Renters' Rights Act Phase 2 introduces landlord database and rent dispute reforms in England

On 9 September 2026, the government announced the latest step in its overhaul of the private rented sector (PRS), a new national PRS database. This marks phase 2 of the government's implementation of reforms under the Renters' Rights Act. The purpose of this latest phase of reforms is threefold: giving landlords a single place to demonstrate compliance; giving local authorities better information for enforcement; and eventually giving tenants access to specified information about landlords and properties.

The announcement confirms that landlords in the PRS will be legally obliged to register their rental properties on a central database aimed at increasing transparency in the sector and enabling councils to identify rogue landlords more quickly. The PRS database will initially operate as a private register, but future legislation is intended to make it publicly available for prospective tenants.

Additionally, in a bid to speed up the resolution of rent disputes, HMRC's Valuation Office will take over responsibility for deciding challenges to rent increases.

Rollout in phases

Rollout will begin in the West Midlands on 15 December 2026 and move through England region-by-region each month. It is understood that landlords will generally have three months from the commencement date for their region to register, with all actively let properties required to be registered by 14 November 2027. 

Landlords may register their properties at any time from 15 December 2026, provided registration is completed by the relevant regional deadline. 

Required information 

Individual private landlords must provide their name, date of birth, residential address, telephone number and email address. Organisational landlords must provide the organisation name and legal entity type, address, telephone number, email address and details of the individual completing the entry on the organisation's behalf. 

For each property, landlords must upload health and safety documentation, such as gas safety records, electrical installation condition reports or electrical installation certificates, and energy performance certificates. 

Full details of the information required are set out in the draft Private Rented Sector Database Regulations 2026.

Fees and fines

A registration fee of £65 applies per property and each property must be renewed annually. This is of particular importance for private landlords with numerous properties, who may incur significant annual registration costs. 

Registration at the PRS database is compulsory and landlords can face substantial financial penalties for failing to comply.

Landlords who fail to meet their registration obligations, for example, by marketing or letting an unregistered property, can face fines of up to £7,000 imposed by the local authority. 

Landlords who breach the rules repeatedly face significantly higher penalties. Where a landlord who has already been fined commits a further breach within five years, this constitutes a criminal offence. In such situations, the local authority may impose a fine of up to £40,000 instead of pursuing criminal prosecution.

Knowingly or recklessly providing false or misleading information to the database is also a criminal offence. The local authority can choose to prosecute the landlord, resulting in an unlimited fine; or impose a civil fine of up to £40,000. These routes are mutually exclusive, meaning a landlord cannot face both a civil fine and criminal conviction for the same conduct.

Rent increase disputes 

Currently, tenants can challenge a proposed rent increase on the basis that it exceeds the open-market rent, with these challenges going to the First-tier Tribunal (Property Chamber). 

The government has now confirmed that HMRC's Valuation Office will take on responsibility for determining rent increase disputes. This change is intended to allow private tenants to resolve rent disputes more quickly by making use of the Valuation Office's expertise, with a secondary benefit of reducing pressure on the tribunal. 

Until the new Valuation Office service is introduced, applications will continue to be made to the First-tier Tribunal. The government has not yet provided a commencement date for the new system.

Student accommodation exception

The Act maintains a distinct regime for student accommodation and some student tenancies are exempt from the new reforms.

Accredited educational institution accommodations and private purpose-built student accommodation sit outside the scope of the Act and will be unaffected by the database and rent dispute changes. Ordinary student houses and private halls which do not qualify for the above exemptions will generally be treated in the same way as the wider PRS. 

Checklist for landlords

The PRS database enlarges the new compliance obligations for landlords. In practice, landlords must ensure that their property portfolios are fully documented and that registration deadlines for each region are noted.

While letting agents or property managers can provide certain information on a landlord's behalf, landlords are ultimately responsible for providing all required information. 

In the short term, landlords should consider:

• Identifying all properties that fall within the scope of the PRS database and collecting required property and personal information, including health and safety documentation.
• Factoring registration and renewal fees into business plans.
• Updating internal policies and processes to ensure registration is completed before properties are marketed, advertised, or let and liaising with any managing agents accordingly.
• Monitoring the development of the new HMRC Valuation Office rent dispute service and reviewing rent dispute clauses.

Osborne Clarke comment

This second phase of reforms continues the swathe of significant changes of the private rented sector in England under the Act. Although the registration fee of £65 may not seem too significant, as it is per property and with an annual renewal obligation, it will weigh most heavily on landlords with large property portfolios. For build-to-rent investors with large blocks of flats, the fee will apply to each flat not the block overall.

It remains to be seen how effective the shift from the First-tier Tribunal to HMRC's Valuation Office will be, and if it will be faster as intended. However, the government's acknowledgment of the concerns that the FTT is likely to be overwhelmed, raised by the sector as the Act was going through Parliament, will no doubt be welcomed. 

Early planning is advisable to prepare for these reforms and it would be prudent to treat the rollout from December 2026 as a preparation window rather than a reason to delay.

Fred Light, trainee solicitor, assisted in preparing this Insight.