Renters' Rights Act 2025, Phase 1 commencement
Transition readiness pack

LPA 1925 s.146 · CLRA 2002 s.168 · FTT Determination · Relief from Forfeiture · Service Charge Disputes

Section 146 Notice — Forfeiture of Residential Long Leases 2026

LPA 1925 Section 146 forfeiture notice guide for residential long leases: CLRA 2002 s.168 requirement that breach must be admitted or determined by FTT before serving s.146 on residential long leases; s.169 CLRA 2002 rent/service charge arrears threshold (£350, 3 years); relief from forfeiture (s.146(2) LPA 1925); distinction from AST possession; interaction with service charge disputes.

13 min readUpdated 6 June 2026Last reviewed: 17 May 2026leaseholdforfeituresection-146clra-2002
Section 146 does NOT apply to ASTs

Assured shorthold tenancy landlords seeking possession use Section 8 (or formerly Section 21) Housing Act 1988 notices. Section 146 LPA 1925 applies exclusively to long residential leases held at a low ground rent — typically flat owners. Mixing up the two regimes is a fundamental error.

CLRA 2002 s.168 — residential long lease: FTT determination required first

The Commonhold and Leasehold Reform Act 2002 s.168 imposes a critical restriction for residential long leases: the freeholder cannot serve a s.146 notice for a non-rent breach unless and until the lessee has admitted the breach or the breach has been determined by the First-tier Tribunal (Property Chamber) or a court.

  • Stage 1: Freeholder applies to FTT (Property Chamber) for determination that lessee has breached a specified covenant
  • FTT hears evidence from both parties and determines whether the breach occurred — this process alone can take 6–18 months
  • Stage 2 (after FTT determination): Freeholder can then serve the s.146 notice requiring remedy
  • Stage 3: If lessee does not remedy and comply, freeholder can issue forfeiture proceedings in the county court
  • Total timeline from FTT application to forfeiture: typically 12–24 months minimum

CLRA 2002 s.167–169 — arrears threshold: no forfeiture below £350 or under 3 years

Section 167–169 CLRA 2002 prohibit forfeiture of a residential long lease for non-payment of rent, service charges, or administration charges unless both thresholds are met:

  • The amount outstanding must exceed £350; AND
  • The amount (or part of it) must have been outstanding for more than 3 years
  • Below either threshold — forfeiture for non-payment is prohibited, even if the freeholder has a right of re-entry clause in the lease
  • Service charge disputes: a disputed service charge need not be paid pending FTT determination (LTA 1985 s.27A(4)) — and the freeholder cannot forfeit unless the FTT has determined it payable and both thresholds are met
  • These thresholds apply to rent, service charges, administration charges — and any combination of them
Forfeiture as threat vs remedy

Because relief from forfeiture is routinely granted where the breach is remedied and costs paid, forfeiture proceedings are often more valuable as a compliance lever than as a terminal remedy. A freeholder who issues forfeiture proceedings typically forces the lessee to remedy the breach and pay legal costs — but rarely actually recovers the property. Budget accordingly.

Frequently asked questions

What is a Section 146 notice?+

A formal notice required by LPA 1925 s.146 before a freeholder can forfeit a long residential lease for breach of any covenant other than rent. For residential long leases, CLRA 2002 s.168 requires the breach to be admitted or determined by the FTT before the s.146 notice can be served.

Can a freeholder forfeit for unpaid service charges below £350?+

No. CLRA 2002 s.169 prohibits forfeiture for service charge, administration charge, or rent arrears below £350 or outstanding for less than 3 years. Both thresholds must be exceeded.

What is relief from forfeiture?+

A court remedy (LPA 1925 s.146(2)) allowing a leaseholder to have the forfeiture set aside on terms — typically remedying the breach and paying the freeholder's legal costs. Courts grant relief in the vast majority of cases where the breach is remediable and has been remedied.

Does Section 146 apply to assured shorthold tenancies?+

No. Section 146 LPA 1925 applies to long residential leases only. AST possession uses Section 8 (and formerly Section 21) notice procedures under the Housing Act 1988 — entirely separate from the leasehold forfeiture regime.

Templates recommended in this guide

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