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Justice for Tenants, Civil Penalties and the Big Shake-up in Renting

Everyone involved in the private rented sector (PRS) will be aware that some significant changes are on the horizon. Recently, Jeremy Manners sat down with Al Mcclenahan from Justice for Tenants (JFT) to chat about where things are heading, following royal assent of the Renters’ Rights Act, and how councils can enforce the rules, with support from JFT and RIAMS.  

From estate agent to tenants’ advocate 

Al didn’t start out as a champion for tenants’ rights and local authority enforcement. He owned an estate agent and was running the letting side of the business when he realised the business pressures just weren’t sitting right with him: landlords wanting specific types of tenants, dodgy practices around deposits . . . it was legal, but it wasn’t ethical. Eventually, he sold up and walked away to set up JFT with his co-founder, Matt. What started as a small service to help tenants with poor written English dispute deposits has now grown into a national organisation supporting over 15,000 tenants and councils every year. 

Taking enforcement seriously 

One of JFT’s biggest roles is supporting tenants. They’ve been behind 75–80% of all rent repayment orders in England, working on around 550 new cases each year. Through this work, they noticed how uneven housing enforcement could be between councils; some went heavy on prosecutions, others barely touched civil penalties at all. 

JFT addressed this inconsistency by building best practice, offering training and creating their now-famous Civil Penalty Notice (CPN) Generator, which allows practitioners to apply policies quickly and consistently. What used to take officers 40 hours of paperwork can now be done in minutes, providing a robust defence on appeal to the tribunal. 

Al explained that the tool has now surpassed its two-year mark, with officers using it to issue millions of pounds worth of penalties during that time, and JFT reviewing around 130 CPNs per month.  

The Renters’ Rights Act – What are the big changes? 

Both Jeremy and Al agree that the end of Section 21 no-fault evictions and the removal of fixed-term tenancies on 1 May 2026 are the biggest changes coming. For years, tenants who complained about poor housing conditions were often just handed a Section 21 and told to leave. Removing that power shifts things considerably: renters can finally feel empowered to stand up for their rights without the fear of losing their home. Feeling more secure for the longer term is likely to have meaningful wellbeing benefits for individuals and families. 

Other changes include: 

  • New investigatory powers: from 27 December 2025 councils will have further powers to require information from people and the potential to seize documents from lettings agents 


  • Clearer rules around rent increases and easier ways for tenants to challenge them 


  • Written tenancy agreements for all renters (amazingly, many renters still don’t have one) 


  • A PRS database which all landlords and properties must be registered on 


  • A PRS Ombudsman which all landlords must sign up to, enabling tenants to complain about a landlord’s actions and seek redress from an independent body 


  • The Decent Homes Standard being extended to the PRS. 

And not to be forgotten, Awaab’s Law phase one applies to the social sector and will come in for the PRS in due course, requiring significant hazards to be addressed in statutory timeframes. 

In short, tenants gain more security and enhanced rights to challenge poor practice, and councils get sharper tools to tackle breaches and offences. 

Why enforcement policies matter 

Al warns that overarching enforcement policies that promise informal action or ‘education first’ can be used against councils on appeal (even where an offence is clear) because landlords can argue that the authority did not follow its own policy.  

That’s why JFT has developed a Model Housing and Licensing Enforcement Policy, which aims to be ‘black or white’, aligns with statutory duties and avoids conflicts with the Regulators’ Code when duties require formal action.  

As Al put it: We work with around 135 local authorities (about 40% in England) on civil penalty policies and ‘consistency is everything’. If one officer issues a penalty where another wouldn’t, that’s not fair in the eyes of the tribunal.  

Working with so many councils has also led JFT to draft model licensing conditions, noting how often current conditions are unenforceable. Their approach tightens wording to make conditions workable and less open to appeal. 

Looking ahead 

The Renters’ Rights Act brings at least 25 new offences that councils will have responsibility to enforce with civil penalties, making it a core part of every housing practitioner’s job. 

The good news? With tools like RIAMS Procedures and JFT’s Model Housing Enforcement Policy and model licensing conditions available on RIAMS Libraries, and The Housing App and the CPN Generator there to make the job more efficient, councils won’t be starting from scratch. Additionally, Al and Jeremy predict that standardisation will increase via statutory guidance for civil penalties, nudging councils toward consistent starting fine levels. 

