Renters Rights Act and Smoke Alarms: What Changes for Landlords

The Structural Shift: Periodic Tenancies and Testing Triggers

The Renters' Rights Act 2025 abolished fixed-term Assured Shorthold Tenancies (ASTs) and Section 21 "no-fault" evictions for assured private tenancies in England. Those tenancies are now periodic and continue until lawfully terminated. This changes how landlords manage the Day-One alarm testing obligation under the Smoke and Carbon Monoxide Alarm (England) Regulations 2015 (as amended 2022).

Under the old framework, a typical two-year fixed-term AST created a clear testing trigger: the Day-One test happened when the tenant moved in at the start of the fixed term. When the fixed term expired and rolled into a statutory periodic tenancy, no new testing trigger arose — the tenancy continued without a fresh grant.

Under the new framework, existing tenancies transitioned to assured periodic status automatically. That transition did not create a new tenancy. It continued the existing one. So no new Day-One test was required at the transition date.

The testing trigger still applies when a genuinely new tenancy is granted, such as when a property is re-let after a void period. A change of occupant in an existing tenancy does not by itself establish that a new tenancy has been granted. A rent review under Section 13 of the Housing Act 1988 with an existing tenant in continuous occupation does not trigger a retest.

What Actually Changes for Alarm Compliance

In practical terms, two things change:

Renewals were not a statutory test trigger. Under the old system, some landlords used fixed-term renewals as a voluntary compliance checkpoint, but a renewal itself did not require a new Day-One test. That voluntary checkpoint disappears with fixed-term renewals. Build a separate schedule for routine testing and tracking alarm ages rather than relying on tenancy milestones.

Longer tenancies, older alarms. Periodic tenancies can last longer. A smoke alarm installed at the start of a tenancy in 2022 has a 10-year manufacturer lifespan expiring in 2032. If the same tenant stays for the full decade, there is no tenancy-start trigger to prompt a replacement check. The alarm ages out quietly unless you track the manufacture date independently.

The Ongoing Duty to Repair

The 2022 amendment introduced Regulation 4(1)(c): when a tenant reports a faulty alarm, you must repair or replace it as soon as reasonably practicable. This duty applies continuously throughout the tenancy — it is not limited to the Day-One check. Under the new periodic tenancy structure, this ongoing duty becomes more important because tenancies last longer and alarms are more likely to fail or expire during the tenancy.

If a tenant has been in the property for seven years and reports that the CO alarm is beeping intermittently, you cannot wait for a tenancy changeover. You must arrange repair or replacement as soon as reasonably practicable, taking the nature of the fault and any immediate risk into account. The regulations do not set a specific number of hours for repairs.

The Decent Homes Standard and PRS Database

The Renters' Rights Act provides for the Decent Homes Standard to apply to the private rented sector for the first time. The new standard is scheduled to apply from 2035. Until then, landlords' smoke and CO alarm duties continue under the existing alarm regulations; the Decent Homes Standard does not replace them.

The Act also provides for a Private Rented Sector Database (PRS Database). Rollout and registration requirements are being phased in, with rollout planned from late 2026. The database is intended to give councils searchable landlord and property information to support targeted enforcement; it does not replace the existing alarm duties.

What to Do Now

The alarm regulations themselves have not changed. The duties are the same: smoke alarms on every storey, CO alarms in rooms used as living accommodation that contain a fixed combustion appliance (excluding gas cookers), Day-One tests for new tenancies, and prompt repair of reported faults. With fixed-term renewals gone, landlords who relied on them as voluntary checkpoints need a system for tracking alarm ages and scheduling periodic checks.

Our Smoke and CO Alarm Compliance Guide includes a hardware lifecycle tracker that logs each alarm's manufacture date and calculates its expiry. It works whether your tenant stays for one year or ten, so you catch ageing alarms before they fail — and before a council inspection catches them first.

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