 1 hazard scores 1,000 or more and falls in the High band. The council has a duty to act on it (Housing Act 2004, section 5). A Category 2 hazard scores under 1,000 and falls in the Medium band (100 to 999) or the Low band (under 100). The council has a power to act on it, but no duty (section 7).

HHSRS bands before and after 23 June 2026

ScoreBeforeFrom 23 June 2026What the council must do
1,000 or moreBands A, B or CHigh bandCategory 1: must take action
100 to 999Bands D to FMedium bandCategory 2: may take action
Under 100Bands G to JLow bandCategory 2: may take action

GOV.UK's landlord guide gives an example. A 1920s house with no working fixed heating scored 31,145 for excess cold. That is far above the 1,000 line. Each hazard is scored on its own, so one home can have a Category 1 hazard and several Category 2 ones at once.

What can the council do about a hazard?

The council can serve a hazard awareness notice, an improvement notice or a prohibition order, or take emergency action, and must explain its choice in a statement of reasons. GOV.UK's landlord guide sets out each option:

  • Hazard awareness notice. Advice only. It requires no work and carries no right of appeal.
  • Improvement notice. Requires set works by a set date. The works can't be required to start sooner than 28 days after service. Not complying is an offence.
  • Prohibition order. Stops use of all or part of the home, or limits who can live there. It takes effect 28 days after it is made.
  • Emergency remedial action. The council does the work itself, for a Category 1 hazard with an imminent risk of serious harm. GOV.UK's examples include exposed cables in a child's bedroom.
  • Emergency prohibition order. Takes effect the same day, for the same level of risk.
  • Demolition order or clearance area. Rare, and for Category 1 hazards only.

The council can charge a reasonable fee for taking action. It can also recover its costs for emergency work. You can appeal most notices to the First-tier Tribunal (Property Chamber), within 21 days for an improvement notice and 28 days for most others. GOV.UK's guide suggests talking to the case officer first. You keep your right of appeal if you settle before the deadline.

HHSRS: from inspection to enforcement A flow chart. A complaint, referral or licensing visit leads to a council inspection against the baseline indicators, and each hazard is scored. A score of 1,000 or more is the High band and a Category 1 hazard: the council must act, and may also fine up to 7,000 pounds if removal was reasonably practicable. A score under 1,000 is the Medium or Low band and a Category 2 hazard: the council may act. The options are a hazard awareness notice, an improvement notice or a prohibition order; for a Category 1 hazard with imminent risk, emergency remedial action or an emergency prohibition order. Ignoring an improvement notice can lead to prosecution or a civil penalty of up to 40,000 pounds, works in default and a rent repayment order. HHSRS: FROM INSPECTION TO ENFORCEMENT Trigger Complaint, referral or licensing Council inspection Against baseline indicators Each hazard scored Likelihood and severity of harm High band: 1,000 or more Category 1: the council must act It may also fine up to £7,000 where removal was reasonably practicable (s.6A) Medium or Low band: under 1,000 Category 2: the council may act Medium is 100 to 999, Low under 100 The council's options Hazard awareness notice (advice only) · Improvement notice · Prohibition order Category 1 with imminent risk only: emergency remedial action or emergency prohibition order Improvement notice ignored Prosecution, or a civil penalty up to £40,000 (offences from 1 May 2026) Works in default · rent repayment order up to two years' rent
From inspection to enforcement under the HHSRS. Category 1 brings a duty to act; Category 2 a power.

What are the penalties under the HHSRS now?

The main penalties are a fine of up to £7,000 for a Category 1 hazard, prosecution or a civil penalty of up to £40,000 for ignoring an improvement notice, and a rent repayment order of up to two years' rent. Two of these changed in 2026.

  1. Category 1 hazard penalty: up to £7,000. Since 22 June 2026, a council taking action on a Category 1 hazard can fine the person responsible up to £7,000. It applies where removing the hazard was reasonably practicable and they failed to do it (Housing Act 2004, section 6A, inserted by the Renters' Rights Act 2025). It does not apply to the common parts of a building containing flats.
  2. Ignoring an improvement notice: up to £40,000. It is a criminal offence. The council can prosecute, with an unlimited fine, or impose a civil penalty instead. That penalty is up to £40,000 for offences on or after 1 May 2026, and £30,000 before (section 249A). Some guides still quote £30,000 as the current figure.
  3. Rent repayment orders. For offences on or after 1 May 2026, a tenant or council can claim back up to two years' rent where an improvement notice or prohibition order was ignored.

