The Renters' Rights Bill received Royal Assent on 27 October 2025. The new Renters' Rights Act 2025 (RRA) has been hailed by Government as “historic” and undoubtedly it will have a transformative effect on private renting through the withdrawal of fixed-term assured tenancies, the ending of assured shorthold tenancies (ASTs), and the abolition of section 21 “no fault” evictions.

Despite the Bill now having completed its passage through Parliament, there are still a number of aspects of the RRA that remain unclear. We have set out below three examples – representing a cross–section of some of the areas where further information is required. 

Over the coming weeks and months, we will be tracking regulations, secondary legislation and implementation timescales.

Timing/commencement 

Many of the provisions within the RRA require additional steps to be taken to bring them into force. The Government has not yet published an implementation timeline and the Government’s press release states, without any specified deadline, that ministers will outline how the reforms will be rolled out “in the coming weeks.”

The following sets out examples of current “unknowns”:

• The RRA reflects the Government’s manifesto promise to ban “no fault” section 21 evictions, however this will not be immediately delivered. Industry has been pushing for a minimum six-month window between Royal Assent and the “commencement date” for the major changes that have been introduced by the RRA (i.e. banning of section 21 “no fault” evictions, the end of ASTs and the end of fixed-term assured tenancies giving way to assured periodic tenancies). Both “Spring 2026” and “May 2026” have been mooted as the anticipated timing for these changes coming into force, but the lack of a fixed timescale creates uncertainty for both tenants and landlords as to when the final date for serving section 21 notices will be. The RRA includes a time-limited mechanism which will preserve valid section 21 notices served before the relevant commencement date and provide a window of time for proceedings to commence. 

• The RRA contains an obligation for landlords to register on a new landlord database but the deadline for this is not yet clear. Some think that this will be of secondary importance (and timing) to the banning of section 21 “no fault” evictions whereas others believe this will come into effect very quickly (possibly driven by the Treasury). Landlords need to be aware that they will need to act quickly to register on the database when it goes live. Not only is commencement unknown, but we also do not yet know the detail of the information that will need to be provided as part of that registration process. It will be an offence not to register and non-compliance will prevent landlords from using certain section 8 possession grounds.

Purpose-Built Student Accommodation (PBSA)

• Government’s expressed intention is that PBSA providers will not be affected (i.e. PBSA providers will be able to grant fixed-term tenancies to work with the academic year) and the RRA contains provisions relating to the much discussed “PBSA exemption”. To benefit from the exemption, the landlord (or person appointed by the landlord to discharge management functions) needs to be a member of a housing code of practice and the tenancy must be granted to a full-time student at a specified educational institution. This will be judged on the circumstances at the time when the tenancy is granted (preventing pre-approved landlords dropping out of the approval conditions prior to tenant occupancy). However, the position remains unclear: 

  • the provisions need to be brought into effect by regulations and the time period for bringing those forward is unknown (although we understand they are well progressed); and 

  • the detail of the regulations is also unknown, and the drafting will be key to the actual impact and effect of the proposals within the RRA (i.e. what bodies will be included in the definition of “specified educational institution”). 

• The status of existing ASTs of PBSA which were entered into prior to the RRA remains somewhat uncertain. The Government has previously indicated that “tenancies entered into prior to the commencement of the Bill will fall outside the scope of the exemption and, therefore, will be subject to the full provisions of the new assured tenancy system.” The Government perceived that a “significant risk” would arise by turning an existing PBSA tenancy into a common law tenancy. The Government introduced an additional provision to “smooth over the transition for the sector” by providing access to a modified ground 4A for certain landlords (i.e. signed up to a housing code of practice) of certain existing PBSA tenancies after the transition date provided the correct notice procedure is followed. It is hoped that the awaited Regulations will further address and clarify the transition arrangements offering further comfort on this point.

Rent Review

• The only way to increase rent when the relevant provision of the RRA comes into force is via the section 13 process and tenants will have new powers to challenge unreasonable rent reviews. There are concerns that the First Tier Tribunal (FTT) will need time to get used to rent review challenges, along with the increased number of cases that they will be dealing with. There has been limited information about how the FTT will be funded to deal with this; however, it is expected that there will be a number of judges recruited for the purpose of sitting in the FTT for rent hearings. The Government will have the power to re-assess the system in the future if it appears not to be working. However, in order for this to be achieved, a body of data will need to be collated regarding FTT delay and there is currently no clear methodology to do so. 

• There are similar capacity concerns regarding the anticipated uptick in section 8 applications for terminating leases in lieu of the section 21 procedure.