Renters’ Rights Act: What the implementation roadmap means for student accommodation

The Renters’ Rights Bill has now completed its journey through Parliament and officially became the Renters’ Rights Act 2025, with Royal Assent granted on 27 October 2025.

Crucially, the Government has also published a detailed implementation roadmap, setting out when each part of the Act will come into force. For student accommodation providers, this is the clearest view yet of how, and when, the biggest shake-up in private renting for a generation will reach PBSA, HMOs, and smaller student portfolios.

In this blog, we’ll look at:

1. The key milestones in the roadmap
2. What actually changes on 1 May 2026, and what doesn’t
3. How the three-tier system we highlighted earlier will play out in practice
4. The specific actions student operators should take between now and next summer

Nothing changes overnight for the 2025/26 academic year. But the countdown to implementation has started.

Phase 1: What changes on 1 May 2026?

The Government is introducing the Act in three phases. The first, and most significant for day-to-day lettings, begins on 1 May 2026 and applies to both new and existing private rented sector (PRS) tenancies.

From that date, the following will apply across the PRS, including the student sector (subject to PBSA exemptions):

Section 21 ‘no fault’ evictions will be abolished

Landlords will no longer be able to use Section 21 to end a tenancy. All possession will need to rely on Section 8 grounds, including revised grounds for sale, move-in, anti-social behaviour and rent arrears.

Assured Periodic Tenancies become the norm

Almost all PRS tenancies will become Assured Periodic Tenancies, including those that started life as fixed-term ASTs. Tenants will be able to stay indefinitely unless a landlord successfully regains possession, and will gain the right to end the tenancy with two months’ notice at any time.

Rent increases are limited to once a year

Landlords will only be able to increase rent once every 12 months, using a revised Section 13 process with at least two months’ notice. Students will be able to challenge rent increases they believe are above market value.

Rent in advance and rent bidding are restricted

1. Landlords and agents will be banned from:
2. Requesting or accepting more than one month’s rent in advance (beyond the initial payment)
3. Encouraging or accepting offers above the advertised rent. This codifies changes that will heavily affect student practices, such as termly advance rent and “bidding” in tight markets.

Discrimination against certain renters is outlawed

It will be illegal to discriminate against renters because they have children, or receive benefits, this applies to advertising, viewings, and decisions to let.

Pet requests must be considered properly

Tenants will have a right to request a pet and landlords will need to respond within 28 days, with valid reasons for any refusal.

Local enforcement powers are strengthened

Civil penalties will increase (with fines up to £40,000 for serious or repeat offences) and rent repayment orders will be extended and toughened. New investigatory powers for local authorities come into force from 27 December 2025, ahead of Phase 1.

The immediate message is, the framework is now fixed, the timing is no longer hypothetical. Phase 1 will go live on 1 May 2026, even if some of the operational details will be filled in by secondary legislation over the coming year.

Section 21: a clear end date, and a short transition window

The roadmap also clarifies the end of Section 21, including transitional protections for notices already served.

1. Landlords can continue to serve valid Section 21 notices up to and including 30 April 2026.
2. If a Section 21 notice is served before that date, any court claim for possession must be issued by 31 July 2026.
3. After 31 July 2026, Section 21 can no longer be used to recover possession. All new cases must rely on the updated Section 8 grounds.

In practice, this means the 2025/26 academic year is likely to be the last in which student landlords can routinely rely on Section 21 to regain possession at the end of a fixed term.

PBSA exemption: UNIPOL and ANUK are now central to eligibility

As we outlined in our previous blog, the Government has long signalled its intention to exempt qualifying PBSA from elements of the new tenancy regime. The roadmap confirms how this will work in principle.

A dedicated statutory instrument, scheduled to come into force on 1 May 2026, will:

1. Exempt private PBSA that complies with the UNIPOL and ANUK student housing codes (approved under section 233 of the Housing Act 2004) from the assured tenancy system; and
2. Ensure those providers have access to an amended Ground 4A for existing tenancies.

For PBSA operators, this effectively preserves the ability to offer fixed-term student contracts, provided:

1. The building meets the bed-space threshold (15+ bed spaces), and
2. The provider is fully compliant with the relevant UNIPOL/ANUK code.

Those conditions will be critical. Operators outside the codes, or in smaller/block-converted schemes that don’t meet the threshold, will not benefit from the exemption and will instead need to operate under the Assured Periodic Tenancy framework.

Secondary legislation will fill in the exact detail, but the direction of travel is now locked in: PBSA that meets national code standards will continue on a fixed-term footing; non-PBSA stock will not.

HMOs, smaller portfolios and the reality of the three-tier system

In February, we described how the reforms risk creating a three-tier system in the student sector:

1. PBSA – with an exemption and continued fixed-term contracts
2. HMOs (3+ tenants, 2+ households) – able to use Ground 4A
3. Non-HMO stock (1–2 tenants) – no Ground 4A, full periodic regime

The implementation roadmap doesn’t alter that underlying structure. If anything, it underlines it.

Ground 4A and early signing limits

For HMO and off-street student housing, Ground 4A becomes the key route to align possession with the academic year – but only where the conditions are met:

1. Tenants are full-time students (or reasonably expected to become so)
2. The landlord gives the prescribed Ground 4A notice at the start of the tenancy
3. The tenancy is not entered into more than six months before the start date
4. The possession notice expires between June and September

That six-month limit will continue to restrict how far in advance landlords can safely sign students without risking problems later on, particularly in markets where signing 9–12 months ahead has been the norm.

