Shokall Property
Landlord Journal
4 min read

One Complaint, Twenty-Four Months of Rent: Why Rent Repayment Orders Deserve a Landlord’s Attention

Rent Repayment Orders can now involve up to 24 months' rent in qualifying cases, making licensing and compliance failures significantly more serious. We examine where landlord exposure can arise and why management agreements do not replace proper oversight.

Thursday, 17 September 2026

There are landlord penalties that arrive as fines.

A Rent Repayment Order, or RRO, works differently.

In qualifying circumstances, a tenant can apply for an order requiring rent to be repaid. Changes introduced through the Renters' Rights Act have made that mechanism considerably more significant: the maximum amount that can potentially be recovered has increased from 12 months to 24 months' rent, and the framework has been expanded in other ways.

For a landlord receiving £2,000 a month, 24 months represents £48,000.

That does not mean every landlord mistake results in an order for that amount. It demonstrates why understanding RRO exposure should sit much higher on the compliance agenda.

An RRO is not compensation for every disagreement

A tenant cannot obtain 24 months of rent simply because the landlord was slow replying to an email or because the parties disagree about decoration.

Rent Repayment Orders relate to specified offences.

Historically, these have included matters such as certain licensing offences, illegal eviction or harassment and other defined housing offences. The 2025 Act expanded the RRO regime and strengthened the consequences associated with qualifying breaches.

The distinction is important because landlords should neither panic about ordinary disagreements nor underestimate genuine compliance failures.

The relevant question is whether the conduct falls within the statutory regime.

Licensing is where property structure meets legal exposure

Imagine a landlord rents a house to several unrelated occupiers.

The property appears well maintained.

Rent is paid.

Nobody complains about the condition.

But the occupation means the property requires an HMO license and the correct license was never obtained.

The fact that the house looks perfectly respectable does not make the licensing requirement disappear.

This is why landlords need to understand how a property is occupied, not merely what type of building it is.

Licensing rules can also vary locally because councils may operate additional or selective schemes.

A property that did not require a particular license several years ago may therefore need one today.

Management arrangements do not automatically make responsibility disappear

The issue becomes even more important where several parties sit between the property owner and the occupier.

A landlord may use an agent.

A superior landlord may let to an intermediary.

A rent-to-rent operator may then let rooms to occupiers.

The Renters' Rights reforms expanded RRO liability, including provisions concerning superior landlords in relevant circumstances.

That makes contracts and operational control important.

An owner should understand who is doing what with the property, what occupation has been authorized and who is responsible for licensing and compliance.

Signing a management agreement should never mean losing visibility over the property completely.

The paperwork needs to match reality

Property compliance often fails because the documents describe one arrangement while the property is operating as another.

Perhaps the agreement anticipated one household, but several unrelated people now occupy the property.

Perhaps management responsibility changed but nobody updated the records.

Perhaps somebody assumed another party had applied for the license.

Those gaps matter.

A good compliance review therefore needs to compare paperwork with reality.

Who actually lives there?

How many households are there?

Who collects the rent?

Who manages repairs?

What license applies?

Who holds it?

These are operational questions before they become legal ones.

Strong enforcement changes the economics of poor administration

The Renters' Rights Act significantly strengthened enforcement across the private rented sector. Alongside expanded RRO provisions, local authorities have additional enforcement tools concerning breaches of the new tenancy rules.

That changes the risk calculation.

Ignoring licensing or compliance because “nothing has happened yet” is not a strategy.

It is delayed exposure.

Professional landlords increasingly need the same discipline expected in other regulated businesses: know which rules apply, document compliance, review changes and correct problems before they become enforcement cases.

Compliance is cheaper before the complaint

Nobody enjoys spending time checking licenses, agreements and records.

It can feel unproductive because there is no immediate rental income attached to it.

The value becomes obvious only when something is wrong.

A compliance audit carried out today may reveal a problem that can still be corrected.

The same problem discovered during an enforcement investigation has already become something else.

That is why the most valuable landlord compliance work is often the work tenants never need to notice.

*DISCLAIMER- THIS PHOTO HAS BEEN TAKEN FROM PINTEREST *