Purpose

Adoption of a new Civil Penalty Policy, Housing Enforcement Policy, and HMO Licence conditions to reflect the changes arising from the Renter's Rights Act 2025

Decision

Cabinet RESOLVED to:

1. Accept the updated Civil Penalties policy in the report appendices.
2. Accept the updated Mandatory HMO Licensing licence conditions as

detailed in the report appendices.

1. Accept the Housing Standards Enforcement Policy in the report

Appendices

Councillors Hogg, Jamil, Ali and Cole did not take part in the vote for this item as per the Declaration of Interests. 

Alternative options considered

Option 1: Approve the new Enforcement Policy, Civil Penalty Policy and

Mandatory Licensing Conditions.  To take effect immediately, with

transitional arrangements allowing the existing policies to operate in tandem

for a limited period to conclude legacy cases. 

This option ensures that the Council can meet its statutory duties under the

Renters’ Rights Act 2025 section 107.  It provides a clear and consistent

framework for enforcement decision making and supports alignment.

This option minimises risk of legal challenge, ensures that the Council is

implementing the Renters’ Rights Act effectively and that the intended

tenant protections are driven forwarded. 

Implications:

• Full compliance with the Renters’ Rights Act 2025

• Clear officer guidance and defensible enforcement outcomes

• Reduces legal challenge and reputational risks

Option 2: Make limited amendments to the current Enforcement and Civil

Penalty Policies to reference the Renters’ Rights Act, without adopting a

revised framework or mandatory licensing conditions linked to civil

penalties.

Implications:

• Policies will not adequately reflect the statutory duty to enforce under

section 107

• Ongoing risk of inconsistency across England

• Reduced clarity for officers, landlords and tenants

• Higher likelihood of legal challenge and policy failure under scrutiny

• Reputational risk for ineffectively implementing the Renters’ Rights

Act

Option 3: Do nothing. This would result in the council not being compliant

with the new enforcement duties imposed by the Renters’ Rights Act.

Option 1 is recommended. It provides the most robust, legally compliant,

and consistent approach to enforcement under the Renters’ Rights Act,

while allowing for managed transition and alignment with national best

practice.