Bath has one of the most distinctive rental markets in England. The University of Bath and Bath Spa University together attract over 30,000 students, generating strong demand for HMO accommodation particularly in the Oldfield Park, Twerton, Widcombe, and Combe Down areas. Bath's world-famous Georgian architecture means a very high proportion of rental properties are listed buildings or sit within conservation areas, adding planning and heritage obligations on top of the standard landlord compliance regime.
From 1 May 2026, the Renters' Rights Act 2025 adds a layer of national obligations that sit alongside Bath & NE Somerset Council's existing HMO licensing and selective licensing regime. This guide covers both, with specific attention to Bath's heritage property stock and its significant student HMO market.
Renters' Rights Act 2025 — England-wide obligations from 1 May 2026
All Bath private landlords must comply with these national changes from 1 May 2026:
- Section 21 abolished: No-fault eviction notices served on or after 1 May 2026 are unlawful. All possession must use Section 8 and one of the revised Schedule 2 grounds only
- Periodic Assured Tenancy Agreement required: All new tenancies from 1 May 2026 must use a PAT-compliant agreement. Fixed-term ASTs are no longer available for new private residential lets in England
- Awaab's Law in force: Mandatory statutory timeframes for responding to, investigating, and repairing damp, mould, and other HHSRS hazards
- Information Sheet obligation: Every landlord with an existing tenancy as at 1 May 2026 must deliver the official RRA 2025 Information Sheet to every named tenant by 31 May 2026. Penalty: up to £7,000 per tenancy
- Pet request right: Tenants on PATs have the right to request a pet. Landlords must respond in writing within 42 days or consent is deemed given
- Civil penalties up to £40,000: The RRA 2025 increases maximum civil penalties for PRS non-compliance to £40,000 per offence
- Rent increase via Section 13 only: Rent on a PAT can only be raised via formal Section 13 notice (Form 4A). Contractual rent-review clauses in new agreements are unenforceable
Bath & NE Somerset Council HMO and selective licensing
BANES administers both mandatory HMO licensing and selective licensing schemes across Bath, with specific designations in high-density rental areas.
- Mandatory HMO licensing: All properties in Bath occupied by 5 or more people forming 2 or more separate households require a mandatory HMO licence under the Housing Act 2004
- Additional HMO licensing: BANES operates an additional HMO licensing scheme covering smaller HMOs (3–4 occupants) in designated areas including Oldfield Park, Twerton, and parts of the city centre. Check the council's current scheme boundaries — penalties for unlicensed HMOs reach up to £30,000 per property
- Selective licensing: BANES has operated selective licensing designations in specific wards. Selective licensing requires all private landlords — not just HMO landlords — to hold a licence in designated areas. Confirm the current designation boundaries on the council website before letting any property in the city
- Student HMO concentration areas: Oldfield Park, Twerton, Weston, and Combe Down are the highest-concentration student HMO areas. Article 4 Directions in parts of Bath restrict the permitted development right to convert C3 dwellinghouses to C4 HMOs, requiring full planning permission for any new student HMO creation
- Licence conditions and room sizes: BANES HMO licence conditions require minimum room sizes (6.51 m² for a single adult sleeping room), specified fire detection grades, fire doors to all habitable rooms in larger HMOs, and maximum occupancy compliance
- No-licence consequences: Unlicensed HMO landlords cannot serve valid Ground 8 (rent arrears) Section 8 notices and are exposed to rent repayment orders of up to 12 months' rent plus unlimited fines
Heritage and listed building obligations in Bath
Bath's UNESCO World Heritage Site designation and dense concentration of Grade I and Grade II* listed buildings create obligations that affect a very high proportion of Bath rental properties.
- Listed building consent: Structural alterations, changes to windows, doors, external appearance, or significant internal changes to listed buildings require listed building consent from BANES. Unauthorised works are a criminal offence carrying unlimited fines and up to 2 years' imprisonment
- Conservation area controls: The Bath World Heritage Site encompasses large parts of the city. Properties in conservation areas are subject to additional controls on permitted development. Roofing works, window replacements, and external cladding may require planning permission even for unlisted properties
- EPC exemptions for listed buildings: Listed buildings and certain conservation-area properties may qualify for EPC exemptions where improvement works would unacceptably alter the character of the building. Register on the national PRS Exemptions Register before letting. Exemptions last 5 years and must be renewed
- EPC Band C 2030 target: Government policy targets EPC Band C for all new PRS tenancies by 2030. Bath's Georgian building stock — solid wall construction, sash windows, limited insulation options — makes Band C genuinely difficult to achieve in many properties. Commission a heritage-aware EPC assessor now to understand your position and plan works
- Solid wall insulation: Most Georgian Bath terraces have solid external walls. External wall insulation is typically prohibited by planning and conservation restrictions. Internal wall insulation is technically feasible but costly. Alternative measures — loft insulation, efficient heating systems, secondary glazing — should be prioritised
Awaab's Law — Bath context
Bath's Georgian and Victorian housing stock includes properties with solid walls, original sash windows, and limited natural ventilation — all factors that contribute to condensation damp. Awaab's Law creates strict obligations regardless of the building's heritage status or the cause of the damp.
