While much of the coverage of the Renters' Rights Act has focused on the abolition of Section 21 and the switch to periodic tenancies, Part 3 of the Act, covering Sections 73 to 94, introduces equally significant structural changes. The creation of a national Private Rented Sector (PRS) Database and a mandatory Landlord Ombudsman will professionalise the sector and expose non-compliance as never before. These changes, coming into effect in March 2026, are designed to foster greater transparency and provide clearer avenues for dispute resolution, ultimately benefiting both landlords and tenants.

The Two Pillars of Part 3: PRS Database and Landlord Ombudsman

Sections 73-94 of the Act establish the PRS Database, while Chapter 2, Part 1, details the Landlord Ombudsman scheme. Together, these institutions aim to create a more regulated and accountable environment for landlords across the UK.

The PRS Database: A New Era of Transparency

The national PRS Database will serve as a central register for all landlords and their properties. This initiative is designed to provide a comprehensive overview of the private rented sector, making it easier to identify and address issues of non-compliance. For landlords, this means a new layer of administrative responsibility, but also an opportunity to demonstrate professionalism and adherence to standards.

Key Aspects of the PRS Database:

• Mandatory Registration: All landlords will be required to register themselves and their properties on the database.
• Information Disclosure: The database will hold key information about landlords and their rental properties, enhancing transparency for tenants and local authorities.
• Enforcement: Local authorities will have greater powers to identify unregistered landlords and take action against those who fail to comply with their legal obligations.
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Costs and Administration

Landlords will be required to pay an annual fee per property to maintain their registration. The government has indicated this will be a modest, cost-recovery fee, and the exact amount will be confirmed ahead of the 2026 regional launch. For portfolio landlords, this will represent a new recurring cost that should be factored into business plans. Agents can register and maintain records on behalf of landlords, and many managing agents are expected to incorporate this into their service offering.

Limited Companies & Joint Ownership

The government has acknowledged that the registration mechanics for limited companies and joint landlords are still being finalised. Current guidance suggests that whoever is named as landlord on the tenancy agreement will be the registering party. Landlords with company-held portfolios should seek specific advice once the secondary legislation is published.

The PRS Landlord Ombudsman: A Fairer Path to Dispute Resolution

For the first time, all private landlords in England will be required to belong to a formal redress scheme, the PRS Landlord Ombudsman. This brings the private rented sector into line with the social housing and property agent sectors, both of which already have mandatory Ombudsman arrangements. Membership will be mandatory regardless of whether a landlord uses a managing agent; the duty falls on the landlord directly.

What Can Tenants Complain About?

The Ombudsman will accept complaints from prospective, current, and former tenants covering a broad range of issues including disrepair and maintenance failures, communication failures or unacceptable delays, unlawful fees or charges, poor management practices, and failure to comply with statutory obligations. The service will be free to use for tenants, with no requirement for legal representation, deliberately designed to be accessible to all renters regardless of means.

How Will the Ombudsman Process Work?

1. Tenant Raises Complaint with Landlord: Before approaching the Ombudsman, tenants must first raise the issue directly with the landlord and allow a reasonable time for resolution. Landlords should maintain a clear, documented complaints process to ensure issues are handled and recorded.
2. Escalation to the Ombudsman: If unresolved, the tenant may refer the complaint to the Ombudsman free of charge. The Ombudsman will independently investigate, requesting evidence from both parties. Landlords will be required to engage and provide documentation within specified timescales.
3. Determination and Remedies: The Ombudsman can require the landlord to take or cease taking an action, issue a formal apology or explanation, and award financial compensation to the tenant. Decisions are legally binding on the landlord.
4. Non-Compliance and Escalation: Failure to comply with an Ombudsman decision may result in the landlord being expelled from the scheme. Expulsion triggers council enforcement action. The Ombudsman also has provision to initiate mediation at the landlord's request, offering an early-resolution route before decisions are issued.

The Housing Ombudsman Connection

The government has indicated that the existing Housing Ombudsman Service, which currently handles social housing complaints, is the most likely administrator of the new PRS scheme, though a formal decision has not yet been confirmed. This would create a single, cross-tenure redress service covering both social and private renting. Where both a landlord and a letting agent are at fault, the PRS Ombudsman can conduct joint investigations with existing agent redress schemes and issue joint decisions.

The Upside for Good Landlords

The Ombudsman is not solely about accountability, it also benefits responsible landlords. It offers a faster, cheaper alternative to court proceedings, can resolve disputes before they escalate, and provides a structured mechanism to demonstrate that a complaint was handled fairly. For landlords who already maintain high standards, the Ombudsman is a tool, not a threat.

Enforcement and Financial Penalties

Local housing authorities have been given significantly strengthened enforcement powers under Part 3 and the broader Act. They may impose civil financial penalties for a range of breaches, with a clear escalating scale for persistent or serious offenders.

