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Surveyor’s notes
— 10 September 2026

The big move today is regulatory: the mandatory landlord database finally has a start date, a fee and a penalty scale, and a quieter second change moves rent-increase disputes out of the tribunal and into HMRC’s hands. Layer on an LSE economist’s warning that two of the Renters’ Rights Act’s flagship protections are already backfiring, a genuinely two-sided read of this week’s market data, and conveyancers still fighting a raid on client account interest, and it’s a day worth landlords, buyers and sellers all paying attention to.

Published 10 September 2026 Reading time · 7 min By Dominic Bowkett · MRPSA

The big move today is regulatory: the mandatory landlord database finally has a start date, a fee and a penalty scale, and a quieter second change moves rent-increase disputes out of the tribunal and into HMRC’s hands. Layer on an LSE economist’s warning that two of the Renters’ Rights Act’s flagship protections are already backfiring, a genuinely two-sided read of this week’s market data, and conveyancers still fighting a raid on client account interest, and it’s a day worth landlords, buyers and sellers all paying attention to.

The landlord database now has a start date, a fee and a penalty scale

On 9 September, MHCLG confirmed the rollout timetable for the mandatory Private Rented Sector Database in its own announcement: the “Register your rental property” service goes live in the West Midlands on 15 December 2026, then rolls region by region — the South East is called forward on 15 March 2027, with a three-month window taking landlords to a deadline of 14 June 2027. Every landlord will eventually need to register, at £65 per property per year, supplying the address, bedroom count, rent and copies of gas, electrical and EPC certificates. Housing minister Matthew Pennycook called it “an important first step toward establishing our innovative database of private rented sector properties.” Miss the deadline and, per LandlordZone’s reporting, the civil penalty runs up to £7,000, rising to £40,000 for serious or repeated breaches — and an unregistered landlord can’t get a possession order except on anti-social-behaviour grounds.

The document list is the detail worth flagging to clients now, eighteen months before the South East deadline arrives: gas, electrical and EPC certificates all have to be current and uploaded, not filed away and forgotten. I still see landlords letting on an EPC that expired two renewals ago because nobody has asked to see it — that grace period ends the day a council can check a public register instead of taking a landlord’s word for it. NRLA chief executive Ben Beadle gave the timetable a cautious welcome but warned it risks becoming “little more than a national directory for councils” unless it actually cross-checks the documents landlords upload rather than just filing them.

If you’re letting in the South East, don’t wait for March 2027 — get gas, electrical and EPC certificates current and filed together now, so registration is an afternoon’s admin rather than a scramble against a possession-order deadline.

Rent disputes move from tribunal to HMRC’s valuers

Buried in the same 9 September announcement is a second change: initial decisions on Section 13 rent-increase challenges move from the First-tier Tribunal to HMRC’s Valuation Office, with financial secretary James Murray and courts minister Sarah Sackman KC both named on the release. The stated aim is speed — the tribunal has been badly backlogged since the Act gave every periodic tenant the right to challenge an increase — and tenants keep one protection either way: they won’t have to pay the higher rent until a challenge is finally decided. Property118 reports the Valuation Office role rolls out over roughly two years alongside the database regions, and the NRLA has welcomed it as good for both sides, calling it a way of “reducing pressure on the tribunal system.”

A valuation officer is a different animal from a tribunal panel — closer to the district valuers I deal with on council tax banding than to a judicial hearing — and it isn’t yet clear from the announcement whether a landlord who disagrees with the initial figure still gets a full oral hearing. Worth watching before assuming faster automatically means fairer.

If you’re a landlord planning a rent increase under a periodic tenancy, keep your comparable-rents evidence in better order than you might have bothered with for a tribunal — a paper-based valuation process rewards a clean written case more than an oral one.

