HHSRS Changes 2026: New Hazard Scoring, 21 Hazards and Civil Penalties Under SI 2026/571

What SI 2026/571 changes to the HHSRS

The Housing Health and Safety Rating System (HHSRS) is the statutory framework used by local authorities in England to assess the risk to health and safety from residential property conditions. It applies to all private rented properties and underpins HHSRS inspections, improvement notices, prohibition orders, and civil penalties.

SI 2026/571 — the Housing Health and Safety Rating System (England) (Amendment) Regulations 2026 — came into force on 22 June 2026. It makes three major structural changes that every private landlord in England needs to understand.

Change 1: New numeric scoring bands replace A–J letters

• High (score ≥1,000): Previously approximately Band A–C. The most serious hazards representing the highest risk of harm. Local authorities must take enforcement action. From 22 June 2026, a High hazard found on inspection triggers the new £7,000 on-the-spot civil penalty
• Medium (score 100–999): Previously approximately Band D–G. Significant hazards representing substantial risk to occupants. Local authorities should take enforcement action, typically via an improvement notice
• Low (score <100): Previously approximately Band H–J. Minor hazards where enforcement is discretionary. Low hazards are unlikely to trigger immediate enforcement action but may be noted in inspection reports
• What landlords must do: Remove A–J letter-band language from all property management documentation, repair logs, inspection checklists, and communications with tenants and local authorities. Use High, Medium, and Low with the numeric threshold from 22 June 2026

Change 2: Hazard list reduced from 29 to 21

SI 2026/571 reduced the HHSRS hazard list from 29 to 21 by consolidating overlapping categories. The consolidation reflects updated evidence about hazard interactions and simplifies local authority enforcement. Key changes:

• Explosions and Structural Collapse consolidated into Fire: The expanded Fire hazard definition now encompasses risks previously assessed separately under Explosions and Structural Collapse. Properties with gas appliances, storage of flammable materials, or structural deficiencies are assessed under the expanded Fire hazard
• Protective scope broadly preserved: The consolidation does not mean these risks are ignored — they are captured within the expanded remaining 21 hazard categories. However, the scoring methodology for these risks has been updated to reflect their inclusion in the consolidated category
• Landlord implications: Repair logs and inspection checklists referencing specific old hazard categories should be updated to reference the consolidated HHSRS framework. The most commonly cited private rented sector hazards — damp and mould, excess cold, fire safety, electrical hazards — all remain as separate, named hazards in the retained 21

Change 3: New £7,000 on-the-spot civil penalty for High hazards

The most significant enforcement change in SI 2026/571 is the introduction of direct civil penalty powers without prior improvement notice. From 22 June 2026:

• £7,000 on-the-spot penalty: If a local authority inspects a private rented property and finds a High hazard (score ≥1,000), it may immediately impose a civil penalty of up to £7,000 without first serving an improvement notice. The traditional two-step route (improvement notice followed by prosecution) is no longer required for the most serious hazards
• Immediate financial risk for landlords: Under the previous framework, a landlord who received an improvement notice had a period to remedy the hazard before enforcement escalated. SI 2026/571 removes that buffer for High hazards — the civil penalty can follow directly from the inspection
• £40,000 for serious or repeat non-compliance: For landlords who fail to pay a civil penalty, repeatedly allow High hazards to persist, or are subject to multiple enforcement actions, the maximum penalty rises to £40,000
• Landlord Database and HMO licensing impact: Civil penalties imposed under SI 2026/571 will be a relevant factor in the Private Landlord Database (PLD) registration (Phase 2 of the Renters' Rights Act 2025, expected 2027) and in HMO licence applications and renewals. Multiple penalties create a track record that affects future compliance status

HHSRS and Awaab's Law — how they interact from 22 June 2026

Awaab's Law currently applies to social housing landlords only (in force 27 October 2025). The extension to the private rented sector is expected under the Renters' Rights Act 2025 but is awaiting a commencement order. When it extends to the PRS:

• Awaab's Law timeframes are HHSRS-based: The initial response, investigation, and repair timeframes under Awaab's Law are triggered by and proportioned to the severity of the hazard as assessed under the HHSRS. From 22 June 2026, severity is expressed in numeric scoring — High, Medium, Low — not the old A–J bands
• High hazards trigger the most urgent Awaab's Law response: Severe damp and mould affecting vulnerable occupants (children, elderly, immunocompromised) is typically a High hazard. Under Awaab's Law, High hazards require the most urgent initial response and repair timeframe
• Damp and mould remains a named HHSRS hazard: Damp and Mould Growth is one of the 21 retained hazards in SI 2026/571. Landlords receiving written tenant reports about damp or mould should treat them as potential High hazard reports and respond accordingly — the combination of Awaab's Law (when in force for PRS) and the £7,000 HHSRS civil penalty creates significant dual-enforcement risk

What landlords must do now

• Update all inspection documentation: Replace A–J letter band references with High / Medium / Low (numeric threshold) in all property inspection checklists, repair logs, and tenant correspondence templates
• Proactively fix High hazards: The removal of the improvement notice buffer for High hazards means that a local authority inspection of a property with a known High hazard carries immediate £7,000 penalty risk. Do not wait for enforcement — identify and fix High hazards before inspection
• Review your damp and mould response process: Damp and mould is the most commonly reported PRS hazard and the original trigger for Awaab's Law. Ensure your tenant response protocol, inspection process, and repair records are current
• Understand the 21-hazard list: Confirm which hazards are now within the consolidated 21-hazard HHSRS list and which were removed or consolidated. Review Schedule 1 to SI 2026/571 for the definitive text
• Keep records for civil penalty challenges: If a civil penalty is imposed under SI 2026/571, the landlord has a right of appeal. Evidence of prompt response to hazard reports, completed repair records, and inspection documentation is essential to mount a successful challenge

LetSafe UK documents for HHSRS compliance

• Periodic Assured Tenancy Agreement (LS-E-001): Includes repair obligations consistent with HHSRS duties and the expected Awaab's Law PRS framework — drafted to reflect current statutory requirements
• Property Inspection and Compliance Checklist (LS-E-029): Property inspection checklist covering HHSRS hazard categories — uses the new 21-hazard list and High / Medium / Low scoring terminology following SI 2026/571
• Hazard Response and Repair Log (LS-E-100): Template for documenting tenant hazard reports, inspection dates, findings, and repair completion — essential evidence if a £7,000 civil penalty is challenged on appeal
• Section 8 Notice Pack (LS-E-010): Where a hazard dispute has escalated to the point of possession proceedings — for example where a tenant is in arrears and the property has also been subject to a disrepair counterclaim — the Section 8 Notice Pack provides the correct Section 8 forms with guidance