The 28-Day PRS Trap

The government’s new Private Rented Sector Database is set to begin its regional rollout on 15 December 2026, starting in the West Midlands. While much of the attention has centred on the £65 annual registration fee and regional deadlines, landlords will also need to meet ongoing requirements to keep their property records up to date.

The draft regulations introduce several obligations that could have significant consequences for landlords who miss deadlines. In certain circumstances, a property’s database entry can automatically become inactive, potentially affecting a landlord’s ability to obtain a possession order through the courts.

The importance of preparing early is highlighted by a LandlordZONE report published on 19 October, which found that only around a quarter of surveyed landlords were aware of the database.

When Will Landlords Need to Register?

The database requirements are set out in Chapter 3 of Part 2 of the Renters’ Rights Act 2025, with further details contained in the draft Private Rented Sector Database Regulations 2026.

The draft regulations were presented to Parliament on 9 September 2026. At the time of writing, they are still awaiting approval from both Houses, meaning some details could change before they are finalised.

The requirements apply to landlords with assured and regulated tenancies, although supported exempt accommodation is excluded under regulation 3.

According to GOV.UK guidance, registration will be introduced across nine regions in England. The deadline depends on the property’s location rather than the landlord’s home address. Registration will open nationally from 15 December 2026, with enforcement beginning once the relevant regional deadline has passed.

Landlords Will Have 28 Days to Submit Missing Information

Registration involves two separate records. The landlord entry contains information about the landlord, while a dwelling entry covers each individual rental property. Under regulation 4(6), a property cannot have a dwelling entry without an active landlord entry.

For properties that are already let, regulation 6(2) allows landlords to create a dwelling entry before submitting all the required tenancy and safety information. However, the outstanding details must be provided within 28 days.

These details include information about occupants and households, whether the property is a house in multiple occupation (HMO), relevant licensing information, gas safety records, electrical safety reports and Energy Performance Certificate (EPC) details. Landlords must also provide information about any registered Minimum Energy Efficiency Standards exemption, the rent, payment frequency and whether the property is furnished.

Failure to provide the required information within the 28-day period could cause the property entry to become inactive under regulation 11(2)(a).

This means landlords who register close to their regional deadline but postpone uploading certificates could find themselves without an active entry shortly afterwards.

Property Details Must Be Updated Within 28 Days

Registration will not be a one-off administrative task. Landlords will also need to keep their records accurate as circumstances change.

Under regulation 9(4), dwelling entries must be updated within 28 days whenever recorded information becomes outdated. Regulation 8 establishes a similar requirement for landlord entries.

Changes that could trigger an update include a new gas safety certificate, an electrical inspection report, an EPC, a rent increase, a change in occupants, a licence renewal or the appointment of a new managing agent.

The draft regulations do not yet clarify precisely how the database operator will interpret information becoming outdated.

Importantly, missing an update does not appear to be an automatic reason for an entry to become inactive under regulation 11. However, section 82(3)(b) of the Renters’ Rights Act establishes an obligation to comply with update requirements, and a breach could attract a civil penalty under section 91.

The distinction matters because the possession restriction is linked to having active landlord and property entries, rather than the separate duty to update information.

One Annual Renewal Date for the Entire Portfolio

Landlords will also need to manage annual renewals.

Under regulation 10(1), an entry becomes inactive the day after its renewal date if it has not been renewed. The renewal date falls at the end of the 12-month period following the original registration.

Regulation 10(4) states that additional property entries linked to an existing landlord entry will share the same renewal date. Consequently, landlords registering several properties may find that their entire portfolio needs renewing on one annual date, determined by their first registration.

GOV.UK guidance states that the annual fee will be £65 per property, with charges adjusted during the rollout to avoid overcharging early registrants. Regulation 14 provides for the database operator to determine the fee by reference to its costs.

Landlords should therefore account for both the renewal date and the cost of renewing each property entry when planning their compliance arrangements.

Landlord Entries Can Become Inactive After Three Months

A separate deadline applies to landlord entries that are not linked to a property.

Under regulation 11(1)(a), a landlord entry becomes inactive if no dwelling entry has been associated with it within three months.

Landlords intending to create their account well before adding their properties should consider this requirement when planning their registration.

What Happens if a Property Entry Becomes Inactive?

An inactive entry could have consequences beyond the need to complete registration again. The Renters’ Rights Act sets out potential penalties and restrictions, although not all the relevant provisions are yet in force.

Under section 82(3), landlords must maintain active landlord and dwelling entries and comply with the applicable information requirements. Section 90 introduces a restriction on courts making possession orders while a landlord is in breach of the active-registration requirement, subject to specified exceptions.

The exceptions cover Ground 7A, relating to serious criminal behaviour, and Ground 14, which concerns anti-social behaviour. Other possession grounds, including rent arrears under Ground 8 and the landlord’s intention to occupy or sell the property under Grounds 1 and 1A, may be affected by the restriction.

The wording refers to the period during which the landlord remains in breach. This may mean that correcting the registration before a court decides a claim could affect whether the restriction applies, although this interpretation has not been tested.

Section 82(5) also confirms that a breach of the registration requirements does not invalidate the tenancy itself.

Other potential consequences include:

• Civil penalties: Section 91 provides for penalties of up to £7,000 for certain breaches of the registration requirements.
• More serious offences: Section 92 addresses offences involving knowingly or recklessly supplying false or misleading information, as well as continuing or repeated breaches. In specified circumstances, councils may impose a civil penalty of up to £40,000 instead of prosecuting.
• Rent repayment orders: The legislation also provides for amendments relating to rent repayment orders in connection with false information and continuing breaches, although the relevant provisions were not shown as commenced at the time of writing.

The precise consequences will depend on which provisions are in force and the circumstances of the breach.

How Landlords Can Prepare for Registration

Landlords can take several practical steps to reduce the risk of missing deadlines or submitting incomplete information.

1. Check the deadline for every property. Landlords should identify the region in which each rental property is located. For example, a landlord based in London who owns a property in Coventry will need to follow the West Midlands deadline.
2. Gather the required documents in advance. Collecting tenancy details, safety certificates, licensing information and EPC records before registration should make it easier to complete each property entry accurately.
3. Create a compliance calendar. Landlords should record their portfolio’s annual renewal date and monitor certificate expiry dates, rent changes and other events that require database updates within 28 days.
4. Review arrangements with letting agents. Although agents may help upload information, landlords remain responsible for ensuring that the required details are supplied and maintained.

Keeping an organised record of certificates, deadlines and property information should help landlords manage these obligations without relying on last-minute updates.

Further Changes Are Expected for the Private Rented Sector

The database is one part of a wider programme of rental reform. Further changes, including the public register view, the Decent Homes Standard and Awaab’s Law, are also expected to affect landlords.

With the registration process approaching, landlords may benefit from reviewing their compliance arrangements now rather than waiting until their region’s deadline.

The draft regulations remain subject to parliamentary approval, so landlords should check the latest official guidance before taking action. This article covers England only and reflects the position described in the draft regulations as at 20 October 2026. It is intended for general information and does not constitute legal advice.

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