Accountability, Transparency & Dispute Resolution under the Renters’ Rights Act 2025
Part 3 of the Renters’ Rights Act 2025 establishes two transformative new institutions — a national landlord registration database and a binding Ombudsman scheme — that will fundamentally reshape accountability and dispute resolution in the private rented sector.
While much of the commentary surrounding the Renters’ Rights Act 2025 has concentrated on the abolition of Section 21 and the transition to periodic tenancies, Part 3 of the Act — covering Sections 73 to 94 — introduces equally significant structural changes. The creation of a national Private Rented Sector (PRS) Database and a mandatory Landlord Ombudsman will professionalise the sector and expose non-compliance to an unprecedented degree. This article explains what is coming, when, and what landlords should do to prepare.
The Two Pillars of Part 3
Part 3 rests on two interdependent mechanisms, designed to work in tandem. Registration on the database will be a prerequisite for access to certain Section 8 possession grounds — meaning landlords who fail to register may find themselves legally unable to recover possession of their properties, even where a substantive ground otherwise exists. The Ombudsman, meanwhile, will provide a free, legally binding alternative to court proceedings for the resolution of tenant complaints.
PRS Database (sections 73-94)
A national register of all private landlords and rental properties in England. Mandatory for all assured and regulated tenancies, with regional rollout beginning late 2026 and full national registration required from 2027.
Non-registration will attract civil financial penalties and restricts a landlord’s ability to invoke certain Section 8 possession grounds.
Landlord Ombudsman (Chapter 2, part 1)
A new mandatory redress scheme for all private landlords — including those using managing agents. Provides tenants with a free, independent route to resolve complaints without court action.
Ombudsman decisions are legally binding on landlords. Mandatory membership is expected from 2028.
The Private Rented Sector Database
S.73–94 The PRS Database has been described by the government as a “one-stop shop” for landlords, tenants, and local councils. It will serve three distinct purposes: enabling tenants to make informed decisions prior to entering a tenancy; assisting landlords in understanding and demonstrating their legal compliance; and equipping local housing authorities with the tools to target enforcement action against non-compliant and rogue operators.
What Information Must Landlords Register?
The precise data fields will be confirmed through secondary legislation. However, the government has indicated that minimum requirements will include the following:
| Kategorie | Required Information |
| Landlord Details | Full name, a UK address for service of notices, contact information for all joint landlords |
| Property Details | Full address, property type (house/flat/HMO), number of bedrooms, number of households and residents, occupancy and furnished status |
| Safety & Compliance | Current Gas Safety Certificate, Electrical Installation Condition Report (EICR), EPC rating and certificate, HMO licence details where applicable |
| Tenancy Information | Confirmation that the property is let on an assured periodic tenancy; details of any appointed letting agent |
Note for Landlords
Using Agents If you use a letting agent to manage your property, the registration obligation may be discharged jointly. However, agents who market a property for a landlord who is not registered will themselves face penalties — meaning your agent has a strong commercial incentive to ensure your registration is in place.
How Will the Database Be Used?
The database is not merely an administrative formality. It will be partially accessible to the public, enabling prospective tenants to verify a landlord’s registration status and review relevant compliance information before committing to a tenancy. Local housing authorities will have a more comprehensive view, enabling them to cross-reference the database against licensing records and proactively identify non-compliant landlords without waiting for a complaint to be made.
Critically, the government has confirmed that certain Section 8 possession grounds will only be available to landlords registered on the database. Unregistered landlords who attempt to rely on these grounds risk having their possession claims dismissed by the court. This linkage transforms registration from a mere bureaucratic obligation into an operationally essential step for any landlord who may need to recover possession of their property.
Before Part 3
- No central national record of private landlords or rental properties in England.
- Local council enforcement was reactive and constrained by limited visibility.
- Tenants had no reliable mechanism to verify a landlord’s compliance status before renting.
After Part 3
- Every PRS landlord and property visible on a national, searchable database.
- Councils able to proactively target non-compliant or unregistered landlords at scale.
- Tenants can check registration status; non-registration linked directly to possession rights.
Registration Costs and Administration
Landlords will be required to pay an annual fee per property to maintain their registration. The government has indicated this will be a cost-recovery fee, with the exact amount to be confirmed ahead of the 2026 regional launch. For portfolio landlords this represents a new recurring overhead that should be factored into financial planning. Managing agents can register and maintain records on behalf of their clients, and many are expected to incorporate database compliance into their standard service offering.
Limited Companies & Joint Ownership
The government has acknowledged that the registration mechanics for limited companies and joint landlords are still being finalised through secondary legislation. Current guidance suggests that whoever is named as landlord on the tenancy agreement will be the registering party. Landlords holding properties within a corporate structure should seek specific legal advice once the secondary legislation is published. Ronald Fletcher Baker LLP’s property team can advise on the implications for your particular structure.
The PRS Landlord Ombudsman
For the first time, all private landlords in England will be required to belong to a formal redress scheme — the PRS Landlord Ombudsman. This aligns the private rented sector with the social housing sector and property agent sector, both of which already operate under mandatory Ombudsman arrangements. The duty falls on the landlord directly, regardless of whether a managing agent is used.
What Can Tenants Complain About?
The Ombudsman will accept complaints from prospective, current, and former tenants across a broad range of issues including disrepair and maintenance failures, communication failures or unacceptable delays in responding to requests, unlawful fees or charges, poor management practices, and failure to comply with statutory obligations. The service will be free for tenants to use with no requirement for legal representation — a deliberate policy choice designed to ensure accessibility regardless of means.
