Redbridge Rent Repayment Order for Unlicensed Property: What Landlords Face

Rent repayment orders are the enforcement mechanism landlords hear about last and fear most. Unlike civil penalties, which come from the council, an RRO is filed by your own tenants at the First-tier Tribunal — and the financial exposure doubled in May 2026.

What a Rent Repayment Order Is

Under the Housing and Planning Act 2016, a tenant or the local authority can apply to the First-tier Tribunal (Property Chamber) for an order requiring the landlord to repay rent for the period the property was operated without a valid licence.

The tenant does not need the council's permission or involvement to file. They apply directly using Form RRO1, setting out the statutory grounds, property details, total rent claimed, and supporting evidence such as the tenancy agreement, rent payment records, and confirmation from the council's public register that the property was unlicensed.

The 24-Month Cap

Before 1 May 2026, the maximum RRO award was 12 months of rent.

The Renters' Rights Act doubled this. For qualifying offences committed on or after 1 May 2026, the cap is 24 months of rent.

For continuing offences that span across 1 May 2026 — for example, a property that was unlicensed from January 2026 through to the present — the 24-month cap applies to rent paid from 1 May 2026 onward, while the pre-May 2026 portion is subject to the old 12-month maximum. In practice, this means the total RRO exposure can cover up to 36 months of combined rent across the two periods.

Who Is Liable

RRO liability extends beyond the landlord named on the tenancy agreement:

• The immediate landlord (the person who granted the tenancy)
• Superior landlords (head lessees or freeholders who receive rent from the mesne landlord)
• Directors of corporate landlords

If a property is owned through a company, individual directors can be personally liable for the RRO payment.

How Tenants Find Out

Redbridge Council maintains a public register of licensed properties. Tenants can search it to check whether their rental is licensed. Advice services including Shelter and Citizens Advice actively guide tenants through the RRO process, and landlord forums show increasing awareness among tenant communities — particularly in Ilford and surrounding areas where selective licensing coverage expanded significantly with Scheme 4.

The council's public register has experienced technical migration issues, which sometimes show licensed properties as unlicensed or return errors. For landlords, this makes maintaining your own evidence trail critical — keeping copies of your application confirmation email, tracking code, and payment receipt proves you applied even if the register is temporarily inaccurate.

What the Tribunal Considers

The tribunal has discretion on the amount awarded. It considers:

• The severity and duration of the offence
• Whether the landlord's failure to licence was deliberate or the result of genuine ignorance
• The landlord's financial circumstances
• The conduct of both landlord and tenant
• Whether the landlord has subsequently obtained a licence

A landlord who applies immediately after discovering the requirement will generally face a lower award than one who has ignored repeated notices from the council.

Protection Through Timely Application

Submitting a complete licence application stops the clock on new unlicensed periods. It does not retrospectively cover the period before submission, but it establishes the point from which the property is treated as having a pending licence.

The practical lesson: apply as soon as you become aware of the requirement. Every month of delay adds to the period of potential RRO exposure.

The Redbridge Landlord Licensing Guide includes an application submission log that documents when you applied, what you submitted, and your tracking reference — evidence you can produce if a tenant ever challenges your licensing status at tribunal.

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