Renters' Rights Act: the first 100 days

At 00:01 on 1 May 2026, the Renters' Rights Act 2025 commenced via Statutory Instrument 2026/421 (the commencement order made under section 145 of the Act). Section 21 was abolished, every existing assured tenancy in England converted to a periodic tenancy by operation of law, the new Section 8 grounds came into force, the bidding ban began to bite, and the new Section 13 mechanics for rent increases became the only lawful route.

This guide is the early-implementation companion to our main Renters' Rights Act overview. Where the overview explains the law, this guide focuses on what is actually happening — early possession activity, tribunal volumes, common landlord errors, and the operational steps the better-organised portfolios are taking through the first 100 days.

1. What landed on day one

For clarity, here is the position from 1 May 2026:

• Section 21 abolished. No further Section 21 notices may be served. Pre-existing Section 21 notices served by 4:30pm on 30 April 2026 remain valid only where possession proceedings are issued by 31 July 2026.
• Automatic conversion to periodic tenancies. Every fixed-term assured tenancy and AST in England converted to a periodic tenancy on 1 May 2026 by operation of law. No grandfathering.
• New Section 8 grounds in force.Ground 1A (sale, mandatory, 4 months' notice, 12-month protected period at start of tenancy, 12-month re-letting ban after possession). Ground 1 (landlord or close family moving in, same terms). Ground 8 (rent arrears, mandatory, threshold raised to 3 months and notice extended to 4 weeks; must be satisfied at both notice and hearing). Other grounds amended.
• Section 13 rent-rise mechanics.One rise per 12-month period, by formal Section 13 notice (Form 4) with at least two months' notice. Tribunal can confirm or reduce — but never increase above the proposed figure.
• Bidding ban. Sections 55–56 require an asking rent to be published in any property advertisement and prohibit accepting offers above that asking rent.
• Civil penalties. Up to £7,000 for first or less-serious breaches, up to £40,000 for serious or repeated breaches.
• Discrimination protections. Blanket bans on tenants with children or those receiving benefits are prohibited.

2. What's playing out in the first 100 days

Section 13 tribunal volumes are up

The leading pre-commencement indicator was Goodlord's 2025 State of the Lettings Industry report (published October 2025, drawn from a survey of more than 2,600 agents, landlords and tenants) which found 22% of tenants said they would always appeal a rent increase, regardless of whether they considered it fair. The first 12 days of post-commencement data are too early to verify whether challenge volumes match that intent figure, but anecdotal reports from FTT Property Chamber clerks indicate Section 13 application volumes are tracking well above the pre-Act baseline. Practitioners should plan for 4–6 month timescales from notice to decision through 2026.

Early Ground 1A possessions and the re-letting ban

The first Ground 1A (sale) possessions are working through county courts on tenancies already past their 12-month protected period. The harder enforcement question is the 12-month re-letting ban that runs from possession. Local authority enforcement teams, already empowered under the Act's expanded investigatory provisions (in force since 27 December 2025), are actively monitoring sales portals and re-letting listings against recently-recovered properties. Expect early test cases on the ban in late 2026 and early 2027.

First Ground 8 mandatory arrears claims

Ground 8 — the mandatory rent arrears ground — now requires three months of arrears at both notice and hearing (up from two months), with notice extended from two weeks to four weeks. The early pattern: claims that would have run to a mandatory possession order under the old threshold are now being defeated where the tenant clears the arrears below three months before the hearing date. Landlords with developing arrears cases need to issue earlier and document Universal Credit interactions carefully — the statutory carve-out for arrears caused by delayed UC payments is being actively tested.

Bidding ban enforcement

Letting agents have, on the whole, adapted quickly — most advertising platforms (Rightmove, Zoopla, OnTheMarket) updated their listing schemas in April 2026 to require a single asking rent and to prohibit “offers in excess of” framing. The early enforcement pattern is focused on agents accepting above-asking offers via off-platform channels (WhatsApp, email). Local authority enforcement teams have begun mystery-shopping exercises on agents in high-demand London and Manchester sub-markets. Expect the first civil penalty publications by end of 2026.

3. Common landlord mistakes in the rush to 30 April

Three errors are showing up repeatedly in early-implementation queries to the NRLA, LRS, and the larger landlord legal helplines:

• Last-minute Section 21 notices that the 31 July longstop won't save. A Section 21 served on 28 April 2026 is valid in principle, but the landlord must issue possession proceedings by 31 July 2026 to act on it. Several practitioners report landlords who served notices on 29–30 April assuming they had “months to use it”, unaware of the issuing longstop. Beyond 31 July the notice is dead and the landlord is back to Section 8 grounds with the new four-month notice periods.
• Missed Section 13 timing.A Section 13 notice served before 1 May 2026 under the old regime, then re-served or modified after 1 May, is governed by the new rules. Some landlords attempted to “front-load” a rent rise just before commencement to get under the wire — only to discover that the conversion to a periodic tenancy on 1 May reset the 12-month clock. Track your rent-rise dates carefully.
• Attempting to use unenforceable rent-review clauses. Tenancy agreement clauses purporting to allow mid-term rent reviews, index-linked rises, or any other non-Section-13 mechanism are unenforceable from 1 May 2026 onwards. Several agents have reported landlord queries assuming a contractual annual escalator survives the Act — it does not. Section 13 is the only route.

4. The pet insurance correction

This deserves its own section because it is the single most common factual error circulating in third-party landlord content since commencement.

