Renters' Rights Act and the PRS Database: What Landlords Must Do

Phase 1 Changed Tenancies — Phase 2 Changes Registration

The Renters' Rights Act 2025 restructured private renting in England across multiple phases. Phase 1 took effect on 1 May 2026, abolishing Section 21 no-fault evictions, converting all Assured Shorthold Tenancies into assured periodic tenancies, standardising rent increases via Form 4A, banning rental bidding, and capping rent-in-advance demands to one month.

The database rollout begins on 15 December 2026 and proceeds region by region, with landlords actively letting property required to register by 14 November 2027. The Private Rented Sector Landlord Ombudsman follows later, with compulsory membership expected in 2028.

The Legal Foundation

The PRS Database sits in Part 2, Chapter 3 of the Act (Sections 75 to 96). The operational details — data fields, fee amounts, portal procedures, and compliance evidence requirements — are set out in the published draft Private Rented Sector Database Regulations 2026. As of 24 October 2026, the draft instrument has not yet been made as a UK Statutory Instrument.

Key provisions:

• Section 75 establishes the database and the database operator under MHCLG
• Section 78 imposes the 28-day update duty for changes in circumstances
• Section 81 authorises database fees; GOV.UK says the announced annual fee is £65 per property
• Section 82 restricts marketing or letting without active registration when the relevant requirement applies; GOV.UK says registering unoccupied properties before marketing will come under future legislation
• Section 90 bars the court from making a possession order while the landlord is in breach of the active-entry duty, except on Grounds 7A and 14
• Sections 91–92 set the penalty framework: up to £7,000 for initial breaches, up to £40,000 or prosecution for serious/repeat offences
• Section 98 expands Rent Repayment Orders to cover database offences (up to 24 months' rent)

What Changed Between the Bill and the Act

The Renters' Rights Bill went through several amendments before receiving Royal Assent on 27 October 2025. The fee structure, regional rollout approach, and possession bar were all refined during parliamentary passage. Some online guides still reference earlier Bill-stage proposals. The £65 per-property fee and the nine-region rollout timetable are in current GOV.UK guidance; the database regulations remain in draft form.

The Act provides for banning-order and other prescribed enforcement entries to be added to the PRS Database. Council enforcement powers under the Housing Act 2004 remain in force alongside database duties.

How Phase 2 Connects to Phase 1

Phase 1 and Phase 2 interact in practical ways. The conversion of ASTs to assured periodic tenancies means former ASTs now fall under the assured tenancy framework — one of the tenancy types the PRS Database covers; regulated tenancies are also covered.

If you adjusted your tenancy management for Phase 1 (serving the statutory Information Sheet by 31 May 2026, switching to Form 4A rent increases, removing break clauses), Phase 2 adds database registration on top. The gas, electrical and EPC information requested for the database overlaps with compliance records many landlords already maintain.

The progression is cumulative. Phase 1 compliance doesn't substitute for Phase 2 registration, and Phase 2 doesn't retroactively change anything about Phase 1. Both apply simultaneously.

The PRS Database Registration Guide covers the full registration process end to end, including how Phase 1 tenancy changes affect your dwelling entry data and which Phase 1 documents feed directly into your database submissions.

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