The government has published further detail on the forthcoming “Register your rental property” service, which forms part of the second phase of implementation of the Renters’ Rights Act 2025 (RRA). The service will require landlords of qualifying residential properties to register both themselves and their rental properties and includes specific provisions for insolvency office holders.

Which properties must be registered?

The registration requirement will apply to landlords of assured and regulated tenancies but also to insolvency practitioners (IPs) may find themselves ‘standing in the shoes’ of a landlord in a number of circumstances, for example:

  • trustees in bankruptcy, when taking control of the former property of the bankrupt, which may include a tenanted residential property;
  • administrators or liquidators of companies which operate(d) as landlords to residential tenants; or
  • receivers appointed over residential property, with a view to achieving a sale.

In those circumstances, the insolvency professionals may find themselves having to grapple with the obligations placed upon landlords by the RRA.

IPs can make an entry on the PRS database as  a ‘third party’ under the new PRS Database Regulations 2026. This is necessary otherwise they cannot seek possession orders in their favour unless there are specific grounds of antisocial behaviour. Each IP and each qualifying property must be registered through the new service. Initially, the requirement only applies to properties that are already let, or which become let during the rollout period. The service will be rolled out region by region from 15 December 2026, with registration requirements taking effect on a staggered basis across England. IPs will have three months to register once the requirement applies in their region. However the fact separate dwelling entries are required for each property is likely to be a time consuming exercise, especially when there is a large portfolio of properties involved.

What information must be provided and when?

IPs acting in a landlord capacity as elaborated above will have a three month period depending on their region to register as a landlord on the database. Dwelling entries depending on their region also have a three month period to be initially registered on the database but will have 28 days to submit any information which wasn’t initially submitted at the time. That information includes landlord details, ownership information, property details, tenancy information, rent information and health and safety documentation. The system expressly caters for registrations being made by trustees in bankruptcy, liquidators, administrators, LPA/fixed charge receivers and mortgagees. However, as is often the case with insolvency scenarios, the quality of books and records received on appointment can vary and IPs often are appointed over businesses with records which have not been maintained properly or are incomplete. This gives IPs a limited opportunity to obtain information that is often unavailable immediately following appointment. It is therefore crucial that IPs take into account the registration requirements because there is a limited window to obtain and register it.  Where possible an IP should try to gather the required information ahead of  their appointment, or at least know that it is available and will be provided upon appointment. This is especially key when there are a large number of properties involved as each property requires a separate dwelling entry.

What penalties are likely if deadlines are missed?

A failure to register risks financial penalties and local authority enforcement action once the relevant deadline has passed. Non-compliance can lead to a £7,000 fine from local housing authorities, while more serious breaches can result in prosecution or civil penalties of up to £40,000.

How is a fine classified in a relevant insolvency?

This would be a case of ‘wait and see’ for the moment as it’s not wholly clear. In light of the position from Re Paperback Collection and Recycling Ltd [2020] EWHC 1601 (Ch), this can potentially be classified as a provable debt/unsecured claim rather than an expense of the administration.

Further guidance on these points would be welcome, particularly where IPs are appointed with limited access to books, records and compliance information.

Obtaining the information needed to complete a registration may be one of the more difficult aspects of compliance for IPs.

Appointments are frequently accepted before all books and records have been recovered. Tenancy information may be held by managing agents, compliance certificates may have expired or not been retained, and key records may simply be unavailable at the point of appointment. The 28-day period provides some flexibility, but it may not always be sufficient where records are incomplete or third parties are slow to engage.

Where information cannot be obtained voluntarily, existing investigatory powers under sections 234-236 of the Insolvency Act 1986 may assist IPs in obtaining documents and information from former directors, managing agents, professional advisers and other third parties. However, while these may be  useful tools for IPs.  the tight timescales to retrieve this information still place a pressure on them. If the relevant person fails to respond or co-operate then a court application may be required which will not result in a solution or order granted within the relevant time limits to register information on the database.

It’s important to consider that there are not just obligations to register the property itself, but ongoing obligations on IPs to keep the information up to date. Where information contained in an active dwelling entry subsequently becomes inaccurate, updated information generally must be provided within 28 days. Compliance therefore extends beyond the initial registration and continues throughout the appointment.

It is unclear how the database operator will deal with registrations submitted by IPs where key information is unavailable despite reasonable efforts to obtain it.

The registration regime sits alongside a number of other changes introduced by the Renters’ Rights Act 2025. Insolvency practitioners dealing with residential property portfolios should consider these requirements as part of the wider reform package. For a broader overview of the legislation and its potential implications for insolvency practitioners, landlords and secured creditors, see our earlier Renters’ Rights Act Alert.