The original Renters' Rights Bill contained a provision allowing landlords to require tenants who kept a pet to take out pet damage insurance. The provision was removed during Lords report stage and is NOTin the final Renters' Rights Act 2025. The position from 1 May 2026 is:

• Tenants have an implied statutory right to request to keep a pet.
• The landlord must respond in writing within 28 days.
• Refusal must be reasonable — head-lease prohibition, unsuitable property (small flat, no outdoor space), or building insurance refusal are recognised reasonable grounds.
• Landlords cannot require tenants to take out pet insurance as a condition of consent.
• Landlords cannot charge a pet rent surcharge or an additional pet deposit (the Tenant Fees Act 2019 five-week cap applies).

If you see a landlord guide, agent template, or blog post referring to mandatory pet insurance under the Act, it is wrong. Verify against the final Act text or the gov.uk Renters' Rights Act Information Sheet 2026 before relying on the provision.

5. PRS Database and the Ombudsman

Two parallel infrastructures are being built out behind the headline reforms:

• PRS Ombudsman (Phase 1). Mandatory landlord membership of an independent redress scheme. Some early provisions commenced on 27 December 2025 (investigatory and reporting powers). The operator has yet to be appointed; mandatory membership expected from 2028 in current government planning, with phased onboarding potentially earlier for larger portfolios.
• PRS Database (Phase 2). A mandatory central register of private landlords and their let properties, operated by central government with local authority access. Phase 2 rollout from late 2026, full operation expected from 2027. Once live, Database registration will become a precondition of serving valid possession notices, with very limited exceptions. Annual registration fee not yet announced.

Practical step: start collating your portfolio compliance evidence now. EPCs (with 2030 MEES C-rating glidepath in mind), annual gas safety certificates, five-year EICRs, deposit protection certificates, and Right to Rent documentation. Database registration will require all of it.

6. Tribunal backlog reality

The government's post-Act roadmap, published alongside the commencement SI, flagged that the digitised possession claims service — intended to speed Section 8 claims through the county courts — will not be operational until approximately April 2027. This is material. Until then, possession proceedings continue to use the existing paper-led process, which was already running with multi-month delays in London and major regional centres pre-commencement.

First-tier Tribunal pressure on Section 13 cases is real and is expected to grow. The Tribunal has not yet announced additional resourcing specifically for Section 13 challenge volumes. Practitioners should:

• Build longer Section 13 timelines into cashflow forecasts — assume 4–6 months at minimum in 2026, longer in London.
• For Ground 8 (mandatory arrears) claims, issue as soon as the three-month threshold is met — do not delay in hope of negotiated repayment, because the threshold must hold to the hearing date.
• Build the tribunal-pressure risk into rent strategy and ICR assumptions. A rent increase challenged at Tribunal effectively freezes the rent at the existing level for 4–6 months — model that into your underwriting on new acquisitions.

7. What good landlords are doing now

The portfolios that have moved fastest through the first 100 days share four habits:

1. Documenting rent comparators. Before serving a Section 13 notice, they assemble a file of Land Registry sold prices, Zoopla and Rightmove asking rents for the same street or block, and any recent letting agent valuations. Because the Tribunal cannot raise rent above the proposed figure, the proposed figure has to be defensible — and the file is what defends it.
2. Tightening tenant referencing.Without Section 21 as a fallback, the cost of a bad tenant decision compounds. The better portfolios are now running deeper affordability checks, three months' payslips minimum, employer reference plus previous landlord reference (in writing) — and applying the same standard to every applicant to avoid discrimination challenges under the new blanket-ban prohibitions.
3. Drafting compliant rent-review correspondence.Standard letter templates have been updated to use Form 4 (Section 13 notice), state the proposed rent as a single figure with at least two months' notice from the next rent due date, include the tenant's Tribunal challenge right, and attach the rent comparator file (or at least reference its availability on request).
4. Pre-positioning for Database registration. A portfolio-wide compliance audit through Q2/Q3 2026 — EPCs, gas, EICR, deposit, Right to Rent — ahead of Database Phase 2 rollout. Better to fix gaps now than to discover them as a barrier to serving a possession notice once registration becomes a precondition.

The Act has not broken the PRS. It has tightened it. Landlords who already ran their portfolios with proper documentation, fair rent strategy and decent tenant relationships are mostly absorbing the change. The discomfort is concentrated where Section 21 was being used as a substitute for proper Section 8 evidence-gathering.

The honest take, 100 days in

The first 100 days have been quieter than the most alarmist pre-commencement commentary predicted, and noisier than the most reassuring official briefings suggested. Section 13 challenges are running hot. Ground 1A possessions are happening but the re-letting ban is being actively policed. The pet insurance myth refuses to die. The Database and Ombudsman infrastructure is being built in the background and will materially change compliance load through 2027.

For long-hold professional landlords with good tenants and decent stock, the Act is a procedural change — manageable. For landlords who relied on Section 21 to paper over weak Section 8 evidence, or who managed portfolios on assumptions about unrestricted rent reviews, the next twelve months will keep being difficult. For new-deal underwriting, the tribunal-backlog risk and the Section 13 downside dynamic should be priced into cashflow forecasts on every acquisition between now and the April 2027 digitised possession service launch.

Guidance only — not legal advice. The Renters' Rights Act 2025 first-implementation period is fast-moving; Statutory Instruments, government guidance and tribunal practice notes are being published throughout 2026. Verify the current position before relying on any specific data point. For any contested possession action, take legal advice.

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