Civil Penalty Scale — Part 3 Breaches

• Initial or Minor Breach: Failing to register on the database; failure to join the Ombudsman. Up to £7,000.
• Serious, Persistent or Repeat Breach: Continued non-registration; failure to comply with Ombudsman decisions. Up to £40,000.
• Criminal Prosecution: Alternative to £40,000 civil penalty for the most serious ongoing breaches. Unlimited.

Beyond civil penalties, tenants (and local councils acting on their behalf) can seek Rent Repayment Orders through the First-tier Tribunal. These orders require landlords to repay rent received during a period of non-compliance, typically up to 12 months of rent. For persistent offenders, this represents a substantial financial exposure that goes well beyond the headline penalty figures above.

⚠️ Possession Rights at Risk Non-registered landlords may be unable to use certain Section 8 possession grounds. This means that failing to register on the PRS Database could directly prevent a landlord from legally recovering possession of their property, even where a valid ground otherwise exists. The stakes for non-compliance extend far beyond the penalty figures alone.

Implementation Timeline for Part 3

• 27 December 2025: Now in Force Enhanced Local Authority Investigatory Powers Local councils gained new powers to inspect properties, demand documents, and access third-party data. These enforcement capabilities underpin the Part 3 regime and are already active.
• Late 2026: Phase 2 Begins PRS Database Regional Rollout Commences The database will begin a phased regional launch from late 2026. Landlords in pilot regions will be the first required to register. Annual fees per property will be charged from this point. An annual fee amount per property will be confirmed ahead of launch.
• 2027: Full National Launch Mandatory Registration for All PRS Landlords Database registration becomes mandatory nationwide. Failure to register at this stage links directly to restrictions on possession grounds.
• 2028: Ombudsman Live PRS Landlord Ombudsman Membership Becomes Mandatory Landlords will be required to become members of the Ombudsman scheme. The scheme administrator will be appointed in 2026 and given time to scale up before mandatory membership is enforced. The Housing Ombudsman Service is the likely administrator.
• 2035: Decent Homes Standard Decent Homes Standard Extended to Private Rented Sector The final phase of the Act's standards agenda. The government has proposed implementation in 2035, with an expectation that landlords begin necessary improvement works earlier where feasible.

What Landlords Should Do Now

The timelines for Part 3 give landlords more runway than the Phase 1 tenancy reforms, but preparation should begin now, not in 2027. Here are the practical steps to take:

• Gather and organise your compliance documentation. The database will require up-to-date Gas Safety Certificates, EICRs, EPCs and other certificates for every property you let. If any are missing or expired, address them now rather than under time pressure when registration opens.
• Implement a documented complaints process. The Ombudsman will expect to see that tenants raised issues with you before escalating to the scheme. A clear, written complaints procedure, and a habit of acknowledging and responding to maintenance requests in writing, will be your first line of defence.
• Budget for registration costs. Each property will attract an annual fee for database registration and, separately, a membership fee for the Ombudsman scheme. Exact amounts remain to be confirmed, but these represent a new ongoing cost for all landlords and should be reflected in your financial planning.
• If you use a managing agent, clarify responsibilities. While the registration obligation falls on the landlord, managing agents can discharge the duty on your behalf. Ensure your agency agreement explicitly addresses who will manage registration and Ombudsman membership, and that your agent is actively preparing for these obligations.
• Watch for secondary legislation. The detail of exactly what information must be registered, the fee structure, and the mechanics for limited companies and joint ownership will all be set out in regulations expected later in 2026. Our team will keep you informed as these are published.

What This Means for Landlords in Our Local Area

For landlords in our local area, these changes represent a shift towards a more professionalised and regulated environment. At Newboulds & Co, we understand that navigating new legislation can feel daunting. Our director-led approach means you'll always deal with an experienced professional who can offer clear, factual advice tailored to your specific situation.

We've always prided ourselves on going above and beyond for our clients, and this commitment extends to helping you understand and comply with the new regulations. Our aim is to ensure your investment remains secure and compliant, allowing you to focus on providing quality homes for your tenants.

Preparing for the Future

As we approach May 2026, it's crucial for landlords to familiarise themselves with the requirements of the PRS Database and the Landlord Ombudsman scheme. Proactive engagement will ensure a smooth transition and help avoid potential penalties for non-compliance. We recommend reviewing your current tenancy agreements and management practices to align with the forthcoming changes.

These reforms are designed to bring greater accountability and transparency, which, in the long run, can only strengthen the reputation of responsible landlords. We are here to support you through every step of this journey, offering expert guidance and practical solutions.

If you require legal advice we would recommend contacting David Burns of Ronald Fletcher Baker LLP at d.burns@rfblegal.co.uk