Renters' Rights Act Phase 2 2026 — PRS Ombudsman, Private Landlord Database and What Landlords Must Prepare For

Phase 1 vs Phase 2 — what has changed and what is coming

Understanding the structure of the RRA 2025 helps landlords prioritise compliance activity:

• Phase 1 (1 May 2026) — in force now: Section 21 abolished for all new and existing assured tenancies. All new tenancies must use Periodic Assured Tenancy Agreements. Awaab's Law mandatory response timeframes apply to PRS landlords. Section 13 (Form 4A) is the only lawful rent increase mechanism. The RRA 2025 Information Sheet was required for all existing tenants by 31 May 2026. Bidding-war ban, pet request right, and strengthened anti-discrimination provisions all apply
• Phase 2 (date TBC) — commencement order awaited: The Private Rented Sector Ombudsman scheme becomes mandatory for all private landlords. The Private Landlord Database (PLD) requires all private landlords in England to register their identity, properties, and tenancy details. Landlords who do not register on the PLD or join the Ombudsman scheme will not be able to issue a valid Section 8 notice
• Awaiting commencement order: Phase 2 provisions in the RRA 2025 are not yet in force. The Secretary of State must make a commencement order specifying the date. Based on government statements, Phase 2 is expected no earlier than 2027, but no exact date has been confirmed
• Preparation window: The gap between Phase 1 and Phase 2 is the period for landlords to understand what registration and Ombudsman membership will require, to ensure their records are accurate and up to date, and to appoint agents if needed to manage registration obligations

The Private Rented Sector (PRS) Ombudsman — what landlords need to know

The PRS Ombudsman is a mandatory dispute resolution scheme established by the Renters' Rights Act 2025 that all private landlords in England must join when Phase 2 commences:

• Who must join: Every private landlord letting residential property in England under an assured tenancy must be a member of the PRS Ombudsman scheme. This includes single-property landlords, portfolio landlords, and company landlords. Agents acting for landlords must also ensure their landlord clients are members
• What the Ombudsman covers: The PRS Ombudsman will handle complaints from tenants about landlord conduct — covering issues such as failure to repair, unlawful eviction, harassment, failure to protect deposits, and non-compliance with tenancy agreement obligations. Landlords must investigate and respond to tenant complaints within set timeframes before the Ombudsman can be invoked
• Binding decisions: Ombudsman decisions will be binding on landlords (subject to any appeal rights). The Ombudsman can award compensation to tenants and require landlords to take corrective action. Non-compliance with an Ombudsman decision will be a ground for further enforcement action
• Membership fee: Landlords will be required to pay an annual membership fee to the PRS Ombudsman scheme. The fee structure has not yet been published but is expected to be proportionate to portfolio size
• Cannot let without membership: Once Phase 2 commences, a landlord who is not a member of the PRS Ombudsman scheme will be unable to serve a valid Section 8 notice or obtain possession through the courts. This mirrors the position of an unlicensed HMO landlord under the Housing Act 2004
• Agents must check client membership: Letting agents acting for private landlords will have obligations to verify that their landlord clients are registered on the Private Landlord Database and are members of the PRS Ombudsman scheme before accepting instructions to manage or let a property

The Private Landlord Database (PLD) — registration obligations

The Private Landlord Database is a national register of all private landlords and their residential properties in England:

• Mandatory registration: Every private landlord in England with at least one residential let property must register on the Private Landlord Database when Phase 2 commences. Registration covers the landlord's identity, all let properties, and key tenancy information
• What must be registered: The landlord's name, address, and contact details. All let residential properties (by address). Evidence of compliance with key obligations — including EPC rating, gas safety certificate, EICR, and deposit protection confirmation. The database is expected to require periodic renewal and updating
• Tenant access: Prospective and current tenants will be able to search the Private Landlord Database to verify whether a landlord is registered and to check compliance records. This creates a reputational incentive for landlords to maintain compliant records
• Enforcement: Local housing authorities will have access to the database and will be able to use it to identify non-registered landlords, trigger enforcement action, and correlate registration data with complaints and licensing records
• Cannot issue valid Section 8 without registration: A landlord who is not registered on the Private Landlord Database will not be able to serve a valid Section 8 notice to seek possession. This is equivalent to the bar on unlicensed HMO landlords using Ground 8
• Agent obligations: Letting agents managing properties on behalf of landlords will be required to verify that all managed properties are registered on the PLD. Agents who knowingly manage unregistered properties will face their own enforcement exposure

What landlords should do now to prepare for Phase 2

Although Phase 2 has not yet commenced, there are immediate preparation steps every landlord should take:

• Audit your portfolio records now: Ensure you have current, accurate records for every let property — EPC certificates (valid for 10 years), gas safety certificates (annual), EICR reports (5-year cycle), and deposit protection confirmation. These are expected to be required for PLD registration
• Check compliance with Phase 1 obligations: Phase 2 enforcement will be more sophisticated with a national database. Landlords with outstanding Phase 1 compliance gaps — unserved Information Sheets, no PAT agreement for new tenancies, or Section 21 notices still served — should resolve these immediately
• Ensure your details are correct with HMRC: The Private Landlord Database is likely to cross-reference with HMRC's Let Property Campaign data. Ensure your rental income is correctly declared in your Self Assessment tax return before registration is required
• Speak to your letting agent: If you use a letting agent, discuss Phase 2 obligations now. Your agent will need to verify your PLD registration status and Ombudsman membership, and may need updated authorisation documentation
• Consider professional compliance review: Before Phase 2 commences, a portfolio compliance review covering all required certificates, tenancy agreements, and compliance records is advisable — particularly for portfolio landlords with multiple properties
• Monitor government announcements: The commencement date for Phase 2 will be set by statutory instrument. Monitor MHCLG (Ministry of Housing, Communities and Local Government) announcements and the GOV.UK website for the publication of Phase 2 commencement orders

Impact on letting agents

Phase 2 of the RRA 2025 creates significant new obligations for letting agents as well as landlords:

• Agent registration requirements: Letting agents will face their own registration and compliance obligations under Phase 2. The detail of agent-specific requirements is expected to be set out in secondary legislation (regulations)
• Duty to verify landlord status: Agents will be obligated to verify that landlord clients are registered on the Private Landlord Database and are PRS Ombudsman members before accepting instructions, advertising a property, or managing a tenancy
• Redress scheme continuation: Letting agents are currently required to belong to one of the approved property redress schemes (Property Ombudsman or Property Redress Scheme). These obligations continue alongside the new PRS Ombudsman, which is specifically for landlord-tenant disputes
• Client money protection: CMP obligations for letting agents continue and are unaffected by Phase 2 of the RRA 2025

Frequently asked questions