Blackpool Council Rent Repayment Order — What Landlords Need to Know

The Basic Mechanism

A rent repayment order (RRO) forces a landlord to pay back rent already collected. Tenants or local authorities can apply to the First-tier Tribunal for an RRO when a landlord has committed certain housing offences — and operating without a required housing licence is one of the qualifying offences.

For Blackpool, this means any landlord letting a property in the eight inner selective licensing wards without a licence (and without a duly made application pending) is exposed to an RRO claim from their tenants.

Two Regimes: Before and After 1 May 2026

The Renters' Rights Act 2025 doubled the stakes. The rules depend on when the offence was committed:

Offences before 1 May 2026 — The original Housing and Planning Act 2016 framework applies. Tenants can recover up to 12 months' rent, and the application must be filed within 12 months of the offence.

Offences from 1 May 2026 onward — The expanded rules under Section 98 of the Renters' Rights Act apply. The maximum recovery jumps to 24 months' rent, and tenants have 2 years from the date of the offence to file.

The Act also reversed the Rakusen v Jepsen decision. A rent repayment order can now be made against a superior landlord if that landlord committed the qualifying offence. In a rent-to-rent arrangement, ownership alone does not make the superior landlord automatically liable; the tenant must be able to show that the superior landlord committed the offence.

What It Means in Practice

Take a single terrace in Bloomfield renting for £650 a month. Under the post-May 2026 rules, a successful 24-month RRO would be £15,600. The tribunal has discretion over the amount — they don't always award the full 24 months — but the ceiling is real.

For a licensing offence committed on or after 1 May 2026, add a civil penalty of up to £40,000 from Blackpool Council. Combined with the £15,600 RRO example, total potential exposure from one unlicensed property is £55,600.

For multi-property landlords, each property generates its own exposure. A portfolio of three unlicensed flats in a converted guesthouse in Talbot could face three separate RRO claims from three separate sets of tenants, plus council enforcement on each unit.

The Expanded List of Qualifying Offences

The Renters' Rights Act expanded the qualifying offences. Current GOV.UK guidance groups them into 10 categories. The ones most relevant to Blackpool landlords include:

• Operating an unlicensed HMO (Section 72(1) Housing Act 2004)
• Operating an unlicensed selective property (Section 95(1) Housing Act 2004)
• Breach of a Banning Order (Section 21 of the Housing and Planning Act 2016)
• Failure to comply with an improvement notice
• Failure to comply with a prohibition order
• Unlawful eviction

The Tribunal Process

Blackpool falls within the Northern Region of the First-tier Tribunal (Property Chamber), based at Piccadilly Exchange, 2 Piccadilly Plaza, Manchester, M1 4AH. The application fee is £114, with a £227 hearing fee if the case proceeds to a hearing. Tenants who can't afford the fees can apply for fee remission using Form EX160.

Either the tenant or Blackpool Council can apply. In practice, council-led RRO applications are rarer — most come from tenants, sometimes supported by organisations like Justice for Tenants.

How to Avoid Exposure

The straightforward answer: get licensed or make sure your application is duly made. A pending application that meets all three criteria (all fields completed, documents uploaded, Part 1 fee paid) gives you statutory defence under Section 95(3)(b) of the Housing Act 2004. No tribunal can award an RRO for a period when you had a valid licence or a duly made application pending.

If you inherited a property with sitting tenants and weren't aware of the licensing requirement, that lack of awareness is not a defence. The obligation to check is on you.

The Blackpool Landlord Licensing Guide covers the RRO framework, the tribunal process, and the exact steps to establish duly-made protection before your exposure starts.

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