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Section 100 makes extensive amendments to Part 1, Housing Act 2004, by creating a new power for the Secretary of State to make regulations which “specify requirements that must be met in England by qualifying residential premises”. The detailed operation of the new standard will be set out in regulations but this reform is not anticipated to come into effect until 2035-2037 (see the “roadmap” for commencement in HousingView, 17 November 2025)
Provision is made for an annual assessment of the quality of housing provided to members of the armed forces and their family members (s.101).
Sections 103-105 make significant amendments to the operation of Rent Repayment Orders under the Housing and Planning Act 2016, including the following:
(a) Permitting a rent repayment order to be made against a superior landlord where that landlord has engaged in conduct which gives rise to a rent repayment order (e.g. the superior landlord is the person having control of or managing an unlicenced HMO, notwithstanding that the immediate landlord of the tenants is a third party). This should make it more difficult for rogue landlords to insulate themselves against rent repayment orders by inserting a shell company between themselves and the tenants.
(b) Providing that, where a body corporate commits an offence which gives rise to a rent repayment order, a member, director “or similar officer” is also to be treated as having committed the offence if the body corporate acted with the consent or connivance of that person or the offence was attributable to “any neglect” on their part. This should provide a route to secure rent repayment orders against the officers of rogue landlord companies and is likely to be utilised where the company is an undercapitalised shell company (e.g. £1 share capital).
The Secretary of State may, by regulation, make arrangements for a lead enforcement authority or authorities (or other public bodies, including the Greater London Authority) to enforce specified landlord legislation in an area of multiple authorities and to issue guidance to those other authorities (ss.111-113).
Local authorities are given new powers to require landlords and any other person to provide information in connection with, amongst other things, the Protection from Eviction Act 1977 and the new Act. Similarly, new powers of entry with and without warrants are created in respect of business premises (ss.118, 119)) and residential premises (ss.126,128). A number of statutes are amended to facilitate information sharing with local authorities (e.g. the tenancy deposit provisions of the Housing Act 2004 are amended to facilitate deposit schemes providing information requested by a local authority).
Published on 07/01/2026