Renters' Rights Act and HMO Licensing in England: What Changes for Landlords

The Renters' Rights Act 2025 is the largest change to private renting law in England in a generation. For HMO landlords, it adds a new registration requirement on top of the existing licensing obligations — and tightens the consequences of non-compliance.

The Private Rented Sector Database

The Act creates a new Private Rented Sector (PRS) Database — a central register where landlords of assured or regulated tenancies must register themselves and each property. This is separate from and in addition to HMO licensing.

The registration service opens on 15 December 2026, beginning in the West Midlands, with a regional rollout through 2027. Registration costs £65 per property per year. Once your property's region opens, you will need to:

• Register as a landlord on the database
• Register each rental property individually
• Keep your registration current (updating occupancy changes, management arrangements, and safety certificate details)

Registration on the PRS Database does not replace or remove the HMO licensing requirement. An HMO landlord will need both: a valid licence from the local council and an active registration on the national database. The two systems serve different purposes — the licence governs property standards and management, while the database creates a central record of who is renting what and where.

Section 21 Abolition

The Act abolished Section 21 "no-fault" eviction notices on 1 May 2026. For HMO landlords, this means:

• You can no longer end a tenancy without giving a statutory ground
• Landlords must rely on statutory grounds for possession, including grounds for landlord sale, landlord or family occupation, redevelopment, and tenant fault (such as rent arrears or anti-social behaviour)
• Existing assured shorthold tenancies became assured periodic tenancies, and new assured tenancies are periodic (no fixed-term ASTs)

The practical impact on HMO licensing: before 1 May 2026, Section 75 of the Housing Act 2004 prevented a landlord of an unlicensed HMO from serving a valid Section 21 notice. Section 21 has now been abolished. The PRS Database rules will prevent a court from granting a possession order when a landlord has not met the registration duty, subject to statutory exceptions; the registration duty starts as each region enters the rollout. Licensing duties and enforcement remain separate.

Licence Compliance Becomes More Important

The Act strengthens the enforcement framework around licensing compliance:

• Civil penalties for operating without a licence can reach £40,000 per offence
• Rent repayment orders remain available to tenants in unlicensed HMOs; the limit is up to 24 months' rent for offences committed on or after 1 May 2026, and 12 months for offences before that date
• The new Landlord Ombudsman — landlords must join an approved ombudsman scheme. Complaints about property conditions, licensing compliance, and management failures can be escalated through this route
• PRS Database cross-referencing — when the database launches, councils will be able to cross-reference registered properties against their licensing records, making it easier to identify unlicensed HMOs

The overall direction is clear: more visibility into the private rented sector, more enforcement tools for councils, and higher costs for non-compliance.

What HMO Landlords Should Do Now

The Renters' Rights Act is being implemented in phases. The PRS Database is not live yet, and the detailed regulations governing registration requirements are still being finalised. But the Act is law, and the direction of travel is set.

For HMO landlords, the immediate priorities are:

1. Ensure your HMO licence is valid and current — the existing licensing framework is unchanged and enforcement continues
2. Update your tenancy agreements — the Act requires tenancy terms that comply with the new periodic tenancy structure
3. Prepare for PRS Database registration — gather the property details, safety certificate records, and management information you will need when registration opens
4. Review your grounds for possession — if you need to regain possession, identify the current statutory ground and follow its notice requirements

The licensing requirement itself is unaffected by the Act. The five-person, two-household test still applies, the fee structure is still set by individual councils, and the application process still requires the same safety certificates and documentation.

Our HMO Licensing Guide for England covers the licensing framework as it stands, with the current rules, fees, and application requirements that apply while the Act's provisions are phased in.

See more England guides →