The PRS Database Regulations

For lenders, receivers and insolvency practitioners, the Private Rented Sector Database (PRS Database) is more than a new landlord registration requirement. It introduces a new compliance gateway that sits directly in the path of possession and enforcement. Failure to address registration requirements at an early stage could delay recoveries, increase costs and affect the viability of enforcement strategies over tenanted residential property.

Kate Hillman comments…

“The publication of the regulations is a significant step forward because it gives lenders, receivers and insolvency practitioners something concrete to plan around. That said, there is still a real gap between understanding the framework on paper and seeing how it will operate in practice once the scheme is live. Until the courts have considered the legislation and the database processes have been tested in real enforcement scenarios, there will inevitably be areas where we are applying our best interpretation rather than working from settled authority.”

The PRS database, known as the "Register your rental property" service, is England's new mandatory landlord registration scheme under the Renters' Rights Act 2025 (RRA). When a lender, receiver or insolvency practitioner takes control of a tenanted residential property, the PRS Database will become an immediate operational concern sitting directly in the path of any enforcement or possession strategy.

The service is being rolled out regionally and in phases across England from 15 December 2026 (starting in the West Midlands) to 14 November 2027 (for the Southwest). Landlords have a three-month window from the date the service goes live in each region to register.

Registration costs £65 per property per annum, payable on initial registration and on each annual renewal. The fee applies per property, not per block, and the cumulative cost may be material where a lender's security comprises, or a receiver is appointed over, a portfolio of tenanted residential properties.

What you are now dealing with

If a landlord does not have an active landlord entry and an active dwelling entry on the PRS Database, the court cannot make a possession order in their favour unless the ground for possession being relied on is Ground 7A or Ground 14 (anti-social behaviour). That bar applies equally to an LPA/Fixed Charge Receiver appointed to recover possession pursuant to a charge, or an administrator seeking to realise a property asset. The abolition of section 21 "no-fault" notices under the RRA compounds this: possession may now only be obtained on specified statutory grounds, each with its own notice period and evidential requirements.

On any appointment or enforcement step over a tenanted residential property, the first question is therefore factual: does an active landlord and dwelling entry exist on the PRS Database, and if not, what is required to comply?

In practice, this means PRS Database compliance is likely to become a pre-appointment due diligence issue rather than an administrative task dealt with afterwards. Lenders, receivers and insolvency practitioners may need to establish the registration position at an earlier stage, particularly where enforcement timetables are sensitive to delay.

A landlord or dwelling entry may only be made by the residential landlord (or intended landlord) or by a person within the third-party list in Schedule 2 to the PRS Database Regulations 2026 — which expressly includes receivers, trustees in bankruptcy, liquidators, administrators, and mortgagees or persons appointed by them. A certified or sealed evidence of authority is required before an entry can be made or updated by any persons on the third-party list.

The 28-day window and ongoing obligations

Where a dwelling entry is made for a property already let, the required tenancy and health and safety information must be provided within 28 days, failing which the dwelling entry becomes inactive automatically.

Third parties on the Schedule 2 list benefit from certain exemptions on initial registration: the entry may be made without the Part 2 tenancy and health and safety information, the number of bedrooms, or the property manager's name and email. The outstanding information must still be provided within 28 days. The practical effect is that a receiver or administrator can secure an active entry before all compliance documentation has been assembled, provided it is supplied within that window.

That flexibility should not be mistaken for an extension of time. The 28-day period creates a short and potentially demanding mobilisation window in which the appointee must identify, verify and submit information that may not have been properly maintained by the existing landlord. The condition of the landlord's records may therefore have an immediate bearing on the work and cost involved following appointment.

Where any information in an active dwelling entry becomes out of date, it must be updated within 28 days. For a receiver managing a tenanted property, this creates a rolling compliance obligation, which will be impacted further by the RRA reforms due to the increased notice periods and increased court timescales for obtaining a possession order.  A new tenancy, an expiring gas safety certificate or a change in HMO licensing status each triggers a mandatory update.

There is a further sequencing point to bear in mind: an active landlord entry becomes inactive automatically if no dwelling entry has been made specifying that landlord within three months of the landlord entry being made. Where a receiver or administrator is establishing entries from scratch, the landlord entry and the dwelling entry must therefore both be in place within that three-month window — the landlord entry alone is not sufficient.

Reactivation of an inactive entry follows the same access rules as making one. Where the entry became inactive because compliance information was not provided in time, that information must be supplied before reactivation — unless the person reactivating falls within the third-party category. A fee is payable on reactivation where the previous renewal date has passed.

Non-compliance with the PRS Database carries direct financial consequences. Local housing authorities may impose civil penalties of up to £7,000 for a breach; more serious offences may attract prosecution or a civil penalty of up to £40,000.

Separately, the RRA requires all private landlords to be members of a Private Rented Sector Landlord Ombudsman Service, which is expected to go live in 2028 . This obligation sits alongside the PRS Database registration requirement but is distinct from it. When introduced, a receiver, administrator or other appointee stepping into the landlord's position will need to verify whether the landlord is a member of the Ombudsman Service and, if not, take steps to join . Non-membership may affect the ability to serve valid notices and could give rise to separate enforcement action by the relevant authority.

The compliance data: an asset or a liability?

The dwelling entry must include tenancy information, gas safety records, electrical safety reports (EICRs or EICs), EPC details, rent information, HMO licensing status and furnishings information. Where the EPC rating falls below the minimum energy efficiency standard (currently band E), the entry must record whether a registered MEES exemption is in place and its type.

On appointment, the existing entry (if any) provides an immediate compliance snapshot. Gaps or expired certificates are visible, though accuracy cannot be assumed — the database operator and local housing authorities have power to verify, correct and remove entries.

Where certificates are missing or expired, the issue extends beyond registration. A property with no valid EICR, an expired gas safety record or a sub-standard EPC without a MEES exemption has underlying compliance problems affecting its let and value. Early identification matters for both the registration obligations and the wider realisation strategy.

The unknowns

This is new legislation and the regulations were in draft form as at the date of this article. Nothing as yet has been considered by the courts. Key unresolved questions include:

• how the court will treat a possession claim where an entry lapses mid-proceedings;
• whether the database operator will accept third-party authority documentation promptly; and
• how the database requirements interact with insolvency moratorium provisions. The compliance obligations should be treated as real and enforceable, while recognising that operational detail will continue to evolve.

This uncertainty is not a reason to defer preparation. It increases the importance of documenting the checks undertaken, the information available on appointment and the steps taken to establish or maintain active entries. Until the legislation and database processes have been tested in live enforcement scenarios, a clear audit trail may be particularly important where an appointee has had to act on incomplete information.

Key considerations on appointment

The PRS Database introduces a new set of questions that must be addressed before any appointment is accepted and/or enforcement action taken over a tenanted residential property:

• Is there an active landlord entry and an active dwelling entry? If not, what is required to establish or reactivate one?
• Are the appointment documents ready to be submitted to the PRS Database?
• What is the state of the compliance documentation: gas safety, electrical, EPC and are there any MEES issues that need to be addressed?
• Who within the team will own the 28-day update obligations while the property is under management?
• Who has responsibility for the annual registration fee and any compliance costs and has this been addressed in the appointment terms?
• Is the landlord a member of an approved landlord ombudsman scheme, and if not, what steps are needed to join one?

These questions cannot be deferred. The 28-day clock runs from the date of entry, not from the date the appointee is in a position to act.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at September 2026.  For more information see our terms & conditions.