- Acknowledge every report in writing: All damp, mould, or HHSRS hazard reports must be acknowledged in writing. Verbal acknowledgments do not satisfy the statutory obligation
- Investigate within the statutory period: Likely 14 days for non-emergency hazards. Identify the root cause — condensation damp in solid wall properties requires different remediation from penetrating damp through a defective roof or rainwater goods
- Repair within the repair period: The repair must address the underlying cause. In solid-wall Georgian properties this typically means improved ventilation (MVHR or trickle vents), reduction in cold bridging, or heating improvement — surface mould treatments alone will not comply
- Emergency hazards: Burst pipes causing structural damp or other immediately dangerous conditions must be addressed within 24 hours
- Listed building complications: Where damp remediation in a listed building requires listed building consent, notify BANES heritage officers immediately. The legal obligation to remedy the hazard within statutory timeframes does not disappear, but early engagement with conservation officers may allow expedited consent for urgent works
- Document all actions: Keep written records of every report, every inspection, all repair instructions, and all completion certificates. These records are essential for any enforcement defence
Student lets in Bath — Ground 4A and HMO requirements
Bath's two universities create one of England's strongest student rental markets. The Renters' Rights Act 2025 changes student lets fundamentally from 1 May 2026.
- Fixed-term ASTs abolished: From 1 May 2026, all new student lets must be Periodic Assured Tenancies. The traditional September-to-June fixed-term student AST is no longer a lawful agreement form
- Ground 4A — student possession: The RRA 2025 introduces Ground 4A specifically for full-time student lets. Where all tenants at the point of notice are full-time students, the landlord may serve 2 months' notice for possession between 1 June and 30 September. This provides partial academic-year certainty replacing the fixed-term
- Mandatory HMO licence: Required for all Bath student HMOs with 5+ occupants and 2+ households. Additional licensing may apply to smaller HMOs in designated areas
- Article 4 Directions: Planning permission is required to convert any C3 dwelling to a C4 HMO in Article 4 Direction areas of Bath. Check current Article 4 boundaries before acquiring or converting any property for student letting
Key documents Bath landlords need
LetSafe UK provides all compliance documents for England landlords — each drafted to current RRA 2025 requirements:
- Periodic Assured Tenancy Agreement (England): PAT-compliant tenancy agreement for all new Bath lettings from 1 May 2026 — includes all prescribed information, pet clause, and RRA 2025 clauses
- Section 8 Notice (Form 3A): Renters' Rights Act 2025 compliant Form 3A — updated for all grounds including Ground 4A for student lets
- Section 13 Rent Increase Notice (Form 4A): The only lawful method of raising rent on a PAT — 2-month advance notice with First-tier Tribunal appeal rights
- RRA 2025 Information Sheet: Required for all existing tenants by 31 May 2026 to avoid £7,000 penalties
Frequently asked questions
Do Bath landlords need an HMO licence in 2026?+
Mandatory HMO licensing applies to all Bath properties with 5 or more occupants forming 2 or more separate households. BANES also operates an additional HMO licensing scheme for smaller HMOs (3–4 occupants) in designated high-density rental areas including Oldfield Park and Twerton. Check the BANES licensing register and confirm which scheme applies to your property. Operating without a required licence is a criminal offence.
Does my listed Bath property need an EPC?+
Listed buildings may qualify for an EPC exemption where improvement works required to meet the minimum energy efficiency standard would unacceptably alter the character of the property. To claim the exemption, you must register it on the national PRS Exemptions Register before the property is let. The exemption lasts 5 years. Many Georgian Bath terraces will qualify — commission a heritage-aware EPC assessor to confirm your position.
Can I still use a fixed-term tenancy for Bath student lets in 2026?+
No. From 1 May 2026, all new private residential tenancies in England must be Periodic Assured Tenancies. Fixed-term ASTs are abolished for new lets. The Renters' Rights Act 2025 introduces Ground 4A as a mandatory possession ground for full-time student lets, allowing possession notices between June and September where all tenants are full-time students.
Does Bath have selective licensing in 2026?+
BANES has operated selective licensing in specific wards of Bath. Selective licensing requires all private landlords in designated areas to hold a licence regardless of property type or occupancy. You must confirm the current designation boundaries on the BANES website before letting any property in Bath. Failing to hold a required licence carries penalties up to £30,000 and loss of access to rent repayment order defences.