And finally 

Both Al and Jeremy are in no doubt that this is a seismic moment in the PRS. It represents considerable work for councils and may take some time to bed in, but it offers a real opportunity to reset rights, consistency and wellbeing outcomes for tenants.  

RIAMS Libraries - Documents available now 

  • RRA procedures and guidance: live documents subject to revision as the RRA is implemented  


  • Model licensing conditions for selective licensing and HMO licensing 


  • Model housing and licensing enforcement policy: to support consistent enforcement.  

24 Nov 2025

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News

RIAMS Unpacked: November

The latest updates and insights from RIAMS Chief Editor Jeremy Manners

Welcome to November’s edition of RIAMS Unpacked, where I’ll give you a quick update on what’s new, what’s been reviewed and anything significant that has come across my desk in the world of environmental health. 

I go on holiday for half term and look what happens! The Renters’ Rights Act received royal assent, Awaab’s Law comes into force for social landlords and the Food Standards Agency updates both the food law code of practice and practice guidance for England, Northern Ireland and Wales. 

And . . . yet another senior government minister, this time the chancellor, falls foul of the law. Our guest blog by Jamie McGowan, housing specialist pupil barrister at Garden Court Chambers, discusses whether Rachel Reeves has a reasonable excuse for failing to license the four-bedroom home she rents out in Dulwich: Does the Chancellor Have a Reasonable Excuse?  

I met up with Ellis Turner from the University of the West of England and joined fellow EH professionals Mike Williams (Food Alert), Rob Easton (Shield Safety) and Julia Wilson (Middlesex University) to discuss working in environmental health in the private sector and how to make the most of opportunities. You can listen to the podcast here. This reminded me of a blog I wrote last year, Five Tips for a Successful Environmental Health Interview, which I hope still proves useful for EHPs looking for a new role.  

Ali Thomas and I also met up with Paul Oatt to have a further chat and address some of the outstanding questions from September’s Housing Roundtable on the skills and knowledge shortage in PSH enforcement. You can watch the follow-up video here.  

Our next Housing Roundtable, sponsored by AirTrap, will be held on 2 December, where we will be welcoming Professor John Edwards. He will be sharing his expertise on damp and mould in buildings and offering advice on how to assess risks and find the right solutions. Register here

Operation Jigsaw has been ramping up the training and guidance for LAs as the powers introduced by the Renters’ Rights Act get closer to implementation. Speak to your Operation Jigsaw regional rep to ensure you stay up to date. 

In the news…

Here are some news stories that caught my eye over the last few weeks: 

  • Richmond-Upon-Thames Council fined a woman £150 for pouring her leftover coffee down a road drain as she boarded a bus. Upon reflection, the council decided to cancel the fixed penalty notice (BBC News). Nonetheless, a helpful procedure and associated notice for environmental offences were at their disposal here in RIAMS Libraries! 

  • The BBC reported on how Bristol City Council has a huge backlog of damp and mould complaints and will be unable to comply with the requirements of Awaab’s Law. The report highlighted that the council has 2,200 active damp and mould cases in its council-owned social housing stock. Clearly, this is not going to be a challenge that is confined to only one social housing provider but is likely to be representative across the country. Our training webinar Understanding and Managing Damp and Mould in Domestic Property has been updated – a few places are still available on 16 December. 

  • Nineteen people who ate Sunday lunch at a pub in Cwmbran, Wales, on 5 October were confirmed by the local authority to have had food poisoning caused by Clostridium perfringens (Wales Online). Clostridium perfringens can develop spores which can survive cooking and germinate into viable cells during slow cooling and unrefrigerated storage. This story is a stark reminder of the importance of robust food safety processes for processing, storing and handling food correctly. We have a range of food procedures and associated templates on RIAMS Libraries relating to food sampling, inspections, complaints and investigations

Legal and regulatory insights  
  • Renters’ Rights Act 2025: After passing all of the political hurdles, the Act received royal assent on 27 October 2025. This has been a long time coming and represents massive changes in the private rented sector for England. Wasting no time, the government has issued a raft of guidance for local authorities and landlords and letting agents to support implementation.   

