Counting down to the implementation of the Renters' Rights Act 2025

The word "game-changer" is overused, however, the Renters' Rights Act 2025 (the "Act") is worthy of the designation. With increased security of tenure effected by the abolition of no fault eviction and the move to rolling assured periodic tenancies, a tenant can feel that a rental property is closer to being their castle now more than at any time since the liberalisation of the rental market during the Thatcher years. That liberalisation rejuvenated a stagnant and unpopular rental market, with financial institutions quickly developing products to enable a new and largely amateur landlord class.  

Appearing recently before the Housing, Communities and Local Government Committee, the Secretary of State for Housing, Communities and Local Government, Steve Reed, suggested that this reform of the rental market would make the Private Rental Sector ("PRS") more attractive to investors. Certainly, in recent years, we have seen a growth in the Build to Rent ("BTR") market, but its target consumer is a wealthy often nomadic occupant who wants a 'plug and play' rental experience. It therefore remains to be seen whether Mr. Reed's optimism is justified. 

Implementation

The failure of the government to give any indication of the timescale for implementation of the Act gave the residential sector the jitters. However, that uncertainty has now ended with the Ministry of Housing, Communities and Local Government issuing a detailed timetable. The "big bang," when all tenancies automatically convert from fixed term assured shorthold to periodic assured, is 1 May 2026. The other core reforms will also happen on that date, as set out in more detail below. 

From late 2026, the PRS database and the PRS Landlord Ombudsman will be rolled out "in stages" After that, so well into 2027, it would seem the quality and safety standards—including a Decent Homes Standard and Awaab’s Law extension—will apply to the PRS, following consultations with the industry. However full application of both measures is not expected for some years after this to give landlords time to adjust. 

Phase 1: Tenancy and possession reforms

Phase 1 of the Act delivers the fundamental tenancy changes. As we said above the headline is the abolition of section 21 "no‑fault" evictions and the automatic conversion of assured shorthold tenancies to an assured periodic model. This mimics the "status of immovability" tenants enjoyed under the Rent Acts. Until the Housing Act 1988 came into force, it had been virtually impossible for a landlord to evict a tenant who had complied with the terms of the lease. Additionally, rents were capped to “a fair rent,” which often bore no relationship to a market rent. 

However, lessons have been learned from the restrictive market practices that hollowed out the rental market during the twentieth century. Under the Act, a landlord may only raise rent once a year, and if the tenant feels that the increase does not reflect the market, they can make an application to the First Tier Tribunal ("FTT") using a revised process under section 13 of the Housing Act 1988. Section 13 allows a tenant to challenge a rent increase which will be adjudicated by the FTT. The FTT, using market comparables, decides whether the increase is market and can set a new rent, based on the evidence it has heard.

Other reforms under Phase 1 include a permissive power for tenants to keep pets. Pet requests must be considered, landlords have 28 days to respond, and they must give valid reasons for refusal. We expect this to be a new source of work for the FTT, and it will be interesting to see whether litigants' lawyers make use of the rich case law from commercial property and refusal of landlord of consent.

Opposition MPs and members of the House of Lords fought a sustained campaign for the introduction of a requirement for an increased security deposit for tenants who wanted to keep companion animals, but the administration's overwhelming majority in both houses meant that the amendment was defeated. 

Also coming into force in May are the anti-discrimination provisions that protect tenants who have children or are receiving benefits. Refusing to rent to tenants with children has a long and undistinguished history, with which the Equality Act 2010 did not directly deal. Similarly, landlords are understandably very wary of tenants who rely on the state to pay their rents, as the local housing allowance does not cover the entirety of rents in more expensive areas. 

While including such provisions may be attractive, a right is only a right in reality if it can easily be enforced. This is something that the Act addresses. Local authorities now have a duty to enforce this legislation and are given new investigatory powers, for example to inspect properties, demand documents, and access third‑party data. These enforcement provisions will come into effect on 27 December 2025. Obviously, this duty on local authorities will impose new financial burdens on them and it is unclear where the funding will come from.

PRS Database and Landlord Ombudsman

Phase 2 of the Act introduces the transparency and redress infrastructure in two stages. 

• Stage 1, which the government hopes to bring in from late 2026, imposes mandatory registration on all PRS landlords on a new, national PRS database. Landlords will also have to pay an annual fee for registration.
• Stage 2 will see the database made public after registration is live. A mandatory PRS Landlord Ombudsman will be established to provide redress to tenants and support to landlords to seek early resolution of disputes. Landlords will fund the service on a fair and proportionate basis, although there are no details on how this will work in practice.

Neither stage will be speedy. The government will need to appoint a scheme administrator 12–18 months ahead of full implementation of the database. Stage 2, which is mandatory membership for landlords, is expected in 2028, once the service is ready. The government aims to share information between the Database and Ombudsman to minimise duplication.

Quality, safety and energy standards

Phase 3 of the Act is intended to lift standards across the PRS. The Decent Homes Standard ("DHS") for the PRS will be introduced. The DHS for social housing was introduced in the early years in this century and has, by and large, been successful in raising standards in that sector. 

As with the social housing sector, all PRS properties must meet a minimum quality benchmark, with local authorities empowered to enforce compliance. Consultation has proposed implementation by 2035 or 2037, with details and final timing to be announced. Landlords are expected to start work earlier where feasible, mindful of tenant impact.

Other statutory measures are expected. The government has consulted on requiring all domestic PRS properties in England and Wales to have an EPC rating of C (or equivalent) by 2030, unless an exemption applies. We are awaiting the consultation response. As part of the DHS pathway, the Housing Health and Safety Rating System ("HHSRS"), introduced by the Housing Act 2004, will be updated. The HHSRS is a risk-based framework used by local authorities to assess hazards in residential properties. It focus on identifying risks to occupants' health and safety and empowers authorities to required landlords to remedy serious hazards.

Finally, Awaab's Law will be extended to the PRS. Legally enforceable timeframes will require PRS landlords to make homes safe where there are serious hazards, supposedly empowering tenants to challenge dangerous conditions. Details and timings will be consulted upon.

Our Thoughts

We have compared the Renters Rights Act 2025 with the other gamechanger in the residential letting sector: the Housing Act 1988. The Housing Act started a cottage industry of amateur landlords, of varying qualities. Will the Act, with the security of tenure and transparency it brings, make the rental market "respectable" so that greater numbers of people are drawn to the sector, thus opening new commercial opportunities for developers and institutions? We shall keep you informed. 

Renters' Rights Act 2025 – Implementation Timeline Matrix