If you’ve spent the past few months getting to grips with the Phase 1 changes under the Renters’ Rights Act (the end of Section 21, the shift to periodic tenancies, the new rent increase rules) you’d be forgiven for thinking the hard work is nearly done.
It isn’t.
Phase 2 introduces two entirely new systems that will fundamentally change how landlords operate, and portfolio landlords in particular need to start preparing now.
The Private Rented Sector (PRS) Database and the PRS Landlord Ombudsman represent the most significant additions to landlord compliance infrastructure in decades. Together, they create a national accountability framework covering all 2.3 million private landlords in England. Here’s what you need to know and, more importantly, what you should be doing about it.
What Is The PRS Database?
The PRS Database is a centralised national register that will require every private landlord in England to register themselves and each property they let. The government’s implementation roadmap, published in November 2025, confirms that roll-out will commence from late 2026, with registration becoming mandatory through a phased regional process.
This isn’t a light-touch formality. Landlords will need to provide comprehensive information for every property, including contact details for all joint landlords, the full property address and type, bedroom count, occupancy status, and compliance documentation such as gas safety certificates, EICRs, and EPCs. The database will also record any fines or penalties issued against the landlord, and certain information will be publicly accessible to tenants.
For portfolio landlords, the administrative implications are significant. Registration fees will apply per property, not per landlord, meaning a portfolio of 20 properties incurs 20 times the annual fee. Exact costs will be confirmed closer to launch.
What Is The Landlord Ombudsman?
The PRS Landlord Ombudsman is a mandatory redress scheme providing tenants with a free, impartial route to resolve complaints without going to court. The government expects it to become operational in 2028, after the database is established, and the Housing Ombudsman Service is widely expected to be appointed as the scheme administrator.
Every private landlord must join, regardless of whether they use a letting agent. This is a critical point that many landlords overlook — using a managing agent does not exempt you from Ombudsman membership. Both landlord and agent remain separately accountable for their respective responsibilities, and tenants will be able to complain through both the Landlord Ombudsman and existing agent redress schemes.
The Ombudsman’s decisions will be legally binding. It will have the power to require landlords to issue apologies, take remedial action, and pay compensation. Landlords who fail to comply with decisions could face enforcement action, including removal from the PRS Database — which, as we’ll see, carries serious consequences.
The Penalties For Non-Compliance
The enforcement framework is robust and deliberately designed to make non-compliance untenable. Landlords who let or advertise a property without registering on the database face civil penalties of up to £7,000 for a first offence, rising to £40,000 for repeated breaches or providing false information. Criminal prosecution is also possible for serious offences.
Perhaps most significantly, unregistered landlords will be unable to obtain possession orders from the courts, except in cases involving serious anti-social behaviour. For portfolio landlords, this effectively means that failing to register a single property could prevent you from regaining possession of it for any reason — including rent arrears, sale of the property, or landlord occupation. That’s a risk no serious investor can afford to take.
Failure to join the Ombudsman carries equivalent penalties, and tenants will additionally be able to seek rent repayment orders against landlords who persistently fail to register.
The Timeline: What Happens When
Understanding the phased implementation is essential for planning:
Late 2026: The PRS Database begins its regional roll-out. Specific registration deadlines will be staggered and confirmed through secondary legislation closer to launch.
2027 (estimated): Mandatory registration is expected to become fully operational, with public access and data sharing enabled. Enforcement begins in earnest.
2028: The Landlord Ombudsman becomes operational. All landlords are required to become members. The government is exploring ways to integrate databases and Ombudsman registration to reduce administrative burden.
2035 onwards: Phase 3 introduces the Decent Homes Standard and Awaab’s Law extensions to the private rented sector, subject to ongoing consultation.
What Portfolio Landlords Should Do Now
While precise registration dates are still to be confirmed, the direction of travel is unambiguous. Portfolio landlords who act early will find the transition significantly smoother than those who wait.
Start by auditing your compliance documentation across every property. Ensure gas safety certificates, EICRs, EPCs, and deposit protection records are current, correctly filed, and easily accessible. The database will require this information at registration, and any gaps will need addressing before you can complete the process.
Review your property records for accuracy. The database will use Unique Property Reference Numbers (UPRNs) and include duplication checks, so getting records in order now avoids delays later. For larger portfolios, consider whether your current record-keeping systems will scale to meet ongoing reporting requirements.
Establish clear complaint-handling procedures in preparation for the Ombudsman. Properties with documented processes for responding to tenant concerns will be far better positioned when the Ombudsman begins assessing landlord conduct.
How Professional Management Simplifies Compliance
For portfolio landlords managing 10, 20, or 50-plus properties, the cumulative administrative burden of database registration, annual renewals, information updates, and Ombudsman compliance represents a substantial time commitment. This is precisely the kind of systematic, ongoing compliance work that professional property management is designed to handle.
A specialist letting agent can manage registration across your entire portfolio, maintain accurate records, ensure documentation stays current, and handle tenant complaints through procedures that satisfy Ombudsman standards — all while keeping you in control of the strategic decisions that matter.
At Slater & Brandley, we’re already helping portfolio landlords prepare for these changes. From compliance audits to systematic documentation management, we ensure your portfolio is ready for the PRS Database and Ombudsman well ahead of the deadlines. Get in touch with our team today to discuss how we can help you stay ahead of the curve.
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