  • November 2025 guidance: 

    • Guidance for local authorities and councils 

    • Guidance for landlords and letting agents  

    • Guide to the Renters’ Rights Act  

  • Implementation roadmap: I have summarised the roadmap in a LinkedIn post here, detailing the implementation dates for the key provisions. The main date everyone is talking about is 1 May 2026, although for LHAs, 27 December 2025 is the first date practitioners will need to be aware of; this is when new investigatory powers come in (see the RIAMS procedure Renters’ Rights Act 2025, Part 4, Chapter 3: Investigatory Powers HP247E). 

  • Crime and Policing Bill: This is currently at committee stage in the House of Lords. 

  • Food Law COP and Practice Guidance: These were all updated on 23 October by the FSA for England, Northern Ireland and Wales.  

  • Awaab’s Law for social housing: Implementation of Phase 1 came in on 27 October 2025 for significant damp and mould hazards and all emergency hazards. The government guidance has been updated, as has the RIAMS Procedure Guidance Note: Awaab’s Law HP256E and our free Navigating Awaab’s Law: Guidance for Social Landlords e-learning. 

  • HMO Licensing in Northern Ireland: Communities Minister Gordon Lyons has indicated his intention to increase the maximum HMO licensing fee that councils can charge landlords. 

  • Tobacco and Vapes Bill: This is currently at committee stage in the House of Lords. The headline measure of the bill aims to create a ‘smoke-free generation’ by banning tobacco sales to anyone born on or after 1 January 2009. A call for evidence to help support policy development is open until 3 December.

  • Supporting economic growth and reducing regulatory burden: The Treasury and the Department for Business and Trade have set out plans to support innovation and economic growth, and are seeking views from businesses on how they are impacted by regulations. 

  • Primate licensing: The Institute of Licensing is running an awareness campaign on the new primate licensing requirements that come into force on 6 April 2026. Procedures and documents to support practitioners can be found in RIAMS Libraries.   

  • Martyn's Law myth buster and leaflet has been published by the Home Office to support existing guidance and public understanding. 

What’s new on RIAMS Libraries?  

Streamlined support for local authority enforcement 

RIAMS Libraries is an online subscription platform that provides a comprehensive library of practical and easily accessible procedures, notices, letters, guidance and forms covering all specialisms of environmental health. Supporting local authorities in delivering robust and consistent enforcement, RIAMS provides a cost-effective solution for your team, keeping your officers on the front line. 

During October, we updated 202 documents on RIAMS Libraries and reviewed 100 procedures for England, Northern Ireland and Wales. We also added new procedures on: 

  • Remediation Orders under the Building Safety Act 2022 HP260E , together with a template letter of claim 

  • Clean Neighbourhoods and Environment Act (Northern Ireland) 2011, Section 65: Scavenging of Common Courts and Passages (PHP96N

  • Housing and Licensing Team Enforcement Policy: This model policy was developed by Justice for Tenants to incorporate the new requirements under the Renters’ Rights Act. I met up with JfT’s founder Al Mcclenahan to discuss the work they are doing and why a consistent policy is so important. Read the blog here. 


If your organisation doesn’t yet subscribe to RIAMS Libraries, contact RHE Global to request a free demonstration and trial.  

What’s new on RIAMS Communities

Local authority practitioners continue to sign up to our environmental health forums and engage in conversations. Take the opportunity to join the discussion and network with colleagues in your chosen subject areas here.  

Take a look at our guest blog by Jamie McGowan, housing specialist pupil barrister at Garden Court Chambers, on the Rachel Reeves renting debacle: Does the Chancellor Have a Reasonable Excuse? 

Thanks to Dr Tim Everett for providing some further tribunal decisions, now available in Housing Professionals

And we have published the Housing Roundtable Q&A session with Paul Oatt, available here

RHE Global  

RHE Global supports environmental health practitioners across all specialisms to work smarter, network and share best practices. Visit RIAMS to stay up to date with the latest environmental health developments and discussions. 

Don’t miss a thing – sign up to get public protection news and jobs straight to your inbox.

27 Nov 2025

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News

Tackling Neighbour Noise – Why Getting It Right Matters

Few challenges test the skills and resilience of local authority officers quite like neighbour noise. On the surface, it may seem like a simple complaint about loud music, barking dogs or late-night DIY – but in practice, noise issues are rarely that straightforward.