Joint tenancies and two months’ notice

At the same time, the shift to Assured Periodic Tenancies and the removal of assignment rules will have significant operational implications for shared student housing:

1. Any one tenant in a joint tenancy will be able to end the tenancy for the whole group with two months’ notice.
2. There will be no simple “swap-out” mechanism. Replacing a leaver will require a new tenancy, not an assignment.

As we noted previously, this sits uncomfortably alongside what students say they value: in our October survey, 23.9% of students cited a lack of contract flexibility as a key concern when searching for accommodation. The reforms increase flexibility in theory, but in a way that could increase complexity and void risk for group lets.

1/2 bed properties: still exposed

For 1/2 bed student properties that don’t qualify as HMOs, the roadmap doesn’t introduce any new protections aligned to the academic year. Those properties will fall fully into the periodic regime without access to Ground 4A, reinforcing the concerns we raised earlier:

1. Potential for properties to fall out of sync with the academic cycle
2. Increased risk of long void periods, particularly in student-dominated neighbourhoods
3. Knock-on effects for local rent levels, if landlords seek to recoup costs in subsequent pricing

The three-tier dynamic remains a key strategic issue for the sector.

Tenancy paperwork: information sheets, written terms and timing

The roadmap also provides more clarity on the documentation landlords will be expected to provide before and after 1 May 2026.

New tenancies from 1 May 2026

For all new PRS tenancies created on or after 1 May 2026:

1. Landlords will need to provide certain prescribed information in writing, likely through a written tenancy agreement.
2. The Government will publish a draft template in January 2026, giving landlords time to update their contracts.

This will be particularly important for Ground 4A, where the wording and notice requirements will need to be precisely followed to avoid enforcement issues.

Existing tenancies

For tenancies created before 1 May 2026:

1. If there is already a written tenancy agreement, landlords will not have to re-issue it.
2. Instead, they must provide tenants with a Government “Information Sheet” by 31 May 2026, explaining the changes made by the Act.
3. Where a tenancy was agreed verbally, landlords must provide a written summary of the main terms by the same date.

That creates a hard deadline for student providers to audit their existing tenancies and ensure they have a plan to communicate the changes proactively, particularly given how low student awareness currently is. In our recent survey, 68.6% of students said they hadn’t even heard of the Renters’ Rights Bill, and only 14.5% felt they understood how it would affect them.

Phase 2 and Phase 3: database, Ombudsman and standards

While most operators will understandably be focused on 1 May 2026, the roadmap makes clear that further waves of change are coming.

Phase 2 – from late 2026

Phase 2 will introduce:

1. A national Private Rented Sector Database, with mandatory registration, an annual fee, and requirements to upload key information (including landlord details, property characteristics and core safety data such as gas, electrical and EPC).
2. A PRS Landlord Ombudsman, providing a free, independent complaints route for tenants. Membership will be compulsory for landlords, with the Government currently expecting this to be in place by 2028.

For larger student operators, both will add a new layer of data management and governance. For smaller landlords, they will formalise expectations around complaint handling and transparency.

Phase 3 – Decent Homes, Awaab’s Law and MEES

Phase 3, with implementation dates following consultation, will extend:

1. A modernised Decent Homes Standard to PRS (with consultation suggesting implementation in 2035 or 2037)
2. Awaab’s Law to PRS, setting strict time limits for resolving serious hazards such as damp and mould
3. Linked measures around HHSRS and minimum energy efficiency standards in the sector

While these changes sit further out, they will ultimately tie the sector’s long-term investment in fabric, safety and energy performance to statutory expectations, something that’s particularly relevant for ageing HMO stock and legacy student housing.

What should be done now?

Although tenancies and processes for the 2025/26 academic year are largely unaffected, the combination of Royal Assent and a firm implementation roadmap means planning can no longer be deferred.

Over the next 6-12 months:

1. Audit portfolios
2. PBSA vs HMO vs 1–2 bed properties
3. Which buildings are likely to qualify for the UNIPOL/ANUK PBSA exemption, and which won’t
4. Review tenancy structures and templates
5. Prepare to migrate non-PBSA stock to Assured Periodic Tenancies
6. Identify where current wording will need to change once the Government publishes draft written statement requirements in January 2026
7. Plan how to incorporate Ground 4A correctly for student HMOs
8. Map out the documentation obligations
9. Put systems in place to send the Information Sheet and any necessary written term summaries by 31 May 2026
10. Build an audit trail to evidence that tenants have received them
11. Revisit rent, cash flow and guarantor strategies
12. Model the impact of one-month rent in advance, one rent increase per year and extended rent arrears thresholds
13. Review reliance on advance rent in lieu of guarantors, particularly for international students
14. Prepare for stronger enforcement and more scrutiny
15. Ensure safety documentation, licences and compliance processes are up to date ahead of new investigatory powers in December 2025
16. Start cleaning and standardising data in anticipation of the PRS Database and Ombudsman

At the same time, student providers will need to think beyond legal compliance and consider how to communicate these changes to their own residents, closing the gap between what students assume the law provides and what it actually will.

Need help preparing for the Renters’ Rights Act?

The Renters’ Rights Act marks a fundamental shift in how student tenancies will operate, but the roadmap also gives clarity and time to prepare.

We’ve created a Renters’ Rights Act Checklist to help understand what to do, and when.