Fee transparency after the Renters' Rights Act: redesign your fee schedule

General information only, not legal advice. As of June 2026.

The Renters’ Rights Act 2025 came into force on 1 May 2026. Landlords have been digesting the headline changes — section 21 gone, fixed terms abolished, periodic tenancies for everyone. But there is a quieter change that should be sitting near the top of your compliance list: tightened obligations around how you disclose, structure, and charge fees to both tenants and landlords.

This is not theoretical. The penalty regime is live, enforcement authorities have had expanded investigatory powers since December 2025, and the rules apply to agents acting on a landlord’s behalf as well as to landlords directly. Now is the time to go through your fee schedule line by line.

What the law already requires — and what has changed

The foundation is the Tenant Fees Act 2019, which banned most letting fees to tenants in England from 1 June 2019. The core prohibitions have not changed: you still cannot charge tenants for referencing, credit checks, inventories, admin, professional cleaning, or tenancy renewals. The permitted list remains: rent, capped holding deposits (one week’s rent, with a default 15-day deadline to enter the tenancy), security deposits (capped at five weeks’ rent for annual rents under £50,000, six weeks at £50,000 or above), default fees for late rent (interest at no more than 3% above the Bank of England base rate, for rent more than 14 days overdue), key replacement, and variation or early-termination fees capped at £50 unless you can demonstrate higher reasonable costs.

The Renters’ Rights Act 2025 has layered new obligations on top of that:

1. The rent-bidding ban. From 1 May 2026, landlords and agents cannot invite, encourage, or accept any offer above the advertised asking rent. You must publish a fixed asking rent and hold that line. Under the gov.uk Civil Penalties guidance, inviting, encouraging or accepting an offer of rent above the advertised amount attracts a civil penalty of up to £4,000; failing to specify a proposed rent in the advertisement attracts up to £3,000.

2. Advance rent restricted. You can no longer require multiple months upfront. Rent cannot be requested or accepted before the tenancy agreement is signed, and the initial payment is limited to one rent period (no more than one month). Breach is treated as a prohibited payment, and gov.uk guidance indicates a civil penalty of up to £7,000 for a first breach, rising to up to £40,000 for a continuing or repeat breach.

3. Strengthened fee disclosure for agents. The Act amended the Tenant Fees Act 2019 (which governs the Consumer Rights Act 2015 duty to publicise fees). Agents advertising on third-party portals — Rightmove, Zoopla and similar — must publish their fees there or ensure a link to their published schedule. Agents must now give the name of their client money protection scheme, not merely confirm membership, and enforcement authorities can impose more than one penalty for a continuing failure to publish.

The penalties for breaching the underlying Tenant Fees Act ban remain: up to £5,000 for a first offence, and up to £30,000 (or prosecution) for a repeat breach within five years. A repeat breach is a criminal offence carrying an unlimited fine, and conviction can trigger a banning order under the Housing and Planning Act 2016.

Why this matters for your landlord relationships

Here is the practical problem: landlords are confused, and they are asking questions you need to answer clearly. They have heard about “new fees” — the tribunal fee for rent-increase appeals (£47 per application), the future Property (PRS) Database registration fee, and the incoming Ombudsman scheme (amounts still to be confirmed by government). They do not always know which of these fall on them, which fall on tenants, and which you will handle.

If your fee schedule — the one you send landlords at instruction, and the one you publish to comply with the Consumer Rights Act — does not address this clearly, you create doubt. Doubt costs you instructions and invites complaints.

The agents handling this well are doing the same thing they were already required to do for tenants: publishing a clean, itemised fee schedule with no ambiguities. Every charge is named, quantified (or given a range with an explanation), and attributed to the party who pays it. Nothing lumped under “administration”.

Redesigning your schedule: a practical checklist

Work through your fee document against these categories:

Landlord fees (your revenue, unaffected by the tenant fee ban): Management commission, let-only fee, tenancy renewal commission, inventory commissioning fee, check-out fee — all permissible. Make sure the amounts are explicit and match what you actually charge. Vague ranges (“8–15% depending on portfolio size”) invite disputes.

Tenant permitted payments: List only the permitted categories above. If anything else appears — even a small “admin fee” — remove it. Trading standards authorities can investigate on a complaint.

Third-party costs passed through at cost: Referencing is the obvious one. If you instruct a referencing provider on the landlord’s behalf and pass the cost through, say so clearly — and confirm it never appears on the tenant side of the schedule.

New RRA-specific items: Note the advance-rent restriction explicitly in your tenant-facing paperwork. If you previously collected larger sums upfront, update your template tenancy agreements.

Costs to come: The PRS Database registration fee and the Ombudsman scheme levy (amounts subject to government confirmation). Note these on your landlord schedule as “subject to government confirmation” so you are not accused of springing costs on clients later.

The case for published per-check referencing pricing

One area where transparency pays dividends directly is referencing. When landlords can see exactly what a reference costs before instructing you, the conversation moves from “what is this charge on my statement?” to “how many references do I need?”

PropertyGoose’s referencing service publishes its pricing openly: £14 per reference, with volume rates from £10, and a full breakdown on the pricing page. There is no hidden margin and no bundled package that obscures unit costs. For agents, this is the model worth mirroring with landlords — not because transparency is a legal requirement on the landlord-facing side, but because it removes the friction that erodes trust.

The fee comparison page shows how published pricing stacks up in practice. Where agents are instructing multiple references per tenancy, the difference between opaque bulk billing and an itemised per-check model is material both for your landlord relationships and for your own audit trail in the event of a dispute.

The enforcement environment has changed

It is worth being direct about what has shifted. Before May 2026, enforcement of the Tenant Fees Act was patchy. The Renters’ Rights Act has introduced a broader civil penalty framework with clearer thresholds and, crucially, investigatory powers for councils that have been live since 27 December 2025. The First-tier Tribunal (Property Chamber) now has a tiered fee structure designed to keep tenant challenges accessible — £47 for a rent-increase appeal (with no hearing fee), and £114 plus a £227 hearing fee for rent repayment order applications.

Where a landlord or agent receives two or more civil penalties within a 12-month period for banning-order offences, the local authority may enter their details on the database of rogue landlords and property agents. That is reputational damage — and for an agency, it can be existential.

A clean, published fee schedule is not just good client management. It is your first line of evidence if a complaint is made.

A clean slate is easier than you think

Most agencies have a fee schedule that has accreted over time — a paragraph here, a bracketed note there, something that made sense when you wrote it but now sits awkwardly against the 2019 Act, let alone the 2025 one. The Act’s entry into force is the natural moment to replace it entirely with a single, current, explicitly compliant document.

If you want to see how an end-to-end referencing and tenancy service handles fee transparency from the ground up — including how we manage the full tenancy lifecycle — get in touch or book a quick call. We are happy to share what we have learned building a pricing model that works for agents and their landlords.

Craig Ryder