Behind every report lies a mix of expectations, emotions and community dynamics. What starts as an irritation can quickly escalate into a long-term dispute, and the line between a noise nuisance and anti-social behaviour (ASB) can blur fast. For enforcement and environmental health teams, the task is not just to investigate, but to resolve – fairly, legally and with empathy.

Achieving that balance requires confidence in the law, good professional judgement and a practical approach that works under real-world pressures. Understanding the links between common law nuisance, statutory nuisance and ASB legislation is essential – as is knowing how to build a defendable process and communicate effectively with all parties involved.

To help professionals strengthen those skills, Chartered Environmental Health Practitioner and public health veteran Tony Lewis will be delivering the Neighbour Noise Investigation (Online) course on 27–28 November 2025 (09:15–12:45 both days).

This two-part online training, delivered via MS Teams, has been designed specifically for UK-based enforcement, environmental health and community safety personnel. Across two half-days, delegates will explore:

  • The legal foundations of nuisance and ASB

  • Good practice for managing service requests and investigations

  • Practical strategies for resolving recurring noise problems

  • The use of tools such as The Noise App and sound-level meters (SLMs).

The sessions are interactive and discussion-led, offering an engaging virtual learning experience that matches the experience of face-to-face delivery.

Neighbour noise is one of the most common – and often most challenging – issues faced by local authorities. Getting it right matters, not just for legal compliance but also for community confidence and fairness.

If you’re involved in investigating or managing noise complaints, this course is an opportunity to refresh your knowledge, gain practical insights and strengthen your professional practice.

Find out more and secure your place here:Neighbour Noise Investigation (Online)

20 Nov 2025

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News

Enhancing Anti-Social Behaviour Case Resolution: The crucial role of independent chairs in ASB case reviews

In the realm of anti-social behaviour (ASB) management, the ASB case review (formerly the community trigger) is  a pivotal tool of the ASB, Crime and Policing Act 2014. 

This essential instrument gives a voice to individuals who feel their ASB cases have been inadequately addressed. Moreover, it provides professionals with an avenue for independent review of the cases they handle. 

However, within this process lies a pivotal factor that significantly affects the effectiveness of the case review – the role of an experienced, independent chairperson.

RHE Global is a leading entity dedicated to community safety and ASB management. We recognise the paramount importance of a proficient and competent chairperson in the ASB case review process. As the director of community safety for RHE Global, with 28 years of experience in this domain, I've witnessed firsthand the transformative impact that an effective chair can have on resolving these cases.

Why is an independent chairperson indispensable in ASB case reviews?

Expertise matters: The nuances and complexities of ASB cases demand discernment and in-depth knowledge. An independent chair with a wealth of experience handling such situations brings invaluable insights, effecting a comprehensive appraisal and a fair assessment of the case at hand.

Impartiality and objectivity: The neutrality of an independent chairperson is fundamental. Their detachment from the case under review provides a non-partisan evaluation, free of bias or conflicts of interest, thereby upholding the integrity of the process.

Ensuring fairness and transparency: A proficient chairperson arranges for all parties involved to be heard and the case evaluated openly. This not only instils confidence in the process but also garners trust among stakeholders.

Facilitating constructive outcomes: The ultimate goal of an ASB case review is resolution and action. An experienced chairperson plays a pivotal role in driving the discussion towards practical solutions and strategies, promoting collaborative efforts among stakeholders to address the issues effectively.

If you’re looking to strengthen your organisation’s approach to ASB case reviews, our Best Practice for ASB Case Review (Community Trigger): A Practical Guide training offers practical tools, legal clarity and real-world insights to help you handle the process more effectively.

Our next session runs on 2 December 2025, 09:30–11:45. Secure your place here and gain the expertise and guidance you need to manage ASB case reviews with confidence.

Why RHE Global?

At RHE Global, we offer the services of highly qualified and experienced independent chairpersons for ASB case reviews. Our team comprises individuals with a robust background in anti-social behaviour management, ensuring that each review benefits from extensive expertise and a commitment to fairness. 

For more details or to engage the services of an experienced independent chairperson, please contact us at sales@rheglobal.com.

17 Nov 2025

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