An LSE economist says the Act is already producing the opposite of what it promised

Tim Leunig, professor of economic history at LSE, told Property118 that two of the Act’s flagship tenant protections are backfiring. On the ban on rental bidding wars, he says landlords have simply started advertising at an inflated price instead of a fair one, so “estate agents then encourage renters to view such flats with the assurance that the landlord will take a lower bid, and then all potential tenants are forced to bid” against a cap set by the fictional advertised figure — recreating the exact stress the ban was meant to end. On the ban on requesting rent in advance, he points out that self-employed applicants who fail a credit check, and international students whose parents could previously guarantee a year’s rent up front, have lost a route into a tenancy that harmed no one.

Both critiques ring true from where I sit, because both describe landlords and agents working around a rule rather than complying with its spirit — which is what tends to happen when a ban addresses the symptom, an upfront cash offer, rather than the underlying scarcity of rental stock relative to demand. Neither has an obvious legislative fix; it’s a genuine trade-off between protecting tenants generally and locking out specific tenants who relied on the exact flexibility that’s now banned.

If you’re self-employed, or acting as guarantor for a student tenant, and a landlord tells you advance rent “isn’t legal any more,” that’s correct — don’t push it, and instead lean on a guarantor service or employer reference letter to close the credit-check gap.

A September bounce, but RICS is nervous about the October Budget

Two market reports landed together on 10 September. Rightmove recorded a 5 per cent jump in buyer demand in the first week of September against a five-year average of 0.4 per cent for the same week, narrowing the year-on-year demand gap from 14 per cent below last year to 9 per cent, with the South East up 6 per cent regionally. RICS’s survey told a consistent story: new buyer enquiries improved to a net balance of -19 per cent, the least negative reading since January, and agreed sales to -17 per cent, the best since February. Both surveys flagged the same headwind — the Bank of England’s hawkish stance on rates, and more pointedly, uncertainty over what the October Budget will do to property taxation.

A back-to-school bounce after a flat summer is normal seasonal noise more than a trend, and RICS’s own members are telling the surveyors who compile that data that they expect it to stall the moment Budget speculation properly kicks in — the three-month sales expectations balance is still negative even as the 12-month outlook improves. I’d treat the improvement as real but fragile, not evidence the market has turned a corner.

If you’re weighing whether to list a property this autumn, the demand uplift is genuine, but don’t assume it holds through October — a Budget that changes stamp duty, capital gains or council tax banding could reverse the sentiment as fast as it arrived.

Conveyancers are still fighting a raid on client account interest

The Conveyancing Association has restated its opposition to the Ministry of Justice’s Interest on Lawyers’ Client Accounts scheme, which would divert a large share of the interest firms earn on client money — the funds held mid-transaction during a house purchase — into the MoJ’s own central budget rather than legal aid. Director of delivery Beth Rudolf pointed out the MoJ has already advertised a “head of additional funding policy” role to implement the scheme, despite the consultation, which closed months ago, still having no published response.

This one’s still a consultation outcome away from being real, but if it lands as proposed, expect conveyancing fees to rise to cover the lost interest income — firms won’t absorb a five- or six-figure hit to income for nothing. Worth mentioning to a client who’s shopping purely on the quoted fee, since today’s cheapest quote may not survive this.

What I’d actually do

  1. Letting in the South East? Get gas, electrical and EPC certificates current and filed together now — the March 2027 registration window will ask for exactly these documents.
  2. Planning a rent increase under a periodic tenancy? Build a written comparable-rents case now; a valuation-office process rewards paperwork over oral argument.
  3. Relying on advance rent to secure a self-employed or overseas-guaranteed tenant? It’s banned — use a guarantor service or employer reference instead.
  4. Thinking of listing this autumn? Move on the current demand bounce, but don’t bank on it surviving the October Budget.
  5. Comparing conveyancing quotes on price alone? Ask what happens to the fee if ILCA goes ahead — cheapest today may not be cheapest in a year.

Today’s notes span lettings compliance, market timing and conveyancing cost as much as bricks and mortar — the practice covers full EPCs and building surveys across the South East for landlords, buyers and sellers weighing exactly these decisions. Get in touch.

Small print. General commentary, not advice for your specific circumstances — regulations, schemes and deadlines change, and your property is not the average property. Sources linked were accurate when read on 10 September 2026.