The Ombudsman Process
- Tenant Raises Complaint with Landlord
Prior to approaching the Ombudsman, tenants must first raise the issue directly with the landlord and allow a reasonable opportunity for resolution. Landlords should ensure they maintain a clear, documented complaints procedure so that all issues are handled and recorded in a way that demonstrates a genuine attempt at resolution.
- Escalation to the Ombudsman
Where the matter remains unresolved, the tenant may refer their complaint to the Ombudsman free of charge. The Ombudsman will investigate independently, requesting evidence from both parties. Landlords will be required to engage and provide documentation within specified time limits — a failure to do so is itself a breach.
- Determination and Remedies
The Ombudsman may require the landlord to take or cease a specific action, provide a formal written apology or explanation, and award financial compensation to the tenant. All determinations are legally binding on the landlord.
- Non-Compliance and Escalation
Failure to comply with an Ombudsman determination may result in expulsion from the scheme, which in turn triggers local authority enforcement action. The Ombudsman also has provision to initiate early-stage mediation at the landlord’s request — providing a less adversarial route to resolution before a formal determination is reached.
The Housing Ombudsman Connection
The government has indicated that the existing Housing Ombudsman Service — which currently oversees social housing complaints — is the most likely administrator of the new PRS scheme, creating a single cross-tenure redress service covering both social and private renting. Where fault lies with both a landlord and a letting agent, the PRS Ombudsman can conduct joint investigations with existing agent redress schemes and issue joint decisions. The administrator will be formally appointed during 2026, ahead of mandatory membership in 2028.
A Note for Well-Managed Portfolios
The Ombudsman is not simply a tool of accountability — it also benefits responsible landlords. It provides a faster, less costly alternative to court proceedings, enables early resolution before disputes escalate, and creates a structured mechanism to demonstrate that a complaint was handled properly and in good faith. For landlords who already maintain high management standards, the Ombudsman is an operational resource, not a threat.
Enforcement and Financial Penalties
Local housing authorities have been given significantly strengthened enforcement powers under Part 3 and across the Act as a whole. Civil financial penalties may be imposed for a range of breaches, with a clear escalating scale for persistent or serious non-compliance.
Civil Penalty Scale — Part 3 Breaches
Initial or Minor Breach
Failing to register on the database; failure to join the Ombudsman scheme
Up to £7,000
Serious, Persistent or Repeat Breach
Continued non-registration; failure to comply with Ombudsman decisions
Up to £40,000
Criminal Prosecution
Alternative to the £40,000 civil penalty for the most serious ongoing breaches
Unlimited fine
Beyond civil penalties, tenants and local councils acting on their behalf may pursue Rent Repayment Orders through the First-tier Tribunal. These orders require landlords to repay rent received during a period of non-compliance — typically up to 12 months of rent. For portfolio landlords, this exposure can substantially exceed the civil penalty figures set out above.
Possession Rights at Risk
Non-registered landlords may be unable to invoke certain Section 8 possession grounds. The practical consequence is that failing to register on the PRS Database could prevent a landlord from lawfully recovering possession of their property — even where a valid substantive ground otherwise exists. This is arguably the most significant operational risk associated with Part 3 non-compliance, exceeding the financial penalties in terms of day-to-day impact on landlords.
Implementation Timeline for Part 3
27 December 2025 — Now in Force
Enhanced Local Authority Investigatory Powers
Local housing councils gained new powers to inspect properties, demand documents, and access third-party data. These enforcement capabilities underpin the entire Part 3 regime and are already in active use.
Late 2026 — Phase 2 Begins
PRS Database Regional Rollout Commences
The database will begin a phased regional launch. Landlords in pilot regions will be the first required to register and begin paying the annual per-property fee. Annual fee amounts will be confirmed ahead of launch.
2027 — Full National Launch
Mandatory Registration for All PRS Landlords
Registration becomes mandatory across England. From this point, non-registration directly restricts access to certain Section 8 possession grounds.
2028 — Ombudsman Live
PRS Landlord Ombudsman Membership Becomes Mandatory
All private landlords will be required to join the Ombudsman scheme. The administrator (likely the Housing Ombudsman Service) will be appointed in 2026 and given time to scale up operations before mandatory membership is enforced.
2035 — Decent Homes Standard
Decent Homes Standard Extended to PRS
The final phase of the Act’s standards agenda. Government has proposed an implementation date of 2035. Landlords are encouraged to begin addressing potential deficiencies — particularly damp, mould and category 1 HHSRS hazards — well in advance.
Practical Steps for Landlords
The timelines for Part 3 afford landlords greater preparation time than the Phase 1 tenancy reforms — but that window should be used actively, not passively. The following steps are advisable now.
Audit and organise your compliance documentation. The database will require current Gas Safety Certificates, EICRs, EPCs and related certificates for every property you let. Any that are missing, expired or not to the required standard should be addressed promptly rather than under time pressure when registration windows open.
Establish a documented complaints procedure. The Ombudsman will require evidence that tenants raised issues with you before escalating to the scheme. A clear, written complaints process — and a consistent practice of acknowledging and responding to communications in writing — will be your first evidential line of defence in any investigation.
Review your financial planning to absorb new costs. Annual per-property database registration fees and Ombudsman membership fees represent new recurring obligations. Both will need to be factored into your rental yield calculations.
Clarify responsibilities with your managing agent. The registration and Ombudsman membership obligations fall on the landlord directly, but agents can discharge them on your behalf. Ensure your agency agreement is explicit as to who is responsible for maintaining registration and membership, and that your agent is actively preparing for these requirements.
Seek legal advice on your specific portfolio structure. Landlords with complex ownership structures — corporate vehicles, joint ownership, trusts — should not assume the standard regime applies to them without qualification. Secondary legislation will clarify the mechanics, and our property team can advise once published.
John Andrews
Head of Corporate and Commercial