The council can also do the work itself and recover the cost. A breach counts against you in the fit and proper person test for a licence. Breaching a prohibition order can only be prosecuted, with no civil penalty option. Our guide to landlord fines puts these next to the certificate penalties.

If a tenant won't let you in to do the work, GOV.UK says you can ask the council to vary or suspend the notice. You can also apply to the magistrates' court for an order requiring access (section 35). Keep a record of every attempt.

How do Awaab's Law and the Decent Homes Standard fit in?

Both build on the HHSRS hazard list, and neither yet applies to private landlords.

Awaab's Law. It sets fixed repair deadlines for social landlords. For private lets the government opened a consultation on 8 October 2026, closing 18 December 2026, with no start date set. GOV.UK points out that Awaab's Law looks at the actual tenant, while the HHSRS assesses a notional vulnerable occupant. Our guide to Awaab's Law for private landlords tracks the consultation.

Decent Homes Standard. Criterion A of the new standard is freedom from Category 1 hazards. The government's policy statement of 28 January 2026 says it will apply to private lets from 2035. That is a policy, not yet law. Until then the Category 1 duty already covers the same ground. Our guide to the Decent Homes Standard for private rentals covers the other four criteria.

The HHSRS also feeds into your repair and fitness duties. A home with a serious prescribed hazard can be unfit for human habitation under section 9A of the Landlord and Tenant Act 1985. A tenant can take you to court over that. The wider changes from the Act are in our guide to the Renters' Rights Act and landlord safety.

Which council enforces in Harrow, Kenton, Stanmore and Edgware?

The council for the address enforces the HHSRS, and in our area that can be Harrow, Brent or Barnet. Harrow covers Harrow and Stanmore. In Kenton, Kenton Road is the boundary between Harrow and Brent. Edgware is split between Barnet, which has the town centre and station, and Harrow's Edgware and Canons wards; a small part of HA8 falls in Brent.

Licensing schemes that can bring an inspection, by council (checked October 2026)

CouncilSelective licensingHMO licensing beyond the mandatory scheme
HarrowSix wards, including Edgware ward, phased in from 2 May to 1 September 2026The first additional HMO scheme ended on 5 August 2026; a new one for 3 or 4 sharers starts on 6 January 2027
BrentEvery ward except Wembley Park, including Brent's Kenton wardAdditional HMO licensing borough-wide since 2 February 2026
BarnetNo scheme in force; the NRLA reported a 2026 consultation on 10 wards, including Burnt Oak, decision pendingAdditional HMO licensing borough-wide until 27 October 2027

Every council can inspect any rented home after a complaint, licensed or not. The Renters' Rights Act also lets an occupier waive the 24 hours' notice a council officer normally gives before entering. The council must then tell the owner afterwards, saying when it entered and why. Our guide to licensing in Harrow, Brent and Barnet shows which scheme covers your address, and our landlord duties checker lists the certificates a let needs.

What should you fix first, and who fixes it?

Start with anything a tenant has reported, then walk the property against the hazards above. Most Category 1 findings in a typical house or flat are trade repairs.

  1. Heating and hot water. No heat is the classic excess cold finding. Our plumbing repairs cover radiators, valves and leaks. Our radiator replacement service handles cold or failed radiators. Work on the boiler itself needs a Gas Safe registered engineer. Our first checks when a rental has no heating or hot water help you triage a report.
  2. Electrics. Close any C1 or C2 codes from the EICR, and fix damaged sockets, exposed wiring and missing RCD protection. Our electricians do remedial work and consumer unit replacement.
  3. Ventilation. Kitchen and bathroom extractor fans that don't work feed condensation and mould. Our electricians handle extractor fan repair and replacement.
  4. Fire safety. Working smoke and CO alarms, and fire doors where the property needs them. See smoke alarm installation, fire door repairs and replacement and our fire door checklist.
  5. Falls. Loose stair treads, missing handrails, lifted carpet and broken thresholds. Our carpentry team re-fixes stairs and rails. Our flooring fitters deal with trip edges.

Keep a dated record of each report, each visit and each repair. If the council does inspect, that record shows what you did and when. For local trade visits, see property maintenance in Harrow, Kenton, Stanmore and Edgware, or book an electrician in Harrow.

Sources

Last reviewed by EliteShires Property Services. This is general guidance on the position in England, not legal advice.

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