Phase 2 of the Renters' Rights Act 2025 (PRS Ombudsman; Private Landlord Database) has not yet commenced. The commencement date will be set by the Secretary of State. However, landlords who act now to audit compliance records and understand the coming obligations will be best placed to register without delay when Phase 2 opens.
The Renters' Rights Act 2025 fundamentally restructures private rented sector regulation in England in two distinct phases. Phase 1 (in force from 1 May 2026) delivered the headline tenancy law reforms — abolishing Section 21, mandating Periodic Assured Tenancy Agreements, and extending Awaab's Law to the PRS. Phase 2 introduces the institutional infrastructure that will underpin long-term enforcement: a mandatory PRS Ombudsman and a comprehensive Private Landlord Database.
The Private Rented Sector Ombudsman — mandatory membership for all landlords
The PRS Ombudsman is a new mandatory dispute resolution body. When Phase 2 commences, every private landlord in England must be a member:
- Who must join: All private landlords letting residential property in England under an assured tenancy, including single-property landlords, portfolio landlords, and company landlords. Agents acting for landlords must verify their client's membership
- What it covers: Tenant complaints about landlord conduct — failure to repair, unlawful eviction, deposit handling, and tenancy management failures. Landlords must investigate and respond to complaints within set timeframes before the Ombudsman can accept a referral
- Binding decisions: Ombudsman determinations are binding on landlords. Remedies include compensation awards and mandatory corrective action
- Annual membership fee: Landlords will pay an annual fee — the structure has not yet been published but is expected to be proportionate to portfolio size
- Possession bar for non-members: A landlord who is not a PRS Ombudsman member when Phase 2 is in force will be unable to serve a valid Section 8 notice and cannot obtain court possession
The Private Landlord Database — registration obligations
The Private Landlord Database is a national register of all private landlords and their let properties in England:
- Mandatory registration: All private landlords must register their identity and all let residential properties on the database
- Supporting documents: Registration is expected to require proof of current EPC certificates, gas safety records, EICR reports, and deposit protection for each property
- Tenant access: Prospective tenants will be able to search the database to verify landlord registration and compliance status — creating a reputational incentive to maintain accurate records
- Local authority enforcement access: Housing authorities will use the database to identify unregistered landlords and cross-reference complaint and licensing records
- Possession bar for unregistered landlords: Landlords who are not registered on the Private Landlord Database will be unable to serve a valid Section 8 notice
- Agent verification obligations: Letting agents must verify that landlord clients are database-registered before accepting management or letting instructions
What landlords should prepare now
- Audit compliance records for every let property: Current EPC (valid, not expired), gas safety certificate (within 12 months), EICR (within 5 years), deposit protection confirmation
- Resolve Phase 1 compliance gaps: Unserved RRA 2025 Information Sheets, tenancies not on PAT agreements, or any Section 21 notices still outstanding from before abolition
- Ensure rental income is declared to HMRC: The database may cross-reference with HMRC Let Property Campaign data — undeclared income creates registration risk
- Speak to your letting agent about Phase 2: Your agent will need to verify your registration status and Ombudsman membership before the Phase 2 commencement date
- Monitor MHCLG for the commencement order: Phase 2 begins on a date set by statutory instrument. Register for government housing updates to receive early notice