The Renters Rights Act 2025 (RRA 2025) coming into force shortly

With the Renters Rights Act 2025 (RRA 2025) coming into force shortly on 1 May 2026, soon upon us are some crucial changes to Rent Repayment Orders (RRO).

Previous RRO claims

Previously, tenants and local housing authorities could seek RROs against landlords to repay rent or benefits where certain housing-related offences had been committed such as:-

• Unlawful evictions
• Harassment
• Failure to comply with improvement notices
• Breaches of licensing requirements (i.e., those relating to HMOs )

RRO claims available from 1 May 2025

However, the RRA 2025 will significantly broaden both the circumstances in which RROs can be sought and the parties who may be held liable.

For example, as well as instances mentioned above, tenants and local authorities can now pursue RROs for additional offences such as: –

• Misusing possession grounds
• Breaches of restrictions on letting or marketing dwellings e.g. advertising the property for rent within 12 months of the previous tenant vacating under a notice/order
• Continuing breaches after penalties have been imposed; and
• Certain violations related to landlord redress schemes and private rented sector databases.

The time limit to make an application for an RRO has also changed – from 12 months to 24 after the commission of the relevant offence.

Which Landlord? All Landlords and the Director too!

A huge change which RRA 2025 will bring is the expansion of liability.

Previously, RROs could only be made against the immediate landlord. However, RRA 2025 brings new provisions meaning that RROs can now be made against superior landlords and the contracting landlord.

In such circumstances where multiple landlords are found liable, they will be jointly and severally liable for the RRO.

Further still, where the landlord is a corporate entity, directors may now be held personally liable if the offence was committed with their consent or due to their neglect. Such an offence does not have to be carried out by the director, but extends to the affairs of the company which are managed by its members, a manager, secretary or other similar officer of the company.

This of course is a huge shake up of the principle where a company has previously been held as having its own legal identity separate to its directors. Under that principle, the company assumes its own debts and liabilities rather than the directors being personally responsible. But with RRA 2025, such protection will seemingly be stripped away.

Repayment Periods

Finally, the recoverable period has also been extended from 12 months to 24 months so should any liability of a breach be found, the amount ordered to pay under an RRO is set to increase.

Next steps

These changes represent a significant strengthening of tenant rights and enforcement mechanisms in the residential rental sector. It is crucial that you ensure full compliance with all licensing requirements, improvement notices, and other regulatory obligations to avoid potential liability – especially those of a corporate nature as the ability to be held liable will be vastly opened up.

If you would like to discuss this further or the new Act generally, please reach out to our Dispute Resolution Team.